report on tyson fish kill investigation: monett municipal

8/12/2019 Report on Tyson Fish Kill Investigation: Monett Municipal

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MISSOURI DEPARTMENT OF NATURAL RESOURCES

REPORT ON FISH KILL INVESTIGATION

MONETT MUNICIPAL WASTEWATER TREATMENT FACILITY

MISSOURI STATE OPERATING PERMIT NUMBER MO-0021440BARRY COUNTY

June 5, 2014

On May 21, 2014, I, Sieu T. Dang of the Missouri Department of Natural Resources (department)

Southwest Regional Office (SWRO) received a call from Mr. David Sims, Operator, City of

Monett (city) Municipal Wastewater Treatment Facility (WWTF), reporting a potential violationof the permitted effluent limit for fecal coliform due to cloudy effluent that the WWTF had been

producing since the day before. Mr. Sims indicated other field parameters were within the

limitations. Mr. Sims reported the city was investigating the matter. I advised Mr. Sims to keep

the department updated about the fecal coliform results and investigation.

On May 22, 2014, I contacted the city and spoke to Mr. Paul Olson, Lab Technician for theCity of Monett WWTF. Mr. Olson indicated that fecal coliform and other field test results

were meeting the effluent limits. However, the effluent was still cloudy and there were odors.Mr. Olson believed the WWTF upset was caused by Tyson Foods Incorporated facility in

Monett (Tyson). He stated that the city is working with Tyson and continuing to monitor all

the parameters daily.

On May 23, 2014, Mr. Sims contacted me stating that fecal coliform results were still meeting

permitted effluent limits, but they exceeded 200 colonies per 100 mL, so the city could not

irrigate the golf course. Mr. Sims also stated the city found some dead minnows downstream of

the WWTF and the in-stream dissolved oxygen (D.O.) was 3.0 mg/L. Effluent ammonia testswere in process. I called the city shortly after to obtain additional information about the fish kill

and spoke to Mr. Paul Olson. Mr. Olson reported that the prior week Tyson received a chemical

named ALIMET, a liquid animal feed supplement, from another Tysons facilityin Aurora and

unknowingly sent the chemical through Tysonspretreatment system which ultimately went to the

Monett Municipal WWTF. This upset resulted in the fish kill downstream of the WWTF.

The departmentsphone records for May 23, 2014 also indicate Mr. Sims and Mr. Skip Shaller,Utilities Director of the city, called Mr. Gregory Perkins, P.E. of the department to determine if

chlorinating effluent from the WWTF to irrigate the golf course could be an option. Mr. Perkins

stated that could be an option since chlorine was not prohibited in a no-discharge system.

Mr. Perkins also discussed with Mr. Sims the upset WWTF. Mr. Sims stated that Tyson Foods

Feed Mill in Aurora had delivered tanks of a waste feed additive to run through the wastewater

pretreatment facility, but it was unknown what the material was from the Aurora facility. Thepretreatment operator of Tyson stated when they noticed the odor from the delivery they

immediately changed the valves to store the material in the flow equalization basin. It was notedthat the Material Safety Data Sheet (MSDS) stated the pH was near 1.0 and the city noticed a

decrease in the influent pH but it was still in the 6.6 range. The city noticed the odor on

May 16, 2014 and by about midnight located the source to be Tyson. Tyson did not notify the

city of the discharge of the material. The city noticed the subsequent effect of a cloudy effluent


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Report on Fish Kill Investigation

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and then fecal coliform greater than 200 colonies/ 100 ml. As of May 23, 2014, the city hadnoted an increase in biological activity in the Oxidation Ditch from earlier in the week as they

had received sewage sludge seed from the City of Mount Vernon. The City of Monett had

advised Tyson they could only discharge the material as part of their normal operation.

Mr. Perkins advised the city to increase the recycle rate over the Trickling Filters as further

pretreatment prior to the activated sludge portion of the facility.

