Technical Development Document for Proposed Effluent Guidelines for the Meat and Poultry Products Category December 2023


vvEPA—

United States
Environmental Protection
Agency

Technical Development Document for
Proposed Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products

Point Source Category

December 2023

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U.S. Environmental Protection Agency
Office of Water (4303T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460

EPA-821-R-23-011

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Table of Contents

Acronyms & Abbreviations	viii

Glossary	ix

1.	Background	1

1.1	Legal Authority	1

1.2	Regulatory History of the MPP Point Source Category	2

1.3	References	3

2.	Summary of the Proposed Rulemaking	5

2.1	Summary of Proposed Discharge Requirements	5

2.1.1	Proposed Requirements for Direct Dischargers	5

2.1.2	Requirements for Indirect Dischargers	5

2.2	Scope and Applicability of Proposed Regulation	6

3.	Data Collection Activities	8

3.1	Site Visits	8

3.2	Sampling Program	9

3.3	MPP Industry Questionnaire	11

3.4	Other Existing Data Sources	13

3.5	Outreach Activities	15

3.6	Protection of Confidential Business Information	16

3.7	References	16

4.	Meat and Poultry Products Industry Operations and Wastewater Generation	17

4.1	Meat First Processing	20

4.2	Meat Further Processing	22

4.3	Poultry First Processing	25

4.4	Poultry Further Processing	27

4.5	Rendering	30

4.6	References	32

5.	Industry Subcategorization	33

5.1	MPP Proposed Subcategorization	33

5.2	References	34

6.	Wastewater Characterization	35

6.1 Meat Processing	35

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6.2	Poultry Processing	39

6.3	Independent Rendering	43

6.4	High Chlorides Wastewater	45

6.5	References	46

7.	Selection of Pollutants and Pollutant Parameters for Regulation	48

7.1	Pollutants Considered for Regulation	48

7.2	Selection of Pollutants of Concern	49

7.3	Selection of Pollutants for Regulation	52

7.3.1	Regulated Pollutants for Direct Dischargers	52

7.3.2	Regulated Pollutants for Indirect Dischargers	55

7.4	References	56

8.	Wastewater Treatment Technologies and Pollutant Prevention Practices	58

8.1	Primary Treatment	61

8.2	Biological Treatment	63

8.3	Phosphorus Removal	68

8.4	Disinfection	69

8.5	Solids Handling	71

8.6	High Chlorides Wastewater Treatment	73

8.7	Zero Discharge	74

8.8	Pollution Prevention and Wastewater Reduction Practices	75

8.9	References	76

9.	Technology Systems and Regulatory Options	77

9.1	Wastewater Treatment Technology Systems	77

9.1.1	Direct Dischargers of MPP Process Wastewater	77

9.1.2	Indirect Dischargers of MPP Process Wastewater	78

9.1.3	High Chlorides Wastewater Discharges	79

9.2	Regulatory Options	79

9.2.1 Selected Regulatory Option	84

9.3	BPT Analysis for Conventional Pollutants	84

9.4	BCT Analysis for Conventional Pollutants	85

9.4.1	Methodology	85

9.4.2	Analysis	86

9.5	References	89

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10.	Incremental Capital, Operation, and Maintenance Costs for the Proposed Regulation	90

10.1	Introduction	90

10.2	Methodology for Estimating Compliance Costs	90

10.2.1	MPP Process Wastewater	92

10.2.2	MPP High Chlorides Wastewater	96

10.3	Example Facility Cost	97

10.4	Summary of Total Estimated Compliance Costs	99

10.5	References	99

11.	Pollutant Loadings	101

11.1	General Methodology	102

11.2	Baseline Pollutant Loadings	105

11.2.1	MPP Process Wastewater	105

11.2.2	High Chlorides Wastewater	106

11.3	Technology System Loadings	107

11.3.1	MPP Process Wastewater	107

11.3.2	High Chlorides Wastewater	108

11.4	Summary of Regulatory Option Loadings and Pollutant Removals	108

11.5	References	110

12.	Non-Water Quality Environmental Impacts	112

12.1	Energy Requirements	112

12.2	Air Emissions Impacts	113

12.3	Solid Waste Generation	116

12.4	References	116

13.	Limitations and Standards	117

13.1	Data Preparation	117

13.1.1	Data Description	117

13.1.2	Data Editing Criteria and Aggregation	120

13.2	Statistical Analysis	123

13.2.1	Autocorrelation	123

13.2.2	Modified Delta Lognormal Distribution	124

13.2.3	Distribution Parameters	125

13.2.4	LTA Calculations	126

13.2.5	Percentile Calculations	127

13.2.6	VF Calculations	128

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13.2.7	Limitation Calculations	129

13.2.8	Sensitivity Analyses	131

13.3	Summary of Limitations	132

13.3.1	Summary of Limitations by Technology Basis	132

13.3.2	Long-Term Averages and Effluent Limitations for MPP Process Wastewater	133

13.4	References	134

Appendix A	136

Appendix B	139

List of Figures

Figure 4-1. MPP Facilities in the United States (Excluding Territories)	19

Figure 8-1. Process Flow Diagram of Conventional Activated Sludge System	64

Figure 8-2. Process Flow Diagram of MLE System to Achieve Denitrification	65

Figure 8-3. Process Flow Diagram of Modified Bardenpho (Five-Stage Bardenpho)	66

Figure 8-4. Process Flow Diagram of a Forced Circulation Evaporator System	74

Figure 13-1. Example of a Modified Delta Lognormal Distribution	125

Figure 13-2. Example Lognormal Distributions Varying by the Parameters |a (Left) and a (Right)	125

Figure 13-3. Box Plots of All Facilities' LTAs and VFs for Each Analyte	130

Figure B-l. Timelines of Series Used for Daily Calculations (Black) Averaged Within Calendar Months

(Blue)	140

Figure B-2. Timelines of All Monthly-Interval Series with at Least 30 Values, Following Aggregation of All

Data Sources	142

Figure B-3. Series' BOD Concentrations (Gray Points), LTAs (Blue Points), and Percentiles (Orange

Triangles, as 99th for Daily and 95th for Monthly)	146

Figure B-4. Series' O&G Concentrations (Gray Points), LTAs (Blue Points), and Percentiles (Orange

Triangles, as 99th for Daily and 95th for Monthly)	147

Figure B-5. Series' TSS Concentrations (Gray Points), LTAs (Blue Points), and Percentiles (Orange Triangles,

as 99th for Daily and 95th for Monthly)	148

Figure B-6. The Daily Chloride Series' Concentrations (Gray Points), LTA (Blue Point), and 99th Percentile

(Orange Triangle)	148

Figure B-7. Series' E. coli Concentrations (Gray Points), LTAs (Blue Points), and Percentiles (Orange

Triangles, as 99th for Daily and 95th for Monthly)	149

Figure B-8. Series' Fecal Coliform Concentrations (Gray Points), LTAs (Blue Points), and Percentiles

(Orange Triangles, as 99th for Daily and 95th for Monthly)	150

Figure B-9. Series' TN Concentrations (Gray Points), LTAs (Blue Points), and Percentiles (Orange Triangles,

as 99th for Daily and 95th for Monthly)	151

Figure B-10. Series' TP Concentrations (Gray Points), LTAs (Blue Points), and Percentiles (Orange Triangles,
as 99th for Daily and 95th for Monthly)	152

List of Tables

Table 2-1. MPP Industry Entities Potentially Regulated by the Proposed Rule	6

Table 2-2. MPP ELG Subcategories	6

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Table 3-1. List of Site Visits 8

Table 3-2. List of Facility-Specific SAPs and SERs 11

Table 3-3. Summary of MPP Questionnaires Responses 13

Table 3-4. Existing Data Collection Sources Used by the EPA 13

Table 3-5. Data Submitted by Industry 15

Table 3-6. Summary of the EPA's Stakeholder Meetings 15

Table 4-1. MPP Facilities from MPP Questionnaires and Industry Profile 19

Table 4-2. States with the Highest Percentages of Meat First Processing Facilities 21

Table 4-3. Meat First Processing Facilities by Annual Production 22

Table 4-4. States with the Highest Percentages of Meat Further Processing Facilities 24

Table 4-5. Meat Further Processing Facilities by Annual Production 25

Table 4-6. States with the Highest Percentages of Poultry First Processing Facilities 27

Table 4-7. Poultry First Processing Facilities by Annual Production 27

Table 4-8. States with the Highest Percentages of Poultry Further Processing Facilities 29

Table 4-9. Poultry Further Processing Facilities by Annual Production 30

Table 4-10. States with the Highest Percentages of Independent Rendering Facilities 31

Table 4-11. Independent Rendering Facilities by Annual Production 32

Table 6-1. MPP Process Wastewater Generation Flow Rates for Meat Processing Facilities By Annual

Production as Reported in the Detailed Questionnaire 36

Table 6-2. MPP Process Wastewater Generation Flow Rates for Meat Processing Facilities By Discharge

Type as Reported in the Detailed Questionnaire 37

Table 6-3. Average Pollutant Concentrations in Untreated MPP Wastewater at Integrated Meat

Processing Facilities 38

Table 6-4. MPP Process Wastewater Generation Flow Rates for Poultry Processing Facilities By Annual

Production as Reported in the Detailed Questionnaire 40

Table 6-5. MPP Process Wastewater Generation Flow Rates for Poultry Processing Facilities By Discharge

Type as Reported in the Detailed Questionnaire 41

Table 6-6. Average Pollutant Concentrations in Untreated MPP Wastewater at Poultry First and Integrated

Poultry Processing Facilities 42

Table 6-7. MPP Process Wastewater Generation Flow Rates for Independent Rendering Facilities By

Annual Production as Reported in the Detailed Questionnaire 43

Table 6-8. MPP Process Wastewater Generation Flow Rates for Independent Rendering Facilities By

Discharge Type as Reported in the Detailed Questionnaire 44

Table 6-9. Average Pollutant Concentrations in Untreated MPP Wastewater at Independent Rendering

Facilities 45

Table 7-1. POC Analysis Results for MPP Process Wastewaters 50

Table 7-2. POCs Eliminated from Consideration for Regulation for Direct Dischargers 54

Table 7-3. POTW Passthrough Analysis for MPP Process Wastewater 55

Table 8-1. MPP Facility Breakdown from Industry Profile and Detailed Questionnaire by Discharge Type 58
Table 8-2. MPP Facility Breakdown from Industry Profile and Detailed Questionnaire by Production by

Process Type and Annual Production 59

Table 8-3. Facilities that Treat MPP Process Wastewater on Site Based on Detailed Questionnaire by

Discharge Type 60

Table 8-4. Facilities that Treat MPP Process Wastewater on Site Based on Detailed Questionnaire by

Process Type and Annual Production 60

Table 8-5. Number of Detailed Questionnaire Respondents That Implement Primary Treatment by
Discharge Type 61

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Table 8-6. Number of Detailed Questionnaire Respondents That Implement Primary Treatment by Process

Type and Annual Production 62

Table 8-7. Primary Treatment Units Used in the MPP Industry 63

Table 8-8. Number of Detailed Questionnaire Respondents That Implement Biological Treatment by

Discharge Type 67

Table 8-9. Number of Detailed Questionnaire Respondents That Implement Biological Treatment by

Process Type and Annual Production 67

Table 8-10. List of Phosphorus Removal Treatment Units 68

Table 8-11. Number of Detailed Questionnaire Respondents That Implement a Disinfection Treatment

Unit by Discharge Type 69

Table 8-12. Number of Detailed Questionnaire Respondents That Implement a Disinfection Treatment

Unit by Processing and Annual Production 70

Table 8-13. List of Disinfection Treatment Units 71

Table 8-14. List of Solids Handling Treatment Units 71

Table 8-15. Number of Detailed Questionnaire Respondents That Implement Treatment for Solids

Handling by Discharge Type 72

Table 8-16. Number of Detailed Questionnaire Respondents That Implement Treatment for Solids

Handling by Processing and Annual Production 72

Table 8-17. Common Treatment Units for Zero Discharging MPP Facilities 74

Table 9-1. Technology Systems Considered for Direct Dischargers 78

Table 9-2. Technology Systems Considered for Indirect Dischargers 79

Table 9-3. Regulatory Options for Direct Dischargers (Level of Control includes BAT and NSPS) for MPP

Process Wastewater 80

Table 9-4. Regulatory Options for Indirect Dischargers (Level of Control includes PSES and PSNS) for MPP

Process Wastewater 82

Table 9-5. Number of MPP Facilities by Regulatory Option 84

Table 9-6. Incremental Costs and Conventional Pollutant Removals—Regulatory Option 1 88

Table 9-7. BCT Cost Test Results—Regulatory Option 1 89

Table 10-1. Cost Data Sources for Process Wastewater Technology Systems and Units 93

Table 10-2. Flow Rates (MGD) Used to Generate MPP Operation Cost Curves 94

Table 10-3. Other Cost Estimates for MPP Process Wastewater 95

Table 10-4. Example Facility—Cost Inputs 97

Table 10-5. Example Facility—Treatment in Place 98

Table 10-6. Example Facility—Estimated Capital and O&M Costs for MPP Process Wastewater 98

Table 10-7. Example Facility—Estimated Capital and O&M Costs for High Chlorides Wastewater 99

Table 10-8. Industry Capital and O&M Costs by Technology System 99

Table 10-9. Industry Capital and O&M Costs by Regulatory Option 99

Table 11-1. MPP POTW Pollutant Removals 103

Table 11-2. Technology Systems for MPP Process Wastewater 107

Table 11-3. Industry-Level Pollutant Loadings and Removals for MPP Process Wastewater by Regulatory

Option 109

Table 11-4. Industry-Level Pollutant Loadings and Removals for High Chlorides Wastewater for Facilities

Producing More Than 5 Million Pounds per Year 110

Table 12-1. Net Incremental Increases in Annual Energy Usage for MPP Process Wastewater Regulatory

Options 112

Table 12-2. Net Incremental Increases in Annual Fuel Usage for MPP Process Wastewater Regulatory
Options 113

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Table 12-3. Net Incremental Increases in Air Emissions By Source for MPP Process Wastewater Regulatory

Options 115

Table 12-4. Net Incremental Increases in Air Emissions (Tons/Year) for High Chlorides Wastewater

Evaporation for Facilities Producing More than 5 Million Pounds per Year 116

Table 12-5. Net Incremental Increases in Solid Waste Generation for MPP Process Wastewater Regulatory

Options 116

Table 13-1. Limitations by Technology Basis 119

Table 13-2. Resulting Limitations for All Analytes 131

Table 13-3. NSPS, BAT, and BPT Limitations by Technology Basis for Direct Dischargers 132

Table 13-4. PSES and PSNS Limitations by Technology Basis for Indirect Dischargers 133

Table 13-5. LTAs and Limitations for Existing and New Sources 134

Table A-l. Incremental Costs and Conventional Pollutant Removals—Regulatory Option 2 136

Table A-2. Incremental Costs and Conventional Pollutant Removals—Regulatory Option 3 137

Table A-3. BCT Cost Test Results—Regulatory Option 2 and 3 138

Table B-l. Summary of LTA Test 143

Table B-2. R Code Used to Calculate Parameters |a and a 145

Table B-3. R Code Used to Calculate Percentiles 145

Table B-4. Metrics Calculated for Each Series of BOD Concentrations (in mg/L): LTAs, Percentiles, and VFs

153

Table B-5. Metrics Calculated for Each Series of O&G Concentrations (in mg/L): LTAs, Percentiles, and VFs

153

Table B-6. Metrics Calculated for Each Series of TSS Concentrations (in mg/L): LTAs, Percentiles, and VFs

154

Table B-7. Metrics Calculated for the Series of Chloride Concentrations (in mg/L): LTAs, Percentiles, and

VFs 154

Table B-8. Metrics Calculated for Each Series of E. coli Concentrations (in MPN/100 mL): LTAs, Percentiles,

and VFs 155

Table B-9. Metrics Calculated for Each Series of Fecal Coliform Concentrations (in MPN/100 mL): LTAs,

Percentiles, and VFs 155

Table B-10. Metrics Calculated for Each Series of TN Concentrations (in mg/L): LTAs, Percentiles, and VFs

156

Table B-ll. Metrics Calculated for Each Series of TP Concentrations (in mg/L): LTAs, Percentiles, and VFs
157

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Acronyms & Abbreviations

BAT

Best Available Technology Economically Achievable

BADCT

Best Available Demonstrated Control Technology

BCT

Best Conventional Pollutant Control Technology

BOD

Biochemical Oxygen Demand

BPT

Best Practicable Control Technology Currently Available

CBI

Confidential Business Information

cBOD

Carbonaceous Biochemical Oxygen Demand

CFR

Code of Federal Regulations

COD

Chemical Oxygen Demand

CWA

Clean Water Act

DAF

Dissolved Air Flotation

DCN

Document Control Number

DMR

Discharge Monitoring Reports

DO

Dissolved Oxygen

E. Coli

Escherichia coli

ELGs

Effluent Limitation Guidelines and Standards

EPA

Environmental Protection Agency

FC

Fecal coliform

FRN

Federal Register Notice

FSIS

Food Safety Inspection Service

GPD

Gallons Per Day

GPY

Gallons Per Year

GSAP

Generic Sampling and Analysis Plan

HRSD

Hampton Roads Sanitation District

ICIS

Integrated Compliance Information System

LTA

Long-Term Average

LWK

Live Weight Killed

MBR

Membrane Bioreactor

MDL

Method Detection Limit

MGD

Millions of Gallons per Day

MGY

Millions of Gallons per Year

MLE

Modified Ludzack-Ettinger

MPI

Meat, Poultry and Egg Product Inspection

MPN

Most Probable Number

MPP

Meat and Poultry Products

MWh

Megawatt Hour

NAICS

North American Industry Classification System

ND

Non-Detect

NPDES

National Pollutant Discharge Elimination System

NSPS

New Source Performance Standards

NWQEI

Non-Water Quality Environmental Impacts

O&G

Oil and grease

O&M

Operation and Maintenance

PM2.5

Particulate Matter 2.5 Microns

POC

Pollutants of Concern

PSES

Pretreatment Standards for Existing Sources

PSNS

Pretreatment Standards for New Sources

POTW

Publicly Owned Treatment Works

SAP

Sampling and Analysis Plan

SBR

Sequencing Batch Reactors

SBREFA

Small Business Regulatory Enforcement Fairness Act

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SER

SRT

TDD

TDS

TIP

TKN

TOC

TSS

U.S.

USDA

Sampling Episode Reports

Sludge Retention Time

Technical Development Document

Total Dissolved Solids

Treatment In Place

Total Kjeldahl Nitrogen

Total Nitrogen

Total Phosphorus

Total Organic Carbon

Total Suspended Solids

United States

United States Department of Agriculture

Ultraviolet

Variability Factor

Glossary

Biological Treatment: Wastewater treatment intended to degrade and reduce organic matter in
wastewater, primarily in the form of soluble organic compounds.

Canned Meat Processor: An operation that prepares and cans meats (such as stew, sandwich spreads, or
similar products) alone or in combination with other finished products.

Complex Slaughterhouse: A slaughterhouse that accomplishes extensive by-product processing, usually at
least three such operations as rendering, paunch and viscera handling, blood processing, hide processing,
or hair processing.

Confidential Business Information: Privileged information, classified information, or specific information
(e.g., trade secrets) of a type for which there is a clear and compelling need to withhold from disclosure.

Conventional Pollutants: Constituents of wastewater as determined by Clean Water Act (CWA) Section
304(a)(4) and the U.S. Environmental Protection Agency regulations (i.e., pollutants classified as
biochemical oxygen demand, total suspended solids, oil and grease, fecal coliform, and pH).

Deepwell Injection: Long-term or permanent disposal of untreated, partially treated, or treated
wastewaters by pumping them into underground formations of suitable character through a bored,
drilled, or driven well.

Denitrification: A microbial process in which nitrite and nitrate are reduced by heterotrophic bacteria into
gaseous nitrous oxide and nitrogen gas under anoxic conditions without the presence of molecular
oxygen. A carbon source, such as methanol, may need to be added to keep the microbes healthy.

Direct Discharger: A facility that discharges or may discharge treated or untreated wastewaters into
waters of the United States.

Disinfection: Destruction of pathogenic microorganisms in wastewater, typically achieved through
chemical and/or physical treatment.

Effluent Limitations Guidelines and Standards: Regulations promulgated by the U.S. EPA under authority
of CWA Sections 301, 304, 306, and 307 that set out minimum, national technology-based standards of
performance for point source wastewater discharges from specific industrial categories (e.g., meat and
poultry products). Effluent limitations guidelines and standards regulations are implemented through the
National Pollutant Discharge Elimination System (NPDES) permit and national pretreatment programs.

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Finished Product: The final fresh or frozen products resulting from the further processing of either whole
or cut-up meat or poultry carcasses.

First Processing: Operations that receive live meat animals and produce a raw, dressed meat product,
either whole or in parts.

Further Processing: Operations that use whole carcasses or cut-up meat or poultry products for the
production of fresh or frozen products. These operations may include the following types of processing:
cutting and deboning, cooking, seasoning, smoking, canning, grinding, chopping, dicing, forming,
breading, breaking, trimming, skinning, tenderizing, marinating, curing, pickling, extruding, and/or linking.

Ham Processor: An operation that manufactures hams alone or in combination with other finished
products.

Hide Processing: Wet or dry hide processing. Includes demanuring, washing, and defleshing, followed by
curing.

High Chlorides Wastewater: A specific type of meat and poultry products (MPP) process wastewater
generated from hide processing, kosher slaughter, curing, smoking, pickling, and marinating.

High-Processing Packinghouse: A packinghouse that processes both animals slaughtered onsite and
additional carcasses from outside sources.

Indirect Discharger: A facility that discharges or may discharge treated or untreated wastewaters into a
Publicly Owned Treatment Works (POTW).

Live Weight Killed: The total weight of the total number of animals slaughtered during the time to which
the effluent limitations apply (i.e., during any one day or any period of 30 consecutive days).

Low-Processing Packinghouse: A packinghouse that processes no more than the total animals killed at
that facility, normally processing less than the total kill.

Meat: Includes all animal products from cattle, calves, hogs, sheep, and lambs, etc., except those defined
as Poultry.

Meat and Poultry Products: Include meat and poultry from cattle, hogs, sheep, chickens, turkeys, ducks
and other fowl. Also includes sausages; luncheon meats; and cured, smoked, canned, or other prepared
meat and poultry products from purchased carcasses and other materials intended for human
consumption. Meat and poultry products for animal food and feeds include animal oils, meat meal, and
grease and tallow rendered from animal fat, bones, and meat scraps.

Meat and Poultry Products Process Wastewater: Commingled wastewater from the MPP facility, including
any water which, during processing, comes into direct contact with any raw material, intermediate
product, finished product, byproduct, or waste product. This includes meat and poultry product
processing areas and animal holding areas.

Meat Cutter: An operation that fabricates, cuts, or otherwise produces fresh meat cuts and related
finished products from livestock carcasses.

Meat Operations/Meat Product Operations: Includes meat slaughtering operations, by-product
operations, rendering, and further processing.

National Pollutant Discharge Elimination System: The national program authorized by CWA Sections 307,
318, 402, and 405 for issuing, modifying, revoking and reissuing, and terminating, monitoring and
enforcing permits, and for imposing and enforcing pretreatment requirements under the CWA. The

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NPDES permit number is assigned by the relative state or EPA Region and typically includes the state
abbreviation in the number.

Nitrification: A two-step aerobic process. First, ammonia is oxidized into nitrite by Nitrosomonas bacteria.
Then, nitrite is oxidized into nitrate by Nitrobacter bacteria. Nitrification only occurs when there is
enough biomass and residence time to fully convert ammonia to nitrite, and then convert nitrite to
nitrate.

Nitrogen Removal: The removal of nitrogen, through nitrification and denitrification, from wastewater
through either biological or physical/chemical means or a combination thereof.

Non-Conventional Pollutants: Pollutants that are neither conventional pollutants nor priority pollutants
listed at 40 CFR 401.15 and 423 Appendix A.

Non-Water Quality Environmental Impacts: Deleterious aspects of control and treatment technologies
applicable to point source category wastes, including, but not limited to air pollution, noise, radiation,
sludge and solid waste generation, and energy used.

North American Industry Classification System: The standard used by federal statistical agencies in
classifying business establishments for the purpose of collecting, analyzing, and publishing statistical data
related to the U.S. business economy. Each facility is categorized within a NAICS code based on the type
of operations conducted at the facility (e.g., NAICS code 311611 is for Animal (except Poultry)
Slaughtering).

Nutrient Removal: Wastewater treatment that is engineered or operated to remove the nutrients
nitrogen and phosphorus in amounts greater than the basic metabolic needs of the biological treatment
system. Nutrient removal may be accomplished through biological or physical/chemical means or a
combination thereof.

Offsite/Off Site: Outside the boundaries of a facility.

Onsite/On Site: The same or geographically contiguous property, which may be divided by a public or
private right-of-way, provided the entrance and exit between the properties is at a crossroads
intersection, and access is by crossing as opposed to going along the right-of-way. Noncontiguous
properties owned by the same company or locality but connected by a right-of-way, which it controls,
and to which the public does not have access, is also considered on-site property.

Outfall: Pipelines or tunnels that discharge municipal or industrial wastewater, storm water, combined
sewer overflows, cooling water, or brine effluents to a receiving water body.

Packinghouse: A facility that both slaughters animals and subsequently processes carcasses into cured,
smoked, canned, or other prepared meat products.

Passthrough: A pollutant is determined to passthrough POTWs when the median percentage removed
nationwide by well-operated POTWs is less than the median percentage removed by the Best Available
Technology Economically Achievable/New Source Performance Standards (BAT/NSPS) technology basis.

Phosphorus Removal: The removal of phosphorus from wastewater through either biological or chemical
means or a combination thereof.

Point Source: Any discernable, confined, and discrete conveyance from which pollutants are or may be
discharged. See CWA Section 502(14).

Pollutants of Concern: Pollutants commonly found in meat and poultry processing wastewaters. Typically,
a pollutant is considered as a pollutant of concern (POC) if it is detected in untreated process wastewater
at five times a baseline value in more than 10 percent of the samples.

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Poultry: Products derived from the slaughter and processing of broilers, other young chickens, mature
chickens, hens, turkeys, capons, geese, ducks, small game fowl such as quail or pheasants, and small
game such as rabbits.

Poultry Operations: Includes poultry slaughtering operations, by-product operations, rendering, and
further processing.

Primary Treatment: An initial wastewater treatment stage intended to remove floating and settleable
solids.

Priority Pollutants: 126 compounds that are a subset of the 65 toxic pollutants and classes of pollutants
outlined, pursuant to CWA Section 307.

Process Wastewater: Any water which, during meat or poultry operations, comes into direct contact with
or results from the storage, production, or use of any raw material, intermediate product, finished
product, by-product, or waste product. Wastewater from equipment cleaning, direct-contact air pollution
control devices, rinse water, storm water associated with industrial activity, and contaminated cooling
water are considered process wastewater. Process wastewater may also include wastewater that is
contract hauled for offsite disposal. Sanitary wastewater, uncontaminated noncontact cooling water, and
storm water not associated with industrial activity are not considered process wastewater.

Publicly Owned Treatment Works: Any device or system owned and operated by a public entity and used
in the storage, treatment, recycling, or reclamation of liquid municipal sewage and/or liquid industrial
wastes. The sewerage system that conveys wastewaters to treatment works is considered part of the
POTW.

Raw Material: The basic input materials to a renderer composed of animal and poultry trimmings, bones,
meat scraps, dead animals, feathers, and related usable by-products.

Renderer: An independent or offsite rendering operation, conducted separate from a slaughterhouse,
packinghouse, or poultry dressing or processing plant, that manufactures meat meal, tankage, animal fats
or oils, grease, and tallow and may cure cattle hides. Excludesg marine oils, fish meal, and fish oils.

Rendering: An operation, conducted separate from a slaughterhouse, packinghouse or poultry dressing or
processing operation that uses raw material, produces meat meal, tankage, animal fats or oils, grease,
and tallow and may cure cattle hides. Excludes marine oils, fish meal, and fish oils.

Sausage and Luncheon Meat Processor: An operation that cuts fresh meats, grinds, mixes, seasons,
smokes, or otherwise produces finished products such as sausage, bologna, and luncheon meats.

Simple Slaughterhouse: A slaughterhouse that does very limited by-product processing, if any, usually no
more than two operations such as rendering, paunch and viscera handling, blood processing, hide
processing, or hair processing.

Slaughterhouse: A facility that slaughters animals and has as its main product fresh meat as whole, half,
or quarter carcasses or smaller meat cuts.

Slaughtering: Operations that kill animals for human consumption and/or animal food and feeds.

Small Business: The definitions of small business for the meat products industries are in the Small
Business Administration (SBA) regulations at 13 CFR 121.201. These size standards were updated
effective October 1, 2000. SBA size standards for the meat and poultry products industry (i.e., for NAICS
codes 311611, 311612, 311613, and 311615) define a "small business" as one with 500 or fewer
employees.

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Small Processor: An operation that produces up to 2,730 kilograms (6,000 pounds) per day of any type or
combination of finished products.

Solids (Biosolids) Handling: Disposal or destruction of biosolids generated during the treatment of
wastewater.

Standard Industrial Classification: A numerical categorization system used by the U.S. Department of
Commerce to catalogue economic activity. SIC codes refer to the products, or group of products,
produced or distributed, or to services rendered by an operating establishment. SIC codes are used to
group establishments by the economic activities in which they are engaged. They often denote a facility's
primary, secondary, tertiary, etc. economic activities.

Surface Water: Waters of the United States as is consistent with the pre-2015 regulatory regime. Refer to
the Current Implementation of Waters of the United States for details and definitions of terms:
https://www.epa.gOv/wotus/current-implementation-waters-united-states#Pre-2015.

Wastewater Treatment: The processing of wastewater by physical, chemical, biological, or other means
to remove specific pollutants from the wastewater stream or to alter the physical or chemical state of
specific pollutants in the wastewater stream. Treatment is performed for discharge of treated
wastewater, recycling of treated wastewater to the same process that generated the wastewater, or for
reuse of the treated wastewater in another process.

Zero Discharge: Disposal of process and/or nonprocess wastewaters other than by direct discharge to a
surface water or by indirect discharge to a POTW. Examples include land application, deep well injection,
and contract hauling.

xiii

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1. Background

The U.S. Environmental Protection Agency is proposing revisions to the effluent limitations guidelines and
standards (ELGs) for the meat and poultry products (MPP) point source category (40 CFR 432). These
revisions are based on a review of available and collected data.

This Technical Development Document (TDD) presents information on the proposed revisions, including
details on the EPA's data collection activities; industry background and profile (e.g., types of processing
facilities, details on wastewater treatment); identification and evaluation of wastewater treatment
technology systems; limitations and standards development; and methodologies for estimating
compliance costs, pollutant removals, and non-water quality impacts. In addition to this TDD, the
following reports support the proposed MPP ELGs:

• Environmental Assessment for the Proposed Effluent Limitations Guidelines and Standards for the
Meat and Poultry Products Point Source Category, Document No. EPA-821-R-23-012. This report
summarizes the environmental and human health improvements that result from implementation of
the proposed ELGs.

• Benefits and Cost Analysis for the Proposed Effluent Limitations Guidelines and Standards for the Meat
and Poultry Products Point Source Category, Document No. EPA-821-R-23-013. This report
summarizes the monetary benefits and societal costs that result from implementation of the
proposed ELGs.

• Regulatory Impact Analysis for Proposed Effluent Limitations Guidelines and Standards for the Meat
and Poultry Products Point Source Category (RIA), Document No. EPA-821-R-23-014. This report
presents a profile of the MPP industry, a summary of the costs and impacts associated with the
regulatory options, and an assessment of the proposed ELGs impact on employment and small
businesses.

The rest of this section describes background information for the EPA's proposed rulemaking. Section 1.1
summarizes the EPA's legal authority to propose changes to the MPP ELGs. Section 1.2 presents the
regulatory history of the MPP ELGs.

All environmental information used is in accordance with the EPA's Guidelines for Ensuring and
Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the
Environmental Protection Agency (the Guidelines), which contains the EPA's policy and procedural
guidance for ensuring and maximizing the quality of information disseminated (U.S. EPA, 2002a). The
EPA's quality assurance (QA) and quality control activities for this rulemaking include developing,
approving, and implementing QA project plans for the use of environmental data generated or collected
from sampling and analyses, existing databases, and literature searches, and for developing any models
that use environmental data.

1.1 Legal Authority

The EPA is proposing to revise the ELGs for MPP under the authority of Clean Water Act (CWA) Sections
301, 304, 306, 307, 308, 402, and 501, 33 U.S.C. 1311, 1314, 1316-1318, 1342, and 1361.

Congress passed the Federal Water Pollution Control Act Amendments of 1972, also known as the CWA,
to "restore and maintain the chemical, physical, and biological integrity of the Nation's waters," per 33
U.S.C. 1251(a). The CWA establishes a comprehensive program for protecting the nation's waters. Among
its core provisions, the CWA prohibits the discharge of pollutants from a point source directly to waters of
the United States or indirectly through discharge to Publicly Owned Treatment Works (POTWs), except as
authorized under the CWA. Under section 402 of the CWA, direct discharges may be authorized through a
National Pollutant Discharge Elimination System (NPDES) permit and national pretreatment standards for

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pollutants that passthrough, interfere with, or are otherwise incompatible with POTW operations apply to
indirect discharges. The CWA also authorizes the EPA to establish national technology-based effluent
limitations guidelines, new source performance standards, and pretreatment standards for discharges
from categories of point sources.1

1.2 Regulatory History of the MPP Point Source Category

The EPA promulgated MPP ELGs in 1974 for meat slaughterhouses and packinghouse facilities (40 CFR
432, Subcategories A through D), and in 1975 for meat further processing facilities (40 CFR 432,
Subcategories E through I) and independent rendering facilities (40 CFR 432 Subcategory J). Although the
Agency proposed ELGs for the poultry industry in 1974, these ELGs were not finalized at that time.

In 2002, the EPA proposed revisions to the meat processing ELGs and proposed new ELGs for poultry
processing. These proposed revisions and new ELGs included new or updated limitations on total nitrogen
(TN), total phosphorus (TP), and ammonia on direct discharges for most subcategories. No pretreatment
standards were proposed at that time (U.S. EPA, 2002b). The Agency intended to promulgate ELGs based
on advanced biological treatment that would achieve higher levels of nutrient removal by facilitating the
conversion of harmful forms of nutrients to less harmful ones (e.g., ammonia to nitrate, nitrate to
nitrogen) prior to discharge. Public comments submitted for the proposal and a Notice of Data Availability
(NODA) expressed concerns about seasonal changes affecting biological nitrification and the disparity of
influent nitrogen concentrations among meat and poultry facilities. The EPA also noted at the time that
the treatment technologies selected as the bases for the proposed limitations did not remove
phosphorus from wastewater (U.S. EPA, 2004a). Following the proposal and NODA, the EPA promulgated
final ELGs with limitations for ammonia and TN for all subcategories except Small Meat Further
Processors (Subcategory E). The EPA did not establish pretreatment standards in the final rule because
there was insufficient evidence of passthrough or interference at POTWs from meat and poultry facilities
to warrant establishing national pretreatment standards for these facilities (U.S. EPA, 2004a).

During the 2017 annual review of ELGs, the EPA evaluated nutrient discharges from industrial point
source categories based on the median facility load and number of facilities reporting discharges in each
industrial category. The EPA found that the MPP point source category contributed some of the highest
nutrient loadings across the nutrient discharge rankings for both TN and TP (U.S. EPA, 2019). Based on
these findings, the EPA pursued a detailed study of the MPP category to gather more information and
evaluate if a rulemaking to revise the ELG is appropriate (announced in Effluent Guidelines Program Plan
14) U.S. EPA, 2021a).

During this study, the EPA evaluated publicly available data for direct discharging facilities as well as
POTWs' annual reports and available indirect discharge inspection reports from significant industrial users
(U.S. EPA, 2021a). The EPA found that the existing ELGs only applied to around 300 of the estimated
7,000 MPP facilities nationwide and do not apply to indirect dischargers. The EPA also found that the MPP
industry discharges the highest phosphorus levels and second highest nitrogen levels of all industrial
categories from facilities across the country. During the study, the EPA identified facilities that were
already removing nutrients and achieving effluent concentrations well below the limitations in the
existing MPP ELGs, using available and affordable wastewater treatment technologies.

As the majority of MPP facilities are indirect dischargers, the EPA analyzed available data on MPP indirect
facilities and POTWs that receive MPP wastewater. The EPA also discussed POTW noncompliance issues
with the regions, states, and stakeholders and analyzed POTW reports, violation and noncompliance
notices, and other correspondence between MPP indirect dischargers and their receiving POTWs. Some
of these examples and case studies include:

1 https://www.ecfr.ROv/current/title-40/chapter-l; the CWA can be found at 33 U.S.C. § 1251 et seq. The CWA
regulations are in 40 CFR 104-108, 110-117, 122-140, 230-233, 401-471, and 501-503.

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• In 2021, the EPA reviewed 220 indirect discharging MPP facilities. Of the 112 POTWs that received
MPP process wastewater from these facilities, the EPA found that 73 percent had violation(s) of
permit limitations for pollutants found in MPP wastewater, including nitrogen, phosphorus, total
suspended solids (TSS), biochemical oxygen demand (BOD), oil and grease (O&G), chloride, total
residual chlorine, fecal coliform bacteria (e.g., E. coli), and metals. Of the more than 100 POTW
discharge permits reviewed, the EPA found the majority did not have limitations for nitrogen or
phosphorus. Thus, many POTWs may not be removing much of the nutrient load discharged by MPP
industrial users because many POTWs do not have treatment designed to remove nutrients (U.S. EPA,
2021b).

• Region 8 visited POTWs that do not have approved pretreatment programs and compiled case
studies. In one case study, a POTW was found to receive more flow and BOD that it was designed for,
and as a result the POTW consistently failed to meet its BOD and flow limitations in 2017 and 2018.
The EPA found that a slaughterhouse was discharging process wastewater to the POTW and causing
the POTW to violate its permit limitations. The POTW has since been required to develop and submit
a pretreatment program, according to the requirements of 40 CFR 403 (U.S. EPA, 2018, 2020).

• Region 1 provided information on a poultry slaughterhouse that caused reported issues at its
receiving POTW with respect to ammonia, carbonaceous biochemical oxygen demand (cBOD), fats,
O&G, ferric sulfate, flow, salt, TSS, and untreated wastewater. Reports also stated that the poultry
facility discharges caused operational difficulties and premature fouling and also "interfered with the
POTW's ability to function" (U.S. DOJ, 2014).

• Between 2006 and 2011, an MPP facility in Nebraska discharged pollutants at levels that exceeded
the permitted limitations, causing interference with the receiving POTW's treatment process. In
2008, one of the violations resulted in a fish kill in nearby rivers. Estimates were that 10,000 fish were
killed in the episode (U.S. DOJ, 2011).

• The EPA estimates that there are 23,000 to 75,000 Sanitary Sewer Overflows (SSOs) each year in the
United States. SSOs involve raw sewage overflowing from municipal sewer systems and can cause
public health issues. SSOs can be caused by blockages from fats, oils, and grease. The EPA's 2004
Report to Congress, Impacts and Controls of CSOs and SSOs found that 47 percent of reported
blockages were due to "grease from restaurants, homes, and industrial sources" and that grease
"solidifies, reduces conveyance capacity, and blocks flows," leading to blockages (U.S. EPA, 2004b).
MPP facilities often discharge high amounts of fats, oils, and grease.

The results of the detailed study indicated a revision to the MPP ELGs may be appropriate (U.S. EPA,

2021c). Accordingly, in Preliminary Effluent Guidelines Program Plan 15, the EPA identified the MPP

category for rulemaking (U.S. EPA, 2021c).

1.3 References

1. U.S. Department of Justice (DOJ). 2011. Swift Beef Company to Pay $1.3 Million Penalty for Clean
Water Act and State Law Violations at Its Grand Island, Nebraska Beef Processing Plant (June). EPA-
HQ-OW-2021-0547-0053. Available online at: https://www.justice.gov/opa/pr/swift-beef-company-
pav-13-million-penaltv-clean-water-act-and-state-law-violations-its-grand.

2. U.S. DOJ. 2014. United States v. Kiryas Joel Poultry Processing (KJPP), 14. Civ. 8458 Complaint
(October). EPA-HQ-OW-2021-0547-0045. Available online at:
https://www.justice.gov/sites/default/files/usao-

sd my/legacy/2.015/03 &20States%20v."%20KJPPP%2C%2014%20Civ.%208458%20%28VB%2

9%20-%20Com pla ii int. pdf.

3. U.S. EPA. 2002a. Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity
of Information Disseminated by the Environmental Protection Agency (October). EPA/260R-02-008.
Available online at: https://www.epa.gov/sites/default/files/2020-02/documents/epa-info-quality-

guiideIIiines pdf veirsiioin.pdf.

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4.	U.S. EPA. 2002b. Development Document for the Proposed Effluent Limitations Guidelines for the
Meat and Poultry Products Industry Point Source Category (January). EPA-821-B-01-007. Available
online at: https://nepis.epa.gov/Exe/ZvPURL.cgi?Dockey=20002F0Q.TXT.

5.	U.S. EPA. 2004a. Technical Development Document for the Final Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products Point Source Category (40 CFR 432) (September). EPA-
821-R-04-011. Available online at: https://www.epa.gov/sites/default/files/2015-

)cuiTients/iTieat-poultirv-piroducts tdd 2.004 Q.pdf.

6.	U.S. EPA. 2004b. Report to Congress: Impacts and Controls ofCSOs andSSOs (August). EPA 833-R-04-
001. Available online at: https://www.epa.gov/sites/default/files/2015-

10/doc u in e nts/csosso rtc2004 fu IIII. pdf.

7.	U.S. EPA. 2018. Region 8 Case Study Slaughterhouse Effect on a Small Town (November). DCN
MP00042. Available online at: https://www.acwa-us.org/wp-content/uploads/2018/ll/AI-Garcia-

IFood-Processiing-SlaughterHouses.pdf.

8.	U.S. EPA. 2019. The EPA's Review of Nutrients in Industrial Wastewater Discharge (October). EPA-830-
R-19-001. Available online at: https://www.reRulations.Rov/docuiTient/IEIPA-HCVOW-2.018-0618-0569

9.	U.S. EPA. 2020. How To Protect Your POTWSystem And Operators From Damaging Influent
(September). DCN MP00705. Available online at: https://www.epa.gov/sites/default/files/2020-
09/documents/pretreatmentweb iinair-slliides.pdf.

10.	U.S. EPA. 2021a. Effluent Guidelines Program Plan 14 (January). EPA-821-R-21-001. Available online
at: https://www.epa.Rov/sites/default/files/2021-01/documents/eR-plan-14 jan-2021.pdf.

11.	U.S. EPA. 2021b. Analyzing Relationships between MPP Indirect Discharges and POTWs (September).
EPA-HQ-OW-2021-0547-0110.

12.	U.S. EPA. 2021c. Preliminary Effluent Guidelines Program Plan 15 (September). EPA-821-R-21-003.
Available online at: https://www.epa.gov/system/files/documents/2021-09/ow-prelim-elg-plan-
15 508.pdf.

4

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2. Summary of the Proposed Rulemaking

This section presents a summary of the changes the U.S. Environmental Protection Agency is proposing to
make to the meat and poultry products (MPP) effluent limitations guidelines and standards (ELGs),
including a summary of the discharge requirements and a description of the scope and applicability
provisions for the proposed MPP regulatory options.

2.1 Summary of Proposed Discharge Requirements

The proposed rule would revise the technology-based ELGs at 40 CFR 432 for certain wastewater
discharges associated with the production of MPP. The EPA is proposing to revise or establish effluent
limitations and standards for the MPP industry based on Best Practicable Control Technology Currently
Available (BPT), Best Conventional Pollutant Control Technology (BCT), Best Available Technology
Economically Achievable (BAT), Best Available Demonstrated Control Technology (BADCT) for New Source
Performance Standards (NSPS), Pretreatment Standards for Existing Sources (PSES), and Pretreatment
Standards for New Sources (PSNS). BPT, BCT, and BAT would apply to existing facilities that directly
discharge to waters of the United States. BADCT/NSPS would apply to new sources that directly discharge
to waters of the United States. PSES and PSNS would apply to existing and new sources, respectively, that
discharge indirectly via Publicly Owned Treatment Works (POTWs). Section 9 includes a detailed
discussion of the technology systems and regulatory options evaluated by the EPA.

Section 2.1.1 describes proposed requirements for direct dischargers, while Section 2.1.2 describes
proposed requirements for indirect dischargers.

2.1.1	Proposed Requirements for Direct Dischargers

Under the preferred option in the proposed rule (Regulatory Option 1), the EPA proposes BPT/BAT
effluent limitations for nitrogen based on biological removal to achieve full denitrification and BPT/BAT
effluent limitations for phosphorus based on biological treatment with chemical precipitation with
filtration. These limitations would apply to direct discharging facilities based on the same production
thresholds as the existing rule: 50 million pounds per year of finished product produced for meat further
processors (Subcategories F-l), 50 million pounds per year of live weight killed (LWK) for meat
slaughtering (Subcategories A-D), 100 million pounds per year of LWK for poultry slaughtering
(Subcategory K), 7 million pounds of finished product per year for poultry further processors (Subcategory
L), and 10 million pounds per year of raw material processed for renderers (Subcategory J). The
limitations for facilities in Subcategory E would not be changed. See Preamble Section VII.C.l for the
EPA's proposed rationale on these technologies as available, economically achievable, and have
acceptable non-water quality environmental impacts.

The EPA evaluated three regulatory options. For a description of the proposed requirements for direct
dischargers under these options, see Preamble Section I.B.

2.1.2	Requirements for Indirect Dischargers

Under the preferred option in the proposed rule (Regulatory Option 1), the EPA proposes to establish
PSES based on the BPT and BCT limitations for biochemical oxygen demand (BOD), total suspended solids
(TSS), and oil and grease (O&G) based on screening and dissolved air floatation (DAF) technology.
Pretreatment standards would apply to facilities producing more than: 50 million pounds per year of
finished product for meat further processors (Subcategories F-l), 50 million pounds per year of LWK for
meat slaughtering (Subcategories A-D), 100 million pounds per year of LWK for poultry slaughtering
(Subcategory K), 7 million pounds per year of finished product for poultry further processors (Subcategory
L), and 10 million pounds per year of raw material processed by renderers (Subcategory J). No new PSES

5

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for Subcategory E would be established. No new PSES for nitrogen and phosphorus would be established.
See Preamble Section VII.C.2 for the EPA's proposed rationale for indirect dischargers.

The EPA evaluated three regulatory options. For a description of the proposed requirements for indirect
dischargers under these options, see Preamble Section I.B.

2.2 Scope and Applicability of Proposed Regulation

Facilities engaged in first processing, further processing, or rendering of MPP may be subject to the
proposed regulatory options. Table 2-1 shows entities that would be potentially regulated by any final
rule following this action, based on industry type and North American Industry Classification System
(NAICS) code. Table 2-2 shows the applicable MPP subcategories included in this proposed rule to show
further examples of the types of MPP facilities that may be subject to the proposed regulatory options.
The scope of the proposed rule does not include any small governmental jurisdictions or not-for-profit
organizations. Other types of entities not included in this table could also be regulated. To determine
whether an entity would be regulated by this action, see the applicability criteria in 40 CFR 432.1, 432.10,
431.20, 432.30, 432.40, 432.50, 432.60, 432.70, 432.80, 432.90, 432.100, 432.110, and 432.120, with
definitions in 40 CFR 432.2.

Table 2-1. MPP Industry Entities Potentially Regulated by the Proposed Rule

Example of Regulated Entity

NAICS Code

Meat Packing Plants

31161

Animal (Except Poultry) Slaughtering

311611

Meat Processed from Carcasses

311612

Sausages and Other Prepared Meat Products

311612

Poultry Slaughtering and Processing

311615

Meat & Meat Product Wholesalers

422470

Poultry Processing

311615

Rendering and Meat Byproduct Processing

311613

Support Activities for Animal Production

11521

Prepared Feed and Feed Ingredients for Animals and Fowls, Except Dogs and Cats

311119

Dog and Cat Food Manufacturing

311111

Other Animal Food Manufacturing

311119

All Other Miscellaneous Food Manufacturing

311999

Animal and Marine Fats and Oils

311613

Livestock Services, Except Veterinary

311611

Table 2-2. MPP ELG Subcategories

Type of Processing

Subcategory

Description

Meat First

Simple Slaughterhouses

Complex Slaughterhouse

Low-Processing Packinghouses

High-Processing Packinghouses

Any

Small Processors3

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Table 2-2. MPP ELG Subcategories

Type of Processing

Subcategory





F

Meat Cutters

Meat Further

G

Sausage and Luncheon Meats Processors

H

Ham Processors



1

Canned Meat Processors

Render

J

Rendering

Poultry First

K

Poultry First Processing

Poultry Further

L

Poultry Further Processing

a — Producing less than 6,000 pounds of product per day or 2.2 million pounds per year.

7

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3. Data Collection Activities

The U.S. Environmental Protection Agency conducted several data collection activities in support of
developing the proposed rule for the meat and poultry products (MPP) effluent limitations guidelines and
standards (ELGs). The EPA used these data to develop an MPP industry profile, determine wastewater
characteristics and potential pollution control technologies, review potential pollutant load reductions
and costs associated with certain wastewater treatment technology systems, review environmental
impacts associated with discharges from this industry, and develop pollutant limitations. This section
discusses the EPA's data collection activities as they relate to the technical aspects of the proposed
rulemaking:

• Site visits (Section 3.1).

• Sampling program (Section 3.2).

• Industry questionnaires (Section 3.3).

• Other information collection activities (Section 3.4).

• Outreach activities (Section 3.5).

The final subsection (Section 3.6) presents the EPA's approach to protect confidential business
information (CBI), which ensures that the data in the public docket explain the basis for the rule and that
the docket provides the opportunity for informed public comment without compromising data
confidentiality.

3.1 Site Visits

During 2022, the EPA conducted site visits at nine different MPP facilities: three meat facilities, five
poultry facilities, and one independent rendering facility. In selecting candidates for site visits, the EPA
attempted to identify facilities with advanced wastewater treatment technologies across the different
types of MPP operations that were achieving low levels of nitrogen and/or phosphorus in their effluent. In
addition, the EPA considered the type of meat and/or poultry processing operation, age of the facility,
size of the facility (in terms of production), wastewater treatment processes employed, and best
management practices and pollution prevention techniques used. During each visit, the EPA collected
information on facility process operations including recent changes and upgrades, wastewater treatment
operations, water usage, and waste management operations. More information can be found in the site
visit notes attached to the administrative record and identified in Table 3-1.

