CITY RECORDS · PILGRIM’S PRIDE · EPA & TCEQ
Wastewater.
Connected responsibilities.
Who owns the plant, who operates it, and what records show the oversight? The agreement, budget, permits and correspondence answer different parts of that question.
The Southwest plant operated by Pilgrim’s Pride and the City’s Southside plant have separate permits. They also share a documented connection through phosphorus-reduction planning for Lake O’ the Pines. Read that relationship alongside the City’s April 13, 2026 pretreatment response and the later compliance records.
Sources and live data checked October 12, 2026. Later records are dated separately from the earlier records request.
01 / OWNERSHIP & OPERATION
Separate the land, the plant and the permit.
The 2023 application names Mount Pleasant as owner of the Southwest plant and its land. The City’s adopted FY2026 budget says the plant is leased to and operated by Pilgrim’s Pride, with permits issued to the company. Titus CAD’s 2026 listing for parcel 9270 identifies the City as the owner of the 20-acre plant site at 664 FM 127.
The September 2026 TCEQ agreed order describes Pilgrim’s as owning and operating the facility. That wording deserves reconciliation with the application, budget and property listing. The records linked here do not establish a later transfer of the land or plant; an appraisal listing is also not a title examination.
02 / THE 1988 OPERATING AGREEMENT
The agreement gives both parties a role.
The agreement in the TCEQ application was signed May 4, 1988, effective June 1. Its September 2009 fax markings do not establish an amendment. The supplied agreement provides a starting point for identifying the approvals, financial records and compliance correspondence that could document the relationship.
| Provision | What it describes | Read the source |
|---|---|---|
| Operations · §2 | Pilgrim’s pays operating and maintenance expenses, subject to the residential-line exception, and supplies trained personnel and a licensed operator. | Selected p. 5 ↗ |
| Capital work · §3 | Capital improvements over $100,000 require presentation to the City for approval. Certain smaller projects affecting major components require plans and specifications. | Selected p. 5 ↗ |
| Other connections · §7 | The City collects sewer charges from other connected customers and remits them monthly to Pilgrim’s. Additional connections require both parties’ consent. | Selected p. 7 ↗ |
| Compliance · §§3, 8 | The agreement addresses regulatory compliance, City cooperation and a conditional right to terminate following agency verification and the stated objection-and-appeal conditions. | Selected pp. 6–7 ↗ |
Those provisions do not establish that the City received a particular submission or that a termination condition has occurred. Current amendments, approvals, remittances and follow-up records would show how the arrangement has operated in practice.
03 / THE REQUEST & THE CITY’S OWN RECORDS
What explains the “no records” response?
Moring’s April 9 request covered January 1, 2020 through the City’s search date unless otherwise stated. In her April 13 response, Webster marked Section 2, items a–d, “NO CITY RECORDS EXIST.” Those items sought records about changes to pretreatment responsibilities and records identifying who performs the work.
The adopted FY2026 budget lists a half-time Pretreatment Operator under Utilities. Its Utilities Fund summary shows $76,058 for the FY2025 amended pretreatment budget and a dash in the FY2026 column. The document is posted as the adopted budget and carries an ADOPTED watermark, although that table retains a “2026 Proposed Budget” heading. These are records about staffing and allocation; the dash does not establish that pretreatment duties ended.
The City’s 2025 budget-workshop recording also discusses a half-time pretreatment position shared with Code Enforcement and the movement of costs into the utility department. Together, the chart, budget and recorded discussion provide concrete records to compare with the scope of Section 2 and the City’s response.
The earlier Council record also matters: the April 18, 2023 minutes included in the May 2 agenda packet record unanimous approval of pretreatment assistance and a general-service agreement with Plummer Associates, not exceeding $100,000. The posted proposal and Council authorization document planned work; they do not establish that all work was performed or that the full amount was spent.
Section 4 separately sought four defined categories of Pilgrim’s regulatory records, including City-issued authorizations and enforcement, reports submitted to the City, and monitoring or correspondence obtained by the City. The older lease and a state-issued permit do not automatically establish that the City held every requested category. The September 2026 order also postdates the April reply.