On May 23, 2014, I arrived at the WWTF at approximately 14:30. Upon arrival, I noticed a

pungent sulfur-like smell. There was foam on top of the aeration basin (photo 1). The city

reported the foaming on the basin was not its normal operation. The effluent was cloudy and

emitted the same odor. There was no flow upstream and the effluent of the WWTF maintained

the flow in the tributary to Clear Creek. There were approximately 30 dead fish in the receivingstream below the discharge from the WWTF. I walked about 20 feet downstream and could not

find any swimming fish. Effluent samples for ammonia, acidity, and total suspended solids werecollected and then sent to the departments Environmental Services Program for analysis. Field

analysis for pH, D.O., and temperature at the effluent were 7.7, 5.79 mg/L, and 25.9oC

respectively. The city reported that Tyson had ceased the discharge of the contaminated

wastewater which contained ALIMET to the citys sewer system and the smell at the WWTF

was significantly less concentrated than a few days prior. The city provided me a copy of the

MSDS for ALIMET. The MSDS identified ALIMET as methionine hydroxy analogue (2-

hydroxy-4-(methylthio) butanoic acid), a liquid animal feed supplement.

On May 23, 2014, after the sample collection, Mr. Sims and Iwent to Tysons facility and

arrived there at approximately 16:00. We then met with Mr. David Young, Complex Manager

of Tyson. Mr. Young stated that there was a chemical leak at Tysonsother facility in Aurora

into its secondary containment, and as part of their Spill Prevention Control and Countermeasure

Plan (SPCC) the chemical (ALIMET) was pumped from the secondary containment and

hauled to Tyson in Monett for treatment. Mr. Young indicated upon noticing the issue, Tyson

ceased the discharge of their pretreated wastewater which contained the chemical to the cityssewer system. Mr. Young said the contaminated wastewater was then properly treated and

discharged back to the city. At the time of the visit, Tyson no longer had any wastewater

containing the chemical at its pretreatment facility. He then guided Mr. Sims and I through

their pretreatment system. The pretreatment system consisted of an aerated influent station, a

DAF (Dissolved Air Flotation) system, and a 900,000 gallon flow equalization basin. Polymers

and organic coagulant were added to the wastewater for a coagulation process. It was reportedthat sodium hydroxide was also being used at this facility for pH adjustment and sodium

hypochlorite was added to the wastewater with ALIMET during the remediation process. Iinformed Mr. Young that the field test parameters that I collected at the citys WWTF effluent

were within the limits and test results for ammonia and other parameters are still pending.

However, the discharge from Tyson upset the citys WWTF, resulting in a fish kill downstream.

This is considered interference of the treatment process of the citys WWTF, which is a violation


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of the pretreatment regulation. I advised him to cooperate with the city to resolve the issue. Ialso asked Mr. Young about the day and time the discharge happened and corrective actions

Tyson had made to remediate the issue. Mr. Young did not have the answers at the time and said

he would email me the requested information.

On May 27, 2014, I received an email from Mr. Young stating that the initial ALIMET lostinto the secondary containment at their Auroras facility was 40,164 pounds. A portion of that

liquid was brought over to the pretreatment facility in Monett, and a portion left in the secondary

containment was neutralized and removed by an outside vendor. Tyson added 115 gallons of

12.5 % of sodium hypochlorite during the remediation process. Tyson began to discharge the

treated wastewater to the citys sewer system on May 20, 2014 and released the last treated

wastewater at approximately 15:00 on May 23, 2014.

On May 27, 2014, I and Mr. Chris Ray of the department went to the WWTF at approximately13:00. The effluent looked clearer compared to the previous visit on May 23, 2014, and we

could observe the bottom of the receiving stream. Mr. Ray indicated that he noticed a typical

smell from a wastewater treatmentfacility and it was not out of the ordinary. The city reported

there was still a little odor coming off the Trickling Filters, but it was not comparable to what

they experienced previously. We took samples at the effluent for BOD, TSS, ammonia, pH,

temperature, and D.O. and took samples for ammonia, pH, temperature, and D.O. downstream of

the effluent. We then proceeded further downstream near Pierce Citys Park wherethe Missouri

Department of Conservation (MDC) staff discovered dead fish. We met with MDC staff atapproximately 14:10. The MDC staff were documenting dead fish counts and species. They

told us that the ammonia in the stream per their field tests were high and had concerns about the

potential fish kill due to high ammonia in the stream. We explained to them the issue at the

Monetts WWTF and said we expect the ammonia to be high as well and have collected samples

at the Monett Municipal WWTFs effluent and immediately downstream. We then proceeded to

collect samples upstream and downstream from the park. Dead fish were observed at both

locations.

On May 28, 2014, Mr. Chris Ray and I returned to Monett and continued to collect wastewater

samples at the WWTFs effluent and downstream. The WWTF appeared to have regained its

treatment capacity. We did not notice the odor at the WWTF. We went to Clear Creek near

Pierce Citys Park and did not observe any additional impacts to stream. We went further

downstream to the bridge near Farm Road 2240 and Farm Road 1020 and collected samples.No visual impacts to the stream were observed at this location.