Table 3-1. List of Site Visits

Facility Name

Type of Operation

Location

Reference to
Site Visit Notes

Abbyland Foods Inc. Plant
and Abbyland Foods Inc.
Pork Pack Plant3

Beef slaughterhouse and sausage
processing facility; pork
slaughterhouse and further
processing facility

Abbotsford, Wl
and Curtiss, Wl

DCN MP00276

Darling Ingredients
Flamilton Plant

Independent rendering facility

Flamilton, Ml

DCN MP00135

Swift Beef Company
Flyrum Plant

Beef slaughterhouse and further
processing facility

Flyrum, UT

DCN MP00138

Smithfield Fresh Meats

Pork further processing and
rendering facility

Smithfield, VA

DCN MP00123

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Table 3-1. List of Site Visits

Facility Name

Type of Operation

Location

Reference to
Site Visit Notes

Tyson Chicken, Inc.
Albertville Facility

Poultry slaughterhouse and further
processing facility

Albertville, AL

DCN MP00144

Tyson Farms, Inc
Blountsvi 1 le Facility

Poultry slaughterhouse and further
processing facility

Blountsville, AL

DCN MP00142

Tyson Foods Inc. Glen
Allen Facility

Poultry slaughterhouse and further
processing facility

Glen Allen, VA

DCN MP00139

Tyson Fresh Meats Inc.
Perry Facility

Pork slaughterhouse, further
processing, and rendering facility

Perry, IA

DCN MP00143

Tyson Foods Inc.
Temperanceville Facility

Poultry slaughterhouse, further
processing, and rendering facility

Temperanceville,
VA

DCN MP00140

Abbreviations: DCN = document control number.

a — Abbyland Food Inc. operates three facilities (Abbyland Foods Plant, Specialty Sausage Plant, and Abbyland Pork Pack Plant) as
distinct facilities, but wastewater from all facilities is comingled for treatment in a combined wastewater treatment system.

3.2 Sampling Program

Between August and November 2022, the EPA conducted sampling at six MPP facilities throughout the
United States to collect wastewater characterization data and treatment performance data.

The EPA selected facilities with low nitrogen and phosphorus discharges based on Discharge Monitoring
Reports (DMRs) data, wastewater treatment information obtained from permits, permit application data,
and site visits. The EPA selected three meat facilities, two poultry facilities, and one independent
rendering facility. All of the sampled facilities were direct discharge facilities. However, since the
wastewater characteristics are the same at direct and indirect facilities, the same wastewater treatment
technology can be used at both types of facilities.

The EPA identified pollutants of interest in MPP wastewater based on data from the previous MPP
rulemaking (U.S. EPA, 2004), discussions with the EPA regions and state environmental agencies, facility
permit limitations, total maximum daily loads (TMDLs) and water quality standards, and literature
searches. Below is a list of pollutant or pollutant groups chosen by the EPA for the MPP sampling
program. The EPA chose not to sample for per-and polyfluoroalkyl substances (PFAS) as the EPA found no
evidence that MPP processes produce PFAS or use it to produce finished products.

• Biochemical oxygen demand (BOD) and carbonaceous biochemical oxygen demand (cBOD).

• Chemical oxygen demand (COD).

• Inorganic anions.

• Oil and grease (O&G).

• Nitrogen compounds.

• Total phosphorus (TP) and ortho-phosphorus.

• Total suspended solids (TSS) and total dissolved solids (TDS).

• Total organic carbon (TOC).

• Fecal Coliform (including E. coli).

• Enterococci.

• Metals.

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See the Pollutants of Concern (POC) Analysis for the Meat and Poultry Products (MPP) Proposed Rule
memorandum, which presents a table of the pollutants by analytical method and corresponding baseline
values (U.S. EPA, 2023a).

During each sampling episode, the EPA collected wastewater samples for five consecutive days. Sampling
points varied by facility and wastewater treatment system, but in general, the EPA collected the following
samples at all selected facilities:

• Treatment system influent (untreated wastewater). Samples were collected downstream of screening
(if present) to ensure large solids were removed to facilitate sampling.

• Effluent from primary treatment (or influent to biological treatment). Primary treatment typically
included a dissolved air flotation unit or anaerobic basin/lagoon.

• Effluent from biological treatment (or influent to tertiary treatment). Biological treatment typically
included complete nitrification/denitrification.

• Effluent from tertiary treatment (e.g., filters, disinfection, and/or chlorination/dechlorination), if
tertiary treatment was in place.

• Final effluent from the treatment system, if different from the effluent from the last level of
treatment (e.g., reaeration basin).

Data collected from the treatment system influent (i.e., untreated wastewater) helped the EPA
characterize the industry, develop the list of pollutants of concern to be evaluated for regulation, and
determine raw wastewater pollutant concentrations. The EPA used the data collected from the influent,
intermediate, and effluent points to analyze the efficacy of treatment at the facilities and to develop
current discharge concentrations and loadings as well as the treatment technology systems for the MPP
industry. The EPA used selected effluent data to estimate the potential long-term averages and numeric
limitations for each regulatory option considered for the proposed rule (see Section 13 for a description
of the data the EPA used for effluent limitation development). During each sampling episode, the EPA
also collected flow rate data for each sample, when possible, as well as production information from each
associated manufacturing operation for use in calculating pollutant loadings and production-normalized
flow rates.

Based on conversations with industry, most MPP facilities use drinking water sources (public water
supplies or well water) for all source water. Because the facilities are generating food-grade products,
facilities may treat their source water with sodium hypochlorite or water softeners before use (U.S. EPA,
2022a, 2022b, 2022c, 2022d). Therefore, the EPA was not concerned about source water contamination
for MPP pollutants of interest and did not collect source water samples.

The EPA also collected operations data during the sampling episode to allow for an engineering
assessment of the design, operation, and performance of treatment systems at MPP facilities. Specifically,
the EPA collected system design information, as well as daily operations data (e.g., production,
wastewater flow, chemical additions, sludge generation).

The Agency (or facilities directed by the Agency) collected, preserved, and transported all samples
according to the EPA protocols, as specified in:

• The EPA's Sampling and Analysis Procedures for Screening of Industrial Effluents for Priority Pollutants
(U.S. EPA, 1977).

• Facility-specific sampling and analysis plan (SAPs).

• Generic Sampling and Analysis Plan (GSAP; U.S. EPA, 2022e).

The EPA collected composite samples for most parameters because it expected wastewater compositions
to vary over the course of a day. The EPA collected composite samples manually or using automated

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samplers. The Agency collected individual aliquots for the composite samples at least once every 4 hours
over each 24-hour period. The Agency took grab samples from unit operations for O&G and
microbiologicals. O&G samples were collected every 6 hours, and microbiologicals were collected once a
day.

The EPA contract laboratories completed all wastewater sample analyses except the field measurements
of temperature, dissolved oxygen (DO), and pH. The EPA or facility staff collected field measurements of
temperature, DO, and pH at the sampling site. The analytical chemistry methods used, as well as the
sample volume requirements, detection limits, and holding times, were consistent with the laboratories'
quality assurance and quality control plans. Laboratories contracted for MPP sample analysis followed
EPA-approved analysis methods for all parameters. The EPA contract laboratories reported data on their
standard report sheets and submitted the sheets to the EPA's sample control center (SCC), which
reviewed them for completeness and reasonableness. The EPA reviewed all reports from the laboratories
to verify that the data were consistent with requirements, reported in the proper units, and in
compliance with the applicable protocol. Quality control measures used in performing all analyses
complied with the guidelines specified in the analytical methods. The EPA reviewed all analytical data to
ensure that these measures had been followed and that the resulting data were within the acceptance
criteria for accuracy and precision.

See the GSAP (U.S. EPA, 2022e) and the facility-specific SAPs for more information on sampling
procedures; see the facility-specific sampling episode reports (SERs) for details on the sampling points
selected for each facility and the operational data collected. The facility-specific SAPs and facility-specific
SERs are summarized in Table 3-2.

Table 3-2. List of Facility-Specific SAPs and SERs

Facility Name and Location

Reference to SAP

Reference to SER

Abbyland Foods, Abbotsford, Wl

DCN MP00149

DCN MP00326

Darling Ingredients, Hamilton, Ml

DCN MP00137

DCN MP00333

Swift Beef Company, Hyrum, UT

DCN MP00150

DCN MP00332

Tyson Fresh Meats, Perry, IA

DCN MP00151

DCN MP00317

Tyson Foods, Inc., Glen Allen, VA

DCN MP00152

DCN MP00315

Tyson Foods, Inc., Temperanceville, VA

DCN MP00153

DCN MP00311

Abbreviations: DCN = document control number.

3.3 MPP Industry Questionnaire

The EPA concurrently administered the Census Questionnaire for the Meat and Poultry Products Effluent
Guidelines (Census Questionnaire) and the Detailed Questionnaire for the Meat and Poultry Products
Effluent Guidelines (Detailed Questionnaire) under the authority of Section 308 of the Clean Water Act
(CWA; Federal Water Pollution Control Act, 33 U.S.C. 1318) to facilities engaging in meat and poultry
processing, including direct and indirect dischargers as well as facilities that do not discharge wastewater.
The Census Questionnaire and Detailed Questionnaire are referred to collectively as the "MPP
Questionnaires" and were approved by the Office of Management and Budget (OMB) in June 2022 (OMB
Control No. 2040-0306). The EPA designed the MPP Questionnaires to obtain technical and financial
information in support of developing the proposed rule for the MPP ELGs. The EPA made every
reasonable attempt to ensure that data and information collected in the questionnaires were not
currently available through less burdensome mechanisms.

The Detailed Questionnaire targeted a subset of all identified MPP facilities, distributed across the
industry based on a stratification scheme that considered facility operation(s) (slaughtering, processing,
rendering), meat type (meat, poultry), and production volume. Using these characteristics, the EPA
grouped identified MPP facilities into 27 strata, each encompassing facilities with similar operations.

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Stratification increases precision (reducing one source of uncertainty) for estimates of costs, benefits, and
other quantities. The EPA deliberately selected approximately 50 "certainty" facilities to obtain site-
specific information needed for evaluating facility operations and best technology systems. The Census
Questionnaire was distributed to all additional MPP facilities (those that were not selected for the
Detailed Questionnaire). Details on the stratification scheme are provided in the Supporting Statement:
US Environmental Protection Agency Meat and Poultry Products Industry Data Collection (U.S. EPA,

2022f).

The Detailed Questionnaire was administered to 1,565 facilities, selected to ensure statistical
representation across all processing operations, production sizes, and discharge types; provide
information on the wastewater treatment technologies currently employed by industry; and assess the
financial impacts of any regulation revisions or additions. The Detailed Questionnaire included all
questions in the Census Questionnaire and additional questions on specific wastewater characterization
information (e.g., pollutants discharged, wastewater flows), pollutant control technologies (e.g., pollution
prevention techniques, pretreatment systems, end-of-pipe treatment systems), and financial information
on facilities and ultimate parent companies. The EPA used the responses to characterize the pollution
discharged from MPP facilities and to determine if pollutant discharges can be controlled beyond current
requirements for any set or subset of MPP facilities. The Detailed Questionnaire consisted of 85 questions
organized into 11 sections.

The Census Questionnaire was administered to 6,127 facilities—i.e., all the MPP facilities not chosen for
the Detailed Questionnaire. It confirmed whether these facilities engaged in meat and/or poultry
slaughtering, further processing, and/or rendering; confirmed where they fall under the applicability of 40
CFR 432; and collected updated identification information. The EPA used this information to verify the
industry population and confirm general information on production details (including type of meat or
poultry and type of processing); the type and size (both production and employees) of facilities; and
wastewater generation, treatment, and discharge. The Census Questionnaire consisted of 32 questions
organized into three sections.

The EPA included a helpline e-mail address and phone numbers in the instructions and on the EPA's MPP
Questionnaires webpage that respondents could use to request assistance in completing the MPP
Questionnaires. Using these assistance methods enabled respondents to receive a response to any
inquiries they had.

The EPA conducted outreach to maximize facility response. The EPA mailed postcards to facilities that had
not begun their questionnaires to encourage them to respond and remind them of the legal requirement
to submit responses. Twice during the response period, the EPA emailed respondents with incomplete
Qualtrics questionnaires (initiated but not submitted) to remind them to complete and submit their
questionnaires. The EPA also reviewed submitted questionnaires to identify incomplete responses, both
in hardcopy and Qualtrics, and followed up with some respondents through phone calls and emails to
obtain missing information. The EPA also followed up with specific facilities to request additional
monitoring data and wastewater treatment details. The EPA used all questionnaire responses in all
analyses supporting the proposed ELGs. See subsequent sections of this TDD for discussions of how the
EPA used questionnaire data.

Table 3-3 presents the number of questionnaire responses received by April 2023. The EPA received a
total of 3,657 responses. Of these, 2,281 responses were from facilities that met the eligibility
requirements for the questionnaire. All remaining responses were screen outs (facilities that did not meet
the eligibility requirements to complete the full questionnaire because they either do not process MPP or
had closed prior to January 1, 2021).

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Table 3-3. Summary of MPP Questionnaires Responses

Questionnaire
Version

Number of Responses
Received from Eligible
Facilities

Number of Screen Out
Responses

Total Responses Received

Census

1,621

1,208

2,829

Detailed

660

168

828

Total

2,281

1,376

3,657

Source: U.S. EPA, 2023b.

More details on the MPP Questionnaires, their administration, additional respondent support provided by
the EPA, and a summary of responses can be found in the MPP Questionnaires Memorandum (U.S. EPA,
2023b).

3.4 Other Existing Data Sources

The EPA collected existing data to inform various portions of the analyses supporting the proposed ELGs
and to fill data gaps for facilities that did not respond to the MPP Questionnaires. Table 3-4 summarizes
the existing data sources, including a description of the data source. The EPA also obtained information
on MPP facilities directly from industry, using sources other than the MPP Questionnaires. Table 3-5
summarizes the additional data obtained from industry.

Table 3-4. Existing Data Collection Sources Used by the EPA

Source of Data

Description

Year of Data

U.S. Department of
Agriculture (USDA)
Food Safety
Inspection Service
(FSIS)

In October 2019, the EPA downloaded the Meat, Poultry and
Egg Product Inspection (MPI) Directory data compiled by the
USDA. The MPI Directory is a list of establishments that
produce meat, poultry, and/or egg products regulated by FSIS.
The EPA also downloaded the USDA's Establishment
Demographic Data (a supplement to the MPI directory), which
provided information on the type of operations and products
for each facility.

2018-2019

Integrated
Compliance
Information System
National Pollutant
Discharge Elimination
System (ICIS-NPDES)

The EPA downloaded 2018 facility data (e.g., facility name,
location, permit limitations, pollutant loadings) from the EPA's
ICIS-NPDES for facilities classified by a Standard Industrial
Classification (SIC) code listed under 40 CFR 432.1 (General
Applicability of the MPP ELGs). The EPA also downloaded 2019
facility data from the EPA's ICIS-NPDES for facilities under Part
432 with individual NPDES permits.

2018-2019

Publicly Owned
Treatment Works
(POTWs) Annual
Reports

POTWs with pretreatment programs are required to submit
annual reports on their programs. These reports typically list
their significant industrial users and their applicable point
source categories. ERG collected publicly available online POTW
Annual Reports from seven states (CA, TN, TX, WA, IN, Ml, NH).
The EPA reviewed the collected reports to identify MPP indirect
dischargers.

Various

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Table 3-4. Existing Data Collection Sources Used by the EPA

Source of Data

Description

Year of Data

National Pollutant
Discharge Elimination
System (NPDES)
Permits, Permit
Applications, and Fact
Sheets

The CWA requires direct dischargers to control their discharges
according to effluent guidelines and water quality-based
effluent limitations included in NPDES permits. The EPA
contacted all the EPA regions and searched online to find
NPDES permits and fact sheets.

Various

U.S. Food and Drug
Administration (FDA)
Data

The EPA contacted the FDA's Center for Veterinary Medicine
and received a list of MPP facilities.

2020

Toxics Release
Inventory (TRI)

Section 313 of the Emergency Planning and Community Right-
to-Know Act requires facilities meeting specified thresholds to
report their annual releases and other waste management
activities for listed toxic chemicals to TRI. This data set includes
direct and indirect dischargers. The EPA downloaded 2017 data
(the most recent data available) for North American Industry
Classification System (NAICS) codes listed under 40 CFR 432.1
(General Applicability of the MPP ELGs).

2017

Discharge Monitoring
Reports (DMRs)

Direct dischargers submit discharge monitoring data to their
permitting authority using DMRs as required by their NPDES
permits. The data are then uploaded into ICIS-NPDES. The EPA
downloaded 2021 DMR data for MPP facilities.

2021

Hampton Roads
Sanitation District
(HRSD)

HRSD sets industrial wastewater discharge regulations for
industrial users based on stepwise flow categories. In
accordance with these regulations, Smithfield Fresh Meats
collected effluent data and flow data. HRSD provided the EPA
with effluent and flow data for Smithfield Fresh Meats for five
years.

2016-2020

Virginia Department
of Environmental
Quality (VDEQ)

VDEQ provided the EPA with effluent data for four facilities that
process poultry. These facilities perform advanced nutrient
removal to meet the Chesapeake Bay TMDL requirement.

2015-2023

Scientific Literature
and Journal Articles

The EPA conducted a literature search for information on
various aspects of the animal processing industry, including
documented environmental impacts, wastewater treatment
technologies, waste generation and facility management, and
pollution prevention.

Various

14

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Table 3-5. Data Submitted by Industry

Source of Data

Description

Year of Data

National Renderers
Association

The EPA received a list of members from this MPP trade
association. From this list, the EPA collected facility names,
addresses, contact information, list of products, and other
notes.

2018

308 Letter for Data
on High Chlorides
Wastestreams and
Treatment

Under the authority of CWA Section 308, the EPA collected
wastewater characterization and treatment information from
MPP facilities with potentially high chlorides wastestreams
resulting from activities such as meat or poultry koshering
and hides processing.

2022-2023

3.5 Outreach Activities

The EPA encouraged all interested parties to participate throughout the development of the MPP rule.
The Agency conducted outreach to trade associations that represent most of the facilities that the rule
will affect. The EPA met with various stakeholders to discuss aspects of the regulation development. The
EPA also participated in industry meetings and gave presentations on the status of the regulation
development. Table 3-6 lists stakeholder meetings conducted by the EPA. Summaries of these meetings
are in the MPP Rulemaking Record.

Table 3-6. Summary of the EPA's Stakeholder Meetings

Meeting Participants

Date of Meeting

Summary of Discussion

U.S. Poultry and Egg Association
Environmental Management
Seminar

September 21,
2022; September
28, 2023

Discussed the EPA's ongoing information
collection efforts, potential revisions to the
MPP ELGs, and rulemaking timeline.

North American Meat Institute

October 12, 2022

Discussed the EPA's ongoing information
collection efforts, potential revisions to the
MPP ELGs, and rulemaking timeline.

Joint Poultry Environmental
Committee

January 25, 2023

Discussed ongoing analyses, information
collection activities, potential revisions to
the MPP ELGs, and rulemaking timeline.

Consultation and Coordination
with Indian Tribes: MPP ELG
Webinars

February 6 and 13,

2023

Discussed current MPP ELGs, potential
revisions to the MPP ELGs, possible interest
to Tribes, opportunities for Tribal
involvement, and rulemaking timeline.

North American Meat Institute

April 18, 2023

Discussed ongoing analyses, information
collection activities, potential revisions to
the MPP ELGs, and rulemaking timeline.

Joint Poultry Environmental
Committee, North American
Meat Institute, North American
Renderers Association

May 18, 2023

Discussed the EPA's data analysis
methodologies, potential ELG revisions and
considerations, rulemaking timeline, and
opportunities for future engagement.

Small Business Regulatory
Enforcement Fairness Act
(SBREFA) Pre-Panel and Formal-
Panel Meeting

May 2 and July 17,

2023

Discussed potential regulatory operations
and alternatives with industry small entity
representatives and requested feedback.

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Table 3-6. Summary of the EPA's Stakeholder Meetings

Meeting Participants

Date of Meeting

Summary of Discussion

Environmental Integrity Project,
Earthjustice, and partners

September 15, 2023

Discussed ongoing analyses, information
collection activities, potential revisions to
the MPP ELGs, and rulemaking timeline.

Southwest Meat Association

September 26, 2023

Discussed ongoing analyses, information
collection activities, potential revisions to
the MPP ELGs, and rulemaking timeline.

The EPA also met with environmental groups and Tribal communities and conducted environmental
justice outreach. For details on these meeting, see the Environmental Assessment for the Proposed
Effluent Limitations Guidelines and Standards for the Meat and Poultry Products Point Source Category
(U.S. EPA, 2023c).

3.6	Protection of Confidential Business Information

Certain data in the rulemaking record have been claimed as CBI. As required by federal regulations at 40
CFR 2, the EPA has taken precautions to prevent the inadvertent disclosure of this CBI. The Agency has
withheld CBI from the public docket in the Federal Docket Management System; it has also found it
necessary to withhold some data not directly claimed as CBI because releasing them could indirectly
reveal CBI. Where necessary, the EPA has aggregated certain data in the public docket, masked facility
identities, or used other strategies to prevent the disclosure of CBI. The Agency's approach to protecting
CBI ensures that the data in the public docket explain the basis for the rule and that the docket provides
the opportunity for informed public comment without compromising data confidentiality.

3.7	References

1.	U.S. EPA. 1977. Sampling and Analysis of Procedures for Screening of Industrial Effluents for Priority
Pollutants (April). 600R77006. Available online at:

https://nepis.epa.Rov/Exe/ZyPDF.CRi/91004V4G.PDF?Dockev=91004V4G.PDF.

2.	U.S. EPA. 2004. Technical Development Document for the Final Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products Point Source Category (40 CFR 432) (September). EPA-
821-R-04-011. Available online at: https://www.epa.gov/sites/default/files/2015-
11/documents/meat-poultry-products tdd 2004 O.pdf.

3.	U.S. EPA. 2022a. Smithfield Fresh Meats Site Visit Report (May). DCN MP00123.

4.	U.S. EPA. 2022b. Abbyland Foods Abbotsford, Wl Site Visit Report (July). DCN MP00276.

5.	U.S. EPA. 2022c. Swift Beef Company, Hyrum Plant Site Visit Report (August). DCN MP00138.

6.	U.S. EPA. 2022d. Tyson Farms, Inc., Blountsville Site Visit Report (October). DCN MP00142.

7.	U.S. EPA. 2022e. Generic Sampling and Analysis Plan for Meat and Poultry Products (MPP) Point
Source Category (August). DCN MP00136.

8.	U.S. EPA. 2022f. Supporting Statement: US Environmental Protection Agency Meat and Poultry
Products Industry Data Collection (February). EPA-HQ-OW-2021-0736. Available online at:
https://www.epa.gov/svstem/files/documents/2022-03/mpp-icr-supporting-statement feb-2022.pdf.

9.	U.S. EPA. 2023a. Pollutants of Concern (POC) Analysis for the Meat and Poultry Products (MPP)
Proposed Rule (November). DCN MP00190.

10.	U.S. EPA. 2023b. U.S. EPA MPP Questionnaires Memorandum (November). DCN MP00234.

11.	U.S. EPA. 2023c. Environmental Assessment for the Proposed Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products Point Source Category (November). EPA-821-R-23-012.

16

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4. Meat and Poultry Products Industry Operations and
Wastewater Generation

The meat and poultry products (MPP) industry comprises facilities that perform one or more of the
following operations:

• Slaughter livestock (e.g., cattle, calves, hogs, sheep, and lambs), poultry (e.g., chickens, turkeys, and
small game such as rabbits), or both.

• Further process meat, poultry, or both.

• Render waste from slaughter and further processing operations (e.g., bones, feathers, fat).

Wastewater generated from these operations is regulated by the MPP effluent limitations guidelines and
standards (ELGs).

Slaughtering facilities, also called first processing or harvesting facilities, receive and hold live animals,
slaughter them, and produce a raw dressed product, either whole or in parts. These products are then
further processed (either onsite or after transfer to further processing facilities) or sold to distributors,
retailers, or consumers. Some slaughtering operations may receive carcasses from off-site slaughter for
initial first processing. Cutting whole carcasses into halves, quarters, or smaller pieces (including pieces
with or without bone or which are ground) is considered part of first processing operations when done at
first processing facilities. Companies that own slaughtering facilities might also own the facilities that raise
the animals; however, wastewater generated by the raising of animals is not covered by the MPP ELGs.

Further processing facilities use whole carcasses or cut-up meat or poultry parts to produce consumable
products. Further processing facilities may receive carcasses or parts from one or more first processing
facilities. A facility that performs both first processing and further processing activities as a single
operation is referred to as an integrated facility. Cutting, boning, and grinding operations are considered
further processing operations when done at facilities not also engaged in first processing activities (U.S.
EPA, 2004).

Further processing facilities process raw meat and/or poultry products to produce finished products,2
such as those that use raw chicken to produce frozen chicken nuggets or fresh seasoned chicken wings.
Food manufacturing facilities typically receive finished products to produce food items for consumption,
such as facilities that use ground sausage to produce frozen pizzas or fresh or frozen stuffed pastas. Based
on information from previous Technical Development Documents (TDDs) and regulatory text, and
through follow up with facilities as part of administering the MPP Questionnaires, the U.S. Environmental
Protection Agency found that there is confusion over how food manufacturing operations are classified
under the existing MPP ELGs. Previous iterations of the MPP ELGs did not clearly define which food
manufacturing operations are considered further processing operations. The "small processors"
subcategory (40 CFR 432.50 and 432.51) does apply to certain operations that involve cooking and
seasoning to produce a final product, including "stews." The ELGs for "canned meats" (40 CFR 432.90 and
432.91) similarly apply to "stews, sandwich spreads or similar products." In these examples, a regulated

2 40 CFR 432.2: "Finished product" means the final fresh or frozen products resulting from the further processing of
either whole or cut-up meat or poultry carcasses. "Further processing" means operations that utilize whole
carcasses or cut-up meat or poultry products for the production of fresh or frozen products and may include the
following types of processing: Cutting and deboning, cooking, seasoning, smoking, canning, grinding, chopping,
dicing, forming, breading, breaking, trimming, skinning, tenderizing, marinating, curing, pickling, extruding and/or
linking.

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facility would do more than simply add a purchased meat product into a stew or apply a meat spread
processed elsewhere onto a sandwich.

Previously, the EPA specifically excluded "plants manufacturing products such as canned soups and TV
dinners" (U.S. EPA, 1975). For the proposed rule, the EPA maintains this exclusion. For this proposal, the
EPA considered only facilities that further process raw meat and/or poultry to produce finished products
as covered by the MPP ELGs. Facilities that take a consumer product that has already been "processed"
and use it as an ingredient in another consumer product are not covered. Similarly, the EPA excluded
retail/wholesale distributors, grocery stores, and delis from the definition of meat processing as these
facilities perform similar functions (e.g., slicing, grinding), but meat processing is not their primary
function. For example, slicing pepperoni as a topping for pizza would not be covered. Likewise, adding
ground meat into a lasagna, heating a lasagna, or packaging a prepared lasagna would not be covered.
For additional questions, please contact the rule writer or Steve Whitlock, the contact on the EPA's
webpage.3

Rendering operations convert byproducts from meat and poultry first and further processes into
marketable edible and inedible products. Rendering operations are commonly integrated into first
processing facilities but may take place at any type of MPP facility. Facilities that only engage in rendering
processes are referred to as independent renderers.

The EPA compiled information from the existing data sources identified in Sections 3.4 and 3.5 to
construct an initial list of facilities in the MPP industry, containing approximately 7,000 facilities. The EPA
compiled data on facility location, MPP operations performed, and production volumes. The EPA
suspected there were duplicate facilities as well as some out-of-date information (e.g., facilities that had
since closed or changed operations) within this facility list. The EPA used response data from the MPP
Questionnaires and industry communications through the Questionnaire Helpline to update the facility
list. Updates included removing duplicates, removing closed facilities, removing facilities that did not
process meat or poultry products, adding new facilities, and updating information such as facility names,
locations, and processing operations. The EPA then developed the current MPP industry profile, primarily
based on MPP Questionnaire responses but supplemented with existing data where MPP Questionnaire
responses were not available. As a result, the current industry profile contains 5,055 facilities. See the
Meat and Poultry Products (MPP) Profile Methodology Memorandum (MPP Profile Memo; U.S. EPA,
2023a) for details on how data from multiple sources were combined to identify MPP facilities,
operations, production levels, and other details.

Throughout this section, the EPA describes MPP industry operations based on two main data sources, the
MPP Questionnaire and the population of MPP facilities operating in the United States. The EPA received
2,248 MPP Questionnaire responses from MPP facilities.4 Using additional publicly available data, the EPA
identified additional MPP facilities operating in the United States to bring the total to 5,055 MPP facilities
operating in the United States. Where information is based solely on a singular data source (e.g., data
from the MPP Questionnaire), it is explicitly identified throughout this section. Table 4-1 identifies the
number of MPP Questionnaire responses received and facilities identified in the U.S. by process type. See
the MPP Profile Memo for details on how MPP Questionnaire data were used to identify processing type
for each facility.

3 https://www.epa.Rov/eR/meat-and-poultry-products-effluent-guidelines

4 The EPA received 3,657 individual responses, but 1,409 of those responses indicated no processing of meat or
poultry products or that the business was closed. These facilities screened out of the MPP Questionnaire.

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Table 4-1. MPP Facilities from MPP Questionnaires and Industry Profile

Process Type

Number of Facilities
Based on Questionnaire Responses

Number of Facilities
Based on Industry Profile

Meat First Processing

417

826

Meat Further Processing

1,209

3,460

Poultry First Processing

217

290

Poultry Further Processing

293

294

Independent Rendering

112

185

Total

2,248

5,055

Source: U.S. EPA, 2023a, 2023b.

MPP facilities are located across the United States. Figure 4-1 illustrates the distribution of 4,988 MPP
facilities identified by the EPA in the United States and included in Table 4-1; 67 MPP facilities located in
United States territories are not included.



i •

Meat Processing
Poultry Processing|
Rendering

Source: U.S. EPA, 2023a.

Figure 4-1. MPP Facilities in the United States (Excluding Territories)

This section provides an overview of MPP operations and wastewater generated during those operations.
The subsections are separated into general categories of industry operation and type of raw material:

Meat first processing (Section 4.1).

19

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• Meat further processing (Section 4.2).

• Poultry first processing (Section 0).

• Poultry further processing (Section 4.4).

• Independent rendering (Section 4.5).

4.1 Meat First Processing

Meat first processing facilities slaughter livestock but not poultry. First processing operations typically
encompass the following steps:

1. Receiving and holding live animals for slaughter.

2. Stunning before slaughter.

3. Slaughter and bleeding.

4. Initial processing of animals (e.g., hide or hair removal, evisceration, washing).

Based on conversations with industry, most MPP facilities use drinking water sources (public water
supplies or well water) for all source water. Facilities may treat their source water with water softeners
before use within the facility to minimize scale build-up in equipment and because the facilities are
generating food-grade products (U.S. EPA, 2022a, 2022b). The waste brine from water softening
generates a high chlorides wastestream. Most or all of the waste brine is discharged or disposed of, as
reuse of brine impacts performance of water softening systems (Liu et al., 2021).

Meat slaughtering operations use substantial amounts of water for initial processing, generating
wastewaters from a variety of operations that include areas where animals are killed and bled, hides or
hair are removed, animals are eviscerated, carcasses are washed and chilled, and carcasses are trimmed
and cut to produce whole carcasses or carcass parts. Wastewaters generated from these operations can
contain varying levels of blood, animal parts, viscera, fats, bones, and other animal waste. In addition,
federal food safety guidelines require frequent and extensive cleanup of slaughtering operations, which
also generates wastewater. These cleanup wastewaters contain not only slaughtering residues and
particulate matter but also products used for cleaning and disinfection (e.g., detergents and sanitizing
agents) (U.S. EPA, 2004). While individual operations may take place on separate production lines, in
separate rooms, or in separate buildings, process wastewater is typically collected via floor drains that
comingle streams for end-of-pipe treatment.

The processes employed by the industry are largely the same as they were when the 2004 MPP ELG was
promulgated, although the mechanization of processes has increased. In general, smaller facilities tend to
rely more on manual processing, while larger facilities use more automated and advanced processing
technology. The Technical Development Document for the Final Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products Point Source Category (40 CFR 432) from 2004 (the 2004
TDD; U.S. EPA, 2004) describes in detail the operations involved in transforming live meat animals into
carcasses. The operations that are sources of process wastewater and those that may generate high
chlorides wastestreams include the following (U.S. EPA, 2004, unless otherwise cited):

• Hide processing: Hides are typically rinsed and washed in freshwater to remove mud, manure, and
debris before being de-fleshed. They are then cured in salt for preservation, often by soaking in a
brine solution for up to 24 hours. Soaked hides are then wrung out to remove brine and moisture and
then dried (U.S. EPA, 2022b).

o Hides curing generates a high chlorides wastestream through soaking and wringing. Hide curing is
often performed in a separate room or separate building from other meat first operations. Brine
soaking can occur in a raceway or tank specified for the purpose (U.S. EPA, 2022b).

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• Hair removal: Carcasses are first scalded in hot water and rubbed with rubber fingers to draw hair out
of the follicles, typically in a dehairing machine. Then, a constant flow of water washes away removed
hair. Any remaining hair is removed either by scraping blades or by passing the carcass through a gas
flame, followed by a water spray. After hair removal, carcasses are washed again to remove any
remaining manure, soil, and hair and to retard microbial growth and spoilage prior to evisceration.

• Meat Koshering: After hide removal and evisceration, carcasses are soaked and then coated in dry
coarse salt and left to rest for one hour to allow blood to drain from the meat. Meat is then dry
tumbled and washed to remove the salt (Chabad-Lubavitch Media Center, 2023).

o Wash water from meat koshering generates a high chlorides wastestream. Industrial or
commercial meat koshering occurs in facilities specially certified to perform the process by
specially trained staff (Orthodox Union, 2023).

• Carcass Washing: Carcass washing removes blood, bone dust, and any other foreign matter.
Processors may add bactericides such as an organic acid, chlorine, potassium chloride, acetic and
lactic acids (in dilute concentrations) to the wash water to reduce microbial populations and the
potential for microbe growth and spoilage.

• Cleaning Operations: Facilities clean regularly to maintain sanitary conditions. Cleaning entails rinsing
equipment, walls, holding pens, floors, flumes, and raceways, followed by scrubbing, chemical
application, and a final rinse. For many facilities, cleaning operations produce the largest volumes of
process wastewater.

Based on the 2,248 Questionnaire responses, in general, meat first processing operations specialize in
processing only meat, not poultry. Of 418 facilities that reported performing meat slaughtering in the
MPP Questionnaire, only 4 percent (18 facilities) also reported performing poultry slaughtering (U.S. EPA,
2023b). If a single facility does slaughter both, it typically uses separate lines, if not separate buildings
(U.S. EPA, 2004). However, a very small meat first processing facility, such as a specialty butcher or a wild
game processor, may process several types of animals in a single building primarily using manual
operations.

Integrated first and further processing operations are common in the meat processing industry. Of the
418 facilities that reported performing meat slaughtering in the MPP Questionnaire, 81 percent (340
facilities) also reported performing meat further processing (U.S. EPA, 2023b). Where first and further
processing occur at the same site, usually some fraction of the carcass produced is marketed as fresh
meat and the remainder is transformed into processed products.

Based on the 5,055 MPP facilities identified in the United States, the EPA identified 826 meat first
processing facilities (including integrated facilities that do both meat first and further processing) in
operation in the U.S. This represents an overall decrease in facilities since the 2004 MPP ELGs, when
1,400 meat first processing facilities were identified. The 2004 TDD also reported meat first processing
facilities were found in the highest numbers (more than 60 establishments in each state) in Texas,
California, Illinois, Iowa, and Wisconsin (U.S. EPA, 2004). Table 4-2 lists the five states that now have the
highest percentages of meat first processing facilities (U.S. EPA, 2023a).

Table 4-2. States with the Highest Percentages of Meat First Processing Facilities

State

Percent of Meat First Processing Facilities (826 Facilities)

Pennsylvania

10.1 (83 facilities)

Texas

4.8 (40 facilities)

New York

4.5 (37 facilities)

Missouri

4.2 (35 facilities)

Nebraska

4.0 (33 facilities)

Source: U.S. EPA, 2023a.

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Of the 826 meat first processing facilities the EPA identified, 32 percent (261 facilities) conduct
operations that could generate high chlorides wastestreams. Of these 261 facilities:

• 163 are integrated facilities that perform specific further processing operations known to be capable
of generating high chlorides wastestreams (described in Section 4.2).

• 58 perform hide curing.

• 39 perform both hide curing and specific further processing operations known to be capable of
generating high chlorides wastestreams.

• One performs meat koshering (U.S. EPA, 2023a).

Table 4-3 includes the number of meat first processing facilities by annual production volume. The table
includes the average production and total production of all the facilities within each range, measured as
million pounds live weight killed (LWK) per year. These data illustrate that 69 percent of all meat first
processing facilities each produce less than 5 million pounds LWK annually and collectively only account
for 0.4 percent of total meat first processing industry production volume. Conversely, 11 percent of all
facilities produce 200 million pounds LWK annually or more and account for 97 percent of total industry
production volume (U.S. EPA, 2023a).

Table 4-3. Meat First Processing Facilities by Annual Production

Range
(M lbs. LWK/yr.)

Number of Facilities

Average Production
(lbs. LWK/yr.)

Total Production
(lbs. LWK/yr.)

570

1,088,096

620,214,968

5 to <10

8,206,075

516,982,727

10 to <200

106

50,075,108

5,307,961,408

>200

1,639,659,410

142,650,368,657

Total

826

180,503,060

149,095,527,759

Source: U.S. EPA, 2023a.

Abbreviations: M = million, lbs. = pounds, yr. = year.

4.2 Meat Further Processing

Meat further processing involves processing or preserving meat and meat byproducts (but not poultry)
from dressed meats. Further processing operations include canning, cooking, cutting and/or deboning,
curing, forming, grinding, linking, marinating, pickling, seasoning, smoking, tenderizing, and trimming. The
operations most commonly produce ground meat, case-ready cuts with or without bone, and/or sausage.
Stand-alone further processing operations receive carcasses, or more commonly carcass parts, from first
processing operations (U.S. EPA, 2004).

Based on conversations with industry, most MPP facilities use drinking water sources (public water
supplies or well water) for all source water. Facilities may treat their source water with water softeners
before use within the facility to minimize scale build-up in equipment and because the facilities are
generating food-grade products (U.S. EPA, 2022a, 2022b). The waste brine from water softening
generates a high chlorides wastestream. Most or all of the waste brine is discharged or disposed of, as
reuse of brine affects performance of water softening systems (Liu et al., 2021).

Wastewaters generated by meat further processing operations contain both soft and hard tissue (e.g.,
muscle, fat, and bone) and blood. Differences in further processing wastestreams are largely driven by
the type of finished product produced, as wastewaters can contain substances used in final product
preparation, such as additives, breading, and sauces. Meat further processing wastewaters will also
contain products used for cleaning and disinfection (detergents and sanitizing agents) (U.S. EPA, 2004).
While individual operations may take place on separate production lines, in separate rooms, or in

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separate buildings, process wastewater is typically collected via floor drains that comingle streams for
end-of-pipe treatment.

As with meat first processing, operations used for meat further processing have not changed much since
2004. The 2004 TDD describes in detail the operations involved in meat further processing. The
operations that are sources of process wastewater and those that may generate high chlorides
wastestreams include the following (U.S. EPA, 2004, unless otherwise cited):

• Thawing: Meat products are submerged in tanks or vats of warm water until thawed.

• Tenderizing: Meat is marinated or injected with salt solutions, such as calcium chloride, or acids, such
as vinegar, to break down the muscle structure.

o Tenderizing with a brine solution could generate a high chlorides wastestream from spilled brine,
waste brine, and wash water. The EPA did not include this operation in its analysis of high
chlorides wastestreams, though, because tenderizing is not always performed with a salt solution
and data were not available on different solutions used by facilities.

• Marinating^ Meat may be immersed in brine, injected with brine, tumbled with brine, or a
combination thereof. Marination extends shelf-life, seals in moisture, increases meat yield, and adds
flavor and tenderness. Marinades typically contain phosphates and salt for meat preservation and
water retention (Alvarado and McKee, 2007).

o Marinating generates high chlorides wastestreams from dripped or spilled brine, waste brine, and
wash water. Brines are applied on dedicated work lines or facility areas.

• Tempering: The temperature or moisture content of meat is adjusted, often by immersion or soaking
in water.

• Curing: Immersion curing submerges meat into a brine or injects brine into the meat to preserve it
and develop a characteristic appearance and flavor. In dry curing, solid salts are rubbed into the meat
surface.

o The immersion curing process generates high chlorides wastestreams, as do rinsing and washing
from all curing processes. Curing brines are often reused but are eventually wasted. Pumps
recirculate brine that spills from the product or injection needles (USDA, 2020), facilitating
capture of waste brine for treatment and/or disposal.

• Pickling: Large amounts of spillage from this operation typically occur by runoff from pickle injection,
pickle oozing out of the meat after injection, dumping of cover pickle, and dumping of residual
pickling solution at the end operations.

o Pickling generates high chlorides wastestreams through preparation of the pickling solutions,
waste pickle, and the pickle application process through both spillage and cleanup. As with liquid
curing processes, pickling solutions are often pumped through equipment during application
(USDA, 2020), facilitating capture of waste pickle for treatment and/or disposal.

• Smoking: Water that overflows during quenching of burned wood to generate smoke generates
wastewater. Some facilities use liquid smoke products transformed into a gas via direct heat for
application (USDA, 2020). Any moisture dripping from products during smoking is also captured in
wash water.

o Smoking generates a high chlorides wastestream through spillage and cleanup of liquid smoke
products and rinsing and washing smoking chambers. Smoking operations typically occur in
smoking chambers or smokehouses with ducts and ventilation that enable smoke to be pumped
into the chamber with the meat products.

• Cooking: Steam condensate or hot water is used as the cooking medium. For example, luncheon
meats are cooked in stainless steel molds, which may leak.

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• Cooling: Cooked and smoked products are showered in water immediately after cooking to cool.
Sausage products may be cooled with a spray of cold water or brine solution. Canned meat and
products prepared in stainless steel molds are usually cooled by submersion in cold water.

o Sausage brine spraying may generate a high chlorides wastestream. The EPA did not include this
operation in its analysis of high chlorides wastestreams, though, because data were not available
to allow differentiation of brine cooling from water cooling at facilities.

• Canning: After meat is sealed in a container, it is heated using steam under pressure. These cans may
leak during the sealing process.

• Casing, linking, and casing peeling: Water is used to prepare natural casings for stuffing and a small
stream of water is used to lubricate the casing to avoid breakage or splitting during linking. Synthetic
casings are not edible and must be removed after cooking and cooling. A small spray of steam parts
the casing from the finished product so the casing can be peeled off; however, the amount of
wastewater generated by this spray is typically minute.

• Cleaning operations: Facilities clean regularly to maintain sanitary conditions. Cleaning entails rinsing
all equipment, walls, and floors followed by scrubbing, chemical application, and a final rinse. For
many facilities, cleaning operations produce the largest volumes of process wastewater.

Based on the 2,248 Questionnaire responses, 1,646 facilities indicated they further process meat. Of
these 1,646 facilities, 79 percent (1,306 facilities) indicated they perform stand-alone meat further
processing, meaning they perform only meat further processing and not meat slaughtering. However,
further processing facilities may process both meat and poultry products on site. Of these 1,306 facilities,
53 percent (691 facilities) indicated they also further process poultry (U.S. EPA, 2023b).

Based on the 5,055 MPP facilities identified in the U.S., the EPA identified 3,460 facilities performing
primarily meat further processing operations in the United States; these are distinct from meat first
processing facilities that may have integrated meat further processing operations. In 2004, the EPA
identified only 1,300 meat further processors, showing a large increase. Table 4-4 lists the top five states
with the most identified meat further processing facilities (U.S. EPA, 2023a). Facility geographic
distribution remains relatively unchanged since 2004 (U.S. EPA, 2004). In the meat processing industry,
the current data show a decrease in meat first processing facilities and an increase in meat further
processing facilities. The 2004 TDD identified 52 percent of the meat processing industry as meat first
processing facilities and 48 percent as meat further processing facilities (U.S. EPA, 2004). Currently, 19
percent of all identified meat processing facilities are meat first processors (826 facilities) and 81 percent
are meat further processors (3,460 facilities) (U.S. EPA, 2023a).

Table 4-4. States with the Highest Percentages of Meat Further Processing Facilities

State

Percent of Meat Further Processing Facilities (3,460 Facilities)

California

13 (449 facilities)

New York

6.7 (230 facilities)

Illinois

6.5 (226 facilities)

Texas

6.2 (213 facilities)

Pennsylvania

5.1 (177 facilities)

Source: U.S. EPA, 2023a.

Of the 3,460 stand-alone meat further processing facilities identified by the EPA, 15 percent (509
facilities) conduct operations that could generate high chlorides wastestreams from specific further
processing operations, such as marinating and pickling (U.S. EPA, 2023a).

Table 4-5 includes the number of meat further processing facilities by annual production volume. The
table also includes the average production and total production of all the facilities within each range,
measured as pounds of finished product per year. These data illustrate that 63 percent of all identified

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meat further processing facilities each produce less than 2 million pounds of finished product annually
and collectively only account for 1.8 percent of the total meat further processing production volume.
Conversely, 10 percent of all facilities produce more than 50 million pounds of finished product annually
and account for 80 percent of total industry production volume (U.S. EPA, 2023a).

Table 4-5. Meat Further Processing Facilities by Annual Production

Range
(M lbs. Finished
Product/yr.)

Number of
Facilities

Average Production
(lbs. Finished Product/yr.)

Total Production
(lbs. Finished Product/yr.)

2,194

423,149

928,388,099

2 to <10

695

5,668,123

3,939,345,703

10 to 50

224

23,480,623

5,259,659,470

>50

347

118,891,109

41,255,214,541

Total

3,460

14,850,465

51,382,607,813

Source: U.S. EPA, 2023a.

Abbreviations: M = million, lbs. = pounds, yr. = year.

4.3 Poultry First Processing

Poultry first processing involves the slaughter of poultry and small game animals (e.g., rabbits). Poultry
first processing operations typically encompass the following steps:

1. Receiving and holding of live animals.

2. Stunning before slaughter.

3. Slaughter and bleeding.

4. Initial processing of animals (defeathering, evisceration).

Based on conversations with industry, most MPP facilities use drinking water sources (public water
supplies or well water) for all source water. Facilities may treat their source water with water softeners
before use to minimize scale build-up in equipment and because the facilities are generating food-grade
products (U.S. EPA, 2022a, 2022b). The waste brine from water softening generates a high chlorides
wastestream. Most or all the waste brine is discharged or disposed of, as reuse of brine affects
performance of water softening systems (Liu et al., 2021).

Like meat slaughtering, poultry slaughter operations use substantial amounts of water for initial
processing, generating wastewaters from a variety of operations that include areas where animals are
killed and bled; feathers are removed; animals are eviscerated; carcasses are washed and chilled; and
carcasses are trimmed and cut to produce the whole carcasses or carcass parts. As a result of these
operations, wastewaters can contain blood, animal parts, viscera, fats, bones, and other animal waste. In
addition, federal food safety guidelines require frequent and extensive cleanup of slaughtering
operations, which also contributes to wastewater generation. These cleanup wastewaters contain not
only slaughtering residues and particulate matter but also products used for cleaning and disinfection
(e.g., detergents and sanitizing agents) (U.S. EPA, 2004). While individual operations may take place on
separate production lines, in separate rooms, or in separate buildings, process wastewater is typically
collected via floor drains that comingle streams for end-of-pipe treatment.

Like meat processing, operations used for poultry first processing have not changed much since 2004.The
2004 TDD describes in detail the operations involved in further processing poultry. Operations that are
sources of process wastewater and those that may generate high chlorides wastestreams include the
following (U.S. EPA, 2004, unless otherwise cited):

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• Scalding and defeathering: After killing and bleeding, birds are scalded by immersion in a scalding
tank (the preferred method) or by spraying with scalding water. Defeathering is performed by
machines with multiple rows of rubber fingers on cylinders that rotate quickly across the birds while a
continuous spray of warm water flushes feathers away. The carcasses are then washed in enclosures
using high-pressure cold-water sprays to sanitize their outsides and thus reduce microbial
contamination of the body cavity during evisceration.

• Poultry koshering: After defeathering, for kosher poultry production, bird carcasses are packed with
dry coarse salt inside and out and propped up for one hour to allow blood to drain before being dry
tumbled and washed to remove the salt. (Chabad-Lubavitch Media Center, 2023).

o Poultry koshering operations may generate wastestreams that contain high concentrations of
chlorides. Industrial or commercial poultry koshering occurs in facilities certified to perform the
process by specially trained staff (Orthodox Union, 2023).

• Evisceration: Depending on the facility, viscera are collected via a wet or dry system. Wet systems use
water to transport the offal by fluming it to a screening area for dewatering before rendering. Dry
systems are not common.

• Edible viscera washing: Hearts and livers are stripped of connective tissue and washed. Gizzards are
split, their contents are washed away, the hard linings are peeled off, and they are given a final wash.

• Bird washing: High-pressure nozzles spray water both inside and outside the carcass. The water is
often mixed with chlorine or other anti-microbiological chemicals.

• Chilling: Most poultry processing facilities use large chilling tanks containing ice water; very few use
air chilling. Most poultry facilities use two chilling tanks in series, a pre-chiller and a main chiller, both
containing cold water.

• Cleaning Operations: Facilities clean regularly to maintain sanitary conditions. Cleaning entails rinsing
all equipment, walls, holding pens or cages, and floors followed by scrubbing, chemical application,
and a final rinse. For many facilities, cleaning operations produce the largest volumes of process
wastewater.

Poultry first processing operations are performed slightly differently based on the type of poultry being
processed. For example, chickens are typically killed by mechanical means due to similarity in bird body
size. Turkeys are killed manually because of the wider variety in body shape and size (U.S. EPA, 2004). In
general, smaller facilities tend to rely more on manual processing throughout all operations, whereas
larger facilities use more automated and advanced processing technology.

Based on the 2,248 Questionnaire responses, in general, poultry first processing operations slaughter
only poultry and not meat animals. Of 231 facilities that reported performing poultry slaughtering in the
MPP Questionnaire, only 8 percent (18 facilities) also reported performing meat slaughtering. However,
integrated first and further poultry processing operations are fairly common; of the 231 facilities that
reported performing poultry slaughtering in the MPP Questionnaire, 68 percent (157 facilities) also
reported performing poultry further processing (U.S. EPA, 2023b). At integrated facilities, usually some
fraction of the carcass produced is marketed as fresh meat and the remainder is transformed into
processed products (U.S. EPA, 2004).

Based on the 5,055 MPP facilities identified in the United States, the EPA identified 290 poultry first
processing facilities (including integrated facilities that do both poultry first and further processing) in
operation in the United States. This represents an overall decrease in facilities since the 2004 MPP ELGs,
when 470 poultry slaughter facilities were identified (U.S. EPA, 2004). Table 4-6 lists the top five states
with the highest percentages of poultry first processing facilities (U.S. EPA, 2023a). Facility geographic
distribution has remained largely unchanged since 2004. In addition, the ratio of meat to poultry first
processing facilities in the MPP industry has remained almost unchanged in that time. In 2004, 25 percent
of the first processing industry processed poultry and 75 percent processed meat (U.S. EPA, 2004). The

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current data collection found the split is now 26 percent poultry first processors (290 facilities) to 74
percent meat first processors (826 facilities) (U.S. EPA, 2023a).

Table 4-6. States with the Highest Percentages of Poultry First Processing Facilities

State

Percent of Poultry First Processing Facilities (290 Facilities)

Arkansas

9.3 (27 facilities)

Georgia

7.6 (22 facilities)

North Carolina

6.6 (19 facilities)

California

6.2 (18 facilities)

Alabama

6.2 (18 facilities)

Source: U.S. EPA, 2023a.

