MISSOURI DEPARTMENT OF NATURAL RESOURCES

REPORT ON FISH KILL INVESTIGATION

MONETT MUNICIPAL WASTEWATER TREATMENT FACILITY
MISSOURI STATE OPERATING PERMIT NUMBER MO-0021440
BARRY 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 violation
of 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 the
City 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 tests
were 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 facility in Aurora and
unknowingly sent the chemical through Tysons pretreatment system which ultimately went to the
Monett Municipal WWTF. This upset resulted in the fish kill downstream of the WWTF.

The departments phone 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. The
pretreatment 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 noted
that 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


City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 2

and then fecal coliform greater than 200 colonies/ 100 ml. As of May 23, 2014, the city had
noted 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 receiving
stream 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 were
collected 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 25.9
o
C
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 I went 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 Tysons other 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 citys
sewer 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 reported
that 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. I
informed 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


City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 3

of the pretreatment regulation. I advised him to cooperate with the city to resolve the issue. I
also 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 lost
into 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 approximately
13:00. 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 treatment facility 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 where the Missouri
Department of Conservation (MDC) staff discovered dead fish. We met with MDC staff at
approximately 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



City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 4

from May 19 to May 23, 2014. All sampling results exceeded the daily maximum of 3.4 mg/L
for 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. I did not see any additional impacts to the stream and the fish kill
appeared 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 responding
to 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 flow
equalization 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 equalization basin 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 system
during 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 chemical
named 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




City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 5

reported to have stopped the discharge within ten minutes upon noticing the issue and sent the
wastewater 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 of
aquatic 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 results
for 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 State
Operating 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.


City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 6

Violations of the Missouri Clean Water Law (continued)

On or before May 23, 2014 through May 27, 2014, the City of Monett caused pollution to a
tributary 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 Section
Southwest Regional Office Southwest Regional Office


City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 7








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








Location: City of Monett WWTF
Photographer: Sieu T. Dang
Photograph Date: May 23, 2014
Comments: Clarifier. The wastewater appeared cloudy.



City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 8








Photo 3








Location: City of Monett WWTF
Photographer: Sieu T. Dang
Photograph Date: May 23, 2014
Comments: Ultraviolet light disinfection.








Photo 4








Location: City of Monett WWTF
Photographer: Sieu T. Dang
Photograph Date: May 23, 2014
Comments: Foam on the effluent.




City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 9








Photo 5








Location: Approximately 20 feet downstream from City of Monett WWTF effluent
Photographer: Sieu T. Dang
Photograph Date: May 23, 2014
Comments: Cloudy looking water with a dead fish








Photo 6









Location: Approximately 20 feet downstream from City of Monett WWTF effluent
Photographer: Sieu T. Dang
Photograph Date: May 23, 2014
Comments: Dead fish



City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 10








Photo 7








Location: City of Monett WWTF
Photographer: Sieu T. Dang
Photograph Date: May 27, 2014
Comments: Less foam on the effluent.








Photo 8








Location: Approximately 20 feet downstream from City of Monett WWTF effluent
Photographer: Sieu T. Dang
Photograph Date: May 27, 2014
Comments: Clearer looking compared to the stream observed on May 23, 2014.




City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 11








Photo 9








Location: Clear Creek at Pierce Citys Park
Photographer: Sieu T. Dang
Photograph Date: May 27, 2014
Comments: Note dead fish on the creek bottom.








Photo 10








Location: Clear Creek near the bridge of Pierce Citys Park, UTM (0411143, 4088859)
Photographer: Sieu T. Dang
Photograph Date: May 27, 2014
Comments: Samples for pH, D.O., temperature, and ammonia were taken at this location.




City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 12








Photo 11








Location: Clear Creek near the bridge at Highway 97 at Pierce City UTM (0410506, 4088861)
Photographer: Sieu T. Dang
Photograph Date: May 27, 2014
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)
Photographer: Sieu T. Dang
Photograph Date: May 28, 2014
Comments: No additional impact observed. Samples for pH, D.O., temperature, ammonia,
acidity, and COD were collected at this location.


City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 13








Photo 13








Location: Clear Creek near Farm Roads 2240 and 1020, UTM (408612, 4088490)
Photographer: Sieu T. Dang
Photograph Date: May 28, 2014
Comments: No visual impacts observed. Samples for pH, D.O., temperature, ammonia, acidity,
and COD were collected at this location.








Photo 14








Location: City of Monett WWTF
Photographer: Sieu T. Dang
Photograph Date: May 29, 2014
Comments: Aeration basin, no foam observed.



City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 14








Photo 15









Location: City of Monett WWTF
Photographer: Sieu T. Dang
Photograph Date: May 29, 2014
Comments: Clarifier. Effluent appeared to be clearer.








Photo 16








Location: City of Monett WWTF
Photographer: Sieu T. Dang
Photograph Date: May 29, 2014
Comments: Effluent structure.



City of Monett
Report on Fish Kill Investigation
June 5, 2014
Page 15








Photo 17








Location: Approximately 20 feet downstream from City of Monett WWTF effluent
Photographer: Sieu T. Dang
Photograph Date: May 29, 2014
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)
Photographer: Sieu T. Dang
Photograph Date: May 29, 2014
Comments: No additional impact observed.