On May 29, 2014, I went to the citys WWTF and walked through the facility with Mr. Paul

Olson and collected wastewater samples at the effluent. The WWTF appeared to be back to

normal operation. Mr. Olson provided me sample results for ammonia that he collected daily


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from May 19 to May 23, 2014. All sampling results exceeded the daily maximum of 3.4 mg/Lfor ammonia as nitrogen. Mr. Olson also provided other test results including BOD and TSS and

noted that the composite samples for BOD on May 22 to May 23 and May 24 to May 25 both

exceeded the weekly average permitted limit of 20 mg/L. I asked Mr. Olson to provide the test

results to the department as soon as he obtained them. I then left the WWTF and went to Clear

Creek near Pierce Citys Park. Idid not see any additional impacts to the stream and the fish killappeared to have stopped.

On June 2, 2014, Mr. Olson faxed me the sample results for ammonia from May 19, 2014 to

May 30, 2014. Except for the ammonia result on May 30, 2014, which met the permitted

monthly average and daily maximum limits, all other sample results exceeded both limits for

ammonia.

On June 4, 2014, the department received an email from Mr. David Young of Tyson respondingto an inquiry from the department. The email indicated on Friday evening, May 16, 2014 two

vacuum trucks hauled a mixture of water and ALIMET from a containment area at the Aurora

feed mill to Tysons pretreatment facility at its Monett plant. One truck driver indicated to the

pretreatment operator that the material was animal fat. After one truck started unloading, the

pretreatment operator quickly determined the material was not animal fat. The Tyson operator

immediately went inside the facility to turn valves to divert the influent pit containing the water

with ALIMET to their flow equalization basin that was currently empty and not in use. From

the time the truck started pumping to the time the influent pit was diverted to the flowequalization was about five minutes and not likely more than ten minutes. The email also

indicated the city informed Tyson about the issue via email on May 17, 2014 and Tyson did not

see the email until May 19, 2014. Tyson then provided the MSDS of ALIMENT to the City

on May 19, 2014. After consulting with the City and WaterTech(Tysons chemical supplier),

Tyson treated the wastewater contained ALIMET in the flow equalizationbasin with sodium

hydroxide to raise pH and then sent the mixture to the pretreatment system on May 20, 2014 to

May 23, 2014. Sodium hypochlorite was injected at the effluent of the pretreatment systemduring the same period.

On June 4, 2014, SWRO received samples results for samples collected during the site visits

from the departments Environmental Services Program. The enclosed results show the Monett

Municipal WWTF exceeded ammonia as nitrogen permitted effluent limits in May 23, 27, 28,

and 29, 2014. The results also confirmed high levels of ammonia in the receiving stream.

In summary, on May 16, 2014, Tyson in Monett received wastewater containing a chemicalnamed ALIMET, a liquid animal feed supplement, from its other facility in Aurora and sent it

to its pretreatment system where it discharged into the City of Monetts sewer system. Tyson


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reported to have stopped the discharge within ten minutes upon noticing the issue and sent thewastewater containing ALIMET to its flow equalization basin. During May 20 to 23, 2014,

Tyson treated the wastewater in the basin with sodium hydroxide and then sent the mixture back

to the pretreatment system. Sodium hypochlorite was added to the effluent of the pretreatment

system prior to discharging to the Citys sewer system during the same period. The discharge on

May 16, 2014 alone, or in combination with the discharge during May 20 to May 23, 2014,upset the Monett Municipal WWTF, causing operational issues at the WWTF and violations

of permitted effluent limits for ammonia from May 19 through May 29, 2014. Consequently,

Monett Municipal WWTF discharged improperly treated wastewater to a tributary of Clear

Creek resulting in a fish kill from downstream of the WWTF effluent to Clear Creek near

highway 97 bridge in Pierce City as determined by department staff and MDC staff. At least

four miles of Clear Creek were documented to be affected from the discharge.