Of the 290 poultry first processing facilities identified by the EPA, 27 percent (77 facilities) conduct
operations that could generate high chlorides wastestreams. Of these 77 facilities:

• 75 are integrated facilities that perform specific further processing operations known to be capable of
generating high chlorides wastestreams (described in Section 4.4).

• One performs poultry koshering.

• One performs poultry koshering and specific further processing operations known to be capable of
generating high chlorides wastestreams (U.S. EPA, 2023a).

Table 4-7 includes the number of poultry first processing facilities by annual production volume. The table
also includes the average production and total production of all the facilities within each range, measured
as pounds LWK per year. These data illustrate that 20 percent of all poultry first processing facilities each
produce less than 5 million pounds LWK annually and collectively only account for 0.05 percent of total
poultry first processing industry production volume. Meanwhile, 52 percent of all facilities produce 200
million pounds LWK annually or more and account for 93 percent of total industry production volume
(U.S. EPA, 2023a).

Table 4-7. Poultry First Processing Facilities by Annual Production

Range
(M lbs. LWK/yr.)

Number of Facilities

Average Production
(lbs. LWK/yr.)

Total Production
(lbs. LWK/yr.)

978,592

55,779,726

5 to 30

9,952,568

189,098,791

>30 to <200

109,186,833

6,987,957,300

>200

150

657,560,764

98,634,114,587

Total

290

365,058,450

105,866,950,403

Source: U.S. EPA, 2023a.

Abbreviations: M = million, lbs. = pounds, yr. = year.

4.4 Poultry Further Processing

Poultry further processing involves processing and preparing poultry and small game products and their
byproducts from dressed poultry carcasses. Further processing can be as simple as splitting a carcass into
two halves or as complex as producing a breaded, fully cooked product from a carcass. Poultry further
processing operations include canning, cooking, cutting and/or deboning, extruding, forming, grinding,
linking, marinating, pickling, seasoning, smoking, tenderizing, and trimming (U.S. EPA, 2004).

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before use within the facility to minimize scale build-up in equipment and because the facilities are
generating food-grade products (U.S. EPA, 2022a, 2022b). The waste brine from water softening
generates a high chlorides wastestream. Most or all of the waste brine is discharged or disposed of, as
reuse of brine affects performance of water softening systems (Liu et al., 2021).

The characteristics of wastewaters generated by further processing operations are similar to those
generated by poultry first operations, such as containing soft and hard tissue (e.g., muscle, fat, and bone)
and blood. Differences in these wastewater characteristics are largely driven by the type of finished
product desired, as further processing wastewaters can contain substances used in final product
preparation, such as breading, stuffing, and marinades. Poultry further processing wastewaters will
contain products used for cleaning and disinfection (detergents and sanitizing agents) (U.S. EPA, 2004).
While individual operations may take place on separate production lines, in separate rooms, or in
separate buildings, process wastewater is typically collected via floor drains that comingle streams for
end-of-pipe treatment.

Like meat processing, operations used for poultry further processing are largely the same as they were in
2004. The 2004 MPP TDD describes in detail the operations involved in further processing poultry.
Operations that are sources of process wastewater and those that may generate high chlorides
wastestreams include the following (U.S. EPA, 2004, unless otherwise cited):

• Thawing: Wet thawing submerges poultry products in tanks or vats containing warm water until
thawed. Some facilities may spray frozen products with water.

• Carcass/poultry handling and preparation: Poultry carcasses may be cut, deboned, diced, or ground.
Some facilities may use high powered water jets to assist in cutting and other operations. Facilities
with manual operations (e.g., knives) typically provide a continuous stream of water on the work line
to clean equipment. However, some carcass handling operations do not generate wastewater.

• Marinating^ Poultry may be immersed in brine, injected with brine, tumbled with brine, or a
combination thereof. Marination extends shelf-life, seals in moisture, increases meat yield, and adds
flavor and tenderness. Marinades typically contain phosphates and salt for meat preservation and
water retention (Alvarado and McKee, 2007).

o Marinating generates high chlorides wastestreams from dripped or spilled brine, waste brine, and
wash water. Brines are applied on dedicated work lines or facility areas.

• Curing: Immersion curing submerges poultry into a liquid brine or injects brine into the poultry to
preserve it and develop a characteristic appearance and flavor. In dry curing, solid salts are rubbed
into the poultry surface, which may be captured in wash water.

o Curing generates high chlorides wastestreams through brine waste as well as rinse and wash

water. Curing brines are often reused, and pumps recirculate brine that spills from the product or
injection needles (USDA, 2020), facilitating capture of waste brine for treatment and/or disposal.

o Pickling generates high chlorides wastestreams through spillage and cleanup from preparation of
the pickling solutions, waste pickle, and spillage and cleanup from the pickle application process.
As with liquid curing processes, pickling solutions are often pumped through equipment during
application (USDA, 2020), facilitating capture of waste pickle for treatment and/or disposal.

• Smoking: Water that overflows during quenching of burned wood to generate dry smoke generates
wastewater. Some facilities use liquid smoke products transformed into a gas via direct heat for
application (USDA, 2020). Gas that condenses and drips off product or equipment is captured in wash
water. Any moisture dripping from products during smoking is also captured in wash water.

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o Smoking generates a high chlorides wastestream through spillage and cleanup of liquid smoke
products and washing smoking chambers/smokehouses.

• Cooking: Poultry products are typically immersed in water in steam-jacketed open vats. Chicken parts,
whole birds, and processed products may be immersed in hot water cookers. Cooking methods
including microwaving and deep frying do not generate wastewater. However, all cooked products
are cooled before any further processing; a common cooling technique is immersion in a cold-water
tank with continuous overflow.

• Casing/stuffing: Water is used to lubricate casings for use in the stuffing operation.

• Canning: During preparation, filling, and can covering, water is used to remove any spilled product
from equipment and outer can surfaces. Condensed steam during these operations is also a source of
wastewater. Hand filling cans typically results in less wastewater than mechanical filling.

Poultry further processing facilities are often highly automated or mechanized. Fully manual operations
are more common in smaller facilities (U.S. EPA, 2004).

OBased on the 2,248 Questionnaire responses, 1,025 facilities indicated they further process poultry. Of
these 1,025 facilities, 85 percent (868 facilities) indicated they perform stand-alone poultry further
processing, meaning they perform only poultry further processing and not poultry slaughtering. Of these
868 facilities, 83 percent (720 facilities) indicated they also further process meat (U.S. EPA, 2023b).

Based on the 5,055 MPP facilities identified in the United States, the EPA identified 294 poultry further
processing facilities in operation in the U.S.; these are distinct from poultry first processing operations
that may have integrated poultry further processing operations. Table 4-8 lists the top five states with the
highest percentages of poultry further processing facilities (U.S. EPA, 2023a). The 2004 TDD did not
include demographic data on stand-alone poultry further processing facilities.

Table 4-8. States with the Highest Percentages of Poultry Further Processing Facilities

State

Percent of Poultry Further Processing Facilities (294 Facilities)

California

9.5 (28 facilities)

Georgia

7.1 (21 facilities)

Arkansas

6.8 (20 facilities)

Pennsylvania

5.4 (16 facilities)

New York

5.1 (15 facilities)

Source: U.S. EPA, 2023a.

Of the 294 poultry further processing facilities the EPA identified, 22 percent (64 facilities) conduct
operations that could generate high chlorides wastestreams from specific further processing operations,
such as marinating and pickling (U.S. EPA, 2023a).

Table 4-9 includes the number of poultry further processing facilities by annual production volume. The
table also includes the average production and total production of all the facilities within each range,
measured as pounds of finished product per year. These data illustrate that 37 percent of all poultry
further processing facilities each produce less than 2 million pounds of finished product annually and
collectively only account for 0.3 percent of total poultry further processing industry production volume.
Another 37 percent of all facilities each produce more than 30 million pounds of finished product
annually and accountfor 94 percent of total industry production volume (U.S. EPA, 2023a).

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Table 4-9. Poultry Further Processing Facilities by Annual Production

Range
(M lbs. Finished
Product/yr.)

Number of
Facilities

Average Production
(lbs. Finished Product/yr.)

Total Production
(lbs. Finished Product/yr.)

110

374,738

41,221,200

2 to <10

5,417,051

270,852,547

10 to 30

19,011,483

475,287,078

>30

109

112,415,194

12,253,256,125

Total

294

44,355,840

13,040,616,950

Source: U.S. EPA, 2023a.

Abbreviations: M = million, lbs. = pounds, yr. = year.

4.5 Rendering

Rendering facilities convert byproducts of meat and poultry processing into marketable products.
Rendering materials include viscera, meat scraps (e.g., fat, bone, blood, feathers), hatchery by-products
(e.g., infertile eggs, dead embryos), and dead animals (U.S. EPA, 2004), as well as used cooking oil from
restaurants (Wilkinson and Meeker, 2021) and other organic waste materials.

The characteristics of wastewater generated by rendering facilities depend on several factors, including
the type of product produced (e.g., edible vs. inedible) and the type(s) of raw material rendered. Factors
such as rate of cooking, speed of agitation, cooker overloading, foaming, and presence of grease traps
can result in volume and composition differences among rendering facilities (U.S. EPA, 2004). While
individual operations may take place on separate production lines, in separate rooms, or in separate
buildings, process wastewater is typically collected via floor drains that comingle streams for end-of-pipe
treatment.

In general, rendering involves cooking raw material to recover fats, oil, and grease; remaining residue is
dried and then granulated or ground into a meal. The 2004 MPP TDD describes the operations involved in
rendering. It also describes operations that are sources of process wastewater (U.S. EPA, 2004). The EPA
did not identify any high chlorides wastestreams produced by rendering operations.

• Cooking: Condensed steam from cooking operations is a large portion of wastewater generated from
rendering operations.

• Blood processing: The drying process generates wastewater.

• Hydrolyzing (feather and hair processing): The drying process generates wastewater.

• Boiler blowdown: Blow-down to remove accumulated solids inside boilers generates wastewater.

• Air scrubbing: Water used in air scrubbers, commonly used to control odor, generates wastewater.

• Cleaning operations: Facilities clean regularly to maintain sanitary conditions. However, rendering
cleanup operations are typically less rigorous than first and further processing operations, generating
a smaller proportion of the total process wastewater flow.

Based on the 2,248 Questionnaire responses received, some MPP processing facilities have integrated
rendering facilities. Data from the MPP Questionnaire show that, of 200 facilities that reported
performing rendering operations, 43 percent (86 facilities) also reported performing first and/or further
processing operations. These facilities typically process only one type of raw material, meat or poultry -
whichever one they process onsite. Of the 86 facilities that reported integrated rendering operations,
only 17 percent (15 facilities) processed both meat and poultry products (U.S. EPA, 2023b). Integrated
rendering facilities typically perform edible rendering, which aims to separate fatty animal tissue into

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edible fats and proteins, such as lard and food-grade tallow, but they can also perform inedible rendering
or produce both types of products (U.S. EPA, 2004).

Independent rendering operations are more common. Of 200 facilities that reported performing
rendering on the MPP Questionnaire, 57 percent (114 facilities) reported performing independent
rendering (U.S. EPA, 2023b). Independent rendering facilities most often produce inedible products (i.e.,
not suitable for human consumption), such as industrial and animal feed-grade fats, meat and poultry
byproduct meals, feather meal, dried blood, hydrolyzed hair (U.S. EPA, 2004), and even refined oil for
biofuel and renewable diesel (Wilkinson and Meeker, 2021). These facilities often process several types of
raw material that require either multiple rendering systems or significant modifications in the operating
conditions for a single system. Raw material is typically received from farms, animal feeding operations,
first processors, further processors, and restaurants (e.g., grease from traps and oil from fryers), but
sources can include a wide range of facilities from butcher shops to animal shelters. Rendering collection
areas for raw material are limited by cost of transportation and travel time for the raw material to reach
the rendering facility (U.S. EPA, 2004).

Based on the 5,055 MPP facilities identified in the U.S., the EPA identified 185 independent rendering
facilities in operation in the U.S. Table 4-10 lists the top five states with the highest percentages of
independent rendering facilities (U.S. EPA, 2023a). This represents a decrease in facilities since
publication of the 2004 MPP ELGs, when 240 facilities were identified and California and Texas hosted the
highest numbers of facilities (U.S. EPA, 2004).

Table 4-10. States with the Highest Percentages of Independent Rendering Facilities

State

Percent of Independent Rendering Facilities (185 Facilities)

California

8.1 (15 facilities)

Iowa

8.1 (15 facilities)

Illinois

7.0 (13 facilities)

Texas

6.5 (12 facilities)

Georgia

6.5 (12 facilities)

Source: U.S. EPA, 2023a.

Table 4-11 includes the number of independent rendering facilities by annual production volume. The
table also includes the average production and total production of all the facilities within each range,
measured as pounds of raw material rendered per year. These data illustrate that 12 percent of all
independent rendering processing facilities each render less than 5 million pounds of raw material
annually and collectively only account for 0.1 percent of total independent rendering processing industry
production volume. Thirteen percent of all facilities render 350 million pounds of raw material or more
annually and account for 46 percent of total industry production volume. However, the bulk of the
industry is represented by the 66 percent of facilities that each render between 30 and 350 million
pounds of raw material annually and account for 54 percent of total industry production volume (U.S.
EPA, 2023a).

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Table 4-11. Independent Rendering Facilities by Annual Production

Range
(M lbs. Raw
Material/yr.)

Number of
Facilities

Average Production
(lbs. Raw Material/yr.)

Total Production
(lbs. Raw Material/yr.)

<5

23

1,504,083

34,593,920

5-30

16

13,340,427

213,446,838

>30-<350

122

165,209,335

20,155,538,830

>350

24

711,812,964

17,083,511,139

Total

185

202,632,923

37,487,090,727

Source: U.S. EPA, 2023a.

Abbreviations: M = million, lbs. = pounds, yr. = year.

4.6 References

1.	Alvarado, C., and McKee, S. 2007. Marination to Improve Functional Properties and Safety of Poultry
Meat (March). Journal of Applied Poultry Research, vol. 16, no. 1, pp. 113-120. DCN MP00286.
Available online at: https://doi.orR/10.1093/iapr/16.1.113.

2.	Chabad-Lubavitch Media Center. 2023. Koshering Meat. Chabad.org. Lubavitch World Headquarters.
DCN MP00287. Available online at:

https://www.chabad.orR/library/article cdo/aid/82678/iewish/KosherinR-Meat.htm#The.

3.	Orthodox Union. 2023. What Does Kosher Certified Mean? (June). DCN MP00289. Available online at:
www.oukosher.orR/what-is-kosher/.

4.	USDA. 2020. Cured Meat and Poultry Product Operations (March). DCN MP00288. Available online at:
www.fsis.usda.Rov/sites/default/files/media file/2021-03/fplic-5a-cured-meat-and-poultry-
operations.pdf.

5.	U.S. EPA, 1975. Development Document for Proposed Effluent Limitation Guidelines and New Source
Performance Standards for the Poultry Segment of the Meat Product and Rendering Process Point
Source Category (April). EPA-440/l-75-031b. Available online at:
https://nepis.epa.Rov/Exe/ZyPU RL.CRi?Dockey= 10004JQM.TXT.

6.	U.S. EPA. 2004. Technical Development Document for the Final Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products Point Source Category (40 CFR 432) (September). EPA-
821-R-04-011. Available online at: https://www.epa.Rov/sites/default/files/2015-
11/documents/meat-poultry-products tdd 2004 O.pdf.

7.	U.S. EPA. 2022a. Abbyland Foods Abbotsford, Wl Site Visit Report (July). DCN MP00276.

8.	U.S. EPA. 2022b. Swift Beef Company, Hyrum Plant Site Visit Report (August). DCN MP00138.

9.	U.S. EPA. 2023a. Meat and Poultry Products (MPP) Profile Methodology Memorandum (November).
DCN MP00306.

10.	U.S. EPA. 2023b. U.S. EPA MPP Questionnaires Memorandum (November). DCN MP00234.

11.	Wilkinson, A.D., and Meeker, D.L. 2021. How Agricultural Rendering Supports Sustainability and
Assists Livestock's Ability to Contribute More than Just Food (March). Animal Frontiers, vol. 11, no. 2,
pp. 24-34. DCN MP00290. Available online at: https://doi.orR/10.1093/af/vfab002.

32

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5. Industry Subcategorization

The Clean Water Act (CWA) requires the U.S. Environmental Protection Agency to consider several
different factors when developing effluent limitations guidelines or standards (ELGs) for a particular
industry category (Section 304(b)(2)(B), 33 U.S.C. § 1314(b)(2)(B)). For determining Best Available
Technology Economically Available (BAT), these factors include the technological availability, the
economic achievability, the age of the equipment and facilities, the process employed, the engineering
aspects of the application of various types of control techniques, process changes, the cost of achieving
such effluent reduction, non-water quality environmental impacts (including emissions from energy
usage), and other factors the Administrator deems appropriate. One way the EPA may take these factors
into account, where appropriate, is by dividing a point source category into groupings called
"subcategories." Regulating an industry with subcategories, where determined to be warranted, ensures
that each subcategory has a uniform set of ELGs that consider technological availability, economic
achievability, and other relevant factors unique to that subcategory.

In establishing the original ELGs for the meat and poultry products (MPP) industry, and again in the 2004
revisions, the EPA broke the industry down into subcategories with similar characteristics. This
breakdown recognized the major differences among companies within the industry, which might reflect,
for example, different processes or economies of scale. Subdividing an industry into subcategories results
in more tailored regulatory standards, thereby increasing regulatory predictability and diminishing the
need to address variations among facilities through a variance process. See Weyerhaeuser Co. v. Costle,
590 F. 2d 1011, 1053 (D.C. Cir. 1978).

5.1 MPP Proposed Subcategorization

Currently, the point source category is divided into 12 subcategories based on operation and material
processed (U.S. EPA, 2004). Discharge requirements within the subcategories vary depending on size,
measured by production rates (e.g., facilities that slaughter more than 50 million pounds per year). The
EPA proposes keeping the same 12 subcategories as they continue to reflect differences in processes and
wastewater strength and composition. The EPA has not identified any additional processes or changes in
processes since the 2004 rulemaking that would warrant revision of the existing subcategories or
consideration of any additional subcategories. The current MPP subcategories are:

•	Simple Slaughterhouse (Subcategory A).

•	Complex Slaughterhouse (Subcategory B).

•	Low Processing Packinghouse (Subcategory C).

•	High-Processing Packinghouse (Subcategory D).

•	Small Processor (Subcategory E).

•	Meat Cutter (Subcategory F).

•	Sausage and Luncheon Meats Processor (Subcategory G).

•	Ham Processor (Subcategory H).

•	Canned Meats Processor (Subcategory I).

•	Renderer (Subcategory J).

•	Poultry First Processing (Subcategory K).

•	Poultry Further Processing (Subcategory L).

The Agency also believes that retaining the existing subcategorization scheme will simplify
implementation for the permit writers, as well as provide a sound basis for limitations and standards for

33

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the facilities. The EPA is proposing revisions to applicable pollutant limitations and proposing the addition
of new pretreatment standards for all subcategories except Subcategory E.

As part of the proposed rule, the EPA considered other regulatory options (Option 2 and Option 3) that
retained the subcategories but factored in different technology bases by production thresholds (see
Preamble Section VILA). The EPA did not select these options as the preferred regulatory option in the
proposed rule, although is soliciting comment on and may consider these and other options in finalizing
the rule; see Section VII.F of the Preamble for details.

5.2 References

1. U.S. EPA. 2004. Technical Development Document for the Final Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products Point Source Category (40 CFR 432) (September). EPA-
821-R-04-011. Available online at: https://www.epa.gov/sites/default/files/2015-
)cuments/meat-poultry-products tdd 2.004 Q.pdf.

34

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6. Wastewater Characterization

This section describes the characteristics of wastewater generated and discharged by meat and poultry
products (MPP) processing facilities. The information in this section is based on data from U.S.
Environmental Protection Agency sampling events and facility-reported data. The EPA is proposing
effluent limitations guidelines and standards (ELGs) for the MPP industry that include regulations on all
sources of MPP process wastewater. Process wastewater from MPP facilities includes any water used
during MPP processing activities that comes into direct contact with any raw material, intermediate
product, finished product, byproduct, or waste product. The proposed pollutants for regulation in MPP
wastestreams are consistent across the MPP industry's various processing operations. Wastewaters
generated during meat processing, poultry processing, and rendering are discussed in Sections 6.1
through 6.3. Section 6.4 discusses the wastewater characteristics of segregated high chlorides
wastestreams, a specific type of MPP process wastewater which may be generated by some MPP
operations. Each section discusses wastewater flow rates and wastewater constituents present in raw
MPP process wastewaters6.4.

6.1 Meat Processing

This section discusses wastewater generated from meat first and meat further processes. Most meat
processing wastewater is generated from carcass washing after hide removal, hair removal (scalding),
evisceration, and cleaning and sanitization of equipment and facilities. In general, meat first processing
uses more water than further processing. Most meat processing facilities operate 5 to 6 days per week
with the killing cycle followed by processing and cleaning operations. A processing shift is typically 8 to 10
hours in duration and a cleaning and sanitation shift is typically 6 to 8 hours. Since water use and
wastewater generation essentially cease after cleanup and do not start again until the next processing
cycle begins, the rate of water use and wastewater generation varies with both time of day and day of the
week. During processing, wastewater generation volumes are relatively lower and more constant
compared to the larger volumes required during cleanup. In addition, there is little water use or
wastewater generation on nonprocessing days, which are usually Saturdays and Sundays (U.S. EPA, 2004).
As described in Section 4, typically all process wastewater, including water used during cleanup and
sanitation, is collected via floor drains and comingled for end-of-pipe treatment.

The EPA evaluated wastewater generation flow rates based on data reported in Question 36 of the
Detailed Questionnaire for the Meat and Poultry Products Effluent Guidelines (Detailed Questionnaire).
For facilities identified as meat first processors or meat further processors in the MPP industry profile,
Table 6-1 includes the number of facilities by annual production volume. The table also includes the
median, minimum, and maximum wastewater generation flow rates in millions of gallons per day (MGD)
using data as reported in the Detailed Questionnaire.

-------
Table 6-1. MPP Process Wastewater Generation Flow Rates for Meat Processing Facilities By Annual
Production as Reported in the Detailed Questionnaire

Production Range

Number

of
Facilities

Median Wastewater
Generation Flow Rate
(MGD)

Range of Wastewater
Generation Flow Rates
(MGD)

Meat First Processing°

<5M lbs. LWK/yr.

0.00196

9.22E-06—1.35

5 to <10M lbs. LWK/yr.

10 to <200M lbs. LWK/yr.

0.0484

0.00260—0.298

>200M lbs. LWK/yr.

1.05

0.110—3.83

Total

123

0.0814

9.22E-06—3.83

Meat Further Processingb

<2M lbs. Finished Product/yr.

0.00109

2.04E-06—2.41

2 to <10M lbs. Finished Product/yr.

0.00653

0.000356—1.62

10 to 50M lbs. Finished Product/yr.

0.0577

0.00178—2.00

>50M lbs. Finished Product/yr.

0.241

0.00791—2.66

Total

0.0926

2.04E-06—2.66

Source: U.S. EPA, 2023a, 2023b.

Abbreviations: M = million, lbs. = pounds, LWK = live weight killed, yr. = year.

Notes: Flow rates presented as three significant figures. Wastewater generation flow rates are based on data from Detailed
Questionnaire responses to Question 36.

a — Of the facilities that reported wastewater generation flow rates in response to the Detailed Questionnaire, the EPA suspects
that as many as 27 (11 producing <5M lbs. LWK/yr., two producing 5 to <10M lbs. LWK/yr., six producing 10 to <200M lbs.
LWK/yr., and eight producing >200M lbs. LWK/yr.) reported rates that include a unit of measurement error. Based on the
distribution of flows reported in the MPP Questionnaires, the EPA suspects that flows reported above 4.4 MGD are reporting
errors. These suspected outlier values were not included in this evaluation of wastewater generation flow rates,
b — Of the facilities that reported wastewater generation flow rates in response to the Detailed Questionnaire, the EPA suspects
that as many as 35 (two producing <2M lbs. finished product/yr., five producing 2 to <10M lbs. finished product/yr., 14 producing
10 to 50M lbs. finished product/yr., and 15 producing >50M lbs. finished product/yr.) reported rates that include a unit of
measurement error. Based on the distribution of flows reported in the MPP Questionnaires, the EPA suspects that flows reported
above 4.4 MGD are reporting errors. These suspected outlier values were not included in this evaluation of wastewater
generation flow rates.

In general, production is directly correlated with the volume of process wastewater generated, higher
production results in higher wastewater generation. In total, meat further processing facilities generate a
slightly higher median volume of wastewater than meat first processing facilities. Meat first processing
facilities generate 0.319 gallons per pound of LWK. Meat further processing facilities generate 0.970
gallons per pound of finished product, more than three times as much as meat first processing facilities
(U.S. EPA, 2023a, 2023b). To get these average production flow rates, the EPA calculated the total pounds
produced per year and total gallons of process wastewater generated per year by each process type,
using data from the Detailed Questionnaire (excluding suspected wastewater generation flow rate
reporting errors).

The EPA also evaluated wastewater generation flow rates by facility discharge type. For facilities
identified as meat first processors or meat further processors and as direct, indirect, or zero dischargers
in the MPP industry profile, Table 6-2 includes the median wastewater generation flow rates in MGD
using data as reported in the Detailed Questionnaire.

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Table 6-2. MPP Process Wastewater Generation Flow Rates for Meat Processing Facilities By Discharge

Type as Reported in the Detailed Questionnaire

Type of Discharge

Number of Facilities

Median Wastewater Generation Flow Rate (MGD)

Meat First Processing°

Direct

1.16

Indirect

0.0521

Zero Discharge

0.00215

Total

123

0.0814

Meat Further Processingb

Direct

0.346

Indirect

0.109

Zero Discharge

0.00731

Total

0.0926

Source: U.S. EPA, 2023a,2023b.

Notes: Flow rates presented as three significant figures. Wastewater generation flow rates are based on data from Detailed
Questionnaire responses to Question 36.

a — Of the facilities that reported wastewater generation flow rates in response to the Detailed Questionnaire, the EPA suspects
that as many as 27 generation flow rates reported for these facilities (one direct discharger, 13 indirect dischargers, and 13 zero
dischargers) reported rates that include a unit of measurement error. Based on the distribution of flows reported in the MPP
Questionnaires, the EPA suspects that flows reported above 4.4 MGD are reporting errors. Including flows greater than these
values, the median generation flow rates are 1.17 MGD for direct dischargers, 0.280 MGD for indirect dischargers, and 0.0195
MGD for zero dischargers.

b — Of the facilities that reported wastewater generation flow rates in response to the Detailed Questionnaire, the EPA suspects
that as many as 36 generation flow rates reported for these facilities (two direct dischargers, 31 indirect dischargers, and three
zero dischargers) reported rates that include a unit of measurement error. Based on the distribution of flows reported in the
MPP Questionnaires, the EPA suspects that flows reported above 4.4 MGD are reporting errors. Including flows greater than
these values, the median generation flow rates are 0.490 MGD for direct dischargers, 0.253 MGD for indirect dischargers, and
0.0210 MGD for zero dischargers.

The current MPP ELGs only include requirements for direct dischargers. 52 percent of meat first
processing facilities and 74 percent of meat further processing facilities are indirect dischargers (U.S. EPA,
2023a). Thus, under the 2004 MPP ELGs, the majority of meat processing facilities are not regulated by
the ELG. Of note, meat processing facilities operating to achieve zero discharge, which may not be
covered by National Pollutant Discharge Elimination System (NPDES) requirements, generate the smallest
quantities of wastewater of all meat processing facilities (U.S. EPA, 2023b).

The principal sources of wastes in meat processing are live animal holding, killing, hide or hair removal,
eviscerating, carcass washing, trimming, and cleanup operations. Meat processing wastes include blood,
viscera, soft tissue, bone, manure (urine and feces), soil from hides and hooves, and various cleaning and
sanitizing compounds. Further processing and hide processing operations are a source of fat and other
soft tissues, as well as substances such as brines, cooking oils, and tanning solutions. Pollutants found in
untreated wastewater from meat processing operations include:

• Biochemical oxygen demand (BOD), total Kjeldahl nitrogen (TKN), ammonia nitrogen, and grease from
blood, fat, and manure.

• Ammonia nitrogen from cleaning and sanitizing compounds.

• Nitrite and nitrate nitrogen from bacon and ham curing operations.

• Phosphorus from bone, soft tissue, blood, manure, and cleaning and sanitizing compounds.

• Total coliforms, fecal coliforms, and fecal streptococcus bacteria from manure.

• Chlorides from brines, meat koshering, hides processing, and water softening.

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• Mineral elements introduced to wastewater from supply water.

• Metals from water supply systems and mechanical equipment. Hog manure may be a significant
source of copper, arsenic, and zinc because these constituents are commonly added to hog feed (U.S.
EPA, 2004).

As discussed in Section 3, the EPA reviewed analytical data gathered through the sampling program and
the Detailed Questionnaire. Table 6-3 displays the average concentrations of pollutants in untreated MPP
process wastewater at integrated meat first processing facilities (facilities that perform both meat first
processing and meat further processing). The EPA did not receive adequate data with which to
characterize wastewater from stand-alone meat first processing facilities. Lacking these data, the EPA
used all available meat processing data to characterize all meat operations (first only, further only, and
integrated meat operations). As described in Section 4.1, only a small portion of meat first processors are
stand-alone facilities. The EPA received data from six integrated meat processing facilities.

Table 6-3. Average Pollutant Concentrations in Untreated MPP Wastewater at Integrated Meat

Processing Facilities

Analyte

Unit

Integrated Meat Processing
Average Concentration

Aluminum

mg/L

0.564

Ammonia

mg/L

61.7

Barium

mg/L

0.0984

Biochemical Oxygen Demand (BOD)

mg/L

3,870

Bromide

mg/L

1.99

Calcium

mg/L

87.9

Carbonaceous Biochemical Oxygen Demand (cBOD)

mg/L

3,620

Chemical Oxygen Demand (COD)

mg/L

5,720

Chloride

mg/L

675

Copper

mg/L

0.110

E. coli

MPN/lOOmL

9,540,000

Enterococci

MPN/lOOmL

6,260,000

Fecal Coliform

MPN/lOOmL

3,730,000

Fluoride

mg/L

23.9

Iron

mg/L

35.1

Magnesium

mg/L

36.4

Manganese

mg/L

0.257

Molybdenum

mg/L

0.0262

Nitrogen, Total

mg/L

195

Oil and Grease

mg/L

1,420

Phosphorus, Total

mg/L

36.1

Sodium

mg/L

512

Sulfate

mg/L

32.0

Titanium

mg/L

0.0831

Total Dissolved Solids (TDS)

mg/L

2,970

Total Organic Carbon

mg/L

545

Total Suspended Solids (TSS)

mg/L

2,160

Vanadium

mg/L

0.0738

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Table 6-3. Average Pollutant Concentrations in Untreated MPP Wastewater at Integrated Meat
Processing FacilitiesTable 6-2. MPP Process Wastewater Generation Flow Rates for Meat Processing
Facilities By Discharge Type as Reported in the Detailed Questionnaire

Analyte

Unit

Integrated Meat Processing
Average Concentration

Zinc

mg/L

0.504

Source: U.S. EPA, 2023c.

Abbreviations: mg/L= milligram per liter, MPN/100mL= most probable number per 100 milliliters.
Note: Results presented as three significant figures.

Data available to characterize stand-alone meat further processing operations are limited to data
reported by one facility for four analytes: ammonia, BOD, total phosphorus, and total suspended solids
(TSS). For all four analytes, the average concentrations from integrated meat processing facilities were at
least four times higher than concentrations reported by the meat further processor (U.S. EPA, 2023c).

6.2 Poultry Processing

In poultry processing, most process wastewater is generated by scalding for feather removal, bird
washing before and after evisceration, chilling, and cleaning and sanitizing of equipment and facilities.
Rates of wastewater generation at poultry first processing facilities typically exceed those generated at
meat first processing facilities, largely due to required continuous overflows from scalding tanks and
carcass immersion in ice bath chillers. Rates of wastewater generation by poultry first processing is
typically higher than poultry further processing. Most poultry processing facilities operate 5 to 6 days per
week with the killing cycle followed by processing and cleaning operations. Water use and wastewater
generation essentially cease after cleanup and do not start again until the next processing cycle begins. As
a result, the rate of wastewater generation varies by both time of day and day of the week (U.S. EPA,
2004). As described in Section 4, typically all process wastewater, including water used during cleanup
and sanitation, is collected via floor drains and comingled for end-of-pipe treatment.

The EPA evaluated wastewater generation flow rates based on data reported in Question 36 of the
Detailed Questionnaire. For facilities identified as poultry first processors or poultry further processors in
the MPP industry profile, Table 6-4 includes the number of facilities by annual production volume. The
table also includes the median, minimum, and maximum wastewater generation flow rates in MGD using
data as reported in the Detailed Questionnaire.

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Table 6-4. MPP Process Wastewater Generation Flow Rates for Poultry Processing Facilities By Annual

Production as Reported in the Detailed Questionnaire

Production Range

Number of
Facilities

Median Wastewater
Flow Rate (MGD)

Range of Wastewater
Flow Rates (MGD)

Poultry First Processing°

<5M lbs. LWK/yr.

0.0112

9.05E-05—0.0997

5 to 30M lbs. LWK/yr.

0.0463

0.000500—0.761

>30 to <200M lbs. LWK/yr.

0.689

0.120—2.04

>200M lbs. LWK/yr.

1.21

0.00312—3.52

Total

103

0.982

9.05E-05—3.52

Poultry Further Processingb

<2M lbs. Finished Product/yr.

0.0666

0.0261—0.107

2 to <10M lbs. Finished Product/yr.

0.0108

0.00350—0.0308

10 to 30M lbs. Finished Product/yr.

0.0346

0.00514—1.06

>30M lbs. Finished Product/yr.

0.234

0.0192—0.882

Total

0.0996

0.00350—1.06

Source: U.S. EPA, 2023a, 2023b.

Abbreviations: M = million, lbs. = pounds, LWK = live weight killed, yr. = year.

Notes: Flow rates presented as three significant figures. Wastewater generation flow rates are based on data from Detailed
Questionnaire responses to Question 36.

a — Of the facilities that reported wastewater generation flow rates in response to the Detailed Questionnaire, the EPA suspects
that as many as 39 generation flow rates reported for these facilities (four producing <5M lbs. LWK/yr., four producing 5 to 30M
lbs. LWK/yr., four producing >30 to <200M lbs. LWK/yr., and 29 producing >200 M lbs. LWK/yr.) reported rates that include a unit
of measurement error. Based on the distribution of flows reported in the MPP Questionnaires, the EPA suspects that flows
reported above 4.4 MGD are reporting errors. These suspected outlier values were not included in this evaluation of wastewater
generation flow rates.

b — Of the facilities that reported wastewater generation flow rates in response to the Detailed Questionnaire, the EPA suspects
that as many as 13 generation flow rates reported for these facilities (two producing <2M lbs. finished product/yr., two
producing 2 to <10M lbs. finished product/yr., two producing 10 to 30M lbs. finished product/yr., and seven producing >30M lbs.
finished product/yr.) reported rates that include a unit of measurement error. Based on the distribution of flows reported in the
MPP Questionnaires, the EPA suspects that flows reported above 4.4 MGD are reporting errors. These suspected outlier values
were not included in this evaluation of wastewater generation flow rates.

In general, production is directly correlated with the volume of process wastewater generated, higher
production results in higher wastewater generation. Poultry first processing facilities generate a higher
median volume of wastewater than poultry further processing facilities. However, on average, poultry
first processing facilities generate 0.645 gallons per pound of LWK. Poultry further processing facilities
generate 1.05 gallons per pound of finished product, 1.6 times as much as poultry first processing
facilities (U.S. EPA, 2023a, 2023b). To get these average production flow rates, the EPA calculated the
total pounds produced per year and total gallons of process wastewater generated per year by each
process type, using data from the Detailed Questionnaire (excluding suspected wastewater generation
flow rate reporting errors).

When comparing gallons of process wastewater generated per pound at meat processing facilities to
those at poultry processing facilities, poultry first processing facilities generate twice as many gallons per
pound as meat first processing facilities. However, meat further processing facilities and poultry further
processing facilities generated nearly equal rates of gallons per pound (U.S. EPA, 2023a, 2023b).

The EPA also evaluated wastewater generation flow rates by facility discharge type. For facilities
identified as poultry first processors or poultry further processors and as direct, indirect, or zero
dischargers in the MPP industry profile, Table 6-5 includes the median wastewater generation flow rates
in MGD using data as reported in the Detailed Questionnaire.

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Table 6-5. MPP Process Wastewater Generation Flow Rates for Poultry Processing Facilities By
Discharge Type as Reported in the Detailed Questionnaire

Type of Discharge

Number of Facilities

Median Wastewater Generation Flow Rate (MGD)

Poultry First Processing°

Direct

1.21

Indirect

0.970

Zero Discharge

0.0938

Total

103

0.982

Poultry Further Processingb

Direct

0.926

Indirect

0.0861

Zero Discharge

0.0185

Total

0.0996

Source: U.S. EPA, 2023a, 2023b.

Notes: Flow rates presented as three significant figures. Wastewater generation flow rates are based on data from Detailed
Questionnaire responses to Question 36.

a — Of the facilities that reported wastewater generation flow rates in response to the Detailed Questionnaire, the EPA suspects
that as many as 41 generation flow rates reported for these facilities (14 direct dischargers, 13 indirect dischargers, and 14 zero
dischargers) reported rates that include a unit of measurement error. Based on the distribution of flows reported in the MPP
Questionnaires, the EPA suspects that flows reported above 4.4 MGD are reporting errors. Including flows greater than these
values, the median generation flow rates are 1.41 MGD for direct dischargers, 1.23 MGD for indirect dischargers, and 1.60 MGD
for zero dischargers.

b — Of the facilities that reported wastewater generation flow rates in response to the Detailed Questionnaire, the EPA suspects
that as many as 13 generation flow rates reported for these facilities (one direct discharger, nine indirect dischargers, and three
zero dischargers) reported rates that include a unit of measurement error. Based on the distribution of flows reported in the
MPP Questionnaires, the EPA suspects that flows reported above 4.4 MGD are reporting errors. Including flows greater than
these values, the median generation flow rates are 1.060 MGD for direct dischargers, 0.202 MGD for indirect dischargers, and
100.2 MGD for zero dischargers.

The current MPP ELGs only include requirements for direct dischargers. 51 percent of poultry first
processing facilities and 81 percent of poultry further processing facilities are indirect dischargers (U.S.
EPA, 2023a). Thus, under the 2004 MPP ELGs, the majority of poultry processing facilities are not
regulated by the ELG. Of note, poultry processing facilities operating to achieve zero discharge, which
may not be covered by National Pollutant Discharge Elimination System (NPDES) requirements, generate
the smallest quantities of wastewater of all meat processing facilities (U.S. EPA, 2023b).

Waste from poultry processing includes blood, feathers, viscera, soft tissue, manure, bone, soil from
feathers, and various cleaning and sanitizing compounds. Further processing operations can produce
animal fat and other soft tissue, as well as other substances such as pickling brines and cooking oils.
Pollutants found in untreated wastewater from poultry processing operations include:

• BOD, TKN, ammonia nitrogen, and grease from blood, fat, and manure. BOD is more significant in
poultry processing wastewaters than in meat processing wastewaters because of fat transmission
from immersion chilling and because of feather and skin oils desorbed during feather removal
scalding.

• Ammonia nitrogen from cleaning chemicals.

• Phosphorus from bone, soft tissue, blood, manure, and cleaning and sanitizing compounds.

• Total coliforms, fecal coliforms, and fecal streptococcus bacteria from manure.

• Chlorides from brines, poultry koshering, and water softening.

• Mineral elements introduced to wastewater from supply water.

-------
• Metals from water supply systems and mechanical equipment. Poultry manure is a significant source
of arsenic and zinc (U.S. EPA, 2004).

As discussed in Section 3, the EPA reviewed analytical data gathered through the sampling program and
the Detailed Questionnaire. Table 6-6 displays the average concentrations of pollutants in untreated MPP
process wastewater at poultry first processing facilities and integrated poultry processing facilities
(facilities that perform both poultry first and further processing). The EPA did not receive adequate data
with which to characterize wastewater from stand-alone poultry further processing facilities. Lacking
these data, the EPA used all available poultry processing data to characterize all poultry operations (first
only, further only, and integrated poultry operations). The EPA received data from one poultry first
processing facility and seven integrated poultry facilities.

Table 6-6. Average Pollutant Concentrations in Untreated MPP Wastewater at Poultry First and

Integrated Poultry Processing Facilities

Analyte

Unit

Poultry First and Integrated
Poultry Processing Average
Concentration

Aluminum

mg/L

0.576

Ammonia

mg/L

88.1

Biochemical Oxygen Demand (BOD)

mg/L

4,660

Bromide

mg/L

0.0580

Calcium

mg/L

24.2

Carbonaceous Biochemical Oxygen Demand (cBOD)

mg/L

1,280

Chemical Oxygen Demand (COD)

mg/L

3,020

Chloride

mg/L

98.8

E. coli

MPN/lOOmL

396,000

Enterococci

MPN/lOOmL

319,000

Fecal Coliform

MPN/lOOmL

169,000

Fluoride

mg/L

15.8

Magnesium

mg/L

10.2

Nitrogen, Total

mg/L

122

Oil and Grease

mg/L

177

Phosphorus, Ortho-P

mg/L

14.5

Phosphorus, Total

mg/L

17.3

Sodium

mg/L

148

Sulfate

mg/L

56.6

Total Dissolved Solids (TDS)

mg/L

4,680

Total Organic Carbon

mg/L

406

Total Suspended Solids (TSS)

mg/L

6,520

Zinc

mg/L

0.156

Source: U.S. EPA, 2023c.

Abbreviations: mg/L= milligram per liter, MPN/100mL= most probable number per 100 milliliters.
Note: Results presented as three significant figures.

Data available to characterize stand-alone poultry first processing operations (not integrated) are limited
to data reported by one facility for two analytes: ammonia and chemical oxygen demand (COD). The
average ammonia concentration from integrated facilities was at least 10 times higher than
concentrations reported by the poultry first processor. The COD concentration reported by the poultry

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first processor was less than half of the average concentration from the integrated facilities (U.S. EPA,
2023c).

6.3 Independent Rendering

Major sources of wastewater from rendering operations include raw material receiving operations,
condensing cooking vapors, drying, facility cleanup, and truck and barrel washing. Variations in
wastewater flow are largely attributable to the fact that different facilities use different types of
condensers on cooking vapors. Inconsistencies in the initial moisture content of the raw material also
contribute to variations in wastewater flow, but to a lesser extent. Rendering usually is a 24-hour
operation and commonly occurs on a seven-days-per-week schedule. However, cleanup of rendering
equipment and facilities is less intensive than that in processing facilities and usually occurs only once per
day, after raw material is received and prepared for processing. Thus, despite consistent weekly
production, wastewater generation flow rates vary throughout the operating day (U.S. EPA, 2004). As
described in Section 4, typically all process wastewater, including water used during cleanup and
sanitation, is collected via floor and ground drains and comingled for end-of-pipe treatment.

The EPA evaluated wastewater generation flow rates based on data reported in Question 36 of the
Detailed Questionnaire. For facilities identified as independent renderers in the MPP industry profile,
Table 6-7 includes the number of facilities by annual production volume. The table also includes the
median, minimum, and maximum wastewater generation flow rates in MGD, using data as reported in
the Detailed Questionnaire.

Table 6-7. MPP Process Wastewater Generation Flow Rates for Independent Rendering Facilities By
Annual Production as Reported in the Detailed Questionnaire

Production Range
(M lbs. Raw
Material/yr.)

Number of
Facilities3

Median Wastewater Flow
Rate (MGD)

Range of Wastewater Flow
Rates (MGD)

5 to 30

0.107

0.107—0.107

>30 to <350

0.0971

0.0202—2.04

>350

0.321

0.151—1.91

Total

0.112

0.0202—2.04

Source: U.S. EPA, 2023a, 2023b.

Abbreviations: M = million, lbs. = pounds, yr. = year.

Notes: Flow rates presented as three significant figures. Wastewater generation flow rates are based on data from Detailed
Questionnaire responses to Question 36.

a — Of the facilities that reported wastewater generation flow rates in response to the Detailed Questionnaire, the EPA suspects
that as many as 13 generation flow rates reported for these facilities (one processing <5M lbs. raw material/yr., one processing 5
to 30M lbs. raw material/yr., nine processing >30 to <350M lbs. raw material/yr., and two processing >350M lbs. raw
material/yr.) reported rates that include a unit of measurement error. Based on the distribution of flows reported in the MPP
Questionnaires, the EPA suspects that flows reported above 4.4 MGD are reporting errors. These suspected outlier values were
not included in this evaluation of flow rates.

In general, production is directly correlated with the volume of process wastewater generated, higher
production results in higher wastewater generation. Independent rendering facilities, on average,
generate 0.333 gallons per pound of raw material. This is most similar to the gallons of process
wastewater generated per pound by meat first processing facilities (U.S. EPA, 2023a, 2023b). To get this
average production flow rate, the EPA calculated the total pounds produced per year and total gallons of
process wastewater generated per year, using data from the Detailed Questionnaire (excluding suspected
wastewater generation flow rate reporting errors).

-------
The EPA also evaluated wastewater discharge flow rates by facility discharge type. For facilities identified
as independent renderers and as direct, indirect, or zero dischargers in the MPP industry profile, Table
6-8 includes the median wastewater generation flow rates in MGD, using data as reported in the Detailed
Questionnaire.

Table 6-8. MPP Process Wastewater Generation Flow Rates for Independent Rendering Facilities By
Discharge Type as Reported in the Detailed Questionnaire

Type of Discharge

Number of Facilities

Median Wastewater Generation Flow Rate (MGD)a

Direct13

0.209

Indirect

0.0986

Zero Discharge

0.133

Total

0.112

Source: U.S. EPA, 2023a, 2023b.

Notes: Flow rates presented as three significant figures. Wastewater generation flow rates are based on data from Detailed
Questionnaire responses to Question 36.

a — Of the facilities that reported wastewater generation flow rates in response to the Detailed Questionnaire, the EPA suspects
that as many as 13 generation flow rates reported for these facilities (three direct dischargers, seven indirect dischargers, and
three zero dischargers) reported rates that include a unit of measurement error. Based on the distribution of flows reported in
the MPP Questionnaires, the EPA suspects that flows reported above 4.4 MGD are reporting errors. Including flows greater than
these values, the median generation flow rates are 85.02 MGD for direct dischargers, 0.1510 MGD for indirect dischargers, and
0.1711 MGD for zero dischargers.

b — Facilities with both direct and indirect discharges were classified as direct dischargers for this presentation.

The current MPP ELGs only include requirements for direct dischargers. 57 percent of independent
rendering facilities are indirect dischargers, and therefore, are not nationally regulated under the ELG
(U.S. EPA, 2023a).

The characteristics of wastewater generated by rendering facilities depend on several factors, including
the type of product produced (e.g., edible vs. inedible) and the type of raw materials rendered. Factors
such as rate of cooking, speed of agitation, cooker overloading, foaming, and presence of grease traps
can result in volume and composition differences among rendering facilities. In some cases, wastewater
treatment solids from dissolved air flotation (DAF) treatment units are recycled back to the rendering
process. In processes that produce edible products, DAF solids are not recycled back to the rendering
process. At facilities that use metal salts for flocculation/coagulation prior to or in DAF treatment, the DAF
solids also cannot be recycled back to the rendering process.

The composition of rendering process wastewaters can be impacted by the degree of decomposition that
occurs before rendering. The rate of decomposition accelerates in warm weather, leading to increased
ammonia concentrations in untreated rendering process wastewater during summer months. Much of
this decomposition occurs during transport of raw material, as raw material is not climate controlled. In
many cases, the threat of decomposition can limit the maximum transport distance for raw materials that
rendering facilities can accept (U.S. EPA, 2004). Pollutants found in untreated wastewater from rendering
operations include:

• BOD resulting from the cooking and drying process.

• Phosphorus from bone, soft tissue, blood, and corrosion control additives in boiler water.

• COD, TKN, ammonia nitrogen, and grease from blood (U.S. EPA, 2004).

As discussed in Section 3, the EPA reviewed analytical data gathered through the sampling program and
the Detailed Questionnaire. Table 6-9 displays the average concentrations of pollutants in untreated MPP
process wastewaters at independent rendering facilities. While the pollutants are similar to those from
meat and poultry processing, the pollutant concentrations tend to be much higher. Rendering facilities

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typically produce less wastewater than first and further processors, which can attribute to higher
pollutant concentrations in the untreated wastewater. This is, in part, due to the less intensive cleanup
and sanitation at rendering facilities compared to first and further processors. The EPA received data
from three independent rendering facilities.

Table 6-9. Average Pollutant Concentrations in Untreated MPP Wastewater at Independent Rendering

Facilities

Analyte

Unit

Independent Rendering
Average Concentration

Aluminum

mg/L

2.35

Ammonia

mg/L

103

Barium

mg/L

0.0974

Biochemical Oxygen Demand (BOD)

mg/L

8,630

Calcium

mg/L

89.5

Carbonaceous Biochemical Oxygen Demand (cBOD)

mg/L

8,270

Chemical Oxygen Demand (COD)

mg/L

21,400

Chloride

mg/L

467

Copper

mg/L

0.225

E. coli

MPN/lOOmL

111,000,000

Enterococci

MPN/lOOmL

7,144,000

Fecal Coliform

MPN/lOOmL

29,900,000

Fluoride

mg/L

89.3

Iron

mg/L

7.73

Lead

mg/L

0.0164

Magnesium

mg/L

39.8

Manganese

mg/L

0.266

Nitrogen, Total

mg/L

257

Oil and Grease

mg/L

1,110

Phosphorus, Total

mg/L

93.3

Sodium

mg/L

365

Sulfate

mg/L

56.0

Titanium

mg/L

0.115

Total Dissolved Solids (TDS)

mg/L

4,530

Total Organic Carbon

mg/L

1,660

Total Suspended Solids (TSS)

mg/L

4,140

Zinc

mg/L

0.814

Source: U.S. EPA, 2023c.

Abbreviations: mg/L= milligram per liter, MPN/100mL= most probable number per 100 milliliters.
Note: Results presented as three significant figures.

6.4 High Chlorides Wastewater

Certain MPP wastewaters with high concentrations of chlorides can be segregated from MPP wastewater
at the time they are generated. Too much salt can impair water use through unpleasant taste, high water-
treatment costs, staining, corrosion, mineral accumulation in plumbing, and restricted use for irrigation
are among the problems associated with elevated concentrations of dissolved solids. MPP operations
generating high chlorides wastewater are described in Sections 4.1 through 4.4. This high chlorides
wastewater, while considered an MPP process wastewater by definition, is of unique interest due to the

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high salt content resulting from these specific MPP operations. As a result, throughout the remainder of
this TDD, the EPA discusses details for high chlorides wastewaters separate from all other MPP process
wastewaters.

Traditional curing and brining recipes often use a ratio of 1 cup salt to 1 gallon water, yielding a
concentration of 7 to 10 percent by weight (70,000 mg/L — 100,000 mg/L), which aligns with the
maximum water uptake for myofibrillar proteins in meat. Reuse of brines is possible but results in more
concentrated solutions (Du et al., 2010), which is not ideal for all processes. Used brine solutions are
usually discharged.

