The City of Bay City is fining Tillamook Country Smoker $9,000 for violating wastewater permit requirements. City documents indicate the problem has been ongoing for around eight or nine months.
Through a public records request, the Headlight Herald obtained a letter that was issued by Bay City Public Works Director Chance Steffey to Tillamook Country Smoker and dated July 24, informing the meat product company of “significant problems” with its wastewater pretreatment system and the effluent being discharged to city system, citing a June discharge monitoring report.
“This cannot continue to occur as it impacts our operation and potentially our NPDES [National Pollutant Discharge Elimination System] permit with Oregon DEQ [Department of Environmental Quality],” the letter highlighted in bold type.
The letter included a spreadsheet of daily monitoring reports identifying permit levels that were out of compliance. On May 22, a biological oxygen demand (BOD) of 1100 milligrams per liter was reported, greatly exceeding the allowed amount. Steffey said because no additional testing was performed, Tillamook Country Smoker violated its wastewater permit for the entire month of June.
“Typically, bacteria in wastewater treatment require oxygen for decomposition of the organic material, so we measure the BOD to determine the relative amount of organic material contained in the wastewater,” Steffey said. “The higher the BOD, the more organic material there is, and the more bacteria and oxygen is required to break down.”
Steffey said high BOD levels discharged into a stream or other body of water, such as the bay, reduces dissolved oxygen, which is problematic for aquatic life.
The BOD value is typically reported in milligrams of oxygen consumed per liter. It can be used to gauge the efficiency of the wastewater treatment process. Properly treated municipal sewage typically has a BOD of around 20 milligrams per liter. Untreated sewage has a BOD of around 200-400 milligrams per liter.
Public works records showed in May, Tillamook Country Smoker exceeded its monthly average allowance of 250 milligrams per liter of BOD a day, hitting an average of 705 milligrams per liter a day in the two tests that were reported. The lack of additional testing means the real monthly average is unknown. The level of total suspended solids in the May discharge averages was also in violation, showing nearly double the permitted limit.
“I think the main reason these are so far over is the volume has jumped up since last summer when production at the plant went up,” Steffey said.
According to the wastewater discharge permit, the City may impose fines of $300 a day on Tillamook Country Smoker for violations. The company is also required to notify public works immediately upon learning of non-compliant discharges, required to provide additional testing until materials are below permitted levels, and required to follow up with a detailed written report.
A March 14 letter to Tillamook Country Smoker corrected a letter issued two days prior that was intended to notify the company about a $4,200 fine and $858.90 in surcharges for increased BOD limits as well as failing to report and do follow up testing. The Headlight Herald obtained both letters through a records request.
The correction letter said the fine was lifted because Steffey was in fact notified in a timely manner and had forgotten while awaiting test results from the company, but he noted that delays in test reporting are concerning and could impact potential fines and surcharges.
Steffey offered to conduct quality control checks on samples from Tillamook Country Smoker through the public works laboratory with a quick turnaround. For $150-$200 worth of staff work, concerns regarding wastewater discharges could then be addressed in shorter time. Certified lab tests would still be required, but potential surcharges could be reduced, Steffey said.
The original March 12 violation letter said for several months, wastewater discharge from the Tillamook Country Smoker had caused disruptions for the City’s treatment plant, impacting the quality of its effluent and requiring “quite a bit” of extra operator time to maintain DEQ compliance.
“We seem to be having problems with your discharge over the last several months even when the regulated concentrations meet permit limits,” Steffey wrote in the March 12 letter.
Tillamook Country Smoker was ordered to pay a total of $11,644.77, including the $9,000 fine and another $2,644.77 in public works surcharges, according to the July 24 letter. The penalty is primarily for the BOD spikes, failure to report being out of permit, and not increasing discharge testing. Steffey said he believes it’s the first such fine against the company, finding no record of previous City actions.
The letter said even if testing indicated concentrations below permit levels, Bay City Public Works still needs to work out why Tillamook Country Smoker’s discharge is disrupting sewer operations. Steffey said he would like to see a report from the company that includes a schedule of actions and preventative measures to be taken in correcting the violations.
“This has been going on now for 8 or 9 months and seems to be getting worse,” Steffey wrote. “If this continues to happen, we will revoke your permit.”
Tillamook Country Smoker Vice President Greg Costley said there is ongoing research to determine the cause of the BOD increases, and the company has called in the engineering firm that designed its wastewater treatment facility to evaluate the system and its capacities. A full report is expected in September and will be followed up with an action plan from the company.
“I don’t have a known cause at this point,” Costley said. “What I can say is that our testing for July has come back at significantly reduced levels from where we were in May.”
Costley said July testing yielded downward trending results at less than half of what May showed. He said testing would continue with the lab the company has been using, as well as through the engineering firm assessing the facility, adding that the offer from public works for additional testing would be considered if necessary.
“This is an important and serious matter for us and we are applying the resources to get it addressed,” Costley said.