1974 records: State warned C. Roy’s over waste decades before lagoon kerfuffle

YALE — Fifty-year-old records show state officials warned C. Roy’s Inc. in 1974 that it could not discharge animal blood into Yale’s municipal wastewater system when moving to its current facility, decades before city staff discovered raw meatpacking waste entering the municipality’s lagoons.

Original blueprints for the South Brockway Road plant, obtained and reviewed by The Expositor, show the meat processor was designed with a dedicated blood storage pit intended to isolate slaughterhouse waste from the city’s sewer system. Only restroom plumbing was meant to funnel directly into municipal lines.

Read More: Read the 1974 correspondence here.

The correspondence and architectural plans, retrieved from city records provided by C. Roy’s, surface amid an ongoing regulatory crisis that threatens to shut down the meat processor. The business serves as a major regional employer and the centerpiece of the annual Yale Bologna Festival.

In a March 15, 1974, letter to Dennis L. Roy, state wastewater official Thomas C. Hoogerhyde made the requirement explicit.

“The fact that the blood from the kill operation is to be contained for removal by a rendering service company, is essential,” wrote Hoogerhyde, who then served as chief of the Municipal Wastewater Division in the Department of Natural Resources.

“The discharge of a slug of blood to the sanitary sewerage system raises a strong potential for severe overloading of the city lagoon with resultant obnoxious odor emission,” Hoogerhyde added. 

It remains unclear how long C. Roy’s discharged untreated slaughterhouse waste into the municipal system before city workers discovered the means of the connection in September 2023. 

Municipal wastewater managers falsely reported to state regulators in 2019 that the lagoons received no nondomestic waste.

“They weren’t supposed to be sending any water down to it,” Nancy Roy said of the 1974 directive during a September 2026 interview at the facility. “They obviously messed up, and they didn’t realize it until [the city] came down.”

“We can’t deny it because the pipe that’s here is the old pipe, and they’ve left us the only one in it,” Roy said, acknowledging the facility’s direct link to the municipal line and the animal waste documented by regulators. “We’re very sure that everything that comes out of that is ours. When they find stuff, it’s got to be ours.”

The discovery of the decades-old warning comes as C. Roy’s appeals a city permit enforcement action that could force the plant to close if requirements are not met.

The compliance struggle has dragged on for three years.

Following the 2023 discovery, representatives from the city, C. Roy’s and a commercial rendering firm met in early 2024 to plan a proper blood holding system. After C. Roy’s didn’t move forward, the city issued a formal violation notice in December 2024, citing breaches of local sewer ordinances and two federal Environmental Protection Agency regulations.

C. Roy’s installed two 2,500-gallon holding tanks in late 2025, but encountered issues constructing tanks capable of properly holding the waste. The company is now attempting to meet city and state mandates for chemical pretreatment.

Meanwhile, state regulators have grown impatient. In a July 2026 inspection report, the Department of Environment, Great Lakes, and Energy noted it recommended a total “cessation of the discharge of processed wastewater, but understands the city’s desire to accommodate an important business in their community.” 

The regulatory paper trail began in late summer 2023. Fearing heavy rains would cause the municipal lagoon to overflow, city officials alerted the state in August 2023, triggering a broader audit of local industrial users.

State and city inspectors checked four local industrial sites that month, noting no concerns over their wastewater. But during a Sept. 14, 2023, walk-through at C. Roy’s, EGLE engineer Kip Mitchell found an active floor drain on the kill floor leading straight to the municipal sewer line.

Photos taken by inspectors that day captured raw blood and animal byproducts in the municipal pipes. 

The open connection caught city officials off guard. In the December 2024 violation letter, city officials noted that when facility staff were asked about waste handling during the initial 2023 walk-through, “the response implied that it went out into the sanitary sewer system, [with] no mention of a pit.” 

“At this time, it was assumed the waste was, at minimum, going into the comminutor [a mechanical device used in wastewater treatment facilities to cut, shred, and grind large solid debris] pit for future pumping by the rendering company,” the city wrote. 

Read More: Read the correspondence with the city.

“It was later determined the pit was no longer in service and all waste from the entire facility flowed directly into the city’s sanitary sewer without any pretreatment or attempt to reduce blood or animal waste,” the city said.

As the city’s primary tool in enforcing wastewater regulations, the city has had a comprehensive sewer use ordinance since at least 1993. Reviewed by The Expositor, the 1993 ordinance included rules against contributing any animal guts or tissue, entrails, paunch manure, or whole blood, and from users discharging wastewater with certain amounts of biochemical oxygen demand, suspended solids and phosphorus.

“We did not know they had an ordinance,” Roy told The Expositor.

Past city supervision of its wastewater system could be described as lackluster or negligent, evidenced by a long record of noncompliance violations handed down by the state. 

State records show Yale officials repeatedly failed to submit mandatory monthly discharge monitoring reports throughout the 2010s. Between June 2018 and May 2023, the city failed to submit or turned in late 28 separate monitoring reports.

In addition, reports submitted between late 2019 and late 2020 contained errors in calculations for suspended solids, phosphorus and oxygen demand. The city also failed to submit required annual biosolids reports for 2020, 2021 and 2022 detailing how it managed sewage sludge. 

DMRs are a monthly required document that the city must send to EGLE to comply with wastewater management regulations. They measure items like suspended solids, ammonia and phosphorus content and dissolved oxygen levels.

Dissolved oxygen content in particular can indicate if or how much animal matter is entering a wastewater system, according to an EPA troubleshooting manual, since animal matter, such as pig blood, binds with it.

Dissolved oxygen is essential to fuel the bacteria that breaks down pollutants and waste. Low dissolved oxygen in a lagoon could manifest in high algae growth, dark color or odors.

Fifty years ago, state officials foresaw that exact failure when C. Roy’s moved from its downtown location — where it had routinely dumped slaughterhouse wash water and blood straight into the municipal sewers. 

The 1974 state directive was meant to end the practice permanently before the new plant opened.