Koshering of meat and poultry also uses chlorides, but there may be options to reduce the wastestream
concentrations. A study on a kosher poultry processor found that dry tumbling the birds to segregate the
high chlorides wastestream can reduce total dissolved solids (TDS) and chlorides concentrations in the
discharged process wastewater by 80 to 85 percent. The high chlorides wastestream at this facility had a
chlorides concentration around 24,000 mg/L (U.S. EPA, 2023d). Halacha rules do not permit surplus salt
from the koshering process to be reused (Weber et al., 1996), but waste salt can be used in other
industries, such as tanneries, if available.

Hide curing also uses large amounts of chlorides. Bovine raw hides are typically cured either in a high
chlorides concentration about half the weight of the hide(s) or in a 95 percent saturated brine solution.
Almost 75 percent of the salt used ends up in the effluent stream during soaking; one study found that
salt can constitute up to 40 percent of total solids content in tannery effluent (Sarker et al., 2018). Some
MPP facilities process and cure hides. Hides sent to tanneries that do not process meat and poultry
products are regulated by 40 CFR 425 (Leather Tanning and Finishing ELG).

Based on conversations with industry, most MPP facilities use drinking water sources (public water
supplies or well water) for all source water. Facilities may treat their source water with water softeners
before use to minimize scale build-up in equipment and because the facilities are generating food-grade
products (U.S. EPA, 2022a, 2022b). Water softening using ion exchange to remove water hardness often
requires sodium chloride brine concentrations of 8 to 20 percent (80,000 mg/L — 200,000 mg/L). After
softening, most or all of the brine is discharged or disposed of, as reuse of brine impacts performance of
water softening systems (Liu et al., 2021).

As part of the EPA's Clean Water Act (CWA) High Chlorides Treatment 308 Request, the EPA requested
information from MPP facilities on operations related to high chlorides wastewater generation,
characterization, treatment, and discharge. All characterization data received demonstrated chlorides
concentrations that were multiple orders of magnitude above the baseline value for chloride, which is
1,000 |ag/l for EPA Method 300.0 (U.S. EPA, 1993). Four facilities provided concentration data for
untreated high chlorides wastestreams from hides processing operations. The average concentration was
94,175.5 mg/L. Fifteen facilities provided flow data specific to high chlorides streams, 12 of which were
from hides curing and tanning operations. The 15 reported flows ranged from 750 gallons per day (GPD)
up to 25,000 GPD, with the average calculated as 9,451 GPD (U.S. EPA, 2023d).

6.5 References

1. Du, L., Zhou, G.-H., Xu, X.-L., and Li, C.-B. 2010. Study on Kinetics of Mass Transfer in Water-Boiled
Salted Duck During Wet-Curing (October). Journal of Food Engineering, vol. 100, no. 4, pp. 578-584.
DCN MP00293. Available online at: https://doi.Org/10.1016/i.ifoodeng.2009.08.034.

2. Liu, Z., Haddad, M., Sauve, S., and Barbeau, B. 2021. Alleviating the Burden of Ion Exchange Brine in
Water Treatment: From Operational Strategies to Brine Management (October). Water Research, vol.
205, p. 117728. DCN MP00296. Available online at: https://doi.Org/10.1016/i.watres.2021.117728.

3. Sarker, M., Long, W., and Liu, C.-K. 2018. Preservation of Bovine Hide Using Less Salt with Low
Concentration of Antiseptic, Part I: Effectiveness of Developed Formulations (January). Journal of the

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American Leather Chemists Association, vol. 113, no. 01, pp. 12-18. DCN MP00298. Available online
at: https://iournals.uc.edu/index.php/JALCA/article/view/3785.

4.	U.S. EPA. 1993. Method 300.0: Determination of Inorganic Anions by Ion Chromatography (August).
Revision 2.1. DCN MP00190A05. Available online at: https://www.epa.gov/sites/default/files/2015-
08/documents/method 300-0 rev 2.-1 1993.pdf.

5.	U.S. EPA. 2004. Technical Development Document for the Final Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products Point Source Category (40 CFR 432) (September). EPA-
821-R-04-011. Available online at: https://www.epa.gov/sites/default/files/2015-

)cumeints/meat-poulltirv-piroducts tdd 2.004 O.pdf.

6.	U.S. EPA. 2022a. Abbyland Foods Abbotsford, Wl Site Visit Report (July). DCN MP00276.

7.	U.S. EPA. 2022b. Swift Beef Company, Hyrum Plant Site Visit Report (August). DCN MP00138.

8.	U.S. EPA. 2023a. Meat and Poultry Products (MPP) Profile Methodology Memorandum (November).
DCN MP00306.

9.	U.S. EPA. 2023b. U.S. EPA MPP Questionnaires Memorandum (November). DCN MP00234.

10.	U.S. EPA. 2023c. Analytical Database Methodology for the Meat and Poultry Products Proposed
Rulemaking (November). DCN MP00303.

11.	U.S. EPA. 2023d. Summary of High Chlorides Wastewater Data (November). DCN MP00305.

12.	Weber, B., Avnimelech, Y., and Juanico, M. 1996. Salt Enrichment of Municipal Sewage: New
Prevention Approaches in Israel (July). Environmental Management, vol. 20, pp. 487-496. DCN
MP00294. Available online at: https://doi.org/10.1007/BF01474651.

47

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7. Selection of Pollutants and Pollutant Parameters for
Regulation

This section describes the U.S. Environmental Protection Agency's process for identifying pollutants of
concern (POCs) and selecting pollutants for the proposed meat and poultry products (MPP) effluent
limitations guidelines and standards (ELGs). Section 7.1 discusses the pollutants in MPP wastewater that
the EPA evaluated as potential POCs for the proposed ELGs. Section 7.2 presents the pollutants selected
as POCs. Section 7.3 presents the subset of POCs for the proposed regulation under each specified level
of technology-based controls under the Clean Water Act (CWA).

7.1 Pollutants Considered for Regulation

As discussed in Sections 4 and 6, the pollutants present in MPP process wastewater typically include
organics, nutrients, microorganisms, salts, and metals. The EPA identified pollutants of interest in MPP
wastewater based on data from the previous MPP rulemaking (U.S. EPA, 2004) and literature searches.
The EPA included the pollutants listed below and others in its data collection and analysis supporting the
proposed ELGs. See the Generic Sampling and Analysis Plan (U.S. EPA, 2022a) for more details.

• Biochemical oxygen demand (BOD) and carbonaceous biochemical oxygen demand (cBOD) are
estimates of the oxygen-consuming requirements of organic matter decomposition. Severe
reductions in dissolved oxygen (DO) concentrations in receiving waters can lead to fish kills and even
moderate decreases can cause decreases in biodiversity.

• Chemical oxygen demand (COD) is an estimate of organic matter content. When the ratio of COD to
BOD is consistent, COD can be used as a surrogate to estimate impacts of wastewater discharges on
receiving waters. COD can be analyzed faster than BOD, making it more useful for real-time
management of biological wastewater treatment systems.

• Total organic carbon (TOC) is a measure of total organic matter content from a variety of organic
compounds, only some of which are captured in measurements of COD and BOD. When wastewater
composition is relatively constant, TOC can be used to estimate BOD and COD. Like COD, TOC
provides a relatively rapid measurement of organic content compared to BOD.

• Oil and grease (O&G) is an estimate of fats, greases, and oils present in wastewater. In MPP
wastewaters, these are primarily biodegradable animal fats and oils, which are significant sources of
BOD and thereby impact DO availability in ecosystems receiving MPP process wastewater discharges.

• Total suspended solids (TSS) and total dissolved solids (TDS) are measures of solids content in
wastewater. Dissolved solids can upset receiving water ecosystems, impacting public and industrial
water supplies. Suspended solids can impact turbidity and have severe impacts on fish and vegetation
in receiving waters.

• Nitrogen is present as organic and inorganic nitrogen in MPP wastewaters and is measured as total
Kjeldahl nitrogen (TKN; the sum of organic nitrogen and ammonia), ammonia nitrogen, and nitrate-
nitrite nitrogen. Total nitrogen (TN) is the sum of TKN and nitrate-nitrite nitrogen. Ammonia is
especially toxic to fish and can decrease DO concentrations in receiving waters. All forms of nitrogen
can contribute to eutrophic conditions in surface waters, which frequently result in fish kills and loss
of biodiversity. Nitrogen, especially nitrate, can also degrade the quality of drinking water supplies.

• Phosphorus is present in several forms in MPP wastewaters. Phosphorus is considered the limiting
nutrient in freshwater ecosystems; excess phosphorus contributes to the growth of algae and aquatic
plants (U.S. EPA, 2023a), making it a driving force of freshwater eutrophication in cases of excess
phosphorus.

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• Chlorides, as described in Section 4, can be found in high concentrations in wastestreams from
specific MPP first and further processing operations. High chlorides concentrations in freshwater
ecosystems can harm both plants and animals, increased TDS and salinity in receiving waters, and
impair drinking water supplies due to taste issues. High chlorides concentrations in wastewater can
also adversely affect biological wastewater treatment processes.

• Fecal coliform and fecal streptococcus bacteria, such as enterococci, can indicate the presence of
fecal contamination and viruses, enteric pathogenic bacteria, and parasites of enteric origin in
wastewater. Detection of these organisms may indicate inadequate disinfection of MPP wastewater
and the presence of pathogens in discharged effluent. These organisms present potential human
health impacts when receiving surface waters are used for recreational activities or as drinking water
supplies. Pathogens can also be infectious to wildlife.

• Escherichia coli, commonly referred to as E. coli, is a single species and typically the principal
component of the fecal coliform group whose presence is used as an indicator of fecal contamination
(U.S. EPA, 2004). E. coli is potentially a more harmful pathogen than other total coliform bacteria (U.S.
EPA, 2022b).

• Metals are potentially toxic to phytoplankton and zooplankton and to higher aquatic plant and animal
species, including fish. They have potential for bioaccumulation and biomagnification in aquatic food
chains and may be present in potable water supplies downstream from effluent receiving waters (U.S.
EPA, 2004).

7.2 Selection of Pollutants of Concern

The EPA collected data on the pollutants described in Section 7.1. To identify POCs, the EPA reviewed
data from the EPA sampling program, from the Detailed Questionnaire for the Meat and Poultry Products
Effluent Guidelines, and from Discharge Monitoring Reports (DMRs) for treated and untreated
wastewater samples. When developing proposed ELGs, the EPA first evaluates which pollutants are
present in untreated wastewater and whether those pollutants are present at treatable levels. Those that
meet these criteria are identified as POCs. More information on this POC analysis (such as the
methodology, the baseline values the EPA used for identification of POCs, and the sensitivity analysis) can
be found in Pollutants of Concern (POCs) Analysis for the Meat and Poultry Products (MPP) Proposed Rule
(the POC Memo; U.S. EPA, 2023b).

To be identified as a POC, a pollutant must have been detected at levels that are 10 times its baseline
value or higher in at least 10 percent of all untreated process wastewater samples. These criteria ensure
that a pollutant was present with sufficient frequency and in sufficient concentrations for treatment. The
EPA evaluated POCs for MPP process wastewater for the three main process types: meat processing,
poultry processing, and independent rendering (U.S. EPA, 2023b). Table 7-1 presents the POCs identified
for each type of process wastewater.

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Table 7-1. POC Analysis Results for MPP Process Wastewaters

Pollutant Group

Pollutant

Meat Processing3

Poultry Processing3

Rendering3



BOD

POC

POC

POC



Bromide

POC

POC

Never detected



cBOD

POC

POC

POC



COD

POC

POC

POC

Classicals/

Fluoride

POC

POC

POC

Biologica Is

O&G

POC

POC

POC



TOC

POC

POC

POC



Sulfate

POC

POC

POC



TDS

POC

POC

POC



TSS

POC

POC

POC

Chlorides

Chloride

POC

POC

POC



Aluminum

POC

POC

POC



Antimony

Never detected

Never detected

Never detected



Arsenic

Not a POC

Not a POC

Not a POC



Barium

POC

Not a POC

POC



Beryllium

Never detected

Never detected

Never detected



Boron

Not a POC

Not a POC

Not a POC



Cadmium

Never detected

Never detected

Never detected



Calcium

POC

POC

POC

Metals

Chromium

Not a POC

Not a POC

Not a POC



Cobalt

Not a POC

Never detected

Not a POC



Copper

POC

Not a POC

POC



Iron

POC

Not a POC

POC



Lead

Not a POC

Not a POC

POC



Magnesium

POC

POC

POC



Manganese

POC

Not a POC

POC



Molybdenum

POC

Not a POC

Not a POC



Nickel

Not a POC

Never detected

Not a POC

50

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Table 7-1. POC Analysis Results for MPP Process Wastewaters

Pollutant Group

Pollutant

Meat Processing3

Poultry Processing3

Rendering3



Selenium

Not a POC

Never detected

Not a POC



Silver

Not a POC

Never detected

Never detected



Sodium

POC

POC

POC



Thallium

Never detected

Never detected

Never detected



Thorium

Never detected

Never detected

Never detected



Tin

Never detected

Never detected

Never detected



Titanium

POC

Not a POC

POC



Uranium

Not a POC

Never detected

Never detected



Vanadium

POC

Never detected

Never detected



Zinc

POC

POC

POC



Ammonia

POC

POC

POC



Nitrogen, Nitrate-Nitrite

Meets criteria

Meets criteria13

Never detected

Nutrients

TKN

Meets criteria13

Meets criteria13

Meets criteria13

TN

POCb

POCb

POCb



Orthophosphate

No data

POC

No data



Phosphorus, Total (TP)

POC

POC

POC



E. coli

POC

POC

POC

Microbiological

Enterococci

POC

POC

POC



Fecal Coliform

POC

POC

POC

Source: U.S. EPA, 2023b.

a — Pollutants identified as POCs for the processing area were present in 10 percent or more of untreated process wastewater samples at levels that are greater than 10 times the
baseline value or higher. If a pollutant does not meet this criterium but was detected, it is listed as "Not a POC."

b — The EPA evaluated nitrate-nitrite nitrogen and TKN samples to determine whether TN is a POC. TN is identified as a POC if 10 percent or more of the TKN and/or nitrate-nitrite
nitrogen samples are at levels greater than 10 times the baseline value or higher. "Meets criteria" indicates the pollutant met the present in 10 percent or more of untreated
process wastewater samples at greater than 10 times the baseline value or higher.

51

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7.3 Selection of Pollutants for Regulation

The EPA selects pollutants for regulation based on applicable CWA provisions regarding the pollutants
subject to each statutory level. For each regulated subcategory within the MPP point source category, the
EPA selected a subset of pollutants for which to establish numeric effluent limitations from the list of
POCs presented in Section 7.2 (regulated subcategories are discussed in Section 5).

Regulating all POCs is not necessary to ensure that MPP wastewater pollution is adequately controlled,
since many pollutants originate from similar sources, have similar treatability, and are removed by similar
mechanisms. While the proposed rule establishes numeric effluent limitations or standards for some
POCs, the EPA did not set limitations and standards for POCs that:

• Are associated with treatment system chemicals because regulating these pollutants could interfere
with efforts to optimize treatment system operation.

• Are not demonstrated to be reliably treated by the Best Available Technology Economically
Achievable (BAT) technology basis for MPP process wastewater effluent limitations and standards.

• Are adequately controlled through the regulation of another indicator pollutant because the two
pollutants have similar properties and are treated by similar mechanisms.

7.3.1 Regulated Pollutants for Direct Dischargers

Direct dischargers are subject to the following four levels of controls:

• Best Practicable Control Technology Currently Available (BPT): Establishes effluent limitations based
on the average of the best performance of facilities within the industry of various ages, sizes,
processes, or other common characteristics. Priority, conventional, and non-conventional pollutants
(as defined by the CWA) are regulated by BPT effluent limitations.

• Best Conventional Pollutant Control Technology (BCT): Addresses conventional pollutants from
existing industrial point sources. In addition to considering other factors, the EPA establishes BCT
limitations after consideration of a two-part cost-reasonableness test.

• Best Available Technology Economically Achievable (BAT): Represents the best available economically
achievable performance of facilities in the industrial subcategory or category. Priority and non-
conventional pollutants are regulated by BAT effluent limitations.

• New Source Performance Standards (NSPS): Reflects effluent reductions that are achievable based on
the Best Available Demonstrated Control Technology (BADCT). New sources have the opportunity to
install the best and most efficient production processes and wastewater treatment technologies. As
such, NSPS should represent the most stringent controls attainable through the application of the
BADCT for conventional, non-conventional, and priority pollutants.

The EPA is proposing new or revised BCT, BAT, or NSPS limitations and standards for:

• TN: The EPA is proposing to regulate total nitrogen more stringently and implement new limitations
on most subcategories. New and revised limitations will ensure greater removals of all forms of
nitrogen, includingTKN and nitrate-nitrite nitrogen.

• TP: The EPA is proposing to regulate total phosphorus across most subcategories to ensure that
treatment systems used by facilities are achieving meaningful reductions in discharges of all forms of
phosphorus.

• Fecal coliform: The EPA is proposing to regulate fecal coliform more stringently to ensure that
treatment systems used by facilities are achieving adequate disinfection and control of pathogens in
discharged effluent.

-------
The EPA is considering regulating E. coli, as it serves as an indicator of sufficient treatment for other
microbiologicals, including fecal coliform and enterococci. The EPA is also considering establishing BAT
zero discharge effluent limitations for chlorides in high chlorides wastestreams from direct discharging
MPP facilities. As discussed in Section 4, high chlorides wastestreams typically can be segregated from
MPP process wastewater, enabling separate treatment and/or disposal.

As noted above, the EPA decided to eliminate a number of POCs from consideration for regulation. The
following paragraphs describe the EPA's rationale for some of those decisions.

• Treatment chemicals: The EPA identified and eliminated from consideration five POCs that are used
as wastewater treatment chemicals as their regulation could interfere with efforts to optimize
treatment system operation. The five POCs—aluminum, calcium, iron, magnesium, and sodium—may
be introduced to the wastewater stream through pipes, mechanical equipment, and animal feed.

• Pollutants not effectively treated by BAT technology: The EPA identified and eliminated from
consideration three POCs—bromide, fluoride, and sulfate—because the BAT technology basis for
MPP process wastewater effluent limitations and standards is not demonstrated to reliably treat
these pollutants. The EPA also eliminated from consideration barium, copper, lead, manganese,
molybdenum, titanium, vanadium, and zinc. While the EPA observed via sampling data that some
biological treatment systems used in the MPP processing industry provide reductions of metal
concentrations, these systems are not specifically engineered to remove metals. Thus, the EPA
believes that not all facilities will be able to manage biological treatment processes to consistently
achieve effluent limitations for metals. Finally, the EPA eliminated TDS from consideration because
organic matter decomposition during biological wastewater treatment may increase TDS
concentrations.

• Pollutants directly regulated or controlled by regulation of other pollutants: The existing BPT, BCT,
and NSPS limitations and standards adequately control BOD, TSS, and O&G in discharges of MPP
process wastewater. These regulations also effectively control discharges of three other POCs: cBOD,
COD, and TOC. The proposed BAT limitations for TN and TP will adequately control discharges of
three other nutrient POCs in MPP process wastewater: nitrate-nitrite nitrogen, TKN, and
orthophosphate. Finally, the proposed and existing BPT and BCT regulations for fecal coliform
adequately control discharges of enterococci in MPP process wastewater.

Table 7-2 provides a summary of POCs eliminated from consideration and the rationale for each.

-------
Table 7-2. POCs Eliminated from Consideration for Regulation for Direct Dischargers

Pollutant Group

Pollutant of Concern

Used As Treatment Chemical

Not Effectively Treated by
the BAT Technology

Directly Regulated or Controlled by
Regulation of Another Pollutant



Bromide3



X





cBOD





X

Classicals/
Biologica Is

COD





X

Fluoride



X



TOC





X



Sulfate



X





TDS



X





Aluminum

X







Bariumb



X





Calcium

X







Copper13



X





lronb

X







Leadc



X



Metals

Magnesium

X







Manganese13



X





Molybdenumd



X





Sodium

X







Titanium13



X





Vanadiumd



X





Zinc



X





Nitrogen, Nitrate-Nitrite





X

Nutrients

TKN





X



Orthophosphate®





X

Microbiological

Enterococci





X

a — Identified as POC for only meat processing and poultry processing.	d — Identified as POC for meat processing only,

b — Identified as POC for only meat processing and rendering.	e — Identified as POC for poultry processing only,

c — Identified as POC for rendering only.

54

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7.3.2 Regulated Pollutants for Indirect Dischargers

Indirect dischargers are subject to two levels of control under ELGs that are designed to prevent the
discharges of pollutants that passthrough, interfere with, or are otherwise incompatible with the
operation of Publicly Owned Treatment Works (POTWs). These controls include:

• Pretreatment Standards for New Sources (PSNS): PSNS are national, uniform, technology-based
standards that apply to facilities within certain industrial categories that discharge to POTWs (i.e.,
indirect dischargers). New indirect dischargers have the opportunity to incorporate into their facilities
the best available demonstrated technologies. The Agency typically considers the same factors in
promulgating PSNS as it considers in promulgating NSPS.

• Pretreatment Standards for Existing Sources (PSES): Like PSNS, PSESare national, uniform,
technology-based standards that apply to indirect dischargers. PSES apply by a specified date,
typically no more than three years after the effective date of the categorical standard. The EPA
typically considers the same factors in promulgating PSES as it considers in promulgating BPT/BAT.

The proposed rule establishes new PSES and PSNS for most subcategories. Before establishing PSES or
PSNS limitations for a POC, the EPA examines whether the pollutant "passes through" a POTW to waters
of the United States, interferes with, or is otherwise incompatible with POTW operations, within the
meaning of CWA Section 307(b).

In establishing categorical pretreatment standards, the EPA determines whether a pollutant passes
through a POTW by comparing the percentage of a pollutant removed by well-operated POTWs
performing secondary treatment to the percentage removed by the BAT/NSPS technology basis. A
pollutant is determined to passthrough POTWs when the median percentage removed nationwide by
well-operated POTWs is less than the median percentage removed by the BAT/NSPS technology basis.
Pretreatment standards are established for those pollutants regulated under BAT/NSPS that passthrough
POTWs.

The EPA determined the percentage of pollutant removed by the proposed rule's technology basis for
pollutants selected for regulation via BAT (PSES) controls or via NSPS (PSNS) controls. Table 7-3
summarizes the results of the POTW Passthrough Analysis for MPP process wastewater for PSES;
determinations for PSNS are equal to PSES. For details on this analysis, see the Meat and Poultry Products
POTW Passthrough Analysis memorandum (U.S. EPA, 2023c).

Table 7-3. POTW Passthrough Analysis for MPP Process Wastewater

Pollutant

Median BAT
Percent Removal

Median POTW
Percent Removal

Is BAT Percent
Removal > POTW
Percent Removal?

Does Pollutant
Passthrough?

Meat Processing

BOD

100%

90%

Yes

O&G

99.9%

87%

Yes

TSS

99.9%

90%

Yes

84.5%

39%

Yes

96.9%

30%

Yes

Poultry Processing

BOD

99.9%

90%

Yes

O&G

99.6%

87%

Yes

TSS

99.6%

90%

Yes

90.2%

39%

Yes

99.5%

30%

Yes

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Table 7-3. POTW Passthrough Analysis for MPP Process Wastewater

Pollutant

Median BAT
Percent Removal

Median POTW
Percent Removal

Is BAT Percent
Removal > POTW
Percent Removal?

Does Pollutant
Passthrough?

Rendering

BOD

100%

90%

Yes

O&G

99.5%

87%

Yes

TSS

99.9%

90%

Yes

73.5%

39%

Yes

99.7%

30%

Yes

Source: U.S. EPA, 2023c.

Because BOD, TSS, and O&G do passthrough POTWs, the EPA is proposing PSES and PSNS requirements
for these pollutants. As described in Section 9, PSES and PSNS limitations for BOD, O&G, and TSS are
based, for some facilities, on treatment that includes screening and a dissolved air flotation (DAF)
treatment unit as the technology basis, referred to as the Indirect Wastewater Treatment Technology
System Targeting Conventionals (BOD, O&G, and TSS).

• BOD: The EPA is proposing to regulate BOD because it serves as an indicator of the performance of
treatment systems in removing oxygen-demanding pollutants. High amounts of BOD can cause
interference in biological treatment at POTWs, and this interference could lead to pollutants passing
through the POTW, which could result in violations.

• TSS: The EPA is proposing to regulate TSS because it serves as an indicator of the performance of
treatment systems in removing solids. High levels of TSS can cause interference through clogging and
fouling of pipes and pumps.

• O&G: The EPA is proposing to regulate O&G to ensure that treatment systems are effective in
removing O&G. O&G can cause blockages in sewer systems and can negatively impact POTW
performance.

The EPA is also concerned about discharges of chlorides from indirect facilities for the same reasons as
discharges from direct facilities (see Section 7.17.3.1). The EPA is considering establishing PSES zero
discharge effluent limitations for chlorides in high chlorides wastestream from indirect discharging MPP
facilities. As such, the EPA did not conduct its traditional passthrough analysis for high chlorides
wastestreams because these limitations and standards achieve 100 percent removal of chlorides.

7.4 References

1. U.S. EPA. 2004. Technical Development Document for the Final Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products Point Source Category (40 CFR 432) (September). EPA-
821-R-04-011. Available online at: https://www.epa.gov/sites/default/files/2015-
11/documents/meat-poultry-products tdd 2004 O.pdf.

2. U.S. EPA. 2022a. Generic Sampling and Analysis Plan for Meat and Poultry Products (MPP) Point
Source Category (August). DCN MP00136.

3. U.S. EPA. 2022b. Addressing Total Coliform Positive or E. Coli Positive Sample Results in EPA Region 8
(September). DCN MP00328. Available online at: https://www.epa.Rov/reRion8-waterops/addressinR-
total-coliform-positive-or-e-coli-positive-sample-results-epa-reRion-8.

4. U.S. EPA. 2023a. Indicators: Phosphorus (June). DCN MP00331. Available online at:
www.epa.Rov/national-aquatic-resource-survevs/indicators-phosphorus.

5. U.S. EPA. 2023b. Pollutants of Concern (POC) Analysis for the Meat and Poultry Products (MPP)
Proposed Rule (November). DCN MP00190.

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6. U.S. EPA. 2023c. Meat and Poultry Products POTW Passthrough Analysis (November). DCN MP00309.

57

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8. Wastewater Treatment Technologies and Pollutant
Prevention Practices

This section provides an overview of the treatment technologies and wastewater management practices
currently in use at meat and poultry products (MPP) facilities. As described in Section 4 of this report, the
U.S. Environmental Protection Agency's current MPP industry population contains 5,055 MPP facilities
that were identified through the Census Questionnaire for the Meat and Poultry Products Effluent
Guidelines (Census Questionnaire), Detailed Questionnaire for the Meat and Poultry Products Effluent
Guidelines (Detailed Questionnaire), and publicly available data. The EPA compiled data on each facility,
including type of operations, discharge status, and location. The Meat and Poultry Products (MPP) Profile
Methodology Memorandum (U.S. EPA, 2023a) explains how data from these multiple sources were
combined to develop this industry population.

The EPA reviewed information specific to treatment technologies and wastewater management practices
from MPP facilities that responded to Section 7 of the Detailed Questionnaire (Wastewater Treatment
Information). See Section 3.3 of this report for more information on the Detailed Questionnaire. Table 8-1
presents a breakdown by discharge type of the 5,055 facilities in the EPA's MPP industry population as
well as the 510 MPP facilities that provided information on their wastewater treatment systems in
response to the Detailed Questionnaire (10 percent of the industry population) (U.S. EPA, 2023b). Table
8-2 presents a breakdown of the same populations by process type and annual production volume.

The EPA identified four types of wastewater dischargers: direct dischargers (facilities discharging to a
surface water), indirect dischargers (facilities discharging to a Publicly Owned Treatment Works [POTW],
direct and indirect dischargers (facilities with both direct discharge and indirect discharge), and zero
dischargers (facilities that generate wastewater but do not discharge any of it). The EPA identified one
facility from the 510 Detailed Questionnaire respondents that is both a direct and indirect discharger. This
facility discharges the majority of its wastewater directly; thus, this facility is classified as a direct
discharger in the remainder of this section.

As described in Section 4, MPP facilities can be differentiated by operation and placed into one of five
categories: meat first processors, meat further processors, poultry first processors, poultry further
processors, and independent renderers. Meat first processors and poultry first processors include MPP
facilities that slaughter meat or poultry (some may also perform further processing and/or rendering).
Meat further processors and poultry further processors include MPP facilities that further process (some
may also render). Independent rendering facilities only perform rendering operations. Some MPP
facilities perform both meat and poultry processing. The EPA categorized each MPP facility in the industry
population based on its dominant operation.

Table 8-1. MPP Facility Breakdown from Industry Profile and Detailed Questionnaire by Discharge

Type

Type of Discharge

Number of Facilities, Based on
Industry Profile

Number of Detailed
Questionnaire Respondents

Indirect Dischargers

3,708

293

Direct Dischargers3

171

Zero Dischargers

1,176

126

Total

5,055

510

Source: U.S. EPA, 2023a, 2023b.

a — One facility discharging both to a receiving water (i.e., direct discharge) and to a POTW (i.e., indirect discharge) is classified
here as a direct discharger.

-------
Table 8-2. MPP Facility Breakdown from Industry Profile and Detailed Questionnaire by Production by

Process Type and Annual Production

Type of Processing and Annual

Number of Facilities, Based on

Number of Detailed

Production

Industry Profile

Questionnaire Respondents

Meat First Processors

<5M lbs. LWK/yr.

570

65

5 to <10M lbs. LWK/yr.

63

2

10 to <200M lbs. LWK/yr.

106

25

>200M lbs. LWK/yr.

87

60

Total Meat First

826

152

Meat Further Processors

<2M lbs. Finished Product/yr.

2194

26

2 to <10M lbs. Finished Product/yr.

695

17

10 to 50M lbs. Finished Product/yr.

224

32

>50M lbs. Finished Product/yr.

347

59

Total Meat Further

3,460

134

Poultry First Processors

<5M lbs. LWK/yr.

57

12

5 to 30M lbs. LWK/yr.

19

10

>30 to <200M lbs. LWK/yr.

64

18

>200M lbs. LWK/yr.

150

104

Total Poultry First

290

144

Poultry Further Processors

<2M lbs. Finished Product/yr.

110

4

2 to <10M lbs. Finished Product/yr.

50

8

10 to 30M lbs. Finished Product/yr.

25

6

>30M lbs. Finished Product/yr.

109

24

Total Poultry Further

294

42

Independent Renderers

<5M lbs. Raw Material/yr.

23

1

5 to 30M lbs. Raw Material/yr.

16

4

>30 to <350M lbs. Raw Material/yr.

122

27

>350M lbs. Raw Material/yr.

24

6

Total Renderers

185

38

Industry Total

5,055

510

Source: U.S. EPA, 2023a, U.S. EPA, 2023b.

Abbreviations: M = million, lbs. = pounds, LWK = live weight killed, yr. = year.

The EPA gathered information through the Detailed Questionnaire on whether respondents treat process
wastewater on site prior to discharge. Table 8-3 presents a breakdown of facilities that treat process
wastewater on site by facility discharge type, and Table 8-4 presents a breakdown of the same facilities by
operation and annual production volume. Of the 510 Detailed Questionnaire respondents, 420 (over 80
percent) reported some level of wastewater treatment on site. All direct discharging respondents
reported implementing wastewater treatment (U.S. EPA, 2023a, 2023b).

59

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Table 8-3. Facilities that Treat MPP Process Wastewater on Site Based on Detailed Questionnaire by

Discharge Type

Type of Discharge

Number of Respondents That Treat
Process Wastewater On Site

Total Number of Detailed
Questionnaire Respondents

Indirect Dischargers

255

293

Direct Dischargers3

91

91

Zero Dischargers

74

126

Total

420

510

Source: U.S. EPA, 2023a, 2023b.

a — One facility with multiple outfalls discharging both to a receiving water (i.e., direct discharge) and to a POTW (i.e., indirect
discharge) is classified here as a direct discharger.

Table 8-4. Facilities that Treat MPP Process Wastewater on Site Based on Detailed Questionnaire by

Process Type and Annual Production

Type of Processing and Annual
Production

Number of Respondents That
Treat Process Wastewater On Site

Total Number of Detailed
Questionnaire Respondents

Meat First Processors

<5M lbs. LWK/yr.

30

65

5 to <10M lbs. LWK/yr.

0

2

10 to <200M lbs. LWK/yr.

20

25

>200M lbs. LWK/yr.

56

60

Total Meat First

106

152

Meat Further Processors

<2M lbs. Finished Product/yr.

14

26

2 to <10M lbs. Finished Product/yr.

15

17

10 to 50M lbs. Finished Product/yr.

28

32

>50M lbs. Finished Product/yr.

54

59

Total Meat Further

111

134

Poultry First Processors

<5M lbs. LWK/yr.

8

12

5 to 30M lbs. LWK/yr.

7

10

>30 to <200M lbs. LWK/yr.

17

18

>200M lbs. LWK/yr.

102

104

Total Poultry First

134

144

Poultry Further Processors

<2M lbs. Finished Product/yr.

2

4

2 to <10M lbs. Finished Product/yr.

5

8

10 to 30M lbs. Finished Product/yr.

4

6

>30M lbs. Finished Product/yr.

24

24

Total Poultry Further

35

42

Independent Renderers

<5M lbs. Raw Material/yr.

0

1

5 to 30M lbs. Raw Material/yr.

2

4

>30 to <350M lbs. Raw Material/yr.

26

27

>350M lbs. Raw Material/yr.

6

6

60

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Table 8-4. Facilities that Treat MPP Process Wastewater on Site Based on Detailed Questionnaire by

Process Type and Annual Production

Type of Processing and Annual
Production

Number of Respondents That
Treat Process Wastewater On Site

Total Number of Detailed
Questionnaire Respondents

Total Renderers

Industry Total

420

510

Source: U.S. EPA, 2023a, U.S. EPA, 2023b.

Abbreviations: M = million, lbs. = pounds, LWK = live weight killed, yr. = year.

Sections 8.1 through 8.5 discuss end-of-pipe wastewater treatment practices and technologies for
process wastewater present at the 384 direct and indirect discharging MPP facilities that reported
treating wastewater on site in the Detailed Questionnaire. Section 8.6 describes wastewater treatment
for high chlorides wastewater. Section 8.7 presents a summary of the 126 MPP facilities achieving zero
discharge. Section 8.8 presents information on pollution prevention and wastewater reduction practices
in the industry. All analyses and statistics presented in the following sections are based on responses to
the Detailed Questionnaire.

8.1 Primary Treatment

Primary treatment typically targets removal of large particulates and floating or settleable solids. These
treatment units are often operated as the initial stage of treatment and may be followed by additional
treatment units. Some facilities that discharge to an outside treatment system, such as a POTW, operate
only primary treatment units. Primary treatment units can be referred to as pretreatment since they may
be physically located and operated in the processing area or otherwise apart from the rest of the
wastewater treatment system. Primary treatment can include other units that provide flow control,
aeration to prevent solids from settling, and/or odor control.

Table 8-5 presents a breakdown of indirect dischargers and direct dischargers that implement at least one
treatment unit for primary treatment as part of their wastewater treatment system. Approximately 81
percent of direct dischargers (74 of 91 facilities) and 62 percent of indirect dischargers (181 of 293
facilities) implement some form of primary treatment (U.S. EPA, 2023a, 2023b).

When facilities are further broken down by process type, the majority of facilities in each category have
some form of primary treatment in place. Table 8-6 presents a breakdown of facilities reporting primary
treatment by process and annual production volume.

Table 8-5. Number of Detailed Questionnaire Respondents That Implement Primary Treatment by

Discharge Type

Type of Discharge

Number of Respondents That
Implement Primary Treatment

Total Number of Detailed
Questionnaire Respondents3

Indirect Dischargers

181

293

Direct Dischargers'3

Total

255

384

Source: U.S. EPA, 2023a, 2023b.

a — Facilities operating in a manner to achieve zero discharge are excluded from this presentation. See Section 8.7 for a
discussion on zero discharge facilities.

b — One facility discharging both to a receiving water (i.e., direct discharge) and to a POTW (i.e., indirect discharge) is classified
here as a direct discharger.

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Table 8-6. Number of Detailed Questionnaire Respondents That Implement Primary Treatment by

Process Type and Annual Production

Type of Processing and Annual
Production

Number of Respondents That
Implement Primary Treatment

Total Number of Detailed
Questionnaire Respondents3

Meat First Processors

<5M lbs. LWK/yr.

4

27

5 to <10M lbs. LWK/yr.

0

1

10 to <200M lbs. LWK/yr.

10

18

>200M lbs. LWK/yr.

45

52

Total Meat First

59

98

Meat Further Processors

<2M lbs. Finished Product/yr.

5

13

2 to <10M lbs. Finished Product/yr.

3

14

10 to 50M lbs. Finished Product/yr.

14

29

>50M lbs. Finished Product/yr.

41

56

Total Meat Further

63

112

Poultry First Processors

<5M lbs. LWK/yr.

4

5

5 to 30M lbs. LWK/yr.

2

4

>30 to <200M lbs. LWK/yr.

8

13

>200M lbs. LWK/yr.

75

90

Total Poultry First

89

112

Poultry Further Processors

<2M lbs. Finished Product/yr.

0

2

2 to <10M lbs. Finished Product/yr.

2

6

10 to 30M lbs. Finished Product/yr.

2

4

>30M lbs. Finished Product/yr.

17

22

Total Poultry Further

21

34

Independent Renderers

<5M lbs. Raw Material/yr.

0

0

5 to 30M lbs. Raw Material/yr.

0

3

>30 to <350M lbs. Raw Material/yr.

18

20

>350M lbs. Raw Material/yr.

5

5

Total Renderers

23

28

Industry Total

255

384

Source: U.S. EPA, 2023a, 2023b.

Abbreviations: M = million, lbs. = pounds, LWK = live weight killed, yr. = year.

a — Facilities operating in a manner to achieve zero discharge are excluded from this presentation. See Section 8.7 for a
discussion on zero discharge facilities.

Table 8-7 describes common primary treatment units used in the MPP industry. Removal of large
particles (such as feathers, offal, bone trimmings, or cartilage) as well as oil and grease (O&G) is
important for MPP wastewater treatment because these particles could damage or interfere with
downstream equipment or disrupt treatment efficiency. Many MPP facilities use a treatment unit for
O&G removal, such as a dissolved air flotation (DAF) unit, an American Petroleum Institute (API)
separator, and/or a catch basin. The most commonly used O&G removal treatment unit, as reported in
the Detailed Questionnaire, is a DAF (U.S. EPA, 2023b).

62

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Table 8-7. Primary Treatment Units Used in the MPP Industry

Treatment Unit

Description

Screens

Screening removes large solid particles (0.01 to 0.06 inch in diameter) from
wastewater. Different types of screens can be used in wastewater treatment,
including static or stationary, rotary drum, brushed, and vibrating. Screens typically
have stainless steel wedge wire that removes medium and coarse particles.

DAF

In a DAF unit, air is dissolved under pressure and then released at atmospheric
pressure in a tank containing wastewater. The released air creates bubbles that
adhere to suspended solids, causing the solids to float to the surface where they
can be removed by skimming. DAF removes suspended solids (e.g., soil, sand), fatty
tissue from meat and poultry, oils, grease, and metals. This treatment unit can also
be used for biological treatment, as it can reduce biochemical oxygen demand
(BOD) and chemical oxygen demand (COD). Solids gathered from this treatment
unit are often combined with sludge from other treatment units and moved to
solids handling, discussed in Section 8.5.

API Separators

API separators remove oils, fatty grease from animals, and suspended solids by
skimming and collecting the materials from the surface of the wastewater.

Catch Basin

Catch basins separate grease and finely suspended solids from wastewater by the
process of gravity separation. Each basin is equipped with a skimmer and a scraper.
The skimmer removes grease and scum on the surface, and the scraper removes
sludge that collects at the bottom of the basin.

Flow

Equalization

A flow equalization unit is any type of basin, lagoon, tank, or reactor that serves to
control a variable flow of wastewater to achieve a near-constant flow into the
treatment system. A separate unit for equalization may not be necessary as many
treatment units (such as DAF, a catch basin, or an anaerobic lagoon) may provide
flow equalization.

Chemical
Addition

Facilities may add chemicals for settling, thickening, and/or pH control. These
chemicals can be added in the DAF, flow equalization, or other units, or before the
wastewater enters these units. Chemicals include polymers, coagulants, and
flocculants.

8.2 Biological Treatment

Biological treatment typically occurs after primary treatment and uses microorganisms to reduce BOD
and COD through the consumption of organic matter in wastewater via microbial respiration and
synthesis. Biological treatment can also reduce the levels of nitrogen through nitrification and
denitrification.

• Nitrification is a two-step aerobic process. First, ammonia is oxidized into nitrite by Nitrosomonas
bacteria. Then, nitrite is oxidized into nitrate by Nitrobacter bacteria. Nitrification only occurs when
there is sufficient biomass and residence time to fully convert ammonia to nitrite, and then convert
nitrite to nitrate (Metcalf & Eddy, 2003).

• Denitrification is a microbial process in which nitrite and nitrate are reduced by heterotrophic
bacteria into gaseous nitrous oxide and nitrogen gas under anoxic conditions without the presence of
molecular oxygen. A carbon source, such as methanol, may need to be added to keep the microbes
healthy.

o Treatment systems may perform varying degrees of denitrification, depending on the solids
retention time and the volume and location of the anoxic areas compared to the aerobic areas.

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Partial denitrification indicates that nitrate-nitrite nitrogen has been partially broken down; full
denitrification indicates a more complete breakdown of nitrate-nitrite nitrogen.

Biological treatment can use aerobic processes to achieve nitrification and anaerobic/anoxic processes to
achieve denitrification in multiple units or within the same treatment unit using different zones.

Anaerobic lagoons pretreat high-strength wastewaters using microorganisms in the absence of dissolved
oxygen to convert organic matter into carbon dioxide and methane. These deep earthen basins allow for
sedimentation of settleable solids; a layer of sludge accumulates over time and eventually is removed.
Anaerobic lagoons are used in biological treatment and often serve as BOD pretreatment.

Aerobic treatment processes use microorganisms to consume biodegradable organic compounds in
aerated wastewater for nitrification. This process reduces BOD and suspended solids as well as ammonia.
MPP facilities can use a variety of biological treatment systems for this, but the most common is a
conventional activated sludge system. Activated sludge systems achieve biological nitrification using
microorganisms to convert ammonia to nitrate in an aerobic envrionment. Wastewater and the
microorganisms are aerated in a reactor for a specified period of time. This process creates a sludge that
later separates from the water by settling in a clarification unit. A portion of the activated sludge is
recirculated to the reactor, and a portion is wasted. The wasted portion is usually sent to the solids
handling treatment units (discussed further in Section 8.5). The most important factor in controlling an
activated sludge system is the sludge retention time (SRT). SRT is a design parameter that can control the
efficacy of the system. See Figure 8-1 for a process flow diagram of a typical activated sludge system.

Pretreated
wastewater

Equalization tank
~

Aerobic tank
(combined oxidation
and nitrification)

Treated
effluent

Air

Return activated sludge

Wasted sludge
to dewatering

Figure 8-1. Process Flow Diagram of Conventional Activated Sludge System

Conventional activated sludge systems typically treat wastewater continuously through a series of
separate tanks. An alternative approach is treating the wastewater in separate batches using a
sequencing batch reactor (SBR) that carries out the activated sludge process sequentially in the same
reactor tank. Attached growth/fixed film reactors are another alternative in which the microbes are
attached to a rigid supporting media. Some MPP facilities use a moving bed biofilm reactor (MBBR), which
is another type of aerobic treatment that uses activated sludge. Specifically, it is a hybrid suspended,
growth-fixed film system in which a "biocarrier" media in the unit provides a place for the
microorganisms to grow on. Another option is a membrane bioreactor (MBR) system, which combines
filtration with a suspended growth bioreactor.

Anaerobic or anoxic wastewater treatment processes reduce complex organic compounds to methane
and carbon dioxide. Anaerobic treatment can achieve partial to complete denitrification, converting
nitrate to nitrogen gas. MPP facilities may use a Modified Ludzack-Ettinger (MLE) system to achieve
denitrification, as shown in Figure 8-2. The MLE is a two-stage system with an anoxic zone followed by an
aerobic zone. The nitrate produced by the aeration zone is recycled back to the anoxic zone and is used

-------
as an oxygen source for facultative bacteria in the anoxic zone. The MLE process removes most BOD and
can achieve 80 percent nitrogen removal (U.S. EPA, 2009). The SRT and the size of the anoxic zone
compared to the aerobic zone are important design parameters that help determine whether the system
will achieve partial or full denitrification.

Nitrified recycle

Wastewater from
aeration tank

Anoxic
zone

Aeration
zone

Treated

*L Clarifier J ' effluent

Air

Return activated sludge

Wasted sludge

to dewatering

Figure 8-2. Process Flow Diagram of MLE System to Achieve Denitrification

Nitrification and denitrification can be achieved within a single multi-stage system where organic matter
is the source for nitrification and organic carbon is the source for denitrification. For example, both the
four-stage Bardenpho and the modified (five-stage) Bardenpho system achieve nitrification and
denitrification through separate aerobic and anoxic zones.

• Four-stage Bardenpho: includes anoxic, aerobic, anoxic, and aerobic stages, followed by a secondary
clarifier. Mixed liquor with high levels of nitrate is recycled from the first aerobic stage back to the
first anoxic stage. Activated sludge from the clarifier is recycled back to the influent. Nitrification
occurs primarily in the second stage (aerobic). Denitrification occurs in the first and third stages
(anoxic). The final aeration stage removes nitrogen gas from the system and increases the
concentration of dissolved oxygen. The four-stage Bardenpho process achieves higher rates of
nitrogen removal compared to the two-stage MLE process.

• Modified Bardenpho (Five-Stage Bardenpho): includes anaerobic, anoxic, aerobic, anoxic, and aerobic
stages, followed by a secondary clarifier. As in the four-stage Bardenpho process, mixed liquor with
high levels of nitrate is recycled from the first aerobic stage back to the first anoxic stage and
activated sludge from the clarifier is recycled back to the influent. The Five-Stage Bardenpho process
can achieve high rates of denitrification. See Figure 8-3 for a process flow diagram of a typical Five-
Stage Bardenpho.

Other systems, such as the SBR, can be configured to achieve nitrification as well as denitrification.

-------

Nitrified recycle

Wastewater from

aeration tank

Qj
nj

.0
c

Aerated
zone

§
c

. o
-Q

Treated

C
T

'L^CIaritier ' effluent

Air

Return activated sludge

Wasted sludge

to dewatering

Figure 8-3. Process Flow Diagram of Modified Bardenpho (Five-Stage Bardenpho)

MPP facilities use a variety of biological treatment units, and some facilities may be implementing and
reporting multiple types of biological treatment. Responses to the Detailed Questionnaire showed that:5

• 86 facilities reported using some type of anaerobic or anoxic treatment.

• 74 facilities reported using some type of aerobic treatment unit.

• 26 facilities reported using an activated sludge system.

• 13 facilities reported using some type of bioreactor (U.S. EPA, 2023b).

Table 8-8 presents a breakdown of the direct and indirect dischargers that implement at least one
treatment unit for biological treatment as part of their wastewater treatment system based on the
Detailed Questionnaire. MPP facilities can use certain biological treatment units, such as anaerobic
lagoons, as primary treatment (i.e., BOD pretreatment). The data in the table exclude respondents who
reported using biological treatment units only for purposes other than biological treatment (e.g., primary
treatment).

In all, 18 percent of indirect dischargers (54 of 293 facilities) compared to 96 percent of direct dischargers
(87 of 91 facilities) implement at least one a biological treatment unit (U.S. EPA, 2023a, 2023b). The low
percentage for indirect dischargers is not unusual given that POTWs perform biological treatment.
Likewise, the high percentage for direct dischargers is expected given that the current MPP ELGs regulate
direct dischargers of a certain size (depending on their subcategory) for total nitrogen (TN) and ammonia.

Table 8-8 presents a breakdown of facilities reporting biological treatment by discharge type. Table 8-9
presents a breakdown of facilities reporting biological treatment by process type and annual production
volume.

5 In the Detailed Questionnaire, respondents reported the names used for treatment units implemented at their
facilities. The EPA used keywords to categorize the type of treatment based on the reported name. Some facilities
that responded with generic names may not be represented here.

-------
Table 8-8. Number of Detailed Questionnaire Respondents That Implement Biological Treatment by

Discharge Type

Type of Discharge

Number of Respondents That
Implement Biological Treatment

Total Number of Detailed
Questionnaire Respondents3

Indirect Dischargers

54

293

Direct Dischargers'3

87

91

Total

141

384

Source: U.S. EPA, 2023a, 2023b.

Note: If a respondent reported using a biological treatment unit for purposes other than biological treatment (e.g., primary
treatment), that facility is not included in this table for that treatment unit.

a — Facilities operating in a manner to achieve zero discharge are excluded from this presentation. See Section 8.7 for a
discussion on zero discharge facilities.

b — One facility discharging both to a receiving water (i.e., direct discharge) and to a POTW (i.e., indirect discharge) is classified
here as a direct discharger.

Table 8-9. Number of Detailed Questionnaire Respondents That Implement Biological Treatment by

Process Type and Annual Production

Type of Processing and Annual

Number of Respondents That

Total Number of Detailed

Production

Implement Biological Treatment

Questionnaire Respondents3

Meat First Processors

<5M lbs. LWK/yr.

2

27

5 to <10M lbs. LWK/yr.

0

1

10 to <200M lbs. LWK/yr.

8

18

>200M lbs. LWK/yr.

35

52

Total Meat First

45

98

Meat Further Processors

<2M lbs. Finished Product/yr.

2

13

2 to <10M lbs. Finished Product/yr.

3

14

10 to 50M lbs. Finished Product/yr.

6

29

>50M lbs. Finished Product/yr.

7

56

Total Meat Further

18

112

Poultry First Processors

<5M lbs. LWK/yr.

3

5

5 to 30M lbs. LWK/yr.

0

4

>30 to <200M lbs. LWK/yr.

6

13

>200M lbs. LWK/yr.

50

90

Total Poultry First

59

112

Poultry Further Processors

<2M lbs. Finished Product/yr.

0

2

2 to <10M lbs. Finished Product/yr.

0

6

10 to 30M lbs. Finished Product/yr.

1

4

>30M lbs. Finished Product/yr.

5

22

Total Poultry Further

6

34

Independent Renderers

<5M lbs. Raw Material/yr.

0

0

5 to 30M lbs. Raw Material/yr.

1

3

67

-------
Table 8-9. Number of Detailed Questionnaire Respondents That Implement Biological Treatment by

Process Type and Annual Production

Type of Processing and Annual
Production

Number of Respondents That
Implement Biological Treatment

Total Number of Detailed
Questionnaire Respondents3

>30 to <350M lbs. Raw Material/yr.

>350M lbs. Raw Material/yr.

Total Renderers

Industry Total

141

384

Source: U.S. EPA, 2023a, 2023b.

Abbreviations: M = million, lbs. = pounds, LWK = live weight killed, yr. = year.

Note: If a respondent reported using a biological treatment unit for purposes other than biological treatment (e.g., primary
treatment), that facility is not included in this table for that treatment unit.

a — Facilities operating in a manner to achieve zero discharge are excluded from this presentation. See Section 8.7 for a
discussion on zero discharge facilities.