Note that ammonia is present in most wastewater discharges and is toxic to many forms ofaquatic life, and is particularly toxic to larval stages of aquatic creatures. Ammonia toxicity

depends on both pH and temperature, and these factors result in different permitted limits for

different seasons of the year. To protect the water quality in the receiving stream, the current

Missouri State Operating Permit (MSOP) number MO0021440 for Monett Municipal WWTF

requires the WWTF to comply with permitted effluent limits for ammonia as nitrogen of 3.4

mg/L daily maximum and 1.3 mg/L monthly average for May 1 to October 31, and 6.2 mg/L

daily maximum and 2.4 mg/L monthly average for November 1 to April 30. Based on

observations during the investigation, information from the city and Tyson, and the test resultsfor ammonia from the city and the department (enclosed), it is reasonably certain that the high

level of ammonia was one of the factors that contributed to the fish kill in a tributary of Clear

Creek and Clear Creek downstream of the WWTF to highway 97 bridge in Pierce City.

Violations of the Missouri Clean Water Law

From May 19, 2014 to May 29, 2014, the City of Monett failed to comply with the ammonia

effluent limits contained in Part "A" of Missouri State Operating Permit (MSOP) number

MO-021440 which is a violation of Missouri Clean Water Law Sections 644.051.1(3) and

644.076.1, RSMo.

The City of Monett failed to comply with special conditions 7 (3) and (4) of Missouri StateOperating Permit (MSOP) number MO0021440 which is a violation of Missouri Clean Water

Law Section 644.076.1, RSMo.

The City of Monett failed to operate and maintain facilities to comply with the Missouri Clean

Water Law and applicable permit conditions which is a violation of Missouri Clean Water Law

Sections 644.051.1(3) and 644.076.1, RSMo.


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Violations of the Missouri Clean Water Law (continued)

On or before May 23, 2014 through May 27, 2014, the City of Monettcaused pollution to atributary of Clear Creek and Clear Creek, waters of the state, resulting in a fish kill which is a

violation of Missouri Clean Water Law Sections 644.051.1(1) and 644.076.1, RSMo.

REQUIRED ACTION:

This matter is being referred for enforcement to the departments Water Pollution Control

Branch, Compliance and Enforcement Section in Jefferson City for enforcement action.

Once the case is assigned, a case manager will contact you with further details.

SUBMITTED BY: REVIEWED BY:

Sieu T. Dang Kevin Hess, Chief

Environmental Engineer Water Pollution SectionSouthwest Regional Office Southwest Regional Office


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Photo 1

Location: City of Monett WWTF

Photographer: Sieu T. Dang

Photograph Date: May 23, 2014

Comments: Foaming on the aeration basin. The city reported they did not have that issue prior

to the incident.

Photo 2




Comments: Clarifier. The wastewater appeared cloudy.


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Photo 3




Comments: Ultraviolet light disinfection.

Photo 4




Comments: Foam on the effluent.


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Photo 5

Location: Approximately 20 feet downstream from City of Monett WWTF effluent



Comments: Cloudy looking water with a dead fish

Photo 6




Comments: Dead fish


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Photo 7




Comments: Less foam on the effluent.

Photo 8




Comments: Clearer looking compared to the stream observed on May 23, 2014.


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Photo 9

Location: Clear Creek at Pierce Citys Park



Comments: Note dead fish on the creek bottom.

Photo 10

Location: Clear Creek near the bridge ofPierce Citys Park, UTM(0411143, 4088859)



Comments: Samples for pH, D.O., temperature, and ammonia were taken at this location.


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Photo 11

Location: Clear Creek near the bridge at Highway 97 at Pierce City UTM (0410506, 4088861)



Comments: Note dead fish. Samples for pH, D.O., temperature, and ammonia were collected at

this location.

Photo 12

Location: Clear Creek near the bridge of Pierce Citys Park, UTM(0411143, 4088859)



Comments: No additional impact observed. Samples for pH, D.O., temperature, ammonia,

acidity, and COD were collected at this location.


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Photo 13

Location: Clear Creek near Farm Roads 2240 and 1020, UTM (408612, 4088490)



Comments: No visual impacts observed. Samples for pH, D.O., temperature, ammonia, acidity,

and COD were collected at this location.

Photo 14




Comments: Aeration basin, no foam observed.


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Photo 15




Comments: Clarifier. Effluent appeared to be clearer.

Photo 16




Comments: Effluent structure.


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Photo 17




Comments: The stream looked clear. Bottom substrate can be seen.

Photo 18

Location: Clear Creek near the bridge of Pierce Citys Park, UTM(411143, 4088859)



Comments: No additional impact observed.

report on tyson fish kill investigation: monett municipal

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