The video was posted August 11, 2025; the links use approximate passage times. The staffing discussion does not identify the employee by name. The budget excerpt preserves source pages 27, 47, 64, 76, 78 and 80.
Historical City program record. EPA’s February 26, 1998 letter ends the program-development requirement described in that letter, while preserving possible state requirements and asking the City to monitor industrial activity. Read it alongside the later City ordinance and records response, with their different dates and scopes. It does not establish current compliance or resolve the Southwest facility’s separate permit obligations. Read the historical letter and connected sources ↗
04 / TWO PERMITS, ONE GROUP REDUCTION PLAN
Why Pilgrim’s phosphorus results matter to the City.
The City’s Southside permit, WQ0010575004, issued June 2, 2025, has phosphorus-monitoring requirements. Its fact sheet says Pilgrim’s agreed to undertake the phosphorus reductions for the eight-permittee group, while the seven municipal permits receive monitoring requirements without individual numeric phosphorus limits. Mount Pleasant is one of those seven.
Other Requirement 10 allows TCEQ to review and reopen the City’s permit if the specified water-quality endpoint or combined annual phosphorus allocation is not achieved. The permit also contains contributing-industry and pretreatment requirements. This is a documented regulatory connection between the City’s plant and Pilgrim’s performance.
Pilgrim’s Southwest permit, WQ0003017000 / TX0062936, issued March 20, 2026, separately sets a phosphorus daily-average limit of 144.89 pounds per day and a rolling annual limit of 44,100 pounds. Monthly Southwest exceedances do not by themselves establish that the eight-facility annual allocation was missed or that the City violated its permit. That comparison needs all eight facilities’ annual data and TCEQ’s evaluation.
The City excerpt retains source PDF pages 6, 7, 43, 45, 99 and 100. The Southwest excerpt retains pages 7–9 and 24 of the March 27 delivery packet, including the permit’s March 20 issue date.
05 / DATED RESULTS & ENFORCEMENT
Keep the monitoring periods visible.
EPA’s discharge-monitoring report displays these Southwest phosphorus exceedances as of October 12, 2026. The table below preserves EPA’s displayed values and percentages; its rounded 145-pound limit corresponds to 144.89 in the issued permit.
| Monitoring period ends | Displayed result | Displayed limit | Reported exceedance |
|---|---|---|---|
| July 31, 2026 | 153 lb/day | 145 lb/day | 5% |
| August 31, 2026 | 295 lb/day | 145 lb/day | 104% |
These two phosphorus rows are not marked as potential outliers in EPA’s report. Other parameters have separate results and some carry data-quality flags; the complete report retains that context.
A signed order addresses earlier monitoring periods.
TCEQ’s agreed order, Docket 2025-1523-IWD-E, was signed September 29, 2026. Its allegations and table concern August and December 2023 and June and July 2024. The company denies the allegations, and the settlement states that entry of the order is not an admission. The July and August 2026 results above are separate from those settled allegations.
The order assesses $60,200, states that $48,160 was paid and defers $12,040 subject to compliance. It requires certification within 130 days of its effective date, with corrective-action documentation and discharge-monitoring reports showing at least three consecutive compliant months. Written extensions are possible under the order. That deadline had not arrived as of this page’s October 12 review date.
EPA’s case page displays a $0 collected field, but the signed order expressly records payment. The database field alone is not evidence that the company failed to pay.
06 / FOLLOW-THROUGH
Which records would complete the explanation?
The comparison is strongest when each question names the record and the period it concerns.
- Which current agreement, amendments or asset records reconcile the ownership descriptions and define the parties’ present responsibilities?
- What capital-work submissions, City approvals, connection consents, remittances and compliance correspondence document the operating relationship?
- How did the City account for the budget chart and recorded staffing discussion when answering the April 2026 request?
- What do the eight facilities’ annual phosphorus totals and TCEQ’s evaluation show about the combined reduction plan?
- When due, what certification and supporting records show compliance with the September 2026 order?
These questions connect the records without treating an unlocated document as proof of concealment or a later enforcement action as proof that an earlier records reply was false.