8.3 Phosphorus Removal

Some MPP facilities implement treatment technologies to achieve phosphorus removal. Table 8-10
provides brief descriptions of a few of these treatment technologies. Other treatment technologies, such
as the DAF units described in Section 8.1, are also often used for phosphorus removal.

Biological treatment can also achieve phosphorus removal as microorganisms used in biological
treatment require phosphorus for cell synthesis and energy transport. Certain biological systems (e.g.,
SBRs) can also be specifically designed and/or operated to remove phosphorus. Multi-stage biological
treatment systems (e.g., Bardenpho, modified Bardenpho) are capable of targeting nitrogen and
phosphorus. In the Modified Bardenpho process, the anaerobic stage at the beginning of the process
results in biological phosphorus removal. Phosphate-accumulating organisms (PAOs) are recycled from
the aerobic stage in the mixed liquor to the anaerobic stage. In the aerobic stages that follow, PAOs
uptake large amounts of phosphorus (U.S. EPA, 2021). Biological phosphorus removal (BPR) and
Enhanced BPR (EBPR) reduce phosphorus in the wastewater but often are not able to remove as much
phosphorus as other treatment systems discussed in Table 8-10.

In all, 24 Detailed Questionnaire respondents (12 direct dischargers and 12 indirect dischargers) reported
implementing a treatment unit specifically for the purpose of phosphorus removal (U.S. EPA, 2023a,
2023b).

Table 8-10. List of Phosphorus Removal Treatment Units

Treatment Unit

Description

Chemical
Precipitation

Chemical precipitation involves adding chemicals that encourage coagulation and
promote particle adhesion to form large, visible clumps (i.e., flocculation) which
can then settle out of the wastewater. The sludge collected from the treatment
unit is moved to solids handling treatment units. MPP facilities use chemical
precipitation for phosphorus removal through the addition of metal salts, most
commonly alum or ferric chloride. MPP facilities may add chemicals to primary
treatment (e.g., DAF), biological treatment, or they may have a separate
treatment unit.

-------
Table 8-10. List of Phosphorus Removal Treatment Units

Treatment Unit

Description

Filtration

Filtration is the process of passing treated wastewater through a granular media,
(e.g., sand, mixed-media, or a filter cloth). This treatment provides further
clarification of wastewater by removing total suspended solids (TSS), nitrogen,
and phosphorus. The sludge collected from the filter is moved to solids handling
treatment units. Reverse osmosis is another type of filtration system, used to
remove small ions from water.

Ion Exchange

Ion exchange is a physical-chemical process in which ions swap between a
solution phase and a solid resin phase. Selective ion exchange targets specific
charged particles. This treatment can be used for nutrient removal and/or
disinfection.

8.4 Disinfection

MPP facilities implement additional treatment units beyond primary and biological treatment to achieve
pathogenic microorganism removal (i.e., disinfection). These additional processes are typically performed
after biological treatment. Table 8-11 presents a breakdown of the indirect dischargers and direct
dischargers that implement at least one treatment unit for disinfection as part of their on-site wastewater
treatment system. Table 8-12 includes counts by process type and annual production of facilities
reporting use of disinfection. Given the nature of the raw material at MPP facilities, disinfection is widely
used by direct dischargers and is more common at first processing facilities than at further processing
facilities. Table 8-13 describes disinfection treatment units commonly used in the MPP industry. MPP
facilities that reported performing disinfection typically use UV or chlorination/dechlorination.

Table 8-11. Number of Detailed Questionnaire Respondents That Implement a Disinfection Treatment

Unit by Discharge Type

Type of Discharge

Number of Respondents That
Implement Disinfection
Treatment

Total Number of Detailed
Questionnaire Respondents3

Indirect Dischargers

293

Direct Dischargers'3

Total

384

Source: U.S. EPA, 2023a, 2023b.

a — Facilities operating in a manner to achieve zero discharge are excluded from this presentation. See Section 8.7 for a
discussion on zero discharge facilities.

b — One facility discharging both to a receiving water (i.e., direct discharge) and to a POTW (i.e., indirect discharge) is classified
here as a direct discharger.

-------
Table 8-12. Number of Detailed Questionnaire Respondents That Implement a Disinfection Treatment

Unit by Processing and Annual Production

Type of Processing and Annual
Production

Number of Respondents That
Implement Disinfection
Treatment

Total Number of Detailed
Questionnaire Respondents3

Meat First Processors

<5M lbs. LWK/yr.

2

27

5 to <10M lbs. LWK/yr.

0

1

10 to <200M lbs. LWK/yr.

2

18

>200M lbs. LWK/yr.

20

52

Total Meat First

24

98

Meat Further Processors

<2M lbs. Finished Product/yr.

2

13

2 to <10M lbs. Finished Product/yr.

2

14

10 to 50M lbs. Finished Product/yr.

1

29

>50M lbs. Finished Product/yr.

4

56

Total Meat Further

9

112

Poultry First Processors

<5M lbs. LWK/yr.

2

5

5 to 30M lbs. LWK/yr.

0

4

>30 to <200M lbs. LWK/yr.

4

13

>200M lbs. LWK/yr.

39

90

Total Poultry First

45

112

Poultry Further Processors

<2M lbs. Finished Product/yr.

0

2

2 to <10M lbs. Finished Product/yr.

0

6

10 to 30M lbs. Finished Product/yr.

1

4

>30M lbs. Finished Product/yr.

1

22

Total Poultry Further

2

34

Independent Renderers

<5M lbs. Raw Material/yr.

0

0

5 to 30M lbs. Raw Material/yr.

0

3

>30 to <350M lbs. Raw Material/yr.

4

20

>350M lbs. Raw Material/yr.

2

5

Total Renderers

6

28

Industry Total

86

384

Source: U.S. EPA, 2023a, 2023b.

Abbreviations: M = million, lbs. = pounds, LWK = live weight killed, yr. = year.

a — Facilities operating in a manner to achieve zero discharge are excluded from this presentation. See Section 8.7 for a
discussion on zero discharge facilities.

70

-------
Table 8-13. List of Disinfection Treatment Units

Treatment Unit

Description

Ion Exchange

Chlorination/
Dechlorination

Chlorination is the process of adding chlorine to wastewater at a rate that results
in residual chlorine, which kills pathogens. Dechlorination is the process of
removing residual chlorine from disinfected wastewater prior to discharge into
the environment. Dechlorination is achieved by adding sulfur dioxide which reacts
with free chlorine.

Ultraviolet Light
(UV)

Ultraviolet light units use a suspended or submerged lamp that produces
ultraviolet light radiation. The radiation penetrates the wastewater to oxidize
organics and/or disinfect by inactivating pathogenic microorganisms.

Filtration

Filtration is the process of passing treated wastewater through a granular media,
(e.g., sand, mixed-media, or a filter cloth). Filtration methods that remove
particles as small as 100 nanometers (microfiltration), 10 nanometers
(ultrafiltration), or 1 nanometer (nanofiltration) can potentially perform
disinfection by filtering pathogens that are too large to pass through, though
Ultrafiltration and Nanofiltration are not typical in the MPP industry.

8.5 Solids Handling

Solids are typically generated from primary treatment (e.g., screens, DAF units, or other O&G separators)
and from biological treatment systems. In responses to the Detailed Questionnaire, 208 indirect
dischargers and 81 direct dischargers reported generating sludge from their wastewater treatment
system (U.S. EPA, 2023a, 2023b).

As discussed in Sections 8.1 through 8.4, solids can either be recycled for additional processing (such as
an activated sludge system) or wasted. Wasted solids removed by screens and the DAF may be rendered
if there aren't added chemicals. Wasted solids can be further treated at the MPP facility prior to disposal.
Table 8-14 lists treatment units typically used for solids handling. Detailed Questionnaire respondents
reported using centrifugation and filter presses. MPP facilities typically return wastewater from these
units either to the end-of-pipe treatment system or back into the solids handling treatment system.

Table 8-14. List of Solids Handling Treatment Units

Treatment Unit

Description

Gravity Thickening

Involves placing the sludge in a tank, often cylindrical, where gravity separates
the solids from the liquid.

Air Flotation

Uses air to encourage solids to float to the top of the tank, where they are
skimmed off the surface.

Anaerobic Digestion

Uses anaerobic bacteria to stabilize sludge, break down organic compounds
into biogas, and reduce pathogens and nutrients in the sludge.

Aerobic Digestion

Uses aerobic bacteria to stabilize sludge, breakdown organic compounds into
biogas, and reduce organic compounds and other nutrients in the sludge.

-------
Table 8-14. List of Solids Handling Treatment Units

Treatment Unit

Description

Filter Press

Involves pushing sludge between two continuous belts set one above the other.
The sludge passes through three process zones: the drainage zone (dewatering
by gravity), the pressure zone (dewatering by pressure applied by rollers on the
belts), and the shear zone (final dewatering through shear forces).

Centrifugation

Involves pumping sludge into a cone-shaped drum. The drum is rotated to
generate centrifugal forces that concentrate solids and cause them to press to
the walls of the drum. These solids are continuously removed by an auger, or
screw conveyer.

Table 8-15 presents a breakdown of indirect dischargers and direct dischargers that implement treatment
units for solids handling on site. Based on data reported in the Detailed Questionnaire, solids handling is
common among indirect dischargers and direct dischargers across all types of operations (U.S. EPA,
2023a, 2023b). Table 8-16 lists facilities reporting solids handling by process type and annual production.

Table 8-15. Number of Detailed Questionnaire Respondents That Implement Treatment for Solids

Handling by Discharge Type

Type of Discharge

Number of Respondents That
Implement Solids Handling

Total Number of Detailed
Questionnaire Respondents3

Indirect Dischargers

150

293

Direct Dischargers'3

Total

216

384

Source: U.S. EPA, 2023a, 2023b.

a — Facilities operating in a manner to achieve zero discharge are excluded from this presentation. See Section 8.7 for a
discussion on zero discharge facilities.

b — One facility discharging both to a receiving water (i.e., direct discharge) and to a POTW (i.e., indirect discharge) is classified
here as a direct discharger.

Table 8-16. Number of Detailed Questionnaire Respondents That Implement Treatment for Solids

Handling by Processing and Annual Production

Type of Processing and Annual
Production

Number of Respondents That
Implement Solids Handling

Total Number of Detailed
Questionnaire Respondents3

Meat First Processors

<5M lbs. LWK/yr.

5 to <10M lbs. LWK/yr.

10 to <200M lbs. LWK/yr.

>200M lbs. LWK/yr.

Total Meat First

Meat Further Processors

<2M lbs. Finished Product/yr.

2 to <10M lbs. Finished Product/yr.

10 to 50M lbs. Finished Product/yr.

>50M lbs. Finished Product/yr.

Total Meat Further

112

Poultry First Processors

<5M lbs. LWK/yr.

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Table 8-16. Number of Detailed Questionnaire Respondents That Implement Treatment for Solids

Handling by Processing and Annual Production

Type of Processing and Annual
Production

Number of Respondents That
Implement Solids Handling

Total Number of Detailed
Questionnaire Respondents3

5 to 30M lbs. LWK/yr.

>30 to <200M lbs. LWK/yr.

>200M lbs. LWK/yr.

Total Poultry First

112

Poultry Further Processors

<2M lbs. Finished Product/yr.

2 to <10M lbs. Finished Product/yr.

10 to 30M lbs. Finished Product/yr.

>30M lbs. Finished Product/yr.

Total Poultry Further

Independent Renderers

<5M lbs. Raw Material/yr.

5 to 30M lbs. Raw Material/yr.

>30 to <350M lbs. Raw Material/yr.

>350M lbs. Raw Material/yr.

Total Renderers

Industry Total

216

384

Source: U.S. EPA, 2023a, U.S. EPA, 2023b.

Abbreviations: M = million, lbs. = pounds, LWK = live weight killed, yr. = year.

a — Facilities operating in a manner to achieve zero discharge are excluded from this presentation. See Section 8.7 for a
discussion on zero discharge facilities.

Dried or further reduced sludge streams from these solids handling treatment units are typically disposed
of through land application, off-site landfilling, off-site composting, or incineration. Land application was
the most common disposal method reported in the Detailed Questionnaire by both indirect and direct
dischargers, followed by off-site landfilling.

8.6 High Chlorides Wastewater Treatment

As discussed in Section 3.4, under the authority of Clean Water Act (CWA) Section 308, the EPA collected
treatment information from MPP facilities with potentially high chlorides wastestreams. The EPA's data,
which are limited, demonstrate that most MPP facilities generating high chlorides wastestreams collect
and commingle it with other process wastewaters. In these cases, the high chlorides wastewater is
diluted, and the commingled wastewaters are then treated using the existing end-of-pipe wastewater
treatment system prior to discharge. However, these treatment systems are not designed to remove
chlorides, which passthrough the system and are ultimately discharged.

The EPA also found that some facilities are able to segregate their high chlorides wastewater using, for
example, dedicated floor drains and/or separate process lines/buildings. This allows for separate handling
of high-strength chlorides-laden wastewater.

Some MPP facilities operating high chlorides processes that have available space and are located in
climates with net evaporation operate a brine evaporation lagoon, which uses an impoundment to allow
the water to naturally evaporate while the solids precipitate. Periodically the solids in the lagoon are
cleaned out to extend the lifetime of the system and the solids are disposed of. In other cases, the lagoon
is allowed to completely fill with salt and is then capped and closed (U.S. EPA, 2023c).

-------
Some facilities use various types of mechanical evaporation systems, which have smaller footprints and
can be used in any type of climate. Submerged combustion evaporators, which use a heat exchanger to
evaporate water by combusting fuel and releasing the heat directly into the water, have had limited
success. More often, MPP facilities that use mechanical evaporation systems for chlorides use forced
circulation evaporators, which use steam with a heat exchanger and condenser to evaporate water and
recover solids (see Figure 8-4). The concentrated brine (condensate) is recirculated to the preheater and
a portion of the brine is either disposed of or sent on to a crysta 11 ize r to create a solid salt wastestream.

Steam

High chlorides
wastewater

Preheater

Evaporator

To Disposal, crystallization, or reuse

Condenser

Brine

Condensate

Figure 8-4. Process Flow Diagram of a Forced Circulation Evaporator System

Some MPP facilities dispose of their high chlorides wastewater using deepwell injection via Class I wells.
Class I wells are used to inject hazardous and nonhazardous wastes into deep, confined rock formations,
typically thousands of feet below the lowermost underground source of drinking water. However,
deepwell injection is not allowed in some states and may not be an option for many facilities.

Lastly, some MPP facilities transfer their high chlorides wastewater to off-site wastewater treatment or to
a renderer for treatment. See the Summary of High Chlorides Wastewater Data memorandum for more
information on treatment technologies for this wastestream (U.S. EPA, 2023c).

8.7 Zero Discharge

A number of MPP facilities that generate wastewater are categorized as zero dischargers, meaning they
operate in a manner that achieves zero discharge (e.g., the facility does not discharge directly to surface
waters or to a POTW). MPP facilities that achieve zero discharge do so through land application of their
treated wastewater, either on site or off site; the majority of these MPP facilities treat their wastewater
before land application. Other facilities achieve zero discharge through complete reuse or by disposing of
wastewater through subsurface injection or septic tanks. Of the 510 Detailed Questionnaire respondents,
126 operate in a manner that achieves zero discharge of MPP process wastewater. Of these, 74 facilities
treat their wastewater prior to reuse or final disposal (U.S. EPA, 2023a, 2023b). Table 8-17 presents
common treatment units implemented by these zero discharging MPP facilities.

Table 8-17. Common Treatment Units for Zero Discharging MPP Facilities

Purpose of Treatment
Unit

Number of Facilities
Implementing at Least
One Treatment Unit

Common Treatment Units

Primary Treatment

Screens, DAF, equalization tank or pond

Biological Treatment

Anaerobic lagoon,3 aerobic basin or lagoon, anoxic
tank or basin, activated sludge, SBR, MBR

-------
Table 8-17. Common Treatment Units for Zero Discharging MPP Facilities

Purpose of Treatment
Unit

Number of Facilities
Implementing at Least
One Treatment Unit

Common Treatment Units

Nutrient Removal

Anoxic pond or lagoon, DAF, SBR

Phosphorus Removal

N/A

Disinfection

Chlorination, UV

Solids Handling

Biological system, DAF, O&G separation, screens

Source: U.S. EPA, 2023a, 2023b.

Note: Facilities may implement multiple treatment units for different purposes.

a — 12 facilities operate anaerobic lagoons, which is a biological treatment unit that may be used as a primary treatment unit for
BOD pretreatment.

8.8 Pollution Prevention and Wastewater Reduction Practices

Process wastewater reuse can occur within the processing facility, prior to any wastewater treatment, or
after treatment but prior to discharge. Based on responses to the Detailed Questionnaire and site visits,
over 20 percent of the 510 MPP facilities that responded to the wastewater treatment section of the
Detailed Questionnaire reported reusing or recycling a portion of the untreated wastewater within the
facility. MPP facilities use screens in the processing area to treat wastewater from late-stage processing
operations (e.g., rinsing or washing meat prior to packaging or chillers) so that it can be reused at initial-
stage operations (e.g., bird washing after slaughter, gizzard machine, or neck breaker) (U.S. EPA, 2022a,
2022b, 2022c, 2023b). For example, the Tyson Foods Inc. Glen Allen facility reused over 40 percent of its
treated wastewater in this way (U.S. EPA, 2022c). Other MPP facilities reported reusing wastewater for
process operations, such as inside-outside bird washing, removing feathers and offal from poultry, or
priming wastewater treatment systems. In the Detailed Questionnaire and during site visits, MPP facilities
reported recycling treated effluent for cleaning slaughter equipment, trucks/trailers, cages, loading dock
areas, and wastewater treatment equipment. Some MPP facilities also recycle a portion of their process
wastewater for cooling towers and other forms of noncontact cooling water (U.S. EPA, 2022d, 2022e,
2022f, 2023b).

Many MPP facilities incorporate flow minimization and wasteload reduction practices to minimize the
amount of process wastewater generated. In the Detailed Questionnaire, the most reported techniques
to reduce wastewater generation are collecting solids or residual product prior to cleaning operations or
performing dry clean up. Other common techniques include using flow-reduction nozzles, spray nozzles
that are sized to control water use, high-pressure/low-volume nozzles, and/or controls that regulate
supply line pressure. Many facilities also commonly shut off all unnecessary water flow during work
breaks or use automatic flow shutoff valves. Some MPP facilities also reported implementing process
changes and techniques to reduce wastewater generation and/or contain pollution. For example, facilities
reported practices such as confining bleeding to reduce the amount of cleaning necessary, providing
sufficient bleed time to reduce the level of pollutants in the wastewater, and/or transporting collectable
blood to rendering tanks instead of commingling it with cleaning water (U.S. EPA, 2023b).

Based on responses to the Detailed Questionnaire, approximately half of the 510 MPP facilities
implement water conservation, environmental management, monitoring, or pollutant prevention and
wastewater management practices other than recycling or reuse of process wastewater. In the Detailed
Questionnaire, the most reported pollution prevention techniques by these facilities were training
employees on good water management practices; performing frequent, regular maintenance on
equipment; and/or using dikes, curbs, and other control measures to contain leaks/spills. Over a third of
MPP facilities that implement pollution prevention practices reported maintaining a water treatment and
reuse system. A third of these facilities reported using smaller quantities of water in scalder/chillers (U.S.
EPA, 2023b).

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8.9 References

1.	Metcalf & Eddy, Inc. 2003. Wastewater Engineering: Treatment, Disposal, and Reuse. 4th ed. DCN
MP00334.

2.	U.S. EPA. 2009. Nutrient Control Design Manual State of Technology Review Report (January).
EPA/600/R-09/012. Available online at: https:://www.epa.gov/siites/c	:iles/2019-

0 2/d oc ii in e in ts/n u t ir ii e in t-co in t iro II-d e s ii gn - in a in u a II -sta te ~tec h. pd f.

3.	U.S. EPA. 2021. Innovative Nutrient Removal Technologies (August). EPA 830-R-01-001. Available
online at: https:://www.epa.gov/system/fiiles/documents/2022-08/iinnovatiive-nutiriient-reinovaI-
technologies-report-082721.pdf

4.	U.S. EPA. 2022a. Tyson Farms, Inc., Albertville Site Visit Report (October). DCN MP00144.

5.	U.S. EPA. 2022b. Tyson Farms, Inc., Blountsville Site Visit Report (October). DCN MP00142.

6.	U.S. EPA. 2022c. Tyson Foods, Inc., Glen Allen Site Visit Report (October). DCN MP00139.

7.	U.S. EPA. 2022d. Abbyland Foods Abbotsford, Wl Site Visit Report (July). DCN MP00276.

8.	U.S. EPA. 2022e. Darling Ingredients, Hamilton Site Visit Report (July). DCN MP00135.

9.	U.S. EPA. 2022f. Tyson Foods, Inc., Temperanceville Site Visit Report (October). DCN MP00140.

10.	U.S. EPA. 2023a. Meat and Poultry Products (MPP) Profile Methodology Memorandum (November).
DCN MP00306.

11.	U.S. EPA. 2023b. U.S. EPA MPP Questionnaires Memorandum (November). DCN MP00234.

12.	U.S. EPA. 2023c. Summary of High Chlorides Wastewater Data (November). DCN MP00305.

76

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9. Technology Systems and Regulatory Options

Using treatment technologies applicable to wastewater generated from meat and poultry products (MPP)
process operations (see Section 8), the U.S. Environmental Protection Agency considered certain
technology systems as the basis for the proposed MPP effluent limitations guidelines and standards
(ELGs). The EPA then developed regulatory options (i.e., combinations of the technology systems and
subcategories that were under consideration) for each level of control. This section describes the EPA's
proposed technology systems and regulatory options for the proposed rulemaking.

The EPA is proposing ELGs based on six levels of control, as appropriate:

• Best Practicable Control Technology Currently Available (BPT).

• Best Conventional Pollutant Control Technology (BCT).

• Best Available Technology Economically Achievable (BAT).

• New Source Performance Standards (NSPS).

• Pretreatment Standards for Existing Sources (PSES).

• Pretreatment Standards for New Sources (PSNS).

BPT, BCT, BAT, and NSPS limitations regulate only those sources that discharge effluent directly into
waters of the United States (i.e., direct dischargers). PSES and PSNS limitations regulate only those
sources that discharge indirectly through discharge to Publicly Owned Treatment Works (POTWs) (i.e.,
indirect dischargers).

Section 9.1 presents the technology systems considered for MPP process wastewater treatment, and
Section 9.2 summarizes the EPA's proposed regulatory options as well as the selected regulatory option.
The EPA's technology systems incorporate pollutant control technologies that are used in the MPP
industry, that minimize water use, and that result in minimal non-water quality environmental impacts.
While the EPA establishes ELGs based on a particular set of in-process and/or end-of-pipe treatment
technologies, the EPA does not require a discharger to use these technologies. Rather, the selection of
technologies used to treat wastewater is left to the discretion of the individual facility operator, as long as
the facility can achieve the numeric discharge limitations and standards, as required by Section 301(b) of
the Clean Water Act (CWA). Direct and indirect dischargers can use any combination of process
modifications, in-process technologies, and end-of-pipe wastewater treatment technologies to achieve
the ELGs.

9.1 Wastewater Treatment Technology Systems

MPP process wastewater includes any water that, during processing, comes into direct contact with any
raw material, intermediate product, finished product, byproduct, or waste product. MPP process
wastewater includes wastewater generated in MPP processing areas and animal holding areas. This
section presents the technology systems considered for direct dischargers (Section 9.1.1) and indirect
dischargers (Section 9.1.2) of MPP process wastewater.

9.1.1 Direct Dischargers of MPP Process Wastewater

Table 9-1 presents two technology systems the EPA considered for MPP process wastewater treatment
for direct dischargers. Direct Wastewater Treatment Technology System Targeting Phosphorus and Partial
Denitrification (P with Partial N Treatment for Direct Dischargers) and Direct Wastewater Treatment
Technology System Targeting Phosphorus and Full Denitrification (P with Full N Treatment for Direct
Dischargers) use the same treatment units. However, P with Full N Treatment for Direct Dischargers is
designed to achieve full denitrification in the biological treatment system, compared to partial

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denitrification in P with Partial N Treatment for Direct Dischargers, because of a longer solids retention
time and larger anoxic zone. Therefore, P with Full N Treatment for Direct Dischargers achieves lower
nitrogen levels compared to P with Partial N Treatment for Direct Dischargers. Both systems are similar to
the current technology basis for direct dischargers, with the addition of phosphorus removal.

Table 9-1. Technology Systems Considered for Direct Dischargers

Treatment Process

Treatment Unit

P with Partial N
Treatment for Direct
Dischargers

P with Full N
Treatment for Direct
Dischargers

Primary Treatment
for Solids Removal

Screen/Grit Removal

Dissolved Air Flotation (DAF)
for Oil and Grease (O&G)
Removal

Biochemical
Oxygen Demand
(BOD)

Pretreatment

Anaerobic Lagoon

Biological
Treatment for
Nitrification and
Denitrification

Activated Sludge Biological
Treatment

X - System has shorter
retention time and
smaller anoxic zone.
Performs partial
denitrification.

X - System has longer
retention time and
larger anoxic zone.
Performs full
denitrification.

Secondary Clarifier

Phosphorus
Removal

Chemical Phosphorus
Removal Using Ferric Chloride

Filtration

Sand Filtration3

Disinfection

Chlorination/Dechlorination

Solids Handling

Gravity Thickener

Filter Press

Hauling and Landfill

a — Sand filtration is not part of the treatment system for rendering facilities.

9.1.2 Indirect Dischargers of MPP Process Wastewater

Table 9-2 presents two technology systems the EPA considered for indirect dischargers (i.e., PSES and
PSNS) of MPP process wastewater. Indirect Wastewater Treatment Technology System Targeting
Conventionals (BOD, O&G, and total suspended solids (TSS)) (BOD, O&G, and TSS Treatment for Indirect
Dischargers) includes only primary treatment for solids removal and assumes other pollutants will be
removed at a POTW. Indirect Wastewater Treatment Technology System Targeting Phosphorus and Full
Denitrification (P with Full N Treatment for Indirect Dischargers) is similar to P with Full N Treatment for
Direct Dischargers, presented in the previous section, as both systems include the same treatment units
and are designed to achieve nitrification and full denitrification.

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Table 9-2. Technology Systems Considered for Indirect Dischargers

Treatment Process

Treatment Unit

BOD, O&G, and TSS
Treatment for Indirect
Dischargers

P with Full N
Treatment for
Indirect Dischargers

Primary Treatment
for Solids Removal

Screen/Grit Removal

DAF for O&G Removal

BOD Pretreatment

Anaerobic Lagoon

Biological
Treatment for
Nitrification and
Denitrification

Activated Sludge Biological
Treatment

Secondary Clarifier

Phosphorus
Removal

Chemical Phosphorus
Removal using Ferric Chloride

Filtration

Sand Filtration3

Solids Handling

Gravity Thickener

Filter Press

Hauling and Landfill

Abbreviations: NA = not applicable.

a -Sand Filtration is not part of the treatment system for rendering facilities.

9.1.3 High Chlorides Wastewater Discharges

The EPA evaluated treatment for discharge of chlorides by two technologies, both achieving zero
discharge of pollutants. The technology basis is segregation of high chlorides wastewaters from other
process wastewater streams and treatment via either evaporation or disposal of the wastewater.

9.2 Regulatory Options

The EPA evaluated three regulatory options for the proposed rulemaking for MPP process wastewater. In
developing these regulatory options, the EPA aimed to reduce pollutant discharges to surface waters,
reduce and/or eliminate interference and passthrough at POTWs receiving MPP wastewater, and
establish effluent limitations and pretreatment standards based on technologies that are available and
affordable to the industry, while minimizing impacts to small businesses.

Table 9-3 and Table 9-4 summarize the technology systems that are the bases for the three regulatory
options for direct dischargers and indirect dischargers, respectively. The regulatory options address each
subcategory in the current ELGs as the EPA is not proposing any changes to the current subcategories.
The EPA is proposing no new regulations for Subcategory E, Small Processors. The technology system for
each regulatory option varies by the facility production volume. Each regulatory option incrementally
increases the number of facilities impacted by the proposed ELG.

For direct dischargers, the EPA proposes to revise BAT limitations and NSPS for nitrogen and phosphorus.
For indirect dischargers, under Regulatory Option 1, the EPA proposes to establish PSES and PSNS for
BOD, O&G, and TSS. Under Regulatory Options 2 and 3, the EPA would include phosphorus and nitrogen
removal for some indirect dischargers.

For high chlorides wastewater, the EPA evaluated requiring zero discharge via evaporation for all facilities
with high chlorides processes producing more than 5 million pounds per year.

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Table 9-3. Regulatory Options for Direct Dischargers (Level of Control includes BAT and NSPS) for MPP

Process Wastewater

Subcategory

Units for
Facility
Production

Facility
Production

Regulatory
Option 1

Regulatory
Option 2

Regulatory
Option 3

Meat First
Processors
(Subcategories
A through D)

M lbs.
LWK/yr.

>10 and <20

NA

NA

P with Partial N
Treatment for
Direct
Dischargers

>20 and <50

NA

NA

P with Full N
Treatment for
Direct
Dischargers

>50

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

Small
Processors
(Subcategory
E)

M lbs.
Finished
Product/yr.

All

NA

NA

NA

Meat Further

Processors
(Subcategories
F through 1)

M lbs.
Finished
Product/yr.

>10 and <20

NA

NA

P with Partial N
Treatment for
Direct
Dischargers

>20 and <50

NA

NA

P with Full N
Treatment for
Direct
Dischargers

>50

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

Renderers
(Subcategory

J)

M lbs. Raw
Material/yr.

>10 and <20

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

P with Partial N
Treatment for
Direct
Dischargers

>20

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

80

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Table 9-3. Regulatory Options for Direct Dischargers (Level of Control includes BAT and NSPS) for MPP

Process Wastewater

Subcategory

Units for
Facility
Production

Facility
Production

Regulatory
Option 1

Regulatory
Option 2

Regulatory
Option 3

Poultry First
Processors
(Subcategory

K)

M lbs.
LWK/yr.

>10 and <20

NA

NA

P with Partial N
Treatment for
Direct
Dischargers

>20 and <100

NA

NA

P with Full N
Treatment for
Direct
Dischargers

>100

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

Poultry
Further
Processor
(Subcategory
L)

M lbs.
Finished
Product/yr.

>7 and <10

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

NA

>10 and <20

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

P with Partial N
Treatment for
Direct
Dischargers

>20

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

P with Full N
Treatment for
Direct
Dischargers

Abbreviations: lbs. = pounds, LWK = live weight killed, M = million, NA = not applicable, yr. = year.

81

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Table 9-4. Regulatory Options for Indirect Dischargers (Level of Control includes PSES and PSNS) for

MPP Process Wastewater

Subcategory

Units for
Facility
Production

Facility
Production

Regulatory
Option 1

Regulatory
Option 2

Regulatory
Option 3

Meat First
Processors
(Subcategories
A through D)

M lbs.
LWK/yr.

>5 and <30

NA

NA

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

>30 and <50

NA

NA

P with Full N
Treatment for
Indirect
Dischargers

>50 and <200

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

P with Full N
Treatment for
Indirect
Dischargers

>200

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

P with Full N
Treatment for
Indirect
Dischargers

P with Full N
Treatment for
Indirect
Dischargers

Small
Processors
(Subcategory
E)

M lbs.
Finished
Product/yr.

All

NA

NA

NA

Meat Further

Processors
(Subcategories
F through 1)

M lbs.
Finished
Product/yr.

>5 and <30

NA

NA

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

>30 and <50

NA

NA

P with Full N
Treatment for
Indirect
Dischargers

>50

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

P with Full N
Treatment for
Indirect
Dischargers

82

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Table 9-4. Regulatory Options for Indirect Dischargers (Level of Control includes PSES and PSNS) for

MPP Process Wastewater

Subcategory

Units for
Facility
Production

Facility
Production

Regulatory
Option 1

Regulatory
Option 2

Regulatory
Option 3

Renderers
(Subcategory

J)

M lbs. Raw
Material/yr.

>5 and <10

NA

NA

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

>10 and <30

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

>30 and <350

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

P with Full N
Treatment for
Indirect
Dischargers

>350

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

P with Full N
Treatment for
Indirect
Dischargers

P with Full N
Treatment for
Indirect
Dischargers

Poultry First
Processors
(Subcategory

K)

M lbs.
LWK/yr.

>5 and <30

NA

NA

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

>30 and <100

NA

NA

P with Full N
Treatment for
Indirect
Dischargers

>100

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

P with Full N
Treatment for
Indirect
Dischargers

Poultry
Further
Processor
(Subcategory
L)

M lbs.
finished
product/yr.

>5 and <7

NA

NA

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

>7 and <30

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

>30

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

BOD, O&G, and
TSS Treatment
for Indirect
Dischargers

P with Full N
Treatment for
Indirect
Dischargers

Abbreviations: lbs. = pounds, LWK = live weight killed, M = million, NA = not applicable, yr. = year.

83

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Table 9-5 presents the number of direct dischargers and indirect dischargers by regulatory option. Section
9.2.1 discusses the selected regulatory option in more detail.

Table 9-5. Number of MPP Facilities by Regulatory Option

Regulatory Option

Number of Direct Dischargers

Number of Indirect Dischargers

Option 1

125

719

Option 2

125

719 (conventional)
143 of 719 (TN and TP)

Option 3

133

1,485

9.2.1 Selected Regulatory Option

The EPA selected Regulatory Option 1 as the preferred option for the proposed rulemaking. For an
explanation of the rationale for the preferred option, see Section VII.C of the Preamble. For an
explanation of the rationale for rejecting Options 2 and 3 as the preferred option, see Section VII.E of the
Preamble.

Under Regulatory Option 1, most facilities would face no new limitations because their production would
fall below the proposed size thresholds. For details on the number of facilities and small businesses
impacted by the preferred option, see Section VILA of the Preamble. See Section XVI.C of the Preamble
for EPA's discussion on impacts to small businesses. For more information on the costs and benefits
associated with the preferred option, including pollutant discharge reductions, see Section LA of the
Preamble.

As described in Preamble Section VII.C.3, the EPA did not include any provisions for high chlorides
wastewater treatment in the selected option. Instead, the EPA is soliciting comment on including
requirements for chlorides in the final rule.

9.3 BPT Analysis for Conventional Pollutants

As part of the proposed rule, the EPA evaluated technologies to control conventional pollutants. CWA
Section 304(b) defines two levels of control for conventional pollutants, BPT and BCT. CWA Section
304(a)(4) designates the following as conventional pollutants: BOD, TSS, fecal coliform, pH, and any
additional pollutants defined by the Administrator as conventional. The Administrator designated O&G as
an additional conventional pollutant (44 FR 44501 (July 30, 1979) and 40 CFR 401.16).

The current MPP ELGs include BPT requirements for BOD, O&G, and TSS for direct discharging facilities.
The EPA is proposing additional requirements for BOD, O&G, and TSS that would apply to indirect
discharging facilities and be based on screening/grit removal and DAF treatment. The proposed rule
would revise BPT limitations for conventional pollutants for indirect dischargers only and consider
whether more stringent BCT limitations pass the two-part BCT cost test for indirect dischargers. A BPT
Wholly Disproportionate Cost Test was performed for all direct and indirect facilities that would be
required to control conventional pollutants under the three regulatory options.

The EPA estimated facility-specific costs and loadings for the use of DAF technology for BOD, O&G, and
TSS Treatment for Indirect Dischargers. This level of technology is already in place for direct discharging
facilities, reflecting the existing rule's BPT, BCT, and BAT requirements, but it would be a new
requirement for indirect discharging facilities. The CWA requires that the EPA consider "the total cost of
application of technology in relation to the effluent reduction benefits to be achieved from such
application," and these costs should not be wholly disproportionate to the corresponding effluent
reduction benefits.

After reviewing the annualized after-tax technology costs and associated pollutant load reductions for
individual subcategories of facilities and the industry, the EPA determined that, under BPT, there would

-------
be significant reductions in conventional pollutant loading for each subcategory and for the industry as a
whole, across all three options. Based on these results, the EPA considers BPT costs to not be wholly
disproportionate to the corresponding effluent reduction benefits.

9.4 BCT Analysis for Conventional Pollutants

As part of the proposed rule, the EPA also considered establishing BCT requirements for BOD, O&G, and
TSS for indirect dischargers based on screening/grit removal, DAF (for O&G treatment), anaerobic lagoon
(for BOD pretreatment), biological treatment with activated sludge to achieve nitrification and full
denitrification, chemical phosphorus removal with ferric chloride, sand filtration, and solids handling
(gravity thickener, filter press, hauling/landfilling).

The EPA evaluated the reasonableness of BCT candidate technologies (those that remove more
conventional pollutants than BPT) by applying a two-part cost reasonableness test. The two-part test
requires: (1) the cost per pound of conventional pollutant removed by dischargers in upgrading from BPT
limitations to the candidate BCT option must be less than the cost per pound of conventional pollutant
removed by upgrading POTWs from secondary treatment to advanced secondary treatment ("the POTW
test"); and (2) an assessment of industry costs per pound removed in upgrading from BPT to BCT relative
to the costs per pound removed in going from no treatment to BPT, followed by a comparison of that
ratio to the analogous ratio for POTWs ("the industry cost effectiveness test").

9.4.1 Methodology

The CWA amendments that created BCT also specify that the cost associated with BCT limitations must be
"reasonable" with respect to the effluent reductions. Accordingly, the EPA developed the "BCT
Methodology" to answer the question of whether it is "cost-reasonable" for industry to control
conventional pollutants at a level more stringent than already required by BPT effluent limitations
guidelines. The BCT Methodology was originally published on August 29, 1979, at the same time that the
EPA promulgated BCT effluent limitations guidelines for 41 industry subcategories (44 FR 50732). The
methodology compares the costs of removing the conventional pollutants for a candidate BCT technology
within a particular industry segment to the costs of removal for an average-sized POTW.

A number of industries and industry associations challenged the methodology, and, in 1981, the United
States Court of Appeals for the Fourth Circuit remanded it to the Agency, directing the EPA to include an
assessment of the cost-effectiveness of industry conventional pollutant removal as part of its evaluation
of cost reasonableness, in addition to the POTW Test. The EPA proposed a revised BCT Methodology in
1982 (47 FR 49176) that addressed the industry cost effectiveness test (the Industry Cost Test, or
"second" test), limiting it to the conventional pollutants BOD and TSS. The EPA proposed to base the
POTW Benchmark on model facility costs in a 1984 notice (49 FR 37046).

The final BCT Methodology was published on July 9, 1986 (51 FR 24974). This methodology maintained
the basic approach of the 1982 proposed BCT Methodology and adopted the use of the new model
POTW data. The published guidelines state that the BCT cost analysis "...answers the question of whether
it is 'cost reasonable' for industry to control conventional pollutants at a level more stringent than BPT
effluent limitations already require."

The 1986 BCT Methodology uses both the POTW Test and the Industry Cost Test to establish cost-
reasonableness.

If a candidate technology is feasible and passes both the POTW Test and the Industry Cost Test, then the
technology system becomes the basis for setting BCT effluent limitations. Alternatively, if no candidate
technology more stringent than BPT passes both tests, then BCT effluent limitations are set equal to BPT
effluent limitations (51 FR 24,976).

The results from each of these tests are compared with established benchmarks. The POTW Benchmark
used in the 1986 Federal Register Notice (FRN) is $0.25 per pound of BOD and TSS removed (in 1976

85

-------
dollars) for industries where cost per pound is based on long-term performance data. The 1986 FRN
Industry Cost Benchmark is 1.29 (a unitless ratio). These benchmarks were developed using only BOD and
TSS pollutant removals (see 51 FR 24974 for more information on these two cost tests and benchmarks).
The EPA assumes that O&G benchmarks (POTW and Industry Cost benchmarks) would be similar to those
for BOD and TSS.

POTW Test

The POTW Test requires "a comparison of the cost of removing additional pounds of conventional
pollutants by industrial dischargers to the cost of conventional pollutant removals by a POTW" (51 FR
24980). Specifically, the POTW Test compares two factors: (1) the incremental cost per pound of
conventional pollutant removal for the industry to increase treatment from BPT to BCT; and (2) the
incremental cost of conventional pollutant removal for a POTW to upgrade from secondary treatment to
advanced secondary treatment (i.e., the POTW Benchmark, which the EPA estimated is $0.25 per pound
in 1976 dollars). If the industrial incremental cost of removal exceeds the POTW Benchmark, the
industrial treatment technology candidate fails the POTW cost test.

Industry Cost Test

The Industry Cost Test compares two calculated values: the Industry Cost Ratio and the Industry Cost
Benchmark.

The EPA computes the Industry Cost Ratio using two incremental costs. The first incremental cost is the
cost per pound of conventional pollutant removed by the candidate BCT relative to BPT. The second
incremental cost is the cost per pound of conventional pollutant removed by BPT relative to no treatment
(i.e., raw wasteload). Historically, this Industry Cost Ratio has been calculated using Equation 9-1:

(iCost of BCT — Cost of BPT) -h (Pollutant Removal of BCT — Pollutant Removal of BPT) Equation
Cost of BPT -h Pollutant Removal of BPT -9-1

Next, the EPA calculates the Industry Cost Benchmark. The Industry Cost Benchmark is the ratio of two
other incremental costs: the cost per pound to upgrade a POTW from secondary treatment to advanced
secondary treatment (the POTW Benchmark) divided by the cost per pound to initially achieve secondary
treatment. The Industry Cost Benchmark is calculated using Equation 9-2:

POTW Benchmark Equation

Cost of Secondary Treatment -h Pollutant Removal of Secondary Treatment

The EPA calculated the Industry Cost Benchmark using the same model POTW data and flow-based
weighting factors that were used to calculate the POTW Benchmark. The Industry Cost Benchmark
established in the 1986 FRN for BOD and TSS is 1.29 (see 51 FR 24974).

To pass the Industry Cost Test, the Industry Cost Ratio for the subcategory must be lower than the
Industry Cost Benchmark.

9.4.2 Analysis
POTW Test

To evaluate the POTW Test, the EPA converted the 1986 POTW Benchmark from 1976 dollars to 2022
dollars to be consistent with the cost basis supporting the proposed MPP ELGs. The EPA used the 2022
RSMeans Historical Cost Indices (Gordian, 2023) and Equation 9-3 to calculate the POTW Benchmark (in
2022$):

-------
IyicIgx fov 2022

—- x POTW Benchmark (in 1976$) Equation 9-3

Index for 1976

Where: POTW Benchmark =$0.25(1976$)

Index for 2022 = 276.9

Index for 1976 =46.9

In 2022 dollars, the =$1,476
POTW Benchmark

To estimate the Industry Incremental Removal Cost, the EPA considered the cost and pollutant removal
for the candidate technologies considered. As described in the Preamble, the EPA is comparing the cost
of upgrading from the candidate BPT (based on screening/grit removal followed by DAF treatment) to
BCT based on biological removal including full denitrification and chemical precipitation with filtration as
described for BAT. For all indirect discharging facilities, the EPA estimated BPT and BCT costs and
pollutant removals as follows:

• Cost of BPT: Costs estimated for BOD, O&G, and TSS Treatment for Indirect Dischargers, which
includes screening/grit removal, DAF, and solids handling. See Compliance Cost Methodology for the
Meat and Poultry Products Proposed Rulemaking (U.S. EPA, 2023a).

• Pollutant Removal of BPT: Estimated as the BOD, O&G, and TSS removals for BOD, O&G, and TSS
Treatment for Indirect Dischargers. See Pollutant Loadings and Removals Methodology for Meat and
Poultry Products Proposed Rulemaking (U.S. EPA, 2023b).

• Cost of BCT: Costs estimated for P with Full N Treatment for Indirect Dischargers, which includes
screening/grit removal, DAF, anaerobic lagoon, biological treatment with activated sludge to achieve
nitrification and full denitrification, chemical phosphorus removal with ferric chloride, sand filtration,
and solids handling (gravity thickener, filter press, hauling/landfilling). See Compliance Cost
Methodology for the Meat and Poultry Products Proposed Rulemaking (U.S. EPA, 2023a).

• Pollutant Removal of BCT: Estimated as the BOD, O&G, and TSS removals for P with Full N Treatment
for Indirect Dischargers. See Pollutant Loadings and Removals Methodology for Meat and Poultry
Products Proposed Rulemaking (U.S. EPA, 2023b).

The EPA evaluated the Industry Incremental Removal Cost for each regulatory option and subcategory.
For each regulatory option, the EPA calculated the total incremental removal cost based on the
population of indirect discharging facilities anticipated to upgrade existing wastewater treatment. The
EPA calculated the Industry Incremental Removal Cost to upgrade from BPT to BCT using Equation 9-4:

Cost of BCT — Cost of BPT ^ .

' ' Equation 9-4

Pollutant Removal of BCT — Pollutant Removal of BPT

For each regulatory option and subcategory, the EPA compared the Industry Incremental Removal Cost to
the POTW Benchmark. Any incremental removal cost greater than $1,476 per pound fails the POTW Test.
Any regulatory option and subcategory with an incremental cost lower than the POTW Benchmark passes
and is further evaluated using the Industry Cost Test.

As noted in Section 9.4.1, the Industry Cost Benchmark is 1.29. This benchmark is unitless and not tied to
a cost year. For all regulatory options and subcategories passing the POTW Test, the EPA calculated the
Industry Cost Ratio using the Industry Cost Ratio equation (Equation 9-1):

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(iCost of BCT — Cost of BPT) -h (Pollutant Removal of BCT — Pollutant Removal of BPT) Equation

9-1

Cost of BPT -h Pollutant Removal of BPT

The Industry Cost Ratio is the Industry Incremental Removal Cost divided by the cost per pound removed
of BPT. To pass the Industry Cost Test, the Industry Cost Ratio must be lower than 1.29.

Results

The EPA evaluated the results of both tests (POTW Test and Industry Cost Test) by regulatory option and
subcategory, except Subcategory E, to determine if BCT requirements could be established. Table 9-6
presents the cost data and removals data for the population of facilities impacted by Regulatory Option 1
(the preferred option) for all subcategories considered. Table 9-7 presents the results of both BCT cost
test components for Regulatory Option 1. See Appendix A for results based on the population of facilities
impacted by Regulatory Options 2 and 3.

Table 9-6. Incremental Costs and Conventional Pollutant Removals—Regulatory Option 1

Level of Control

Annualized

Costs
(M 2022$,
Post-Tax)

Total
Incremental
Removals
(M lbs.)

Industry
Incremental
Removal Cost
(2022$/lbs.)

Subcategories A-D

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$1.63

12.8

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$162

627

$0.26

Subcategories F-l

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$2.11

5.98

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$162

263

$0.62

Subcategory J

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$0.64

2.90

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$51.50

177

$0.29

Subcategory K

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$6.64

164

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$219

377

$1.00

Subcategory L

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$1.42

22.0

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$68.90

73.0

$1.32

Source: U.S. EPA, 2023b, 2023c.

Abbreviations: M = million, lbs. = pounds.

Note: Values presented as three significant figures.

88

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Table 9-7. BCT Cost Test Results—Regulatory Option 1

Subcategory

Industry
Incremental
Removal Cost
(2022$/lbs.)

POTW
Benchmark
(2022$/lbs.)

Industry
Cost Ratio

Industry Cost
Benchmark

Test 1
Results

A-D

$0.26

$1,476

2.04

1.29

Pass

Fail

F-l

$0.62

$1,476

1.76

1.29

Pass

Fail

$0.29

$1,476

1.33

1.29

Pass

Fail

$1.00

$1,476

24.5

1.29

Pass

Fail

$1.32

$1,476

20.5

1.29

Pass

Fail

Abbreviations: lbs. = pounds.

Note: Values presented as three significant figures.

When considering how to establish limitations for conventional pollutants for indirect dischargers, the
EPA evaluated the BCT cost test by comparing the BOD, O&G, and TSS Treatment for Indirect Dischargers
to the P with Full N Treatment for Indirect Dischargers. Both are pretreatment technologies. In both
cases, wastewater from the MPP facilities will be further treated at a POTW (not directly discharged to
surface water). Although the cost to upgrade MPP treatment from BOD, O&G, and TSS Treatment for
Indirect Dischargers to the P with Full N Treatment for Indirect Dischargers is not directly comparable to
the upgrade cost of a POTW, which discharges to a surface water, information from the comparison can
be used to evaluate "the cost of removing additional pounds of conventional pollutants by industrial
dischargers to the cost of conventional pollutant removals by a POTW" (51 FR 24980). All MPP
subcategories evaluated did pass the POTW Test, but the EPA acknowledges that these treatment
technology costs for indirect dischargers may not be directly comparable to what it would cost direct
dischargers to perform the same or similar treatment. For example, a facility would need to install
additional treatment beyond screening/grit removal and DAF to discharge to surface waters. Doing the
analysis in this way may underestimate the upgrade costs compared to POTW upgrade costs; however,
this would not change the result of the analysis as all categories evaluated failed the BCT test.

9.5 References

1. Gordian. 2023. RS Means Historical Cost Indices (January). DCN MP00707. Available online at:
rsmeans.co.

2. U.S. EPA. 2023a. Compliance Cost Methodology for the Meat and Poultry Products Proposed
Rulemaking (November). DCN MP00301.

3. U.S. EPA. 2023b. Pollutant Loadings and Removals Methodology for the Meat and Poultry Products
Proposed Rulemaking (November). DCN MP00302.

4. U.S. EPA. 2023c. Regulatory Impact Analysis for Proposed Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products Point Source Category (RIA) (November). EPA-821-R-23-
014.

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10. Incremental Capital, Operation, and Maintenance Costs
for the Proposed Regulation

This section presents the U.S. Environmental Protection Agency's methodology for estimating the
incremental capital and operation and maintenance (O&M) costs for the meat and poultry products
(MPP) industry to meet the requirements of the technology systems the Agency considered as the basis
for the proposed MPP regulatory options.

The sections that follow include a detailed description of the cost methodology, an example facility cost
calculation, and a summary of total estimated compliance costs for the industry.

10.1 Introduction

Effluent limitations guidelines and standards (ELGs) are based on the performance of specific technology
systems that the EPA evaluated for the regulatory options. Implementation of these specific technology
systems is not required; regulated facilities can choose their own methods to meet the ELGs. However,
the EPA calculates the cost for MPP facilities to implement these technologies in order to estimate the
compliance costs for the industry to meet the ELGs. For existing sources, compliance costs are
incremental, meaning that they represent the additional costs facilities are expected to incur as they
revise their existing operations to meet the proposed requirements. For new sources, the EPA estimates
the costs to install such technologies compared to what a typical source would do in the absence of the
rule.

The EPA may estimate costs on a per-facility basis and then sum or otherwise escalate the facility-specific
values to represent industry-wide compliance costs. Calculating costs on a per-facility basis allows the
EPA to account for differences in facility characteristics such as types of processes used, types of
wastewaters generated and their flows/volumes and characteristics, and categories of wastewater
controls in place (e.g., best management practices and end-of-pipe treatment). The EPA took this
approach in estimating the compliance costs associated with the proposed rule.

The EPA estimated compliance costs associated with each of the regulatory options using data collected
through site visits, sampling episodes, and responses to the MPP Questionnaire. EPA also used data
generated by CapdetWorks v.4 (Capdet), a cost modeling software (see Section 10.2.1 for more
information on Capdet).

The EPA's cost estimates include capital costs (one-time costs) and annual O&M costs (which are incurred
every year). Capital costs include costs associated with the purchase, delivery, and installation of pollution
control technologies. Capital cost elements are specific to the industry and commonly include purchase
and installation of equipment, construction and renovation of buildings, site preparation, engineering
costs, construction expenses, contractors' fees, and contingency. Annual O&M costs include costs related
to operating and maintaining the pollution control technologies for a period of one year. O&M costs are
also specific to the industry and commonly include costs associated with operating labor, maintenance
labor, maintenance materials (routine replacement of equipment due to wear and tear), chemical
purchase, energy requirements, residual disposal, and compliance monitoring.

10.2 Methodology for Estimating Compliance Costs

For the proposed rule, the EPA developed compliance capital and annual O&M cost estimates based on
the evaluation of six different technology systems. These technology systems were developed based on
the wastewater and type of discharger.

-------
MPP process wastewater includes any water that, during processing, comes into direct contact with any
raw material, intermediate product, finished product, byproduct, or waste product. MPP process
wastewater includes any wastewater generated in MPP processing areas and animal holding areas.

The following technology systems were evaluated for MPP process wastewater. More details on the
specific treatment units included in each system are provided in Table 10-1.

• Direct Wastewater Treatment Technology System Targeting Phosphorus and Partial Denitrification (P
with Partial N Treatment for Direct Dischargers): Screening/grit removal, dissolved air flotation (DAF)
(for oil and grease [O&G] treatment), anaerobic lagoon (for biochemical oxygen demand [BOD]
pretreatment), biological treatment with activated sludge to achieve nitrification and partial
denitrification, chemical phosphorus removal with ferric chloride, sand filtration,6
chlorination/dechlorination, solids handling (gravity thickener, filter press, hauling/landfilling).

• Direct Wastewater Treatment Technology System Targeting Phosphorus and Full Denitrification (P
with Full N Treatment for Direct Dischargers): Screening/grit removal, DAF (for O&G treatment),
anaerobic lagoon (for BOD pretreatment), biological treatment with activated sludge to achieve
nitrification and full denitrification, chemical phosphorus removal with ferric chloride, sand filtration,6
chlorination/dechlorination, solids handling (gravity thickener, filter press, hauling/landfilling).

• Indirect Wastewater Treatment Technology System Targeting Conventionals (BOD, O&G, and total
suspended solids [TSS]) (BOD, O&G, and TSS Treatment for Indirect Dischargers): Screening/grit
removal, DAF (for O&G treatment), solids handling.

• Indirect Wastewater Treatment Technology System Targeting Phosphorus and Full Denitrification (P
with Full N Treatment for Indirect Dischargers): Screening/grit removal, DAF (for O&G treatment),
anaerobic lagoon (for BOD pretreatment), biological treatment with activated sludge to achieve
nitrification and full denitrification, chemical phosphorus removal with ferric chloride, sand filtration,6
solids handling (gravity thickener, filter press, hauling/landfilling).

High chlorides wastewater is a specific type of MPP process wastewater that can contain high
concentrations of salinity and dissolved solids. It is generated from certain MPP operations like hides
processing, meat and poultry koshering, water softening, curing, smoking, pickling, and marinating.

The following technology systems were evaluated for high chlorides wastewater. More information on
the treatment of high chlorides wastewater can be found in Section 10.2.2 and in the EPA's Summary of
High Chlorides Wastewater Data (U.S. EPA, 2023a).

• Zero Discharge Evaporation: Utilizing a forced circulation evaporation system to evaporate the high
chlorides wastewater and potentially save salt crystals for reuse.

• Zero Discharge Disposal: Disposal of high chlorides wastewater by deepwell injection.

The EPA used the following characteristics of MPP facilities as facility-specific inputs for the compliance
cost methodologies:

• MPP facility processing type (i.e., meat first processing, meat further processing, poultry first
processing, poultry further processing, and rendering).

• Size (i.e., amount of meat and/or poultry processed annually).

• Process wastewater discharge type (i.e., direct discharge, indirect discharge, zero discharge, or both
direct and indirect discharge).

• Wastewater flow rate in millions of gallons per year (MGY).

6 Sand filtration does not apply to rendering facilities.

-------
• Population of facilities with high chlorides wastewater (i.e., facilities identified as having processes
that generate a high chlorides wastestream).

• High chlorides wastewater flow rate in MGY.

Section 10.2.1 provides information about the costing of MPP process wastewater technology systems,
and Section 10.2.2 details the methodology behind the costing of high chlorides wastewater technology
systems.

10.2.1 MPP Process Wastewater

General Approach

Table 10-1 includes a list of the treatment units costed for each of the technology systems the EPA
evaluated for MPP process wastewater. The EPA calculated facility-specific capital and annual O&M costs
for each treatment unit of a proposed technology system. The EPA based calculations on a facility's
reported wastewater flow rate and estimated pollutant concentrations in the untreated wastewater.
Where data were not reported, the EPA estimated the flow rate and pollutant concentrations based on
the amount of annual production and the type of facility processing operation (i.e., meat first processing,
meat further processing, poultry first processing, poultry further processing, or rendering). Table 10-1
also includes the method(s) used to estimate those costs.

The EPA used Capdet software tool to design and cost many of the treatment units included in each of
the technology systems evaluated for MPP process wastewater. Capdet is based on the process and cost
estimating algorithms for the Computer-Assisted Procedure for the Design and Evaluation of Wastewater
Treatment System, originally developed by the U.S. Army Corps of Engineers. The EPA used the latest
version (2018) of the software, which has kept pace with technology improvements and includes an
extensive cost database (Hydromantis ESS Inc., 2018). The values and cost indices in the software were
scaled and updated to costs in reflect 2022 dollars.

For this analysis, the EPA made modifications within the tool to better represent MPP process
wastewater. Since MPP process wastewater has higher concentrations of nitrogen (i.e., ammonia, nitrate-
nitrite nitrogen, and total Kjeldahl nitrogen [TKN]), BOD, TSS, O&G, and phosphorus compared to
municipal wastewater. The Capdet default data on influent wastewater were updated to reflect those
differences. Within the tool, modifications and assumptions were also made on the types of treatment
units to represent appropriate wastewater treatment for the MPP industry. For example, anaerobic
lagoons were adjusted to a depth of 15 feet (typical depth is between 12 and 15 feet) to minimize
footprint; ferric chloride was assumed to be the chemical added to remove phosphorus; chlorination was
assumed to be used for disinfection; and high-flow facilities (with wastewater flow rates greater than
10,000 gallons per day [GPD]) were costed for solids handling systems. The full list of modifications and
assumptions made within Capdet to appropriately model MPP process wastewater can be found in Table
11 of the EPA's Compliance Cost Methodoloqy for the Meat and Poultry Products Proposed Rulemakinq
(U.S. EPA, 2023b).

The EPA estimated some capital and O&M costs (described later in this section) using cost estimates
developed outside of Capdet. These costs include:

• Capital costs for chemical phosphorus removal.

• Capital and O&M costs for coagulant addition for a sand filter.

• Annual O&M costs for compliance monitoring, based on the type of facility process operation and
wastewater flow rate.

The EPA used the modified Capdet tool to generate costs for meat first, meat further, poultry first,
poultry further, and rendering facilities. For each of these five facility types, the EPA generated costs for
five different flow rate scenarios. The flow scenarios differ for each facility processing type and are based
on the typical range of wastewater flows generated by these MPP facilities (see Table 10-2). Capdet

-------
provided cost elements for every treatment unit studied in these 25 scenarios. The cost elements
included the capital cost of construction and the annual costs of operation, maintenance, materials,
chemicals, and energy. See Table 8 in the EPA's Compliance Cost Methodology for the Meat and Poultry
Products Proposed Rulemaking (U.S. EPA, 2023b) for more details.

For each treatment unit studied within one of 25 scenarios, the EPA summed the estimates for the
individual costs components (both the estimates output from Capdet and those developed using an
alternative method), to calculate the total capital and O&M costs for the treatment unit. The EPA then
generated treatment unit cost curves for each processing type as (1) a relationship between flow and
total capital cost and (2) a relationship between flow and total O&M cost. The EPA calculated the
equation of each curve based on a linear relationship using slope and intercept formulas in Excel. See the
EPA's Compliance Cost Methodology for the Meat and Poultry Products Proposed Rulemaking (U.S. EPA,
2023b) for more details.

The EPA calculated facility-specific capital and O&M costs using the following methodology:

• Calculated facility-specific capital and O&M costs using linear equations generated from the 25
Capdet modeling scenarios. These costs were calculated for each treatment unit within a technology
system, for each type of processing facility (five), and for each wastewater flow rate (five) (Table 10-1
and Table 10-2).

• Calculated the sum of the capital costs and the sum of annual O&M costs for each treatment unit.

• Calculated other direct and indirect capital costs, like site preparation and engineering design, for
each facility. Again, these calculations were based on the facility processing type and wastewater flow
rate. The costs were based on the treatment technologies already in place at the facility.

• Calculated the total facility-specific capital costs by summing the capital cost elements for all
applicable treatment units. Calculated the facility-specific O&M costs by summing O&M costs for all
applicable treatment units.

Table 10-1. Cost Data Sources for Process Wastewater Technology Systems and Units

Treatment Unit

Technology System

Method for Cost
Estimation

P with
Partial N
Treatment
for Direct
Dischargers

P with Full N
Treatment
for Direct
Dischargers

BOD, O&G,

and TSS
Treatment
for Indirect
Dischargers

P with Full N
Treatment
for Indirect
Dischargers

Capdet
Tool

Other Cost
Estimates

Screening/Grit
Removal

DAF

Anaerobic
Lagoon

Biological
Treatment

Chemical

Phosphorus

Removal

(O&M)

X (Capital)

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Table 10-1. Cost Data Sources for Process Wastewater Technology Systems and Units

Treatment Unit

Technology System

Method for Cost
Estimation

P with
Partial N
Treatment
for Direct
Dischargers

P with Full N
Treatment
for Direct
Dischargers

BOD, O&G,

and TSS
Treatment
for Indirect
Dischargers

P with Full N
Treatment
for Indirect
Dischargers

Capdet
Tool

Other Cost
Estimates

Sand Filtration3

X (Capital and
O&M for
coagulant
addition)

Chlorination/
Dechlorination

Solids Handling

Compliance
Monitoring

X (O&M)

a — Not costed for rendering processing type.

Table 10-2. Flow Rates (MGD) Used to Generate MPP Operation Cost Curves

MPP Processing Type

Flow 1

Flow 2

Flow 3

Flow 4

Flow 5

Meat First

0.01

0.025

0.05

3.5

Meat Further

0.0001

0.0003

0.0005

0.25

1.4

Poultry First

0.01

0.1

0.2

Poultry Further

0.001

0.0025

0.005

0.3

0.9

Rendering

0.0001

0.05

0.5

0.75

1.1

Source: U.S. EPA, 2023b.

Abbreviations: MGD = millions of gallons per day.

Other Direct and Indirect Capital Costs

Other direct and indirect capital costs were estimated using the 1991 version of Plant Design and
Economics for Chemical Engineers (Peters and Timmerhaus, 1991).7 Capdet was not used to estimate
other direct capital cost factors because the modeling software generates these costs only for greenfield
construction (i.e., brand-new construction) and not for modifications to an existing facility. The indirect
capital cost factors can apply to both new construction and retrofits.

For this costing analysis, other direct capital costs include instrumentation and controls, piping, electrical,
and land. Indirect capital costs include the following:

• Engineering and supervision (engineering costs-administrative; process, design, and general

engineering; drafting, cost engineering, procuring, expediting, reproduction, communications, scale
models, consultant fees, travel, engineering supervision, and inspection).

7 After finalizing cost estimates for the proposed rulemaking, the EPA identified a newer version of the Plant Design
and Economics for Chemical Engineers by Peters et al. from 2003 (Peters et al., 2003). The EPA will update the values
used to estimate direct capital costs for the final rulemaking.

-------
• Construction expenses (construction and O&M of temporary facilities and infrastructure, including
offices, roads, parking lots, railroads, electrical, piping, communications, fencing; construction tools
and equipment; construction supervision, accounting, timekeeping, purchasing, expediting;
warehouse personnel and expense, guards; safety, medical, fringe benefits; permits, field tests,
special licenses; taxes, insurance, interest).

• Contractors' Fees.

• Contingency.

The EPA calculated that instrumentation and controls, piping, electrical, and land (other direct capital
costs) account for approximately 26 percent of the direct capital costs (e.g., purchased equipment,
installation, buildings, and service facilities). The EPA calculated that engineering and supervision,
construction expenses, contractor's fees, and contingency account for 43 percent of the total direct
capital costs (direct capital costs plus other direct capital costs) (U.S. EPA, 2023b).

Other Cost Estimates

As noted in Table 10-1, other cost estimation methods were used instead of Capdet to calculate certain
treatment unit costs. These include the capital costs associated with chemical phosphorus removal, the
capital and O&M costs for coagulant addition at the sand filter,8 and the O&M costs for compliance
monitoring. Table 10-3 describes the cost data and the methodology behind the cost estimates for these
treatment units.

Table 10-3. Other Cost Estimates for MPP Process Wastewater

Treatment Unit Cost Data and Methodology

Chemical Phosphorus
Removal

The EPA estimated capital costs associated with chemical addition equipment
using existing EPA-cost data. The EPA used fiberglass reinforced plastic (FRP)
tank costs, which factor in field-erected costs, auxiliary equipment, and
freight costs. See Appendix 2 of the EPA's Compliance Cost Methodology for
the Meat and Poultry Products Proposed Rulemaking for more information
(U.S. EPA, 2023b).

Sand Filtration3

The EPA estimated costs for aluminum chloride coagulant solution using
information from existing EPA-cost data, the MPP Questionnaires, the EPA's
sampling data, and industry data. For chemical storage, the EPA estimated
FRP tank costs, which factor in field-erected costs, auxiliary equipment, and
freight costs. See Appendix 3 of the EPA's Compliance Cost Methodology for
the Meat and Poultry Products Proposed Rulemaking for more information
(U.S. EPA, 2023b).

8 The costs for the filter itself are included in the Capdet output, but Capdet does not include chemical costs for
filters.

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Table 10-3. Other Cost Estimates for MPP Process Wastewater

Treatment Unit

Cost Data and Methodology

Compliance
Monitoring

The EPA estimated annual O&M costs associated with monthly monitoring for
the following:

• P with Partial N Treatment for Direct Dischargers: total phosphorus (TP),
total nitrogen (TN),b and E. coli.

• P with Full N Treatment for Direct Dischargers: TP, TN,b and E. coli.

• BOD, O&G, and TSS Treatment for Indirect Dischargers: 0&G.C

• P with Full N Treatment for Indirect Dischargers: TP, TN, and 0&G.C

• See Appendix 4 of the EPA's Compliance Cost Methodology for the Meat
and Poultry Products Proposed Rulemaking for more information (U.S.
EPA, 2023b).

a — Not costed for rendering processing type.

b — TN monitoring requirements are only applicable to facilities without TN limitations under the current ELG.
c — The EPA underestimated compliance monitoring costs for indirect treatment options by excluding monitoring costs for BOD
and TSS. The EPA will update estimated compliance costs for the final rulemaking.

Facility Treatment in Place

For each facility, the EPA estimated costs for each treatment unit associated with each technology
system. These costs assume greenfield installation of the entire technology system as described in Table
10-1. The EPA then used information on each facility's treatment in place to assess full or partial credit for
the cost of individual treatment components that the facility has already in place. For facilities that
responded to the MPP Questionnaires, the EPA used data from individual facility responses. The EPA
evaluated the most common responses provided in the Detailed Questionnaire population to extrapolate
treatment in place to other facilities without MPP Questionnaires response data based on discharge
location and type of processing. See the Treatment in Place (TIP) Analysis for the Meat and Poultry
Products (MPP) Proposed Rule for additional details on the EPA's methodology for determining treatment
in place for each facility (U.S. EPA, 2023c).

Where the EPA identified a particular treatment unit in place, the EPA adjusted costs as described in
Section 4.1.6 of the EPA's Compliance Cost Methodology for the Meat and Poultry Products Proposed
Rulemaking (U.S. EPA, 2023b) in Table 13 (P with Partial N Treatment for Direct Dischargers), Table 14 (P
with Full N Treatment for Direct Dischargers), Table 15 (BOD, O&G, and TSS Treatment for Indirect
Dischargers), and Table 16 (P with Full N Treatment for Indirect Dischargers). Each table represents one of
the four MPP process wastewater technology systems and describes how much cost credit was applied
for each treatment unit within the technology system for both capital and O&M costs.

In addition to individual treatment unit costs, the EPA also adjusted the solids handling costs depending
on whether a facility was already handling solids from a treatment unit in the technology basis. For
example, where a facility currently operates a DAF, the EPA adjusted costs to reflect zero capital and
O&M costs for this treatment unit. The EPA also assumed that the facility was handling solids generated
by this unit; as such, the EPA adjusted the estimate of solids handling costs to cover only the equipment
needed for additional (or incremental) solids handled. The EPA accounted for incremental solids handling
costs where a facility had any of the following units in place: DAF, biological treatment, or phosphorus
removal treatment. For more details, see Appendix 5 of the EPA's Compliance Cost Methodology for the
Meat and Poultry Products Proposed Rulemaking (U.S. EPA, 2023b).

10.2.2 MPP High Chlorides Wastewater

The EPA estimated compliance costs associated with two zero discharge technology systems for the
treatment of high chlorides wastewater: Zero Discharge Evaporation and Zero Discharge Disposal. This
high chlorides and high salinity brine is generated from certain MPP operations, and, under the proposed

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rule, the EPA assumes that this wastestream would be treated separately from other MPP process
wastewaters. Where the treatment in place evaluation indicated that facilities already handle all their
high chlorides wastewater via zero discharge, the EPA did not estimate costs associated with either high
chlorides technology system.

Zero Discharge Evaporation

For Zero Discharge Evaporation, the EPA estimated the costs of utilizing a forced circulation evaporation
system. A forced circulation evaporation system uses steam with a heat exchanger and condenser, which
causes the wastewater to evaporate and the salty brine to crystalize (see Figure 8-3 in Section 8). The salt
crystals that are saved from this process can then be reused in a facility's MPP operations.

The EPA used facility-provided capital cost information for an evaporation system to develop a capital
cost per GPD curve. The capital cost curve was used to estimate costs per facility for installing this
treatment technology. Capital costs include costs for equipment, electrical, engineering, construction,
and greenfield installation. The EPA also used facility-provided O&M cost information for an evaporation
system to develop an O&M cost per GPD curve. The O&M cost curve was used to estimate costs per
facility for operating and maintaining this treatment technology. O&M costs include labor, materials,
energy (natural gas and electricity), and nonroutine chemicals. The EPA used the segregated, high
chlorides brine flow rate and the capital and O&M cost curves to estimate zero discharge evaporation
costs for each facility with high chlorides wastewater. In cases where a facility is already treating part, or
all, of the high chlorides wastestream, the EPA adjusted the flow rate to estimate only costs associated
with the untreated portion of the wastestream.

Zero Discharge Disposal

For Zero Discharge Disposal, the EPA estimated the costs to dispose of high chlorides wastewater using
deepwell injection into Class I nonhazardous industrial well sites. Data from previous rulemakings and EPA
Region 6 were used to estimate the annual O&M costs for the disposal of the segregated, high chlorides
wastewater. The EPA estimated annual O&M costs based on the amount of high chlorides wastewater
expected to be transported, the cost of transportation, and the disposal cost. In cases where a facility is
already treating part, or all, of the high chlorides waste stream, the EPA adjusted the flow rate to
estimate only costs associated with the untreated portion of the wastestream. Estimated compliance
costs for this technology system include costs to haul the high chlorides wastewater off site via truck and
disposal costs for utilizing the well site. The EPA assumed that facilities do not incur capital costs
associated with the deepwell injection of high chlorides wastewater. Deepwell injection is not allowed in
some states and may not be an option for many facilities.

10.3 Example Facility Cost

In this subsection, the EPA is presenting estimated compliance costs for an example MPP facility. The
intent is to show how the Agency's cost methodology was applied to a specific facility based on its
processing type, wastewater flow rate, and treatment in place. The example facility is a poultry first
processing facility that also performs koshering (i.e., produces high chlorides wastewater). Table 10-4
presents the cost inputs associated with the example facility.

Table 10-4. Example Facility—Cost Inputs

Facility Characteristic

Assumption

Process Type

Poultry First

Process Flow

255 MGY

High Chlorides Flow

5.9 MGY

Abbreviations: MGY = millions of gallons peryear.

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Table 10-5 presents the treatment units already in place at the example facility prior to implementation
of the proposed rule; the EPA will adjust compliance costs for this facility based on this treatment in
place. Note that there is no treatment in place for the management of the high chlorides wastewater
generated from the example facility's koshering operations.

Table 10-5. Example Facility—Treatment in Place

Treatment Unit

In Place?

MPP Process Wastewater Treatment

Screening/Grit Removal

Yes

DAF

Yes

Anaerobic Lagoon

Yes

Biological Treatment

Yes

Chemical Phosphorus Removal

Sand Filtration

Chlorination/Dechlorination

Yes

Solids Handling

Yes

High Chlorides Wastewater Treatment

Evaporation

Disposal

The example facility's total capital costs and annual O&M costs for treating MPP process wastewater
were calculated by summing all estimated costs. These include the costs for each treatment unit
generated from the Capdet modeling scenarios, the additional direct and indirect capital costs, and the
calculated costs from other estimation methods. These costs were then adjusted based on the treatment
already in place at the facility. Table 10-6 summarizes the estimated compliance costs for each
technology system for the example facility's MPP process wastewater.

Table 10-6. Example Facility—Estimated Capital and O&M Costs for MPP Process Wastewater

Technology System

Capital Cost (2022$)

O&M Cost (2022$/yr.)

P with Partial N Treatment for Direct Dischargers

$6,540,000

$1,460,000

P with Full N Treatment for Direct Dischargers

$9,550,000

$1,670,000

BOD, O&G, and TSS Treatment for Indirect Dischargers

$3,820

P with Full N Treatment for Indirect Dischargers

$10,100,000

$1,900,000

Abbreviations: yr. = year.

Note: Values presented as three significant figures.

The example facility's compliance costs for brine management were calculated for both high chlorides
wastewater technology systems: Zero Discharge Evaporation (forced circulation evaporation system) and
Zero Discharge Disposal (deepwell injection). Table 10-7 presents the estimated total capital costs and
annual O&M costs for both high chlorides technology systems for the example facility.

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Table 10-7. Example Facility—Estimated Capital and O&M Costs for High Chlorides Wastewater

Technology System

Capital Cost (2022$)

O&M Cost (2022$/yr.)

Zero Discharge Evaporation

$5,800,000

$1,360,000

Zero Discharge Disposal

$2,680,000

Abbreviations: yr. = year.

Note: Values presented as three significant figures.

10.4 Summary of Total Estimated Compliance Costs

Table 10-8 presents a summary of the estimated compliance capital costs and annual O&M costs by
technology system. As described in Section 9, the EPA considered different regulatory options based on
various production thresholds across the ELG subcategories. Table 10-9 presents a summary of the
estimated compliance capital costs and annual O&M costs by regulatory option.

Table 10-8. Industry Capital and O&M Costs by Technology System

Technology System

Number of
Facilities

Total Capital
Cost (2022$)

Total O&M Cost
(2022$/yr.)

P with Partial N Treatment for Direct Dischargers

171

$451,000,000

$168,000,000

P with Full N Treatment for Direct Dischargers

171

$873,000,000

$220,000,000

BOD, O&G, and TSS Treatment for Indirect
Dischargers

3,708

$339,000,000

$46,600,000

P with Full N Treatment for Indirect Dischargers

3,708

$8,770,000,000

$1,500,000,000

Zero Discharge Evaporation

470

$623,000,000

$146,000,000

Zero Discharge Disposal

470

$287,000,000

Abbreviations: yr. = year.

Note: Costs presented as three significant figures.

Table 10-9. Industry Capital and O&M Costs by Regulatory Option

Regulatory Option

Number of
Facilities

Total Capital Cost
(2022$)

Total O&M Cost
(2022$/yr.)

Option 1

845

$824,000,000

$210,000,000

Option 2

845

$2,510,000,000

$571,000,000

Option 3

1,620

$4,720,000,000

$928,000,000

Abbreviations: yr. = year.

Note: Values presented as three significant figures.

The EPA also estimated total capital costs and total O&M costs associated with 320 facilities that produce
more than 5 million pounds per year and that generate high chlorides wastewaters, implementing
evaporation for the treatment of the high chlorides wastewaters. For the 320 facilities, the EPA estimated
a capital cost of $600,000,000 and an O&M cost of $141,000,000 per year in 2022 dollars.

10.5 References

1. Hydromantis ESS, Inc. 2018. Process Design and Cost Estimating Algorithms for the Computer Assisted
Procedure for the Design and Evaluation of Wastewater Treatment Systems (CAPDET) Version 4.0
(May). DCN MP00342. Available online at: https://www.hvdromantis.com/CapdetWorks.html.

-------
2.	Peters, M. S. and Timmerhaus, K. D. 1991. Plant Design and Economics for Chemical Engineers. 4th ed.,
McGraw-Hill College. DCN MP00343.

3.	Peters, M. S., Timmerhaus, K. D., and West, R. 2003. Plant Design and Economics for Chemical
Engineers. 5th ed., McGraw-Hill College. DCN MP00344.

4.	U.S. EPA. 2023a. Summary of High Chlorides Wastewater Data (November). DCN MP00305.

5.	U.S. EPA. 2023b. Compliance Cost Methodology for the Meat and Poultry Products Proposed
Rulemaking (November). DCN MP00301.

6.	U.S. EPA. 2023c. Treatment in Place (TIP) Analysis for the Meat and Poultry Products (MPP) Proposed
Rule (November). DCN MP00191.

100

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11. Pollutant Loadings

This section presents the methodology used to estimate annual pollutant loadings for the meat and
poultry products (MPP) industry. The U.S. Environmental Protection Agency estimates pollutant loadings
to evaluate the effectiveness of technology systems, to quantify the benefits gained from reducing the
amounts of pollutants discharged, and to evaluate the cost in relation to the benefits achieved.

As discussed in Section 9, the EPA is evaluating technology systems for MPP process wastestreams. For
each of these wastestreams, the EPA defines baseline loadings, technology system loadings, regulatory
option pollutant loadings, and pollutant changes as follows:

• Baseline loadings: Pollutant loadings, in pounds per year, in MPP wastewater discharges to surface
water before implementation of the proposed rule. For direct dischargers, baseline loadings were
estimated at the discharge location leaving the MPP facility. For indirect dischargers, baseline
loadings were estimated (1) at the location where discharge leaves the MPP facility, and (2) in the
MPP contribution in the Publicly Owned Treatment Works (POTW) effluent (i.e., following treatment
at the POTW).

• Technology system loadings: Estimated pollutant loadings, in pounds per year, in MPP process
wastewater discharges based on the implementation of the technology systems considered as the
basis for the proposed MPP effluent limitations guidelines and standards (ELGs). Target effluent
concentrations for each technology system were calculated for the MPP pollutants of concern (POCs)
to estimate annual discharges from all MPP facilities to which the proposed MPP ELGs apply. For
direct dischargers, technology system loadings were estimated at the discharge location leaving the
MPP facility. For indirect dischargers, technology system loadings were estimated (1) at the location
where discharge leaves the MPP facility, and (2) in the MPP contribution in the POTW effluent (i.e.,
following treatment at the POTW).

• Regulatory option loadings: Estimated pollutant loadings, in pounds per year, in MPP process
wastewater discharges after implementation of the proposed regulatory options. The EPA combined
the wastestream-level POC loadings associated with the technology systems, processing type, and
production threshold that reflect compliance with each regulatory option to determine post-
compliance loadings for each regulatory option.

• Pollutant changes (presented as removals): The difference between the baseline loadings and the
loadings for each technology system or each regulatory option. Note that the technology system
operations may result in conversion of one pollutant form into another, resulting in an increase in
pollutant loadings from baseline to the technology system or regulatory option loadings for specific
pollutants. For direct dischargers, pollutant changes (removals) in wastewater discharges were
estimated at the location where discharge leaves the MPP facility. For indirect dischargers, pollutant
changes (removals) in wastewater discharges were estimated (1) at the location where discharge
leaves the MPP facility, and (2) in the MPP contribution in the POTW effluent (i.e., following
treatment at the POTW).

This section describes the detailed pollutant loadings evaluation that the EPA performed for facilities to
which the proposed MPP ELGs will apply.

Section 11.1 presents background information and the EPA's general methodology for estimating
pollutant loadings. Section 11.2 and Section 11.3 describe the baseline pollutant loadings and technology
system loadings, respectively, for the MPP process wastewater and high chlorides wastewater streams.
Section 11.4 presents the regulatory option loadings and pollutant removals.

101

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11.1 General Methodology

To calculate pollutant loadings for an MPP facility, the EPA multiplied the pollutant concentration in the
facility's wastewater discharge (effluent) by the wastewater flow rate, as shown in Equation 9-lEquation
11-la and Equation 11-la.

Where:

WW

Load = C x WWpiow x Factor

Equation 11-la -
All pollutants
except

microbiologicals

Load
C

Flow
Factor

= Pollutant loading in the facility effluent (pounds per year [lbs./yr.])

= Pollutant concentration (milligrams per liter [mg/L])

= Effluent flow rate (millions of gallons per year [MGY])

= Conversion factor of 8.344 (derived from 3.785 liter per gallon [L/gal] x 2.2046 pounds
per kilogram [Ibs./kg] x 1 kilogram per million milligrams [kg/M mg])

Loadfij = Cj(j x wwFlow x Factory

Equation 11-lb -
Microbiologicals

Where: Loady
CM

W^Flow

Factor^

= Pollutant loading in the facility effluent (MPN/yr.)

= Pollutant concentration (MPN/100 mL)

= Effluent flow rate (MGY)

= Conversion factor of 37.85 (derived from 3,785 milliliter per gallon [mL/gal] x 1
MPN/lOOmL x 106 gallon per million gallon [gal/MG] x 1 million MPN/106 MPN)

Equation 11-la and Equation 11-la represent the pollutant loadings in the discharge from the facility,
which are the same as the pollutant loadings entering the receiving water for direct dischargers. If the
facility is an indirect discharger (i.e., discharges to a POTW), the EPA accounted for pollutant removal that
occurs at the POTW using Equation 11-2 to calculate the baseline loadings to the receiving water.

POTW Load = Load x (1 - POTWRemoval)

Equation 11-2

Where: POTW Load = Pollutant loading in the POTW discharge (lbs./yr. or million MPN/yr.)

Load = Pollutant loading in the facility effluent (lbs./yr. or million MPN/yr.)
POTWRemova| = POTW percent removal for the pollutant (see Table 11-1)

Table 11-1 presents the POTW pollutant removals (percentages) that the EPA used to estimate the
quantity of pollutant discharged to surface waters from POTWs.

102

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Table 11-1. MPP POTW Pollutant Removals

Pollutant Group

Analyte

POTW Percent Removal

Reference



Biochemical Oxygen
Demand (BOD)

90%

U.S. EPA, 1982



Bromide

1.89%

U.S. EPA, 2018



Carbonaceous Biochemical
Oxygen Demand (cBOD)

90%

Transferred from BOD

Classica Is/
Biologica Is

Chemical Oxygen Demand
(COD)

81%

U.S. EPA, 1982

Fluoride

54%

U.S. EPA, 2002

Oil and Grease (O&G)

87%

U.S. EPA, 1982



Organic Carbon, Total

70%

U.S. EPA, 1982



Sulfate

85%

U.S. EPA, 2003



Total Dissolved Solids

8%

U.S. EPA, 2003



Total Suspended Solids
(TSS)

90%

U.S. EPA, 1982

Chlorides

Chloride

57%

U.S. EPA, 2003



Aluminum

91%

U.S. EPA, 1982



Antimony

67%

U.S. EPA, 1982



Arsenic

66%

U.S. EPA, 1982



Barium

55%

U.S. EPA, 1982



Beryllium

61%

U.S. EPA, 2002



Boron

24%

U.S. EPA, 1982



Cadmium

90%

U.S. EPA, 1982



Calcium

9%

U.S. EPA, 2003



Chromium

80%

U.S. EPA, 1982



Cobalt

10%

U.S. EPA, 1982



Copper

84%

U.S. EPA, 1982



Iron

82%

U.S. EPA, 1982

Metals

Lead

77%

U.S. EPA, 1982



Magnesium

14%

U.S. EPA, 1982



Manganese

33%

U.S. EPA, 1982



Molybdenum

19%

U.S. EPA, 1982



Nickel

51%

U.S. EPA, 1982



Selenium

34%

U.S. EPA, 2002



Silver

88%

U.S. EPA, 1982



Sodium

2.69%

U.S. EPA, 2003



Thallium

54%

U.S. EPA, 2002



Tin

43%

U.S. EPA, 1982



Titanium

92%

U.S. EPA, 1982



Vanadium

8%

U.S. EPA, 1982



Zinc

79%

U.S. EPA, 1982

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Table 11-1. MPP POTW Pollutant Removals

Pollutant Group

Analyte

POTW Percent Removal

Reference

Nutrients

Ammonia, as Nitrogen

39%

U.S. EPA, 1982

Nitrogen, Total

39%

Transferred from
ammonia

Orthophosphate

Not analyzed

—

Phosphorus, Total

30%

Ruzhitskaya & Gogina,
2017

Microbiologicals

Escherichia coli (E. coli)

Not analyzed

—

Enterococci

Not analyzed

—

Fecal Coliform

Not analyzed

—

Equation 11-3 represents the change in pollutant loadings following implementation of the technology
system. A positive value represents pollutant removals, and a negative value represents an increase in the
pollutant loading. This same equation can be used to determine loading change for both direct
dischargers and indirect dischargers.

Load-chdngg = Loadgase — LoadQpfion Equation 11-3

Where: LoadQ|-|ange = Pollutant change for either direct or indirect discharges for a technology system

(Ibs./yr. or million MPN/yr.)

Loadgase = Pollutant loading in the effluent at baseline (direct or indirect) (Ibs./yr. or million
MPN/yr.)

LoadQptjon = Pollutant loading in the effluent following implementation of the technology system
(direct or indirect) (Ibs./yr. or million MPN/yr.)

The Pollutant Loadings and Removals Methodology for the Meat and Poultry Products Proposed
Rulemaking memo (Loadings Methodology Memo; U.S. EPA, 2023a) includes brief descriptions of the
supporting analyses and data sets for the MPP loadings calculations. Section 2 of the Loadings
Methodology Memo includes a description of the input data used in the equations. Using data from the
Detailed Questionnaire for the Meat and Poultry Products Effluent Guidelines (Detailed Questionnaire)
and other existing data, the EPA identified facility-specific details on operations,9 discharge status, and
existing wastewater treatment in place (TIP). The EPA then used analytical data to calculate pollutant-
level characterization data sets for wastewater being discharged by each facility under two scenarios:
baseline conditions (using current TIP) and following implementation of each technology system. Section
2.2.1 of the Loadings Methodology Memo describes how the EPA characterized MPP process wastewater
influent, Section 2.2.2 describes how the EPA characterized the wastewater discharges following
implementation of each of the technology systems, and Section 2.2.3 describes how the EPA
characterized other combinations of TIP at MPP facilities.

9 Details on operations include type of processing, categorized as meat, poultry, or independent rendering and first
or further processing. For facilities that process both meat and poultry, the EPA categorized each facility based on
which meat type it processes in greatest quantities (e.g., the EPA assigned poultry if greater than 50 percent of
material handled is poultry). If a facility processes equal amounts of meat and poultry, the facility was categorized as
meat. See the Meat and Poultry Products (MPP) Profile Methodology Memorandum (U.S. EPA, 2023b) for additional
details.

104

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11.2 Baseline Pollutant Loadings

This section describes the analytical data sources and methodology that the EPA used to determine
baseline pollutant loadings for the MPP process wastewater and high chlorides wastewater streams.
Baseline loadings represent the current pollutant loadings in wastewater discharges before
implementation of the proposed MPP ELGs. Section 11.2.1 presents the EPA's methodology for
determining baseline pollutant loadings for all facilities discharging MPP process wastewater. Section
11.2.2 presents the EPA's methodology for determining baseline pollutant loadings for all facilities
identified in the MPP Industry Profile as discharging high chlorides wastewater.

11.2.1 MPP Process Wastewater

As described in the Treatment in Place (TIP) Analysis for the Meat and Poultry Products (MPP) Proposed
Rule (U.S. EPA, 2023c), for all facilities discharging MPP process wastewater, the EPA used data from the
Detailed Questionnaire and engineering best judgment to identify existing treatment of MPP process
wastewater.

The EPA used analytical data from the EPA sampling program, data from the Detailed Questionnaire, and
other existing data to characterize wastewater discharged from each facility under baseline conditions, as
described in Section 2.2 of the Loadings Methodology Memo (U.S. EPA, 2023a). In general, the EPA used
the following steps to estimate the characteristics of discharges from facilities using the treatment
combinations listed in Appendix B of the Loadings Methodology Memo:

• Where a facility does not treat wastewater, the EPA used the influent characterization data set
described in Section 2.2.1 of the Loadings Methodology Memo to characterize the untreated MPP
process wastewater discharged by the facility.

• Where a facility operates a technology consistent with one of the technology systems evaluated in
this rulemaking, the EPA used the characterization data set corresponding with that technology
system and with the type of processing conducted at the facility. The characterization data set is from
Section 2.2.2 of the Loadings Methodology Memo.

• As described in Section 2.2.3 of the Loadings Methodology Memo, where a facility uses only select
treatment units from one or more of the technology systems evaluated in this rulemaking, the EPA
used the characterization data set for the technology system and adjusted based on what treatment
units were or were not present, transferring concentrations for specific pollutants as appropriate. For
example, for a facility with screening and disinfection, the EPA used the influent characterization data
set. For this treatment train, the EPA expects additional treatment of microbiologicals beyond what is
represented in the influent data set; therefore, the EPA adjusted the concentration of
microbiologicals to reflect this treatment by transferring concentrations of E. coli, enterococci, and
fecal coliform from the Direct Wastewater Treatment Technology System Targeting Phosphorus and
Partial Denitrification (P with Partial N Treatment for Direct Dischargers) data set.

Table 4 within the Loadings Methodology Memo lists the TIP configurations identified at MPP facilities
discharging wastewater, notes treatment assumptions for each TIP configuration, and includes details on
the concentration data set used to estimate effluent concentrations for each TIP configuration. Appendix
D of the Loadings Methodology Memo includes the average concentrations for POCs for all TIP
combinations identified in Appendix B, organized by processing type (U.S. EPA, 2023a).

To estimate baseline loadings for each facility, the EPA used the facility-specific wastewater flow from the
MPP Industry Profile and the concentration data set corresponding with the facility-specific TIP and type
of processing conducted at the facility. For indirect dischargers, the EPA further estimated the POTW
loadings using Equation 11-2.

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11.2.2 High Chlorides Wastewater

MPP processes that are often salt intensive include hides processing, koshering meat, and brining
processes. Many MPP facilities also use water softening for food safety. The EPA used data from the
Detailed Questionnaire and publicly available information to create a list of facilities that may have
processes that use high amounts of chlorides. Facilities that, when responding to the Detailed
Questionnaire, selected hides processing, curing, pickling, marinating, or smoking were identified.
Facilities that listed the amount of kosher meat products were also identified. The EPA recognizes that
not all these facilities generate high chlorides.

Consistent with the approach used for the MPP process wastewater stream, for facilities discharging high
chlorides wastewater directly, the EPA estimated baseline loadings based on existing treatment of this
high chlorides wastewater and technology system loadings. For baseline loadings where facilities are
discharging indirectly, the EPA estimated the loadings discharged by the facility and the loadings
discharged by the POTW (after POTW removals) for the portion of the POTW discharge associated with
the MPP facility.

For all facilities identified in the MPP Industry Profile as discharging high chlorides wastewater, baseline
loadings were estimated using the facility-specific wastewater flow and the average chlorides baseline
concentration (see Equation 11-lc).

Loa(^Chloride ~ ^Chloride x Flow x ^actor Equation 11-lc

Where: Load^hloride = Pollutant loading in the facility effluent (Ibs./yr.)

'-Chloride = Pollutant concentration (mg/L)

WWpiow = H'Sl"1 chlorides wastewater flow rate (MGY)

Factor = Conversion factor of 8.344 (derived from 3.785 L/gal x 2.2046 Ibs./kg x 1 kg/M mg)

The EPA estimated the untreated chlorides concentration using data obtained from the EPA's Clean
Water Act (CWA) High Chlorides Treatment 308 Request. For baseline discharges, the EPA estimated the
untreated concentration for chloride in this wastewater using data obtained from literature and the EPA's
CWA High Chlorides Treatment 308 Request.

Basic curing/brining recipes often use a ratio of one cup salt to one gallon water. This gives a salt
concentration between 7 and 10 percent by weight (70,000 to 100,000 mg/L) (Graiver et al., 2009). Hides
are cured in a concentrated salt solution. Based on the EPA's CWA High Chlorides Treatment 308 Request
data for hides processors, an average salt concentration of 94,200 mg/L was calculated. Exact brine
concentrations vary by facility and process. The EPA is requesting comment on chlorides limitations in the
proposed MPP ELGs. In preliminary calculations, the EPA used a salt concentration of 94,200 mg/L for
high chlorides wastewater loadings calculations. This concentration is within the typical range of high
chlorides MPP process wastewaters.

Section 2.4 of the Loadings Methodology Memo describes the EPA's methodology for determining
baseline concentrations for the high chlorides wastewater in more detail. Where the EPA had data
indicating that a facility is already achieving zero discharge, baseline loadings were calculated as zero. For
facilities managing a portion of the wastewater as zero discharge, the EPA determined the percentage of
the wastewater being discharged and estimated baseline loadings using this adjusted flow rate (U.S. EPA,
2023a).

106

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11.3 Technology System Loadings

This section describes the analytical data sources and methodology that the EPA used to estimate
pollutant loadings in MPP process wastewater and high chlorides wastewater discharges based on
implementation of the technology systems considered as the basis for the proposed MPP ELGs. Section
11.3.1 presents the EPA's methodology for estimating pollutant loadings based on implementation of
technology systems considered for direct dischargers and indirect dischargers of MPP process
wastewater. Section 11.3.2 presents the EPA's methodology for determining pollutant loadings for all
facilities identified in the MPP Industry Profile as discharging high chlorides wastewater based on
implementation of two zero discharge technology systems.

11.3.1 MPP Process Wastewater

The EPA used analytical data from the EPA sampling program, data from the Detailed Questionnaire, and
other existing data to calculate pollutant-level characterization data sets for each of the four MPP process
wastewater technology systems considered for the proposed rule. The four technology systems are the P
with Partial N Treatment for Direct Dischargers, the Direct Wastewater Treatment Technology System
Targeting Phosphorus and Full Denitrification (P with Full N Treatment for Direct Dischargers), the Indirect
Wastewater Treatment Technology System Targeting Conventionals (BOD, O&G, and TSS) (BOD, O&G,
and TSS Treatment for Indirect Dischargers), and the Indirect Wastewater Treatment Technology System
Targeting Phosphorus and Full Denitrification (P with Full N Treatment for Indirect Dischargers)
technology systems (U.S. EPA, 2023a). Section 2.2.2 of the Loadings Methodology Memo describes the
methodology that the EPA used to calculate the pollutant-level characterization data sets for these
technology systems. Table 11-2 presents the pollutants treated and treatment description for each of the
technology systems.

Table 11-2. Technology Systems for MPP Process Wastewater

Technology System
Name

Pollutants Treated

Treatment Description

P with Partial N
Treatment for Direct
Dischargers

P removal and N removal
(partial denitrification)

Screening/grit removal, DAF (for O&G
treatment), anaerobic lagoon (for BOD
pretreatment), biological treatment with
activated sludge to achieve nitrification and
partial denitrification, chemical phosphorus
removal with ferric chloride, sand filtration,3
chlorination/dechlorination, solids handling
(gravity thickener, filter press,
haul i ng/la ndf i lling).

P with Full N
Treatment for Direct
Dischargers

P removal and increased N
removal (full denitrification)

Screening/grit removal, DAF (for O&G
treatment), anaerobic lagoon (for BOD
pretreatment), biological treatment with
activated sludge to achieve nitrification and
full denitrification, chemical phosphorus
removal with ferric chloride, sand filtration,3
chlorination/dechlorination, solids handling
(gravity thickener, filter press,
haul i ng/la ndf i lling).

BOD, O&G, and TSS
Treatment for Indirect
Dischargers

O&G removal

Screening/grit removal, DAF (for O&G
treatment), solids handling.

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Table 11-2. Technology Systems for MPP Process Wastewater

Technology System
Name

Pollutants Treated

Treatment Description

P with Full N
Treatment for Indirect
Dischargers

P removal and N removal
(full denitrification)

Screening/grit removal, DAF (for O&G
treatment), anaerobic lagoon (for BOD
pretreatment), biological treatment with
activated sludge to achieve nitrification and
full denitrification, chemical phosphorus
removal with ferric chloride, sand filtration,3
solids handling (gravity thickener, filter press,
haul i ng/la ndf i lling).

a — Sand filtration is not included in the technology basis for rendering facilities.

For each technology system, the EPA estimated the pollutant loadings that would result if all MPP
facilities discharging MPP process wastewater would install the technology basis and achieve the effluent
concentrations referenced in Section 2.2.2 and Appendix C of the Loadings Methodology Memo. Where a
facility already has TIP to achieve these effluent concentrations, pollutant loadings are unchanged from
baseline loadings. For example, for P with Partial N Treatment for Direct Dischargers, the EPA assumed
that any facility that directly discharges MPP process wastewater and does not achieve the effluent
quality associated with having partial denitrification and phosphorus removal treatment will install
treatment. For these facilities, the EPA calculated their P with Partial N Treatment for Direct Dischargers
technology system loadings to reflect this added treatment. The technology system loadings were
estimated based on facility-specific wastewater flow and the P with Partial N Treatment for Direct
Dischargers data set corresponding to each facility's type of processing, as presented in Table C-4 within
the Loadings Methodology Memo (U.S. EPA, 2023a). For all other facilities (e.g., those with full
denitrification and phosphorus removal or those with indirect discharges of wastewater), their P with
Partial N Treatment for Direct Dischargers technology system loadings were set equal to their baseline
loadings.

To calculate pollutant changes for each technology system, the EPA compared baseline loadings to the
technology system loadings for each facility. Pollutant changes for each facility were calculated using
Equation 11-3 (baseline minus technology system loadings).

Section 2.3 of the Loadings Methodology Memo presents the total industry-level estimated loadings and
pollutant changes for direct discharge technology systems (Table 7 within the Loadings Methodology
Memo) and indirect discharge technology systems and POTWs (Table 8 within the Loadings Methodology
Memo) (U.S. EPA, 2023a).

11.3.2 High Chlorides Wastewater

As described in Section 738.6, the EPA evaluated two zero discharge technology systems for high
chlorides wastewater. All technology system loadings for high chlorides wastewater are zero because the
technology systems achieve zero discharge.

Section 2.5 of the Loadings Methodology Memo presents the total industry-level estimated loadings and
pollutant changes for each technology system for high chlorides MPP process wastewater (U.S. EPA,
2023a).

11.4 Summary of Regulatory Option Loadings and Pollutant Removals

The EPA evaluated three regulatory options to control discharges of MPP process wastewater. See
Section 9 for details on the regulatory options evaluated as part of the proposed ELG.

108

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To calculate total regulatory option loadings for each regulatory option, the EPA combined the pollutant
loadings associated with the technology systems, processing type, and production threshold that reflect
compliance with the option. The EPA also calculated pollutant removals as the difference in loadings
between baseline and each regulatory option. This section discusses the specific loadings and removals
calculations for each pollutant group associated with each regulatory option evaluated by the EPA.

In calculating the pollutant loadings estimates for each regulatory option, the EPA considered the
subcategorizations established by each option. The Preamble describes the applicable subcategories and
requirements for each of the regulatory options evaluated by the EPA.

Table 11-3 presents the EPA's estimated total industry-level pollutant loadings and removals for baseline
and for each regulatory option. Table 11-4 presents the EPA's estimated total industry-level chlorides
loadings and removals for facilities that produce more than 5 million pounds per year and that could be
impacted by potential requirements for high chlorides wastewater limitations. The EPA estimated the
pollutant removals by subtracting the regulatory option loadings from the baseline loadings. Values
presented in this document do not account for the timing or exact date of implementation (e.g., when
technology systems are installed by the industry).

Table 11-3. Industry-Level Pollutant Loadings and Removals for MPP Process Wastewater by

Regulatory Option

Regulatory
Option

Number of
Facilities

Pollutant Groupa

Industry-Level Loadings

Removal

Baseline

3,879

ClassicaIs/BiologicaIs (lbs./yr.)b

5,560,000,000

—

Metals (Ibs./yr.)

496,000,000

Nutrients (Ibs./yr.)

112,000,000

Microbiologicals (MPN/yr.)

66,700,000,000,000

Option 1

845

Classica Is/B iologica Is (Ibs./yr. )c

4,600,000,000

965,000,000

Metals (Ibs./yr.)

491,000,000

4,150,000

Nutrients (Ibs./yr.)

95,500,000

16,500,000

Microbiologicals (MPN/yr.)

66,700,000,000,000

0

Option 2

845

Classica Is/B iologica Is (Ibs./yr.)d

3,320,000,000

2,250,000,000

Metals (Ibs./yr.)

490,000,000

5,470,000

Nutrients (Ibs./yr.)

51,100,000

60,900,000

Microbiologicals (MPN/yr.)

66,700,000,000,000

0

109

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Table 11-3. Industry-Level Pollutant Loadings and Removals for MPP Process Wastewater by

Regulatory Option

Regulatory
Option

Number of
Facilities

Pollutant Groupa

Industry-Level Loadings

Removal

Option 3

1,620

Classicals/Biologicals (Ibs./yr.)e

2,530,000,000

3,030,000,000

Metals (Ibs./yr.)

488,000,000

7,470,000

Nutrients (Ibs./yr.)

16,300,000

95,700,000

Microbiologicals (MPN/yr.)

66,700,000,000,000

Abbreviations: lbs. = pounds, yr. = year, MPN = most probable number.

Note: Loading and removal values presented as three significant figures.

a — Classicals/Biologicals include BOD, bromide, COD, chloride, fluoride, O&G, total organic carbon (TOC), sulfate, total dissolved
solids (TDS), and TSS. Metals include aluminum, antimony, arsenic, barium, beryllium, boron, cadmium, calcium, chromium,
cobalt, copper, iron, lead, magnesium, manganese, molybdenum, nickel, selenium, silver, sodium, thallium, tin, titanium,
vanadium, and zinc. Nutrients include total nitrogen (TN) and total phosphorus (TP). Microbiological include E. coli, enterococci,
and fecal coliform.

The EPA excluded cBOD, ammonia, and orthophosphate so as not to double-count loadings already included with BOD, TN, and
TP.

b — Baseline BOD loadings are 102,000,000 Ibs./yr. and TOC loadings are 298,000,000 Ibs./yr.
c — Regulatory Option 1 BOD loadings are 92,700,000 Ibs./yr. and TOC loadings are 150,000,000 Ibs./yr.
d — Regulatory Option 2 BOD loadings are 45,100,000 Ibs./yr. and TOC loadings are 83,400,000 Ibs./yr.
e — Regulatory Option 3 BOD loadings are 12,300,000 Ibs./yr. and TOD loadings are 29,600,000 Ibs./yr.

Table 11-4. Industry-Level Pollutant Loadings and Removals for High Chlorides Wastewater for
Facilities Producing More Than 5 Million Pounds per Year

Regulatory
Option

Number of
Facilities

Pollutant Groupa

Industry-Level
Loadings

Removal

Baseline

466

Chlorides (Ibs./yr.)

489,000,000

Option

320

12,200,000

477,000,000

Abbreviations: lbs. = pounds, yr. = year.

Note: Loading and removal values presented as three significant figures.

a — Loadings are calculated only for pollutants identified as POCs. For high chlorides wastewater, this includes only chlorides.

11.5 References

1. Graiver, N., Pinotti, A., Califano, A., and Zaritzky, N. 2009. Mathematical Modeling of the Uptake of
Curing Salts in Pork Meat (December). Journal of Food Engineering, vol. 95, issue 4, pp. 533-540. DCN
MP00322. Available online at: https://doi.Org/10.1016/i.ifoodeng.2009.06.027.

2. Ruzhitskaya, O. and Gogina, E. 2017. Methods for Removing of Phosphates from Wastewater (May).
MATEC Web of Conferences, vol. 106, 07006. DCN MP00321. Available online at:
https://doi.org/10.1051/matecconf/2017106070Q6.

3. U.S. EPA. 1982. Fate of Priority Pollutants in Publicly Owned Treatment Works (September). EPA
440/1-82/303. Available online at:

https://nepis.epa.gov/Exe/ZvPDF.cgi/000012HL.PDF?Dockev=000012HL.PDF.

4. U.S. EPA. 2002. Development Document for the Final Effluent Limitations Guidelines and Standards for
the Iron and Steel Manufacturing Point Source Category (April). EPA-821-R-02-004. Available online
at: https://www.epa.Rov/sites/default/files/2015-10/documents/ironsteel dd 2002.pdf.

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5.	U.S. EPA. 2003. Development Document for Final Effluent Limitations Guidelines and Standards for the
Metal Products & Machinery Point Source Category (February). EPA-821-B-03-001. Available online at:
https://www.epa.Bov/sites/default/files/2015-ll/documents/mp-m dd 2003.pdf.

6.	U.S. EPA. 2018. Risk-Screening Environmental Indicators (RSEI) Technical Appendices Version 2.3.6.
Technical Appendix B: Physicochemical Properties for TRI Chemicals and Chemical Categories
(January). DCN MP00335. Available online at: https:://www.epa.gov/rsei/risk-screeiniing-

en viiiron menta ll-ii nd iicatoirs-irse ii-teclh n iica ll-a ppe nd iices-veirsiion-236.

7.	U.S. EPA. 2023a. Pollutant Loadings and Removals Methodology for the Meat and Poultry Products
Proposed Rulemaking (November). DCN MP00302.

8.	U.S. EPA. 2023b. Meat and Poultry Products (MPP) Profile Methodology Memorandum (November).
DCN MP00306.

9.	U.S. EPA. 2023c. Treatment in Place (TIP) Analysis for the Meat and Poultry Products (MPP) Proposed
Rule (November). DCN MP00191.

Ill

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12. Non-Water Quality Environmental Impacts

The elimination or reduction of one form of pollution has the potential to aggravate other environmental
problems, an effect often referred to as cross-media impacts. Sections 304(b) and 306 of the Clean Water
Act (CWA) require the EPA to consider non-water quality environmental impacts (NWQEI), including
energy impacts, associated with effluent limitations guidelines and standards (ELGs). Accordingly, the U.S.
Environmental Protection Agency has considered the potential impact of the proposed ELG revisions to
the meat and poultry products (MPP) point source category on energy usage, air emissions, and solid
waste generation.

The EPA estimated facility-specific NWQEI for each technology evaluated for the proposed ELG. See
Section 8.6 for details on the technologies evaluated for treating both MPP process wastewater and high
chlorides wastewater. Refer to Non-Water Quality Environmental Impacts (NWQEI) for the Meat and
Poultry Products (MPP) Proposed Rule—MPP Process Wastewater (the NWQEI MPP Process Wastewater
Memo; U.S. EPA, 2023a) and Non-Water Quality Environmental Impacts (NWQEI) for the Meat and
Poultry Products (MPP) Proposed Rule—High Chlorides Wastewater (the NWQEI High Chlorides
Wastewater Memo; U.S. EPA, 2023b) for details on the methodology used to estimate NWQEI from
energy, air emissions, and solid waste generated by these technologies. As discussed in Section 9,
regulatory options considered for the proposed rule require additional treatment for removal of
conventional pollutants (e.g., biochemical oxygen demand [BOD], total suspended solids [TSS], oil and
grease [O&G]) by screening and dissolved air flotation (DAF), phosphorus removal by chemical
precipitation, and nitrogen removal by full denitrification in MPP process wastewater.

Section 12.1 discusses the energy requirements for implementing wastewater treatment technologies at
MPP facilities. Section 12.2 and Section 12.3 discuss the impact of the treatment technologies on air
emissions and wastewater treatment solid waste generation, respectively. Each section also includes
estimates of each NWQEI element by regulatory option. Regulatory options are detailed in Section I of
the Preamble.

12.1 Energy Requirements

Energy usage associated with the implementation of the proposed rule includes the use of electricity to
operate wastewater treatment systems. Energy use rates vary depending on the treatment system
evaluated and the current operations (i.e., treatment in place) of the MPP facility. The EPA calculated the
incremental increases in energy usage for MPP facilities that would incur costs under the regulatory
options evaluated. For facilities that discharge MPP process wastewater, the EPA estimated increases in
electricity usage under each regulatory option, as shown in Table 12-1. Inputs, assumptions, and
equations used to make these estimates are described in the NWQEI MPP Process Wastewater Memo
(U.S. EPA, 2023a). See Preamble Section X.A for information on this increase in energy as a percentage of
the total electricity generated in the United States in 2021.

Table 12-1. Net Incremental Increases in Annual Energy Usage for MPP Process Wastewater

Regulatory Options

Regulatory Option

Increase in Energy (MWh/yr.)

Option 1

104,000

Option 2

385,000

Option 3

554,000

Source: U.S. EPA, 2023a.

Abbreviations: MWh = megawatt hours, yr. =year.
Note: Results presented as three significant figures.

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Energy usage also includes fuel consumption associated with transport operations since the EPA's
treatment systems for MPP process wastewater assume each facility's wastewater treatment solids will
be hauled to an off-site landfill. The EPA estimated incremental solids generation requiring disposal for
the treatment systems and calculated the increase in energy usage (in gallons of fuel) to transport the
solid waste to the landfill; see Section 12.3 for details on solids generation. For facilities that discharge
MPP process wastewater, the EPA estimated increases in fuel usage (in gallons per year [GPY]) under
each regulatory option, as shown in Table 12-2. Inputs, assumptions, and equations used to make these
estimates are described in the NWQEI MPP Process Wastewater Memo (U.S. EPA, 2023a). Responses to
the Detailed Questionnaire for the Meat and Poultry Products Effluent Guidelines indicated other waste
management techniques (e.g., land application, composting) may also be used (U.S. EPA, 2023c).
Therefore, the estimated increase in fuel consumption for all facilities may overestimate the impacts for
facilities managing solid waste on site.

Table 12-2. Net Incremental Increases in Annual Fuel Usage for MPP Process Wastewater Regulatory

Options

Regulatory Option

Increase in Fuel Consumption (GPY)

Option 1

128,000

Option 2

331,000

Option 3

405,000

Source: U.S. EPA, 2023a.

Abbreviations: GPY = gallons per year.

Note: Results presented as three significant figures.

The EPA also calculated the incremental increase in energy usage for MPP facilities that generate high
chlorides wastewater (through MPP operations described in Section 4). The EPA estimated the energy
usage based on the high chlorides wastewater flow rate data developed as part of the industry profile
(U.S. EPA, 2023d) and other publicly available data. Additional inputs, assumptions, and equations used to
make these estimates are described in the NWQEI High Chlorides Wastewater Memo (U.S. EPA, 2023b).

The EPA estimated the following increases in energy usage for the high chlorides wastwater evaporation
system for the 320 facilities producing more than 5 million pounds per year with high chlorides processes:

• Energy usage increased by less than 350,000 megawatt hours (MWh) per year.

• Natural gas usage increased by less than 30,000,000 million British thermal units (mmBTU) per year.

12.2 Air Emissions Impacts

The EPA estimated the increase in annual air emissions from the following sources:

• Emissions from increased elecricity usage by MPP facilities to operate wastewater treatment systems:

Increased electricity generation from operation of additional treatment systems will result in
increased air emissions of criteria air pollutants and greenhouse gases when fossil fuels are burned.
Based on data from the U.S. Energy Information Administration (EIA), approximately 40 percent of
the United States' electricity generation in 2022 was from renewable or nuclear sources (U.S. EIA,
2023). Based on this information, the EPA estimated increased air emissions from only the portion of
the electricity generation that comes from the burning of fossil fuels. Criteria air pollutants are those
pollutants for which a National Ambient Air Quality Standard (NAAQS) has been set and include sulfur
dioxide (S02) and nitrogen oxides (NOx). Greenhouse gases are gases, such as carbon dioxide (C02),
methane (CH4), and nitrous oxide (N20), that absorb radiation, thereby trapping heat in the

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atmosphere and contributing to climate change.10 Pollutant-specific national emission factors are
described in the NWQEI MPP Process Wastewater Memo (U.S. EPA, 2023a).

• Emissions from fuel consumption by trucking material off site (e.g., solid waste and high chlorides
wastewater): Air emissions are generated from operating vehicles to transport materials through
burning diesel fuel, which releases criteria air pollutants and greenhouse gases. The EPA's process for
generating pollutant-specific air emission factors as well as inputs, assumptions, and equations used
to make these estimates are described in the NWQEI MPP Process Wastewater Memo (U.S. EPA,
2023a).

• Methane emissions from uncovered anaerobic lagoons: Anaerobic wastewater treatment (e.g.,
anaerobic lagoon) uses microorganisms that consume biodegradable organic compounds, reducing
organic matter and BOD in wastewater. The process generates CH4 and C02. This combination of
gases, predominantly CH4, is commonly referred to as biogas. The EPA expects that the microbial
consumption of biodegradable organic compounds is currently occurring downstream at Publicly
Owned Treatment Works (POTWs) or in the receiving waters; under the proposed rule, the treatment
of organic matter and BOD would be performed at the MPP facility instead of the receiving waters or
POTW. For this analysis, the EPA does not consider the biogas from anaerobic wastewater treatment
as added (or incremental) air emissions as a result of the proposed ELG. MPP facilities may release
biogas directly to the atmosphere, collect biogas for energy generation (i.e., boiler fuel), or destroy it
via flaring.11 For facilities that the EPA determined will need to install anaerobic lagoon(s), the EPA
calculated the incremental methane emissions from anaerobic lagoons that would occur at the MPP
facilities. This calculation is intended to show the amount of methane that facilities may be able to
capture and reuse as a result of the proposed rule from the reduction of organic matter occurring at
the MPP facility. The calculated methane emissions occurring at the MPP facilities are not included in
the net air emissions calculations, as these emissions would be offset by the decrease in methane
emissions from POTWs and receiving waters. The EPA's inputs, assumptions, and equations used to
make these estimates are described in the NWQEI MPP Process Wastewater Memo (U.S. EPA,

2023a).

• N2O and particulate matter emissions associated with biological treatment: While MPP facilities can
use a variety of biological treatment systems to manage MPP process wastewater, the EPA's
proposed treatment systems include an activated sludge system that achieves biological nitrification
using microorganisms to convert ammonia to nitrate in an aerobic environment. Air emissions from
activated sludge systems include ammonia (NH3), which along with NOx and sulfur oxides (SOx), can
contribute to the formation of Particulate Matter 2.5 Microns (PM2.5) (fine inhalable particles of
diameters typically 2.5 micrometers and smaller). Biological treatment systems also release N20
emissions. For those facilities that it determined will need to install biological treatment under the
proposed regulatory options, the EPA calculated incremental PM2.5 and N20 emissions from
biological treatment at the MPP facilities. The EPA expects that nitrification of MPP process
wastewater is currently occurring downstream at POTWs or in the receiving waters and that, under
the proposed rule, the biological treatment of MPP process wastewater would be performed at the
MPP facility instead of the receiving waters or POTW. For this analysis, the EPA does not consider the
air emissions from biological treatment as added (or incremental) air emissions as a result of the
proposed ELG. The EPA's inputs, assumptions, and equations used to make these estimates are
described in the NWQEI MPP Process Wastewater Memo (U.S. EPA, 2023a).

10 The EPA calculated either NO* or N2O emissions for the energy usage air emission analysis to avoid double
counting. NO* emissions include N2O emissions.

11 Based on responses to the MPP Questionnaire, 41 facilities reported collecting biogas for destruction (via flare) or
energy generation. MPP facilities may choose to install biogas collection systems in addition to anaerobic lagoons;
therefore, the results of this analysis may overestimate the net emission of methane from anaerobic lagoons.

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In summary, for MPP facilities that discharge MPP process wastewater, the EPA estimated the increases
in air emissions for the following pollutants:

•	NOx, C02, CH4, and S02 from energy usage.

•	CH4 emissions from anaerobic lagoons.

•	PM2.5 and N20 emissions from biological treatment.

Table 12-3 presents the increases in air emissions in tons per year under the proposed regulatory options
for MPP process wastewater.

Table 12-3. Net Incremental Increases in Air Emissions By Source for MPP Process Wastewater

Regulatory Options

Source and NWQEI

Regulatory Option
1

Regulatory Option
2

Regulatory Option
3

Energy Use

Increase in Energy Use (MWh/yr.)

104,000

386,000

558,000

Increase in NOx (tons/yr.)

15.6

57.7

83.1

Increase in C02 (tons/yr.)

26,600

98,300

142,000

Increase in CH4 (tons/yr.)

2.22

8.19

11.8

Increase in S02 (tons/yr.)

16.6

61.3

88.3

Transp orta tion/Fuel

Increase in Fuel Usage (GPY)

128,000

331,000

405,000

Increase in NOx (tons/yr.)

2.15

5.56

6.78

Increase in C02 (tons/yr.)

960

2,490

3,030

Increase in CH4 (tons/yr.)

0.0297

0.0769

0.0937

Increase in S02 (tons/yr.)

0.00328

0.00851

0.0104

Wastewater Treatment

Increase in CH4 (tons/yr.)

0

0

0

Increase in PM2.5 (tons/yr.)

0

0

0

Increase in N20 (tons/yr.)

0

0

0

Increase in Solids Generation
(tons/yr.)

384,000

996,000

1,214,000

Source: U.S. EPA, 2023a.

Abbreviations: yr. = year.

Note: Results presented as three significant figures.

For all facilities producing more than 5 million pounds per year with high chlorides processes, the EPA
calculated the incremental increases in air emissions (NOx, C02, CH4, S02) from electricity usage and air
emissions (N20, C02, CH4) from natural gas usage. Additional inputs, assumptions, and equations used to
make these estimates are described in the NWQEI High Chlorides Wastewater Memo (U.S. EPA, 2023b).
Table 12-4 presents the increase in energy usage in tons per year for the high chlorides wastewater
evaporation system for facilities producing more than 5 million pounds per year.

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Table 12-4. Net Incremental Increases in Air Emissions (Tons/Year) for High Chlorides Wastewater
Evaporation for Facilities Producing More than 5 Million Pounds per Year

Treatment/
Management System

Increase in

NOx
Emissions

Increase in

N20
Emissions

Increase in

C02
Emissions

Increase in

ch4

Emissions

Increase in

S02
Emissions

Chloride Evaporation

<55

<1,600,000

<40

<60

Source: U.S. EPA, 2023b.

12.3 Solid Waste Generation

Solids are generated from wastewater treatment of MPP process wastewater. The EPA's proposed
treatment systems for MPP process wastewater assume solid waste from wastewater treatment will be
hauled to off-site landfills. The EPA estimated solids generation under the regulatory options evaluated by
using MPP facility treatment in place to identify the technologies the EPA expects facilities to install. For
facilities the EPA determined will need to install DAF, biological treatment, or chemical phosphorus
removal with ferric chloride, the EPA calculated the incremental solids generated for the treatment
technologies. The EPA's inputs, assumptions, and equations used to make these estimates are described
in the NWQEI MPP Process Wastewater Memo (U.S. EPA, 2023a). Table 12-5 presents the incremental
increases in solids generation for discharging MPP facilities that incurred costs under the proposed
regulatory options.

Table 12-5. Net Incremental Increases in Solid Waste Generation for MPP Process Wastewater

Regulatory Options

Regulatory Option

Increase in Solid Waste Generation (Tons/yr.)

Option 1

384,000

Option 2

996,000

Option 3

1,210,000

Source: U.S. EPA, 2023a.

Abbreviations: yr. = year.

Note: Results presented as three significant figures.

12.4 References

1. U.S. EIA. 2023. Electricity Explained: Electricity in the United States (June). DCN MP00327. Available
online at: https://www.eia.gov/energyexplained/electricitv/electricitv-in-the-us.php

2. U.S. EPA. 2023a. Non-Water Quality Environmental Impacts (NWQEI) for the Meat and Poultry
Products (MPP) Proposed Rule—MPP Process Wastewater (November). DCN MP00318.

3. U.S. EPA. 2023b. Non-Water Quality Environmental Impacts (NWQEI) for the Meat and Poultry
Products (MPP) Proposed Rule—High Chlorides Wastewater (November). DCN MP00336.

4. U.S. EPA. 2023c. U.S. EPA MPP Questionnaires Memorandum (November). DCN MP00234.

5. U.S. EPA. 2023d. Meat and Poultry Products (MPP) Profile Methodology Memorandum (November).
DCN MP00306.

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13. Limitations and Standards

As described in Section 9, the U.S. Environmental Protection Agency evaluated three regulatory options
based on combinations of treatment technologies and production thresholds for direct and indirect
dischargers of meat and poultry products (MPP) process wastewater. This section explains data
characteristics, preparation, statistical analysis, and results for effluent limitations. The EPA evaluated
conventional limitations for biochemical oxygen demand (BOD), total suspended solids (TSS), and oil and
grease (O&G), as well as total nitrogen (TN) and total phosphorus (TP) limitations for indirect dischargers.
The EPA also evaluated limitations for TN, TP, fecal coliform, and E. coli for direct dischargers.

The EPA also considered establishing requirements for high chlorides wastewater discharges. See the
Preamble for details on the EPA's proposed approach for handling high chlorides wastewater.

Section 13.1 describes data preparation, including appropriate data selection, standardization, and
aggregation for the analysis. Section 13.2 describes the statistical methodology that EPA used to calculate
concentration averages, variabilities, and resulting limitations. Section 13.3 lists the limitations for all
analytes, with further tables and figures in Appendix B. All data analyses were completed in R software (R
Foundation, 2023).

13.1 Data Preparation
13.1.1 Data Description

The Analytical Database Methodology for the Meat and Poultry Products Proposed Rulemaking
memorandum (the Database Memo) describes the EPA's methodology for compiling wastewater
sampling data from publicly available sources and other collection efforts executed as part of the
proposed rule (U.S. EPA, 2023a). The data sources include facility-specific wastewater monitoring data
from the Detailed Questionnaire for the Meat and Poultry Products Effluent Guidelines (Detailed
Questionnaire), data from the EPA sampling, 2021 Discharge Monitoring Report (DMR) data, and data
from the EPA state and region offices. The EPA selected a subset of data from these sources for use in the
calculation of limitations.

As described in Section 9, the EPA evaluated four different technology bases, also referred to as model
technologies (two for direct dischargers and two for indirect dischargers):

• Direct Wastewater Treatment Technology System Targeting Phosphorus and Partial Denitrification (P
with Partial N Treatment for Direct Dischargers): Screening/grit removal, DAF (for O&G treatment),
anaerobic lagoon (for BOD pretreatment), biological treatment with activated sludge to achieve
nitrification and partial denitrification, chemical phosphorus removal with ferric chloride, sand
filtration,12 chlorination/dechlorination.

• Indirect Wastewater Treatment Technology System Targeting Conventionals (BOD, O&G, and TSS
Treatment for Indirect Dischargers): Screening/grit removal, DAF (for O&G treatment).

12 Sand filtration does not apply to rendering facilities.

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nitrification and full electrification, chemical phosphorus removal with ferric chloride, sand
filtration.12

The EPA excluded data that did not represent treatment consistent with the technology basis. For
example:

• The EPA excluded data for E. coli and fecal coliform at facilities that did not disinfect final effluent
(either through ultraviolet [UV] or chlorination/dechlorination).

• The EPA excluded TN data or TP data based on an evaluation of wastewater treatment at the Best
Available Technology Economically Achievable (BAT) facilities (U.S. EPA, 2023b). For example, TP data
from a facility operating BAT for nitrogen treatment but not for phosphorus were excluded.

To calculate limitations for the BOD, O&G, and TSS Treatment for Indirect Dischargers technology, the
EPA used data from direct or indirect discharging MPP facilities with similar levels of treatment for MPP
process wastewater (screening and DAF). Where a facility had more advanced treatment, the EPA used
sampling data collected at the primary treatment effluent and any data from the MPP Questionnaire at
the primary treatment effluent to characterize this level of treatment.

As the technology basis for nitrogen removal (i.e., biological nitrogen removal using nitrification and
denitrification) is different than the technology basis for phosphorus removal (i.e., chemical phosphorus
removal using precipitation), the EPA identified some facilities as demonstrating BAT performance
consistent with P with Full N Treatment for Direct Dischargers for one pollutant but not the other.
Accordingly, the data used to calculate limitations for TN and TP differed.

• To calculate limitations for TN, the EPA used data from direct or indirect discharging MPP facilities
identified as BAT for TN; see Evaluation of Technology Basis and Identification of BAT Facilities (U.S.
EPA, 2023b) for details on this evaluation.

• To calculate limitations for TP, the EPA used data from direct or indirect discharging MPP facility
identified as BAT for TP; see Evaluation of Technology Basis and Identification of BAT Facilities (U.S.
EPA, 2023b) for details on this evaluation.

To calculate limitations for E. coli and fecal coliform, the EPA used data from any direct or indirect
discharging MPP facility with treatment consistent with P with Full N Treatment for Direct Dischargers
technology basis.

As described in the Preamble, the EPA evaluated treatment for high chlorides that achieves zero
discharge of the segregated high chlorides wastewater. In addition to considering zero discharge, the EPA
also calculated effluent limitations based on one facility operating a forced circulation evaporation
system. The EPA used the MPP process wastewater effluent from this facility's wastewater treatment
system to calculate possible limitations for chlorides in process wastewater based on operating the
technology basis for treatment of high chlorides.

See Table 13-1 for details on technology bases, analytes, and levels of control evaluated for limitations.
Limitations for chlorides are not included, as the EPA is not proposing limitations for this analyte.

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Table 13-1. Limitations by Technology Basis

Technology
Basis

BOD

O&G

TSS

Fecal
Coliform

E. coli

P with Partial
N Treatment
for Direct
Dischargers

NSPS, BAT

NSPS,a
BPTa

P with Full N
Treatment
for Direct
Dischargers

NSPS, BAT

NSPS,
BAT

NSPS, BPT

BOD, O&G,
and TSS
Treatment
for Indirect
Dischargers

PSES,
PSNS

P with Full N
Treatment
for Indirect
Dischargers

PSES,b
PSNSb

PSES,a
PSNSa

Abbreviations: NSPS= New Source Performance Standards, BPT = Best Practicable Technology, PSES = Pretreatment Standards
for Existing Sources, PSNS = Pretreatment Standards for New Sources,
a — Transferred from P with Full N Treatment for Direct Dischargers,
b — Transferred from BOD, O&G, and TSS Treatment for Indirect Dischargers.

For the proposed limitations, the EPA combined data sets across all MPP processes to give a single limit
per analyte for the industry. As the raw materials for MPP processes are animals/animal products,
principally composed of carbon, nitrogen, and phosphorus, the EPA found combining data from different
MPP processes to be reasonable. The EPA did not receive adequate data with which to calculate unique
limitations for MPP facilities that perform different MPP processes, either in number of observations or in
number of facilities represented in the data set used for limitations.

Throughout this section, the EPA discusses the number of facilities represented in the data set. In
addition, the treatment technologies considered for the proposed rule are similar across all types of
processing (see Section 9). As described in Section 7, BOD, O&G, TSS, TP, TN, fecal coliform, and E. coli
were all identified in influent wastewater at treatable levels for all processing types. The treatment
technologies can remove these pollutants to the levels demonstrated by the data evaluated for
limitations.

In addition to selecting the analytes to be evaluated for limitations (BOD, O&G, TSS, E. coli, fecal coliform,
TP, and TN), the EPA also used data collected for total Kjeldahl nitrogen (TKN) and nitrate-nitrite nitrogen
(nitrate-nitrite). In the absence of TN data, the EPA used the sum of TKN and nitrate-nitrite to represent
TN. In addition, the EPA excluded E. coli data with unknown dilution.

The EPA used only a subset of the 2021 DMR data collected. Only DMR data with a statistical basis of daily
results or monthly average were evaluated for limitations. DMR data of other statistical bases (maximum,
daily maximum, weekly average, maximum monthly average, etc.) were excluded as they were not
consistent with the proposed limitation bases being evaluated. As described in Section 13.2, the EPA
combined daily sampling results to calculate daily maximum limitations and averaged daily sampling
results as part of calculating monthly average limitations. Using data already reported as daily maximum
results would misrepresent the definition of daily limitations and would introduce a high bias.

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In total, the EPA used data from 35 facilities in the limitations analysis. Of these, 18 had data from DAF
effluent (BOD, O&G, and/or TSS based on BOD, O&G, and TSS Treatment for Indirect Dischargers) and 23
had data from final effluent (based on P with Full N Treatment for Direct Dischargers). These facilities
were classified as poultry first processing (15), meat first processing (10), rendering (five), meat further
processing (four), and poultry further processing (one) based on the type of operation identified in the
Meat and Poultry Products Profile Methodology Memorandum (U.S. EPA, 2023c). This data set, which has
been subset to the appropriate facilities, analytes, and effluent monitoring locations, can be found in the
Limitations Supplemental Data (U.S. EPA, 2023d).

13.1.2 Data Editing Criteria and Aggregation

The EPA reviewed the data described in Section 13.1.1 and completed steps to prepare those data for
statistical analysis. In some cases, the EPA either excluded or substituted certain data. The following
sections describe the EPA's preparation and evaluation, as well as the reasons individual results were
excluded, substituted, or aggregated for the calculation of limitations.

Time Period and Intervals

The EPA used analytical data from January 2018 to January 2023 to focus the resulting limitations on the
most current system operation. In conversations with states and regions, the EPA is aware of various
ongoing initiatives and compliance requirements to target additional treatment of TN and TP at MPP
facilities. The Database Memo lists the date ranges of the different data sources.

Since the EPA is proposing daily as well as monthly limitations, the length of time between data points at
facilities is an important factor in this methodology. The EPA's review of each data source and set of data
for individual facilities noted different sampling intervals, or days between reported concentrations. With
the goal of calculating both a monthly average limitation and a daily maximum limitation, the EPA
identified which concentrations would most appropriately inform each calculation. Values used to
calculate monthly average limitations—referred to in this document as "monthly-interval data"—were
identified as those reported as monthly average results (e.g., some data from DMR), as well as
questionnaire data with values occurring about one month apart (>28 days). Values used to calculate
daily maximum limitations—referred to in this document as "daily-interval data"—were defined as
occuring fewer than 28 days apart. Where occasional aberrations occurred, the logical increment was
applied; e.g., a series of monthly values including an early date (such as 21 days from the previous date)
was still assigned as monthly-interval data, and a series of weekly values with a skipped month (such as 30
days from the previous date) was still assigned as daily-interval data. Interval assignments are specified in
Limitations Supplemental Data (U.S. EPA, 2023d), in the "Interval" field.

Concentrations Below the Detection Limit

Concentrations were marked as detected or non-detected (ND) relative to their method detection limits
(MDLs). A concentration is ND if it is known to have a low value beneath an analytical detection limit,
ranging from zero to its MDL. These values are also called left-censored, since they lack information to
the left of a lower bound. In the limitation calculations, NDs were substituted with their MDLs.

However, not all NDs were identified as such in the given data. ND identifications primarily appeared in
the EPA sampling data and data from the Detailed Questionnaire. To identify other possible NDs, the EPA
generated one timeline of concentrations for each facility, analyte, and data source combination.13 If the
minimum value of the series occurred at least three times consecutively, this was a strong indicator of a
concentration having reached a lower analytical limit; values equal to it in the series were therefore
marked as ND. In some series, the minimum was consistent, then changed to a different value for the
remainder of the period; both minimums were treated as MDLs (e.g., see Appendix B Figure B-l, plot
"F19, Fecal Coliform"). This step resulted in adding ND identifications to TP (ranging from 0.025 to 0.100

13 The EPA evaluated DMR and Virginia Department of Environmental Quality data together, because they formed
contiguous series of monthly values across years.

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milligrams per liter [mg/L]), fecal coliform (1 to 3 most probable number per 100 milliliters [MPN/100
ml_]), and E. coli concentrations (1 MPN/100 ml_) in different series. All NDs in the data set, both original
and added in this way, were of these three analytes, making up 50 percent of E. coli, 34 percent of fecal
coliform, and 14 percent of TP data.

At three different facilities, TP concentrations taken during the EPA sampling had NDs with MDLs greater
than the detected results within the same data set. For example, 0.49 mg/L was the highest detected
concentration at one facility, but five NDs had MDLs at 3.20 mg/L. NDs with MDLs greater than all the
detected values in a data set can invalidate statistical calculations (see Section 13.2.3), and were
therefore removed from this analysis (11 results were removed in total, marked in Limitations
Supplemental Data [U.S. EPA, 2023d], in the "High-MDL Exclusions" field). The detected values and NDs
with lower MDLs were retained, resulting in smaller sample sizes at those facilities and from this data
source.

Additional Data Exclusions

In reviewing the data, the EPA identified samples with partial or anomalous concentrations. These values
are described in this section and were excluded from the remainder of the analysis.

Ratherthan providingTN concentrations, some facilities provided concentrations of TKN and/or nitrate-
nitrite. For dates with incomplete data, the EPA could not calculate TN as a sum of TKN and nitrate-nitrite,
and therefore excluded the data. This resulted in the removal of one entire facility, since it only provided
nitrate-nitrite data. Where TN was available on a given date, only TN was retained. Excluded records are
identified in Limitations Supplemental Data (U.S. EPA, 2023d), in the "Nitrogen Exclusions" field.

One TN concentration taken during an EPA sampling event was two magnitudes higher than a duplicate
concentration (180 mg/L, compared to a duplicate value of 4.5 mg/L). It was outside the range of values
at the facility, as it was 20 times greater than the next-highest measurement. The corresponding TKN
value was also 180 mg/L. In its own review of the Sampling Episode Report (SER), the facility identified
these results as abnormal or in error. The EPA therefore removed these two high points, with both
marked in Limitations Supplemental Data (U.S. EPA, 2023d), in the "Anomaly Exclusions" field.

Aggregation

Some samples were replicates, meaning the sample was taken from the same data source, at the same
facility and monitoring location, of the same analyte, on the same date. The EPA took the mean of
replicates to produce one value per day. These means were calculated from reported concentrations
when detected and from MDLs when ND. If at least one of the replicates was detected, the resulting
mean was labeled as detected, in recognition of the analyte having been measured as present. If all were
ND, the mean was marked as ND. This aggregation of replicate results decreased the total number of
records by 5 percent.

Where a concentration of TKN and a concentration of nitrate-nitrite were both available, the EPA
summed the two values to estimate TN. The EPA defined these paired concentrations as being from the
same facility, data source, and date. All TKN concentrations were detected, whereas nitrate-nitrite was
ND in nearly half of the samples, represented in the summations by their MDLs (all at 0.06 mg/L). In total,
39 TN concentrations were calculated using this method, making up 11 percent of all TN concentrations
in this analysis.

Next, to serve as additional inputs to the calculation of monthly average limitations, the EPA aggregated
daily-interval data within calendar months. Where a facility had daily-interval data for an analyte,
concentrations were averaged within months to create a new series of monthly-interval data (graphed in
Appendix B Figure B-l). The EPA did not consider series with date ranges of less than one week as
representative of a month; this excluded the EPA sampling data, which spanned for approximately five
days at each facility. Importantly, these newly aggregated series were in addition to, not instead of,
original data on the daily scale. Thus, a series of daily data at a facility could serve as an input to both the

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daily-interval calculations as-is, and to the monthly-interval calculations after aggregation within calendar
months, addressed in percentile calculations below (Section 13.2.5).

At some facilities, different data sources contributed to measurements within the same time period.
Where more than one concentration of an analyte was available at the same place and at the same time,
the EPA took the mean of the concentrations, as has typically been done in ELGs (e.g., U.S. EPA, 2015).
Although there were no instances of different sources with measurements on the same date in daily-
interval data, there were different monthly-interval data sources that occurred within the same calendar
months. This included, but was not limited to, series of daily-interval data aggregated within months.
Therefore, the EPA averaged monthly-interval concentrations that shared the same facility, analyte, and
calendar month. As with previous aggregation steps, where at least one value was detected, the mean
was marked as detected.

Following the aggregation of replicates and nitrogen analytes, the calculation of additional monthly data
sets, and combining the different sources of data, each of the 34 facilities ultimately had one or two
series of concentrations per analyte: one series of daily-interval data and/or one series of monthly-
interval data. These served as the basis for calculations of statistical metrics that defined the limitations
and are available in Limitations Supplemental Data (U.S. EPA, 2023d), in the "Post-Aggregation"
spreadsheet.

Influent Data

After excluding and aggregating the data, the EPA applied data editing criteria by pollutant and facility to
select the datasets to be used for developing the limitations. These criteria are referred to as the long-
term average (LTA) test. The EPA often uses the LTA test to ensure that the pollutants are present in the
influent at sufficient concentrations to evaluate treatment effectiveness at the facility for the purpose of
calculating effluent limitations. By applying the LTA test, the EPA ensures that the limitations result from
treatment of the wastewater and not simply the absence or substantial dilution of that pollutant in the
wastestream. For each pollutant for which the EPA calculated a limitation, the influent first had to pass a
basic requirement that at least 50 percent of the influent measurements had to be detected at any
concentration. If the data set at a facility passed the basic requirement, then the data had to pass one of
the following two criteria to pass the LTA test:

• Criterion 1: At least 50 percent of the influent measurements in a data set at a facility were detected
at levels equal to or greater than 10 times the baseline value.

• Criterion 2: At least 50 percent of the influent measurements in a data set at a facility were detected
at any concentration and the influent arithmetic average was equal to or greater than 10 times the
baseline value.

The EPA used the baseline values that were developed for the previous MPP effluent limitations
guidelines and standard (ELGs), finalized in 2004. The baseline values are typically equal to the nominal
quantitation limit identified for the analytical method for a pollutant. See the Pollutants of Concern (POC)
Analysis for the Meat and Poultry Products Proposed Rule (U.S. EPA, 2023e) for details on how baseline
values were identified. No baseline value is available for TN; consistent with the POC analysis, EPA used
the MDL of 0.012 mg/L in place of baseline value for the purpose of this LTA test.

If the data set at a facility failed the basic requirement, then the EPA excluded the facility's effluent data
for that pollutant when calculating limitations. If the data set for a facility passed the basic requirement
but failed both criteria, the EPA excluded the facility's effluent data for that pollutant when calculating
limitations.

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For the 34 facilities included in the EPA's limitations analysis, the EPA compiled influent data by analyte.
Influent data were available for 13 facilities.14 The EPA lacked influent data for 21 facilities, but—because
all the available influent data pass the LTA test, showing that pollutants are present in the influent at
sufficient concentrations to evaluate treatment effectiveness—the EPA reasonably assumes that
additional facility data would demonstrate a similar result. Therefore, the EPA continued to include data
for all facilities in the limitations analysis. If additional influent data become available (through public
comment, additional sampling, or other data submissions), the EPA will further evaluate the data
following proposal. See Appendix B, Table B-l, for a summary of the data by facility and results of the LTA
test.

13.2 Statistical Analysis

The proposed limitations for pollutants are "daily maximums" and "maximums for monthly averages."
Definitions provided in 40 CFR 122.2 state that the daily maximum limitation is the "highest allowable
'daily discharge'" and the maximum for monthly average limitation (also referred to as the "monthly
average limitation") is the "highest allowable average of 'daily discharges' over a calendar month,
calculated as the sum of all 'daily discharges' measured during a calendar month divided by the number
of 'daily discharges' measured during that month." Daily discharges are defined as the "'discharge of a
pollutant' measured during a calendar day or any 24-hour period that reasonably represents the calendar
day for purposes of samplings."

The effluent limitations and standards are based on LTA effluent values and variability factors (VFs; one
on the daily scale and another on the monthly scale) that account for variation in treatment performance
within a particular treatment technology over time. For simplicity, in the remainder of this document, the
final effluent limitations and/or standards are referred to as "limitations."

In establishing daily maximum limitations, the EPA's objective is to restrict the discharges on a daily basis
at a level that is achievable for a facility that targets its treatment at the LTA. The EPA acknowledges that
variability around the LTA results from normal operations, such that facilities at times discharge at levels
that are greater than or less than the LTA. To allow for the possibly higher daily discharges, the EPA has
established the daily maximum limitation. A facility that discharges consistently at the daily maximum
limitation would not be operating its treatment to achieve the LTA, which is part of the EPA's objective in
establishing the daily maximum limitations. That is, targeting treatment to achieve the limitations may
result in frequent values in exceedance due to routine variability in treated effluent.

In establishing monthly average limitations, the EPA's objective is to provide an additional restriction to
help ensure that facilities target their average discharges to achieve the LTA. The monthly average
limitation requires continuous dischargers to provide ongoing control, on a monthly basis, that
complements controls imposed by the daily maximum limitation. To meet the monthly average limitation,
a facility must counterbalance a value near the daily maximum limitation with one or more values well
below it. To achieve compliance, these values must result in a monthly average value at or below the
monthly average limitation.

13.2.1 Autocorrelation

The EPA considered whether autocorrelation was likely to be present in the effluent data. When data are
said to be positively autocorrelated, it means that consecutive measurements are related; for example, a
high measurement on one day would likely indicate a high measurement on the next day as well. In such
a case, the variability of the data (more specifically, the a parameter in Section 13.2.3) would increase.
The EPA has not incorporated an autocorrelation adjustment into its estimates of VFs or LTAs for the
proposed rule. In many industries, measurements in final effluent are likely to be similar from one day to

14 One other facility did provide data for one of two streams entering the wastewater treatment system. It was
excluded from the analysis, though, as the characterization data were representative of a wastewater that was only
partially treated (e.g., the stream entered the treatment system downstream of the DAF).

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the next because of the consistency from day to day in the production processes, and in final effluent
discharges due to the hydraulic retention time of wastewater in basins, holding ponds, and other
components of wastewater treatment systems. To determine if autocorrelation exists in the data, a
statistical evaluation is necessary. For proposal, the EPA has assumed no autocorrelation adjustment is
necessary because of the following:

• Based on data collected from industry through site visits and the MPP Questionnaire, MPP treatment
systems include units such as equalization tanks, holding ponds, or basins. Retention times of these
systems are likely on the order of days, not months, likely making autocorrelation irrelevant or
negligible on a monthly scale.

• Many equally spaced, detected measurements for each pollutant are required to estimate
autocorrelation. Often, series of data used in this limitations analysis had inconsistent intervals. For
example, one series may contain data for daily or every other day concentrations, skipping weekends;
another series may be weekly on average but actually have data in six- to nine-day increments.
Frequent gaps exist due to NDs, a lack of measurements, or both. Such inconsistencies would make
autocorrelation estimates unlikely to be reliable.

• Large sample sizes are needed for potential evaluation of autocorrelation; the EPA considers series
with at least 30 values sufficient. In Appendix B, Figure B-2 shows timelines of monthly-interval series
with at least 30 values and Figure B-l shows those of daily-interval series (as well as others with
fewer values). Despite their sufficient sample sizes, some of these series are not usable due to gaps or
irregular spacing, and not all combinations of analyte and interval are represented.

• Transferring any autocorrelation estimates calculated from one series to other series may be
inappropriate in this application. MPP data used for the calculation of daily limitations are available
for daily, weekly, biweekly, and irregular sub-monthly intervals. Since autocorrelation estimates are
specific to their time increments only, a different estimate would be needed for each actual
increment. Also, analytes have different chemical properties, and thus could be affected differently
by the same treatment systems, adding uncertainty to the representativeness of any transfers across
analytes.

If additional sampling data are collected, through the comment period or via additional sampling, the EPA
intends to evaluate autocorrelation and, if necessary, adjust the limitations for the final rule.

13.2.2 Modified Delta Lognormal Distribution

For the limitation calculations, the EPA used the modified delta lognormal distribution, which is a mixed
distribution due to its two components.

• First, detected values are assumed to follow the lognormal distribution (shown as the curve in Figure
13-1), which is continuous.

• Second, NDs are treated as additional discrete values represented by their MDLs (shown as the bars
in Figure 13-1; discussed in Kahn and Rubin, 1989).

This is a modification of what is also called the zero-adjusted lognormal distribution (Rigby et al., 2019),
since discrete values are numbers other than zero. This distribution has been applied to pollution
concentrations in multiple applications, including ELGs (Owen and DeRouen, 1980; U.S. EPA, 1995, 2002a,
2002b, 2004, 2015). In series of concentrations without NDs, results are equal to those of a lognormal
distribution. Assuming a distribution is necessary because calculations based on data sets with small
sample sizes are less likely to be representative of a system, especially calculations quantifying the upper
tail of a distribution (as described below).

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Figure 13-1. Example of a Modified Delta Lognormal Distribution

Although bacteria, including fecal coliform and E. coli, are often measured as discrete values (i.e., counts
of colonies, without fractions), some available data were provided with fractional values. These bacterial
values were used as-is and treated as continuous, like the other analytes.

Calculations using the distribution were performed within series of concentrations defined by common
facility, analyte, and time interval (daily- or monthly-interval data). After the EPA calculated the metrics of
each series, they were combined. The following sections describe these steps, all completed using R
software (R Foundation, 2023; graphs made using R package ggplot2, Wickham, 2023).

13.2.3 Distribution Parameters

For the LTA and VF metrics of a series to be calculated, its distributional parameters must first be
quantified. Not all lognormal distributions look the same: the center can move to the left or right (greater
than zero), and they can be wide or narrow. These characteristics are defined using two parameters:

• The ju parameter is equal to the mean of the natural-log-transformed concentrations, defining the
location of the distribution.

• The a parameter defines the scale of how widely or narrowly the concentrations are distributed and
is the standard deviation of the population of log-transformed values.

Figure 13-2 shows how different ranges of each parameter affect the resulting shape of a lognormal
distribution.

Constant o, varying ^ Constant n, varying a

Figure 13-2. Example Lognormal Distributions Varying by the Parameters \i (Left) and o (Right)

Note: Low values of |i and a are represented by light gray, and high values are represented by dark gray. The X axis is on the log

scale, making lognormal distributions appear normally distributed.

The EPA computed these parameters using software functions based in maximum likelihood estimation, a
common statistical method used for this purpose. The software functions work by finding the maximum
point of the lognormal distribution's log-likelihood function, which is derived from its probability density
function. The software uses numerical maximization, an iterative optimization method, to converge on ju

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and a values for each series. Details of the distributional formulas and computational methods are found
in Rigby et al., 2019 (Chapters 10, 11, and 19). In practice, the EPA computed the parameters using R
function gamlss() for series of concentrations without NDs (Rigby and Stasinopoulos, 2023) and
gamlssZadjO for those with any NDs (Enea et al., 2019); R code is provided in Appendix B, Table B-2. The
EPA used these functions to produce a column of ju values and a column of a values, one pair per series of
concentrations.

However, these methods can only be applied to series with at least two distinct detected values. For
series with fewer values, the EPA computed ju as the arithmetic mean of the untransformed
concentrations, using MDL substitutions for NDs. It is not possible to calculate a a or standard deviation
for these series because they inherently have no or negligible variation. Sets with fewer than two distinct
detected values therefore cannot contribute to VF calculations but do contribute to analytes' LTA
calculations.

The two parameters of location and scale served as the inputs to the remaining calculations.

13.2.4 LTA Calculations

In calculating the limitations, the EPA determined an average performance level (the LTA) over time that a
facility with well-designed, well-operated model technologies can achieve, using data from facilities that
use the model technologies. Statistically, the LTA is the mean of the underlying statistical distribution of
the daily values. The EPA expects that all facilities subject to the limitations will design and operate their
treatment systems to achieve the LTA performance level consistently, since facilities with well-designed
and well-operated model technologies have demonstrated that this can be done.

The EPA defines the LTA using both the continuous and discrete portions of the modified delta lognormal
distribution. The continuous portion of the distribution, representing detected concentrations, is defined
as the expected value of the lognormal distribution (Kahn and Rubin, 1989). An expected value represents
the most likely LTA of a data set, and its formula is derived from the lognormal distribution's probability
density function (e.g., Rigby et al., 2019). Equation 13-1 is the expected value of the continuous
lognormal distribution (Ec), where ju and a are the parameters calculated as described in Section 13.2.3.

Equation 13-1

The mean of the discrete portion of the modified delta lognormal distribution (Ed), representing NDs, is
simply a weighted average of their MDLs:

Ed=-^SiLi Equation 13-2

i=i

where <5 is the proportion of ND values and the sum of 5,, i = 1, k, which represents the proportion of
ND values associated with the ith detection limit, E.

In practice, the EPA calculated this by taking the mean of series' NDs, which had been substituted with
their MDLs and undergone earlier aggregation steps. Equation 13-2 is what "modifies" the delta
lognormal distribution.

The discrete and continuous expected values proportionally combine to define the LTA of a series:

LTA = SEd + (1 — S)EC Equation 13-3

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For series without NDs, which make up most of the series in this analysis, <5 is zero; the continuous
expected value Ec is therefore the LTA.

LTA calculations differed in some circumstances. This distribution-based LTA calculation method is only
possible in series with at least two distinct detected values, where parameters are quantifiable. In the
remaining series with one or no distinct detected values, the EPA used the arithmetic mean of the
untransformed concentrations, with MDL substitutions for NDs, as the LTA. Also, the daily-interval data
aggregated within calendar months to become monthly-interval data were not used for LTA calculations,
since their monthly and daily LTAs would be the same. Differently stated, the EPA calculated the LTA of a
daily-interval data series for a facility and analyte and did not recalculate another LTA using the same data
aggregated to a monthly interval. This also ensured consistency within each facility.

At this stage, each combination of common facility, analyte, and interval (daily or monthly) had an LTA.
The next step was to calculate a corresponding VF to each LTA.

13.2.5 Percentile Calculations

In addition to the LTA, which describes an average concentration of each series, limitations must reflect
the demonstrated variability or range of those concentrations. The EPA calculates effluent limitations
based on percentiles that should be both high enough to accommodate reasonably anticipated variability
within control of the facility and low enough to reflect a level of performance consistent with the Clean
Water Act (CWA) requirement that these effluent limitations be based on the "best" technology. The
daily maximum limitation is an estimate of the 99th percentile of the distribution of the daily
measurements. The monthly average limitation is an estimate of the 95th percentile of the distribution of
the monthly averages of the daily measurements.

The EPA uses the 99th and 95th percentiles to draw a line at a definite point in the statistical distributions
that would ensure that facility operators work to establish and maintain the appropriate level of control.
These percentiles reflect a longstanding Agency policy judgment. Statistical methods provide a logical and
consistent framework for determining values that form a reasonable basis for effluent limitations.
Limitations development accounts for the reasonably anticipated variability in discharges that may occur
at a well-operated facility. By targeting the LTA, a well-operated facility will be able to always meet the
effluent limitations because the EPA has incorporated an appropriate allowance for variability.

The EPA's methodology for establishing effluent limitations based on certain percentiles of the statistical
distributions may give the impression that the EPA expects occasional exceedances of the limitations. This
conclusion is incorrect. The EPA promulgates limitations that facilities can always meet by properly
operating and maintaining their treatment technologies. The EPA does not expect facilities to operate
their treatment systems so as to violate the limitations at some pre-set rate merely because probability
models are used to develop limitations. If an exceedance is caused by an upset condition, the facility
would have an affirmative defense to an enforcement action if the requirements of 40 CFR 122.41(n) are
met. Exceedances caused by a design or operational deficiency, however, are indications that the facility's
performance does not represent the appropriate level of control. Public commenters often raise the issue
of exceedances or excursions of limitations (i.e., values that exceed the limitations). For a summary of
court rulings on this point from other ELGs, see U.S. EPA, 2015, Section 13.5.3, "Compliance with
Limitations."

The facility-specific data sets represent operation of treatment systems that represents the BAT or Best
Available Demonstrated Control Technology (BADCT). In some cases, however, although these facilities
were operating model technology, these data sets, or periods of time within a data set, may not
necessarily represent the optimized performance of the technology. As described in Section 13.1, the EPA
excluded certain data from the data sets used to calculate the effluent limitations. At the same time,
however, the data sets used to calculate effluent limitations still retain some observations that likely
reflect periods of less-than-optimal performance or periods where the facility was targeting less than
optimal effluent quality (e.g., only limitations identified in an individual permit as opposed to the best

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effluent quality possible). The EPA retained these data in developing the limitations because they help to
characterize the variability in treatment system effluent.

The calculation of a percentile assumes the same modified delta lognormal distribution. The EPA
calculated percentiles using a software function that solves for the inverse cumulative distribution
function of the lognormal, in combination with the proportion of NDs, or 6 (Rigby et al., 2019, Chapters 2
and 9; functions gen.Zadj() and ql_OGNOZadj() from Enea et al., 2019; Kahn and Rubin, 1989). The output
is the concentration at which, for example, 99 percent of the values in a modified delta lognormal
distribution with a given ju, a, and <5 are smaller. For series without NDs, the EPA used a standard
lognormal function only requiring |a and a (qLOGNO from Rigby and Stasinopoulos, 2023). The R code is
provided in Appendix B, Table B-3.

Each series' 99th percentile concentrations were calculated from daily-interval data, and each series' 95th
percentile concentrations were calculated from monthly-interval data. The series of daily-interval data
averaged within calendar months were included in these 95th percentiles of monthly-interval data, since
distributions of averages across time have different, lower variability than more frequent measurements.

Percentile calculations are dependent on a to inform the spread of the distribution, and therefore could
only be calculated for series with at least two distinct detected values.

13.2.6 VF Calculations

The VF is an allowance for the variability in pollutant concentrations when processed through well-
designed, well-operated treatment systems. It incorporates all components of variability, including
shipping, sampling, storage, and analytical variability. VFs are calculated from the data from facilities
using the model technologies. If a facility designs and operates its treatment system to meet the relevant
LTA, the EPA expects the facility should be capable of always meeting the proposed limitations. VFs
ensure that normal fluctuations in a facility's treatment are accounted for in the limitations. By
accounting for these reasonable excursions above the LTA, the EPA's use of VFs results in limitations that
are typically well above the actual LTAs.

As a metric, the VF scales the calculated percentiles relative to their distributions' LTAs and is therefore
unitless. Narrow distributions have percentiles relatively near their LTAs, and thus are greater than but
near 1; wide distributions have percentiles relatively far from their LTAs and can be multiple times larger.
The VF equations are:

VFd = if a Equation 13-4

VFm = P95/lta Equation 13-5

Where: d = daily interval

m = monthly interval
P = percentile as labeled

The percentiles and LTAs were calculated from the same series of concentrations, sharing the same
facility, analyte, and interval. Where a faciIity-analyte combination had sufficient daily-interval data as
well as monthly-interval data, it had both a VFd and a VFm. Where daily-interval data were averaged within
calendar months to create monthly-interval data, both VF calculations used the same LTA, calculated
from the daily-interval data. Because percentiles can only be calculated from series with enough
variability, only series with at least two distinct detected values had VFs.

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13.2.7 Limitation Calculations

At this stage, each facility-analyte-intervaI series had an LTA, a VFd if it had enough daily-interval data, and
a VFm if it had enough monthly-interval data. The EPA performed several checks of these metrics. No VFs
were less than 1. Within each distribution, no LTAs were greater than their 95th or 99th percentiles, and no
95th percentiles were greater than corresponding 99th percentiles. All LTAs and percentiles were
superimposed on their series' concentrations graphically to check whether LTAs were plausibly near
distribution means and high percentiles were at upper tails (Appendix B, Figure B-3 through Figure B-10).

Some facilities had two LTAs for the same analyte: one calculated from a daily-interval series and another
from a monthly-interval series. Since each facility should be represented by one LTA, the EPA took the
mean of the two values to produce that single LTA. Metrics for all facilities are listed in Table B-4 through
Table B-ll. In these tables, each row is one series, labeled by facility code (to protect confidential
business information [CBI]) and interval. If a daily series had at least two distinct detected values, its 99th
percentile and daily VF columns were populated; similarly, if a monthly series had at least two distinct
detected values, its 95th percentile and monthly VF columns were populated. Rows with both daily and
monthly VFs came from daily-interval series that were averaged within calendar months.

Next, the EPA calculated one LTA for each analyte by taking the median of all facilities' LTAs, producing
industry-wide values. Similarly, the EPA calculated one median daily VF and one median monthly VF for
each analyte, combining those of all facilities. Calculating medians rather than means across facilities
recognizes that some sets of metrics formed skewed distributions when combined, making the median a
more representative measure of centrality. Figure 13-3 shows box plots of the LTAs and the VFd and VFm
values. Each point represents one facility, colored by its type of MPP processing. Boxes extend from the
25th to the 75th percentile (interquartile range, or IQR), with a thick line at the median, a diamond at the
mean, and whiskers extending up to 1.5 times the IQR. Facilities' values are also listed in Appendix B,

Table B-4 through Table B-ll, with medians in Table 13-2 below.

129

-------
A. LTAs by Analyte

©

ro

TSS -
TP-
TN-
O&G -

c Fecal coliform -
<

E. coli-

Chloride-

BOD-



•i

-HL

of h*

3~3

O

k

¦ 1111	i	1111in|	i	11111111	i	11111111	i	111'iiii| p 11111

0.1

1	10	100	1000

LTA (mg/L orMPN/100 mL)

B. Daily VFs by Analyte

3	10

Daily VF (unitless)

C. Monthly VFs by Analyte

Monthly VF (unitless)

O Mean

Type of
Processing

•	Meat First
Meat Further
Poultry First

•	Render

Figure 13-3. Box Plots of Afi Facilities' LTAs and VFs for Each Analyte

130

-------
With one LTA, VFd, and VFm per analyte, the EPA calculated a daily maximum limitation and a monthly
average limitation using:

Daily maximum limit = median LTA x median VFd Equation 13-6

Monthly average limit = median LTA X median VFm Equation 13-7

See Table 13-2 for a breakdown of the number of facilities informing the LTA, VFd, and VFm per analyte
and the results of the statistical analysis. Columns list the number of facilities that informed each median
LTA and VF, the resulting overall LTAs and VFs, and the daily maximum and monthly average limitations.

Table 13-2. Resulting Limitations for All Analytes

Analyte

Number

of
Facility
LTAs

Number

of
Facility
Daily VFs

Number
of Facility
Monthly
VFs

Median LTA

(mg/L or
MPN/100 mL)

Median
Daily VF
(Unitless)

Median
Monthly

VF
(Unitless)

Daily Max
Limitation
(mg/L or
MPN/100 mL)

¦Ofni

BOD

903

2.16

1.47

1,950

1,320

O&G

484

3.38

2.88

1,630

1,390

TSS

676

2.34

1.37

1,580

925

Chlorides

533

1.07

—

569

—

E. coli

2.88

5.01

3.01

14.4

8.66

Fecal
coliform

8.07

6.21

2.73

50.1

22.1

6.50

3.14

1.91

20.4

12.4

0.373

3.97

2.07

1.48

0.772

Abbreviations: mg/L = milligrams per liter, ml_ = milliliters, MPN = most probable number.

Notes: Units are in mg/L for all analytes, except E. coli and fecal coliform which are in MPN/100 mL. Values are presented as
three significant figures. Chlorides only have daily-interval data over five days. As a result, only a daily maximum limitation was
calculated. No monthly average chloride limitation could be calculated due to lack of data.

The number of facilities informing LTAs was always greater than or equal to the number of facilities
informing VFs, since series with fewer than two distinct detected values could have arithmetic means, but
not standard deviations, calculated. TP had the most facility-level data, whereas chlorides data were only
available from one facility on a daily interval. All facilities' LTAs and VFs used to calculate these overall
medians are listed in Appendix B, Table B-4 through Table B-ll, and graphed in Figure 13-3 below.

13.2.8 Sensitivity Analyses

As an additional check, the EPA reran the analysis without concentrations that were spaced at annual
intervals (i.e., 12 months apart) or quarterly intervals (i.e., three months apart). In the main analysis,
these 19 concentrations were classified as monthly-interval data and most were aggregated with monthly
data from other sources at the same facility (in Section 13.1.2). Their interval suggests that they might be
representative of one year or one quarter, rather than one month. The EPA does not have further
information from the facilities to clarify this uncertainty; therefore, the EPA removed these 19
concentrations and reran the calculations as a sensitivity analysis. Their omission changed the BOD and
TN limitations by a range of -5.0 percent to +0.6 percent. This occurred because two monthly series were
made up of only quarterly concentrations; their removal decreased the number of LTAs and monthly VFs
by one for each of BOD and TN, affecting the medians. Given the small effect of these concentrations on
the results, the EPA retained them in the interest of using the most data available to inform national
limitations.

131

-------
The EPA also reran the analysis using a left-censored lognormal distribution rather than a modified delta
lognormal distribution, to quantify the effect of this applied distributional form. Although both
distributions are based in the lognormal shape, the left-censored distribution differs in the handling of
NDs: rather than being mixed, comprising a discrete (ND) part and a continuous (detected) part, it
handles NDs as continuous values. It does so using the lognormal cumulative distribution function to
calculate likelihoods, considering NDs as values between their MDL and zero. The EPA used functions
from package gamlss.cens to recalculate ju and a parameters for all series with at least one ND (for more
details on the functions, see Chapter 6 of Stasinopoulos et al., 2017, and Stasinopoulos et al., 2018).
Although results were the same for analytes without NDs, this method was found to be sensitive to the
most skewed distributions with NDs. A few values of afor bacteria were large, inflating expected values
and percentiles. Modified delta lognormal distributions' a values are not affected by NDs, making them
less sensitive. Therefore, the EPA continued to base the main limitation calculations on the modified delta
lognormal distribution, as it has historically.

13.3 Summary of Limitations

Section 13.3.1 summarizes the effluent limitations by technology basis, and Section 13.3.2 presents the
proposed effluent limitations for MPP process wastewater by level of control.

13.3.1 Summary of Limitations by Technology Basis

Results for all limitations evaluated are shown in Table 13-3 and Table 13-4 for direct and indirect
dischargers, respectively. The daily maximum and monthly average limitations in Table 13-3 and Table
13-4 are based on the values shown in Section 13.2.7.

Table 13-3. NSPS, BAT, and BPT Limitations by Technology Basis for Direct Dischargers

Treatment System

TP
(mg/L)

TN
(mg/L)

Fecal Coliform
(MPN/100
mL)

E. coli
(MPN/100 mL)

Daily Maximum Limitations

P with Partial N Treatment for Direct
Dischargers

1.48

5o.r

14.4a

P with Full N Treatment for Direct
Dischargers

1.48

20.4

50.1

14.4

Monthly Average Limitations

P with Partial N Treatment for Direct
Dischargers

0.772

22.1

8.66

P with Full N Treatment for Direct
Dischargers

0.772

12.4

22.1

8.66

Abbreviations: Best Practicable Technology (BPT), mg/L = milligrams per liter, ml_ = milliliters, MPN = most probable number, New
Source Performance Standards (NSPS).

a — Transferred from P with Full N Treatment for Direct Dischargers.

132

-------
Table 13-4. PSES and PSNS Limitations by Technology Basis for Indirect Dischargers

Treatment System

BOD
(mg/L)

O&G
(mg/L)

TSS
(mg/L)

TP
(mg/L)

TN
(mg/L)

Daily Maximum Limitations

BOD, O&G, and TSS Treatment for Indirect
Dischargers

1,950

1,630

1,580





P with Full N Treatment for Indirect Dischargers

l,950a

l,630a

l,580a

1.48b

20.4b

Monthly Average Limitations

BOD, O&G, and TSS Treatment for Indirect
Dischargers

1,320

1,390

925





P with Full N Treatment for Indirect Dischargers

l,320a

l,390a

925a

0.772b

12.4b

Abbreviations: mg/L = milligrams per liter, ml_ = milliliters, MPN = most probable number, PSES = Pretreatment Standards for
Existing Sources, PSNS = Pretreatment Standards for New Sources,
a — Transferred from BOD, O&G, and TSS Treatment for Indirect Dischargers,
b — Transferred from P with Full N Treatment for Direct Dischargers.

Effluent limitations for direct dischargers were developed as follows:

•	P with Full N Treatment for Direct Dischargers establishes limitations for TP, TN, fecal coliform, and E.
coli.

•	P with Partial N Treatment for Direct Dischargers establishes limitation for TP, fecal coliform, and E.
coli.

Effluent limitations for indirect dischargers were developed as follows:

•	BOD, O&G, and TSS Treatment for Indirect Dischargers limitations for all pollutants are based on DAF
effluent data from facilities operating treatment systems that include the technology basis as either
their sole treatment or as a component of a larger treatment system.

•	BOD, O&G, and TSS limitations for P with Full N Treatment for Indirect Dischargers are based on DAF
effluent data and transferred from BOD, O&G, and TSS Treatment for Indirect Dischargers. The
technology basis for BOD, O&G, and TSS treatment is included in both technology systems; therefore,
the EPA assumes both technologies can achieve the same level of treatment in the effluent from
wastewater treatment.15

•	TN and TP limitations for P with Full N Treatment for Indirect Dischargers are transferred from P with
Full N Treatment for Direct Dischargers. The technology basis for TP treatment and TN treatment
includes these treatment technologies; therefore, the EPA assumes both technologies can achieve
the same level of treatment in the effluent from wastewater treatment.

See Sections 9 and 10 and the Preamble for additional details on the EPA's selection of the technology
systems and development of the technology bases.

13.3.2 Long-Term Averages and Effluent Limitations for MPP Process Wastewater

Table 13-5 presents LTAs and effluent limitations for MPP process wastewater for existing and new
sources. As described in the Preamble, the proposed limitations vary by ELG subpart; these subparts are
also noted in Table 13-5.

Due to routine variability in treated effluent, an MPP facility that targets its treatment to achieve
pollutant concentrations at a level near the values of the daily maximum limitation or the monthly

15 The EPA will reevaluate this approach for the final rulemaking and consider calculating separate limitations for
BOD, O&G, and TSS for P with Full N Treatment for Indirect Dischargers.

133

-------
average limitation may experience frequent values exceeding the limitations. For this reason, the EPA
recommends that facilities design and operate their treatment systems to achieve the LTA for the model
technology. In doing so, a system that is designed to achieve the BAT/NSPS level of control would be
expected to meet those limitations.

Table 13-5. LTAs and Limitations for Existing and New Sources

ELG
Subpart

Level of
Control

Pollutant

LTA

Daily Maximum
Limitation

Monthly Average
Limitation



BPTa

Fecal coliform (MPN/100 ml_)

8.07

50.1

22.1



BAT,a
NSPSb

TN (mg/L)

6.50

20.4

12.4

A-D,
F-L

TP (mg/L)

0.373

1.48

0.772

E. coli (MPN/100 mL)

2.88

14.4

8.66

PSES,a
PSNSb

BOD (mg/L)

903

1,950

1,320



TSS (mg/L)

676

1,580

925



O&G (mg/L)

484

1,640

1,390

Abbreviations: Best Practicable Technology (BPT), mg/L = milligrams per liter, ml_ = milliliters, MPN = most probable number, New

Source Performance Standards (NSPS), PSES = Pretreatment Standards for Existing Sources, PSNS = Pretreatment Standards for

New Sources.

a — For existing sources.

b — For new sources.

13.4 References

1.	Enea, M., Stasinopoulos, M., Rigby, R., and Hossain, A. 2019. gamlss.inf: Fitting Mixed (Inflated and
Adjusted) Distributions (March). R package version 1.0-1. DCN MPP00875. Available online at:
https://CRAN.R-proiect.org/package=gamlss.inf.

2.	Kahn, H. D. and Rubin, M. B. 1989. Use of Statistical Methods in Industrial Water Pollution Control
Regulations in the United States (November). Environmental Monitoring and Assessment, vol. 12, pp.
129-148. DCN MP00876. Available online at: https://doi.org/10.1007/BF0Q394226.

3.	Owen, W. J. and DeRouen, T.A. 1980. Estimation of the Mean for Lognormal Data Containing Zeroes
and Left-Censored Values, with Applications to the Measurement of Worker Exposure to Air
Contaminants (December). Biometrics, vol 36, no. 4, pp. 707-719. DCN MP00878. Available online at:
https://doi.orR/10.2307/2556125.

4.	R Foundation. 2023. R: A Language and Environment for Statistical Computing (June). R version 4.3.1
(Beagle Scouts). DCN MP00879. Available online at: https://www.R-project.org/.

5.	Rigby, R. and Stasinopoulos, M. 2023. gamlss: Generalized Additive Models for Location, Scale and
Shape (January). R package gamlss. Version 5.4-12. DCN MP00880. Available online at:
https://CRAN.R-project.org/package=gamlss.

6.	Rigby, R., Stasinopoulos, M., Heller, G. Z., and De Bastiani, F. 2019. Distributions for Modeling
Location, Scale, and Shape: Using GAMLSS in R (September). Ed. 1. DCN MP00881. Available online at:
https://doi.org/10.1201/9780429298547.

7.	Stasinopoulos, M., Rigby, R., Heller, G. Z., Voudouris, V., and De Bastiani, F. 2017. Flexible Regression
and Smoothing: Using GAMLSS in R (April). DCN MP00882. Available online at:
https://doi.org/10.1201/b21973.

8.	Stasinopoulos, M., Rigby, R., and Mortan. N. 2018. gamlss.cens: Fitting an Interval Response Variable
Using "gamlss.family" Distributions (January). R package version 5.0-1. DCN MP00883. Available
online at: https://CRAN.R-project.org/package=gamiss.cens.

134

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9. U.S. EPA. 1995. Statistical Support Document for Proposed Effluent Limitations Guidelines and
Standards for the Centralized Waste Treatment Industry (January). EPA-821-R-95-005. Available
online at: https://nepis.epa.gov/Exe/ZvPURL.cgi?Dockev=200055NA.TXT

10. U.S. EPA. 2002a. Development Document for the Final Effluent Limitations Guidelines and Standards
for the Iron and Steel Manufacturing Point Source Category (April). EPA-821-R-02-004. Available
online at: https://www.epa.Bov/sites/default/files/2015-10/documents/ironsteel dd 2002.pdf

11. U.S. EPA. 2002b. Development Document for the Proposed Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products Industry Point Source Category (January). EPA-821-B-01-
007. Available online at: https://nepis.epa.gov/Exe/ZyPURL.cgi?Dockev=20002F0Q.TXT

12. U.S. EPA. 2004. Technical Development Document for the Final Effluent Limitations Guidelines and
New Source Performance Standards for the Concentrated Aquatic Animal Production Point Source
Category (August). EPA-821-R-04-012. Available online at:

https://www.epa.gov/sites/default/files/2015-ll/documents/caap-aquE I 2QQ4.pdf

13. U.S. EPA. 2015. Technical Development Document for the Effluent Limitations Guidelines and
Standards for the Steam Electric Power Generating Point Source Category (September). EPA-821-R-15-
007. Available online at: https://www.epa.gov/sites/default/files/2015-10/documents/steam-electric-
tc f

14. U.S. EPA. 2023a. Analytical Database Methodology for the Meat and Poultry Products Proposed
Rulemaking (November). DCN MP00303.

15. U.S. EPA. 2023b. Evaluation of Technology Basis and Identification of BAT Facilities (November). DCN
MP00304.

16. U.S. EPA. 2023c. Meat and Poultry Products Profile Methodology Memorandum (November). DCN
MP00306.

17. U.S. EPA. 2023d. Limitations Supplemental Data (November). DCN MP00210.

18. U.S. EPA. 2023e. Pollutants of Concern (POC) Analysis for the Meat and Poultry Products Proposed
Rule (November). DCN MP00190.

19. Wickham, H. 2023. ggplot2: Elegant Graphics for Data Analysis (April). R package version 3.4.2. DCN
MP00889. Available online at: https://ggplot2.tidyverse.org/.

135

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Appendix A

For completeness, the U.S. Environmental Protection Agency evaluated regulatory options 2 and 3. Table
A-l and Table A-2 present the annualized cost and removals for Best Practicable Control Technology
Currently Available (BPT) and Best Conventional Pollutant Control Technology (BCT) used to calculate the
incremental cost per pound for Regulatory Options 2 and 3, respectively. Table A-3 includes the results of
the Publicly Owned Treatment Works (POTW) Test and Industry Cost Test for both regulatory options.
Regulatory Option 2 affects the same population of facilities as Regulatory Option 1 (see Section 9); thus,
the incremental costs and removals are identical.

Table A-l. Incremental Costs and Conventional Pollutant Removals—Regulatory Option 2

Level of Control

Annualized

Costs
(M 2022$,
Post-Tax)

Total
Incremental
Removals
(M lbs.)

Industry
Incremental
Removal Cost
(2022$/lbs.)

Subcategories A—D

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$1.63

12.8

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$162

627

$0.26

Subcategories F—l

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$2.11

5.98

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$162

263

$0.62

Subcategory J

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$0.64

2.90

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$51.50

177

$0.29

Subcategory K

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$6.64

164

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$219

377

$1.00

Subcategory L

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$1.42

22.0

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$68.90

73.0

$1.32

Source: U.S. EPA. 2023. Pollutant Loadings and Removals Methodology for the Meat and Poultry Products Proposed Rulemaking
(November). DCN MP00302; U.S. EPA. 2023. Regulatory Impact Analysis for Proposed Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products Point Source Category (RIA) (November). EPA-821-R-23-014.

Abbreviations: BOD = biochemical oxygen demand, lbs. = pounds, M = million, N = nitrogen, O&G = oil and grease, P =
phosphorus, TSS = total suspended solids.

Note: Values presented as three significant figures.

136

-------
Table A-2. Incremental Costs and Conventional Pollutant Removals—Regulatory Option 3

Level of Control

Annualized

Costs
(M 2022$,
Post-Tax)

Total
Incremental
Removals
(M lbs.)

Industry
Incremental
Removal Cost
(2022$/lbs.)

Subcategories A—D

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$12.70

28.2

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$205

661

$0.30

Subcategories F—l

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$5.94

11.2

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$350

366

$0.97

Subcategory J

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$0.68

2.91

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$52.70

178

$0.30

Subcategory K

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$7.21

170

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$243

400

$1.03

Subcategory L

BPT (BOD, O&G, and TSS Treatment for Indirect
Dischargers)

$1.73

26.2

NA

BCT (P with Full N Treatment for Indirect Dischargers)

$71.90

77.9

$1.36

Source: U.S. EPA. 2023. Pollutant Loadings and Removals Methodology for the Meat and Poultry Products Proposed Rulemaking
(November). DCN MP00302; U.S. EPA. 2023. Regulatory Impact Analysis for Proposed Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products Point Source Category (RIA) (November). EPA-821-R-23-014.

Abbreviations: BOD = biochemical oxygen demand, lbs. = pounds, M = million, N = nitrogen, O&G = oil and grease, P =
phosphorus, TSS = total suspended solids.

Note: Values presented as three significant figures.

137

-------
Table A-3. BCT Cost Test Results—Regulatory Option 2 and 3

Subcategory

Industry
Incremental
Removal Cost

POTW
Benchmark
(2022$)

Industry Cost
Ratio



Test 1
Results



Regulatory Option 2

A-D

$0.26

$1,476

2.04

1.29

Pass

Fail

F-l

$0.62

$1,476

1.76

1.29

Pass

Fail

J

$0.29

$1,476

1.33

1.29

Pass

Fail

K

$1.00

$1,476

24.5

1.29

Pass

Fail

L

$1.32

$1,476

20.5

1.29

Pass

Fail

Regulatory Option 3

A-D

$0.30

$1,476

0.678

1.29

Pass

Pass

F-l

$0.97

$1,476

1.82

1.29

Pass

Fail

J

$0.30

$1,476

1.27

1.29

Pass

Pass

K

$1.03

$1,476

24.2

1.29

Pass

Fail

L

$1.36

$1,476

20.5

1.29

Pass

Fail

Note: Values presented as three significant figures.

-------
Appendix B

This appendix provides supplemental information on limitations and standards (see Section 13).

139

-------
o
o

O)
£

c
a>
o
c
o
O

Days

Detected or ND: ° D v nd Interval: Daily Monthly means

Figure B-l. Timelines of Series Used for Daily Calculations (Black) Averaged Within Calendar Months (Blue)

Page 1 of 2

Note: Monthly means are graphed at the midpoint of each month. All data are from the MPP Questionnaires. Facilities and dates are masked to protect confidential business information
(CBI). Series are labeled by facility code and analyte. Units are in milligrams per liter (mg/L) for all analytes, except fecal coliform in most probably number per 100 milliliter (MPN/100 mL).
Some of these averaged monthly series were iater aggregated with other data sources' monthly-interval data at the same facility.

F11.TSS

300--

100
50



0.50
0.30

0.10
0.05

300
100
30
10
3

F07, TP

F10, BOD

10

5
3

F03, TP

F07, BOD

0 30 60 90 120 150180 210 240 270 300 330 360

F07, Fecal Coliform

1000
700

2000

1000
700

F19, Fecal Coliform

F19, TN

F19, TP

200
100
50

0 30 60 90 120 150 180 210 240 270 300 330 360

F21, TSS

3000

1000

0 30 60 90 120 150 180 210 240 270 300 330 360

F11, BOD

0 30 60 90 120 150 180 210 240 270 300 330 360

0 30 60 90 120150180 210240270300330 360

0 30 60 90 120 150 180 210 240 270 300 330 360

300

0 30 60 90 120 150 180 210 240 270 300 330 360

1000

0 30 60 90 120 150 180 210 240 270 300 330 360

140

-------
o
o

U)

E.

c

o

c
01
o
c
o

o

0 30 60 90 120 150180 210 240 270 300 330 360

0 30 60 90 120150 180 210 240 270 300 330 360

0 30 60 90 120 150 180 210 240 270 300 330 360

F23, TP

F24, Fecal Coliform

0 30 60 90 120 150 180 210 240 270 300 330 360

0 30 60 90 120 150 180 210 240 270 300 330 360

0 30 60 90 120150 180 210 240 270 300 330 360

0 30 60 90 120 150 180 210 240 270 300 330 360

3000
1000
300

1000

500
300

0 30 60 90 120 150 180 210 240 270 300 330 360

F31.TP

300
100
30

1.00
0.30
0.10
0.03

0.5
0.3

F27, TSS

Days

Detected or ND: ° D V ND Interval: Daily Monthly means

Figure B-l. Timelines of Series Used for Daily Calculations (Black) Averaged Within Calendar Months (Blue)

Page 2 of 2

Note: Monthly means are graphed at the midpoint of each month. All data are from the MPP Questionnaires. Facilities and dates are masked to protect CBI. Series are labeled by facility
code and analyte. Units are in mg/Lfor all analytes, except fecal coliform in MPN/100 mL. Some of these averaged monthly series were later aggregated with other data sources' monthly-
interval data at the same facility.

141

-------
Year

Detected or ND: ° d v nd
Figure B-2. Timelines of All Monthly-Interval Series with at Least 30 Values, Following Aggregation of All Data Sources

Note: The equivalent timelines for daily-interval series are all visible in Figure B-l (in addition to others with <30 values).

142

-------
Table B-l. Summary of LTA Test

Facility

Pollutant

Number of
Observations

Percentage
Detected

>50%
Detected3

Baseline
Valueb

% Observations
>10 x Baseline

Criterion 1
Pass/Failc

Mean
Concentration

Criterion 2
Pass/Faild

F02

BOD (mg/L)

5

100%

Yes

2

100%

Pass

3,121.10

Pass

F02

O&G (mg/L)

5

100%

Yes

5

60%

Pass

67.70

Pass

F02

TN (mg/L)

5

100%

Yes

0.012

100%

Pass

246.95

Pass

F02

TP (mg/L)

5

100%

Yes

0.01

100%

Pass

42.55

Pass

F02

TSS (mg/L)

5

100%

Yes

4

100%

Pass

3,384.55

Pass

F04

BOD (mg/L)

3

100%

Yes

2

100%

Pass

9,716.67

Pass

F04

E. coli (MPN/100 mL)

4

100%

Yes

1

100%

Pass

111,050,750.00

Pass

F04

FC (MPN/100 mL)

4

100%

Yes

1

100%

Pass

29,859,325.00

Pass

F04

O&G (mg/L)

4

100%

Yes

5

75%

Pass

1,127.90

Pass

F04

TP (mg/L)

3

100%

Yes

0.01

100%

Pass

93.33

Pass

F04

TSS (mg/L)

3

100%

Yes

4

100%

Pass

5,488.33

Pass

F07

BOD (mg/L)

48

100%

Yes

2

100%

Pass

4,085.21

Pass

F08

BOD (mg/L)

5

100%

Yes

2

100%

Pass

3,150.00

Pass

F08

O&G (mg/L)

5

100%

Yes

5

100%

Pass

1,327.67

Pass

F08

TSS (mg/L)

47

100%

Yes

4

100%

Pass

1,723.83

Pass

F10

TSS (mg/L)

52

100%

Yes

4

100%

Pass

2,006.19

Pass

Fll

BOD (mg/L)

14

100%

Yes

2

100%

Pass

925.21

Pass

Fll

TSS (mg/L)

27

100%

Yes

4

100%

Pass

226.59

Pass

F17

BOD (mg/L)

5

100%

Yes

2

100%

Pass

1,167.60

Pass

F17

E. coli (MPN/100 mL)

5

100%

Yes

1

100%

Pass

10,478.00

Pass

F17

FC (MPN/100 mL)

5

100%

Yes

1

100%

Pass

3,629.80

Pass

F17

O&G (mg/L)

5

100%

Yes

5

60%

Pass

42.89

Fail

F17

TN (mg/L)

5

100%

Yes

0.012

100%

Pass

87.00

Pass

F17

TP (mg/L)

5

100%

Yes

0.01

100%

Pass

16.40

Pass

F17

TSS (mg/L)

5

100%

Yes

4

100%

Pass

1,376.80

Pass

F19

E. coli (MPN/100 mL)

5

100%

Yes

1

100%

Pass

781,102.00

Pass

F19

FC (MPN/100 mL)

5

100%

Yes

1

100%

Pass

333,405.27

Pass

F19

TN (mg/L)

5

100%

Yes

0.012

100%

Pass

156.00

Pass

F19

TP (mg/L)

5

80%

Yes

0.01

100%

Pass

18.44

Pass

-------
Table B-l. Summary of LTA Test

Facility

Pollutant

Number of
Observations

Percentage
Detected

>50%
Detected3

Baseline
Valueb

% Observations
>10 x Baseline

Criterion 1
Pass/Failc

Mean
Concentration

Criterion 2
Pass/Faild

F20

BOD (mg/L)

5

100%

Yes

2

100%

Pass

5,346.33

Pass

F20

Chloride (mg/L)

5

100%

Yes

1

100%

Pass

1,286.60

Pass

F20

E. coli (MPN/100 mL)

5

100%

Yes

1

100%

Pass

5,133,021.67

Pass

F20

FC (MPN/100 mL)

5

100%

Yes

1

100%

Pass

3,960,200.00

Pass

F20

O&G (mg/L)

5

100%

Yes

5

100%

Pass

4,558.90

Pass

F20

TP (mg/L)

5

100%

Yes

0.01

100%

Pass

34.80

Pass

F20

TSS (mg/L)

5

100%

Yes

4

100%

Pass

4,429.00

Pass

F22

BOD (mg/L)

2

100%

Yes

2

100%

Pass

13,500.00

Pass

F27

TSS (mg/L)

100

100%

Yes

4

100%

Pass

903.76

Pass

F32

BOD (mg/L)

51

100%

Yes

2

100%

Pass

2,212.65

Pass

F34

BOD (mg/L)

102

100%

Yes

2

100%

Pass

2,680.25

Pass

F34

TSS (mg/L)

98

100%

Yes

4

100%

Pass

2,789.35

Pass

Abbreviations: BOD = biochemical oxygen demand, FC = fecal coliform, LTA = long-term average, mg/L = milligrams per liter, ml_ = milliliters, MPN = most probable number, O&G = oil and
grease, TN = total nitrogen, TP = total phosphorus, TSS = total suspended solids.

a — The basic criterion for the LTA test is whether at least 50 percent of the influent concentrations for the pollutant are detected,
b — There is no baseline value applicable to TN. The EPA instead used the MDL.

c — At least 50 percent of the influent concentrations were detected at levels 10 times the baseline value or higher,
d — The influent arithmetic average was 10 times the baseline value or higher.

-------
Table B-2. R Code Used to Calculate Parameters \i and o

Parameter

ND(s) in
Series

Abbreviations: ND = non-detect.

Package
Name

R Code to Calculate Parameters



No

fitted(gamlss(Conc ~ 1, family = LOGNO, what = "mu")[l] )

gamlss



Yes

gamlssZadj(ConcZ, family = LOGNO)$mu.coefficients

gamlss.inf

o

No

fitted(gamlss(Conc ~ 1, family = LOGNO, what = "sigma")[l] )

gamlss

o

Yes

exp(gamlssZadj(ConcZ, family = LOGNO)$sigma.coefficients

gamlss.inf

Note: Two different functions are applicable: gamlss() for series without NDs (Rigby and Stasinopoulos, 2023) and gamlssZadjQ for
series with any NDs (Enea et al., 2019). In the R code, "Cone" is a column of concentrations (in milligrams per liter [mg/L] or most
probable number per 100 milliliters [MPN/100 mL]) in a series, and ConcZ is a column replacing ND values with zeroes, as required by
the software.

Table B-3. R Code Used to Calculate Percentiles

ND(s) in Series

R Code to Calculate Percentiles

Package Name

No

qLOGNO(mu = Mu, sigma = Sigma, p = 0.99)

gamlss

Yes

gen.Zadj (family = "LOGNO")

qLOGNOZadj(mu = Mu, sigma = Sigma, xiO = Delta, p = 0.99)

gamlss.inf

Abbreviations: ND = non-detect.

Note: For series without NDs, the EPA used qLOGNO (Rigby and Stasinopoulos, 2023), which references function qnorm() (R
Foundation, 2023). For series with any NDs, function gen.Zadj() first generates functions used to implement a mixed zero-adjusted
lognormal distribution, the name of a delta lognormal distribution in this package (Enea et al., 2019). The generated function
qLOGNOZadj() then calculates the percentile, run one row at a time. In the R code, "Mu" is a column of/i parameters, "Sigma" is a
column of a parameters, and "Delta" is a column of 5 parameters, one of each per series. The code was run with p = 0.99 for daily-
interval data, and p = 0.95 for monthly-interval data.

145

-------
d)
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ro

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i
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F34-

Render,

F04-

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F33-

Poultry First,

F32-

Poultry First,

F17-

Poultry First,

F10-

Poultry First,

F07-

Meat Further,

F11 -

Meat First,

F20-

Meat First,

F08-

Meat First,

F02-

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w Poultry First
Poultry First
Poultry First
Poultry First
Meat First
Meat First

F34
F32
F21
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300

1000

BOD (mg/L)

3000

10000

Figure B-3. Series' BOD Concentrations (Gray Points), LTAs (Blue Points), and Percentiles (Orange Triangles,

99th for Daily and 95th for Monthly)

as

146

-------
Render, F04 -

-§ Poultry First, F17 -
o
o

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5= Meat First, F20 -
o
ro

M—

Meat First, F08 -

cl
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w


10

100

O&G (mg/L)

1000

10000

Figure B-4. Series' O&G Concentrations (Gray Points), LTAs (Blue Points), and Percentiles (Orange Triangles, as

99th for Daily and 95th for Monthly)

147

-------


_i	i	I	i	« ¦ * I

T—

t

HE-'



31

i i I i i i i

. i I ¦ i i

i i I i i i i

100	1000

TSS (mg/L)

10000

Figure B-5. Series' TSS Concentrations (Gray Points), LTAs (Blue Points), and Percentiles (Orange Triangles,

99th for Daily and 95th for Monthly)

as



O)

Q- o

CL O

2 >, Meat First, F20

-------
cd Render, F04 -

"O

o

^ Poultry First, F19 -
"o Poultry First, F17 -

ro

Meat First, F20 -

^ Poultry First, F24 -
Jg Poultry First, F19

d
CD

CO Poultry First, F17 -











1

m A











D







A

Q>









<









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,

k





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F04-

Poultry First,

F24-

Poultry First,

F23-

Poultry First,

F19-

Q)

T3 Poultry First,

F17-

o

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F07-

nj Meat First,

F20-

CD

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F24-







 ~

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4 *

ZE

ZE

•	o

~EH

V

i ... 11



i ... 11

10	100

Fecal Coliform (MPN/100 mL)



1000

Figure B-8. Series' Fecal Coliform Concentrations (Gray Points), LTAs (Blue Points), and Percentiles (Orange

Triangles, as 99th for Daily and 95th for Monthly)

150

-------
CD
"O

o
o

o
03

Poultry First,
Poultry First,
Meat First,

Render,
Render,
Render,

~ Poultry First,

<1>~
n

>. Poultry First,
CL

Q_ Poultry First,

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 i I	i	i	i	I	i	i i i I

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_i	i	

. i

tT ~ ;

i i i i i 1111

_l	I	L

1.0	10.0

TN (mg/L)

i i ¦ 111

100.0

Figure B-9. Series' TN Concentrations (Gray Points), LTAs (Blue Points), and Percentiles (Orange Triangles,

99th for Daily and 95th for Monthly)

as

151

-------
CD
T3
O
O

Render,

F04-

Poultry First,

F24-

Poultry First,

F23-

Poultry First,

F19-

Poultry First,

F17-

Poultry First,

F07-

Poultry First,

F03-

Meat Further,

F31 -

Meat First,

F20-

Meat First,

F02-

>*

Render,

F13-

o
m

Poultry First,

F24-

«4—





0)

o

Poultry First,

F23-

>





n

Poultry First,

F19-

Q.







Poultry First,

F17-

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• - 1 * K —*•

HH~ A

a

_i	i	iiii

_1	I	L_

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M-

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¦ 1*.

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—tC3EHa

•—A«



. . I

0.1

1.0

TP (mg/L)

10.0

Figure B-10. Series' TP Concentrations (Gray Points), LTAs (Blue Points), and Percentiles (Orange Triangles,

99th for Daily and 95th for Monthly)

as

152

-------
Table B-4. Metrics Calculated for Each Series of BOD Concentrations (in mg/L): LTAs, Percentiles, and VFs

Analyte



Facility

Interval
of Data

For LTA

For Daily VF

For Monthly VF

Processing
Type

#

Values

% ND

>2
Distinct
Detected
Values

Series
LTA

Facility
LTA

Daily 99th
Percentile

Daily VF
(Unitless)

#

Monthly
Values

% ND of
Monthly
Values

Monthly

95th
Percentile



BOD

Meat F

rst

F02

Daily

5

0%

Yes

907.78

907.78

2309.45

2.54









BOD

Meat F

rst

F08

Daily

5

0%

Yes

2043.27

2043.27

4728.43

2.31









BOD

Meat F

rst

F20

Daily

5

0%

Yes

3555.17

3555.17

11362.35

3.20









BOD

Meat F

rst

F27

Monthly

4

0%

Yes

869.71

869.71





4

0%

1358.82

1.56

BOD

Meat F

rst

F30

Monthly

12

0%

Yes

2462.46

2462.46





12

0%

5258.24

2.14

BOD

Meat Further

Fll

Daily

14

0%

Yes

897.59

897.59

1808.06

2.01









BOD

Poultry F

rst

F07

Daily

48

0%

Yes

2349.72

2349.72

5395.64

2.30

12

0%

3062.50

1.30

BOD

Poultry F

rst

F10

Daily

48

0%

Yes

668.77

668.77

1098.13

1.64

12

0%

849.34

1.27

BOD

Poultry F

rst

F17

Daily

4

0%

Yes

510.26

510.26

644.56

1.26









BOD

Poultry F

rst

F21

Monthly

6

0%

Yes

539.90

539.90





6

0%

878.88

1.63

BOD

Poultry F

rst

F32

Daily

51

0%

Yes

519.57

519.57

752.77

1.45

12

0%

612.14

1.18

BOD

Poultry F

rst

F33

Daily

1

0%

No

175.00

175.00













BOD

Render

F04

Daily

3

0%

Yes

4484.67

4484.67

5596.75

1.25









BOD

Render

F34

Daily

48

0%

Yes

2064.19

2064.19

5909.23

2.86

11

0%

3027.03

1.47

Abbreviations: BOD = biochemical oxygen demand, LTA = long-term average, mg/L = milligrams per liter, ND = non-detect, VF = variability factor.

Table B-5. Metrics Calculated for Each Series of O&G Concentrations (in mg/L): LTAs, Percentiles, and VFs

Analyte

Processing
Type

Facility

Interval
of Data

For LTA

For Daily VF

For Monthly VF

#

Values

% ND

>2
Distinct
Detected
Values

Series
LTA

Facility
LTA

Daily 99th
Percentile

Daily VF
(Unitless)

#

Monthly
Values

% ND of
Monthly
Values

Monthly

95th
Percentile



O&G

Meat First

F02

Daily

5

0%

Yes

12.01

12.01

40.59

3.38









O&G

Meat First

F08

Daily

6

0%

Yes

483.80

483.80

1053.95

2.18









O&G

Meat First

F20

Daily

5

0%

Yes

941.61

941.61

2761.20

2.93









O&G

Meat First

F30

Monthly

12

0%

Yes

527.00

527.00





12

0%

1442.39

2.74

O&G

Poultry First

F09

Monthly

4

0%

Yes

44.71

44.71





4

0%

135.06

3.02

O&G

Poultry First

F17

Daily

6

0%

Yes

6.11

6.11

21.08

3.45









O&G

Render

F04

Daily

4

0%

Yes

775.17

775.17

10845.40

13.99









Abbreviations: LTA = long-term average, mg/L = milligrams per liter, ND = non-detect, O&G = oil and grease, VF = variability factor.

153

-------
Table B-6. Metrics Calculated for Each Series of TSS Concentrations (in mg/L): LTAs, Percentiles, and VFs

Analyte



Facility

Interval
of Data

For LTA

For Daily VF

For Monthly VF

Processing
Type

#

Values

% ND

>2
Distinct
Detected
Values

Series
LTA

Facility
LTA

Daily 99th
Percentile

Daily VF
(Unitless)

#

Monthly
Values

% ND of
Monthly
Values

Monthly

95th
Percentile



TSS

Meat F

rst

F02

Daily

5

0%

Yes

836.21

836.21

8857.44

10.59









TSS

Meat F

rst

F08

Daily

5

0%

Yes

819.37

819.37

1794.64

2.19









TSS

Meat F

rst

F18

Monthly

12

0%

Yes

2092.85

2092.85





12

0%

2612.20

1.25

TSS

Meat F

rst

F20

Daily

5

0%

Yes

2941.49

2941.49

3779.01

1.28









TSS

Meat F

rst

F26

Monthly

12

0%

Yes

1048.86

1048.86





12

0%

1275.19

1.22

TSS

Meat F

rst

F27

Daily

101

0%

Yes

80.77

80.77

242.15

3.00

12

0%

117.66

1.46

TSS

Meat F

rst

F30

Monthly

12

0%

Yes

1115.72

1115.72





12

0%

2631.42

2.36

TSS

Meat Further

Fll

Daily

27

0%

Yes

218.58

218.58

462.56

2.12

2

0%

225.92

1.03

TSS

Poultry First

F10

Daily

251

0%

Yes

135.67

135.67

513.53

3.79

12

0%

173.76

1.28

TSS

Poultry First

F17

Daily

4

0%

Yes

184.04

184.04

242.36

1.32









TSS

Poultry First

F21

Daily

38

0%

Yes

149.40

149.40

370.33

2.48

9

0%

240.09

1.61

TSS

Poultry First

F28

Monthly

1

0%

No

145.00

145.00













TSS

Poultry First

F33

Daily

1

0%

No

10.00

10.00













TSS

Render

F04

Daily

3

0%

Yes

2094.87

2094.87

2617.40

1.25









TSS

Render

F34

Daily

52

0%

Yes

675.90

675.90

2169.79

3.21

12

0%

1279.58

1.89

Abbreviations: LTA = long-term average, mg/L = milligrams per liter, ND = non-detect, TSS = total suspended solids, VF = variability factor.

Table B-7. Metrics Calculated for the Series of Chloride Concentrations (in mg/L): LTAs, Percentiles, and VFs









For LTA

For Daily VF

For Monthly VF

Analyte

Processing
Type

Facility

Interval
of Data

#

Values

% ND

>2
Distinct
Detected
Values

Series
LTA

Facility
LTA

Daily 99th
Percentile

Daily VF
(Unitless)

#

Monthly
Values

% ND of
Monthly
Values

Monthly

95th
Percentile



Chloride

Meat First

F20

Daily

5

0%

Yes

532.70

532.70

568.67

1.07









Abbreviations: LTA= long-term average, mg/L= milligrams per liter, ND = non-detect, VF = variability factor.

154

-------
Table B-8. Metrics Calculated for Each Series off. coli Concentrations (in MPN/100 mL): LTAs, Percentiles, and VFs











For LTA

For Daily VF

For Monthly VF

Analyte

Processing
Type

Facility

Interval
of Data

#

Values

% ND

>2
Distinct
Detected
Values

Series
LTA

Facility
LTA

Daily 99th
Percentile

Daily VF
(Unitless)

#

Monthly
Values

% ND of
Monthly
Values

Monthly

95th
Percentile



E. coli

Meat First

F20

Daily

5

60.0%

Yes

2.68

2.68

7.74

2.89









E. coli

Poultry F

rst

F17

Daily

5

100.0%

No

1.00

1.00













E. coli

Poultry F

rst

F17

Monthly

12

100.0%

No

1.00













E. coli

Poultry F

rst

F19

Daily

5

40.0%

Yes

1.81

5.06

9.06

5.01









E. coli

Poultry F

rst

F19

Monthly

9

0%

Yes

8.31





9

0%

28.45

3.42

E. coli

Poultry F

rst

F24

Monthly

7

0%

Yes

2.88

2.88





7

0%

7.45

2.59

E. coli

Render

F04

Daily

5

40.0%

Yes

15.22

15.22

140.53

9.24









Abbreviations: LTA = long-term average, mL = milliliters, MPN = most probable number, ND = non-detect, VF = variability factor.

Table B-9. Metrics Calculated for Each Series of Fecal Coliform Concentrations (in MPN/100 mL): LTAs, Percentiles, and VFs



Processing
Type

Facility

Interval
of Data

For LTA

For Daily VF

For Monthly VF

Analyte

#

Values

% ND

>2 Distinct
Detected
Values

Series
LTA

Facility
LTA

Daily 99th
Percentile

Daily VF
(Unitless)

#

Monthly
Values

% ND of
Monthly
Values

Monthly

95th
Percentile



Fecal Col

form

Meat First

F20

Daily

5

0%

Yes

20.68

20.68

119.85

5.79









Fecal Col

form

Poultry First

F03

Monthly

12

0%

Yes

24.71

24.71





12

0%

33.55

1.36

Fecal Col

form

Poultry First

F06

Monthly

12

91.7%

No

3.17

3.17













Fecal Col

form

Poultry First

F07

Daily

12

0%

Yes

82.34

82.34

1010.04

12.27

6

0%

439.87

5.34

Fecal Col

form

Poultry First

F12

Monthly

12

41.7%

Yes

3.17

3.17





12

41.7%

5.12

1.62

Fecal Col

form

Poultry First

F17

Daily

5

60.0%

No

1.00

1.00













Fecal Col

form

Poultry First

F19

Daily

57

68.4%

Yes

55.46

55.46

950.35

17.13

12

25.0%

219.04

3.95

Fecal Col

form

Poultry First

F23

Daily

26

0%

Yes

8.07

8.07

49.98

6.19

9

0%

22.05

2.73

Fecal Col

form

Poultry First

F24

Daily

12

0%

Yes

7.85

5.46

46.60

5.93









Fecal Col

form

Poultry First

F24

Monthly

4

0%

Yes

3.07





7

0%

16.48

5.37

Fecal Col

form

Render

F04

Daily

5

0%

Yes

18.95

18.95

118.04

6.23









Fecal Col

form

Render

F22

Monthly

10

0%

Yes

1.91

1.91





10

0%

2.63

1.38

Abbreviations: LTA = long-term average, mL = milliliters, MPN = most probable number, ND = non-detect, VF = variability factor.

155

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Table B-10. Metrics Calculated for Each Series of TN Concentrations (in mg/L): LTAs, Percentiles, and VFs

Analyte



Facility

Interval
of Data

For LTA

For Daily VF

For Monthly VF

Processing
Type

#

Values

% ND

>2
Distinct
Detected
Values

Series
LTA

Facility
LTA

Daily 99th
Percentile

Daily VF
(Unitless)

#

Monthly
Values

% ND of
Monthly
Values

Monthly

95th
Percentile



TN

Meat First

F02

Daily

5

0%

Yes

32.69

18.34

102.64

3.14









TN

Meat First

F02

Monthly

12

0%

Yes

3.98





12

0%

12.57

3.15

TN

Meat Further

F05

Monthly

12

0%

Yes

6.54

6.54





12

0%

12.60

1.93

TN

Meat First

F29

Monthly

12

0%

Yes

3.35

3.35





12

0%

5.91

1.77

TN

Meat Further

F31

Monthly

4

0%

Yes

7.53

7.53





4

0%

14.89

1.98

TN

Poultry F

rst

F07

Monthly

12

0%

Yes

1.44

1.44





12

0%

2.86

1.98

TN

Poultry F

rst

F09

Monthly

61

0%

Yes

3.40

3.40





61

0%

6.19

1.82

TN

Poultry F

rst

F16

Monthly

61

0%

Yes

6.66

6.66





61

0%

11.20

1.68

TN

Poultry F

rst

F17

Daily

5

0%

Yes

5.81

5.11

8.47

1.46









TN

Poultry F

rst

F17

Monthly

50

0%

Yes

4.42





50

0%

8.36

1.89

TN

Poultry F

rst

F19

Daily

29

0%

Yes

3.00

3.03

15.03

5.02









TN

Poultry F

rst

F19

Monthly

61

0%

Yes

3.06





61

0%

5.94

1.94

TN

Render

F01

Monthly

12

0%

Yes

78.94

78.94





12

0%

127.71

1.62

TN

Render

F13

Monthly

8

0%

Yes

6.46

6.46





8

0%

12.22

1.89

TN

Render

F22

Monthly

12

0%

Yes

21.71

21.71





12

0%

63.61

2.93

Abbreviations: LTA = long-term average, mL = milliliters, MPN = most probable number, ND = non-detect, TN = total nitrogen, VF = variability factor.

156

-------
Table B-ll. Metrics Calculated for Each Series of TP Concentrations (in mg/L): LTAs, Percentiles, and VFs

Analyte



Facility

Interval
of Data

For LTA

For Daily VF

For Monthly VF

Processing
Type

#

Values

% ND

>2
Distinct
Detected
Values

Series
LTA

Facility
LTA

Daily 99th
Percentile

Daily VF
(Unitless)

#

Monthly
Values

% ND of
Monthly
Values

Monthly

95th
Percentile



TP

Meat F

rst

F02

Daily

5

0%

Yes

1.32

1.32

3.51

2.65









TP

Meat F

rst

F14

Monthly

12

0%

Yes

0.63

0.63





12

0%

0.99

1.58

TP

Meat F

rst

F20

Daily

2

0%

Yes

0.67

0.67

1.27

1.89









TP

Meat F

rst

F25

Monthly

12

0%

Yes

0.75

0.75





12

0%

0.97

1.28

TP

Meat F

rst

F29

Monthly

12

0%

Yes

0.26

0.26





12

0%

0.33

1.24

TP

Meat Further

F15

Monthly

12

0%

Yes

0.45

0.45





12

0%

0.67

1.49

TP

Meat Further

F31

Daily

52

0%

Yes

0.35

0.35

1.50

4.28

12

0%

0.70

2.01

TP

Poultry F

rst

F03

Daily

24

0%

Yes

0.22

0.23

0.80

3.66









TP

Poultry F

rst

F03

Monthly

11

0%

Yes

0.24





12

0%

0.52

2.17

TP

Poultry F

rst

F06

Monthly

12

0%

Yes

0.22

0.22





12

0%

0.40

1.83

TP

Poultry F

rst

F07

Daily

51

0%

Yes

4.12

4.14

20.09

4.87









TP

Poultry F

rst

F07

Monthly

12

0%

Yes

4.15





12

0%

8.85

2.13

TP

Poultry F

rst

F09

Monthly

61

19.7%

Yes

0.10

0.10





61

19.7%

0.22

2.23

TP

Poultry F

rst

F12

Monthly

12

0%

Yes

0.06

0.06





12

0%

0.12

1.79

TP

Poultry F

rst

F16

Monthly

61

0%

Yes

0.65

0.65





61

0%

1.58

2.44

TP

Poultry F

rst

F17

Daily

5

40.0%

Yes

0.08

0.07

0.54

6.64









TP

Poultry F

rst

F17

Monthly

53

52.8%

Yes

0.05





53

52.8%

0.12

2.28

TP

Poultry F

rst

F19

Daily

29

48.3%

Yes

0.17

0.14

0.92

5.34









TP

Poultry F

rst

F19

Monthly

56

46.4%

Yes

0.11





61

47.5%

0.28

2.60

TP

Poultry F

rst

F23

Daily

24

0%

Yes

0.37

0.37

1.18

3.17

12

0%

0.65

1.75

TP

Poultry F

rst

F24

Daily

52

0%

Yes

1.07

1.04

7.65

7.14









TP

Poultry F

rst

F24

Monthly

12

0%

Yes

1.00





12

0%

2.51

2.51

TP

Render

F04

Daily

2

0%

Yes

0.10

0.10

0.23

2.23









TP

Render

F13

Monthly

12

33.3%

Yes

0.68

0.68





12

33.3%

2.17

3.20

Abbreviations: LTA = long-term average, mL = milliliters, MPN = most probable number, ND = non-detect, TP = total phosphorus, VF = variability factor.

157

-------