United States
Environmental Protection
Agency
Office of Water
Washington, DC 20460
EPA-821 -R-2 3-012
December 11, 2023
SERA Environmental Assessment
for Revisions to the Effluent
Limitations Guidelines and
Standards for the Meat and
Poultry Products Point
Source Category
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v>EPA
United States
Environmental Protection
Agency
Environmental Assessment for Revisions to
the Effluent Limitations Guidelines and
Standards for the Meat and Poultry Products
Point Source Category
EPA-821 -R-23-012
December 11, 2023
U.S. Environmental Protection Agency
Office of Water (4303T)
Engineering and Analysis Division
1200 Pennsylvania Avenue, NW
Washington, DC 20460
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Acknowledgements and Disclaimer
This report was prepared by the U.S. Environmental Protection Agency. Neither the United States
Government nor any of its employees, contractors, subcontractors, or their employees make any warranty,
expressed or implied, or assume any legal liability or responsibility for any third party's use of or the
results of such use of any information, apparatus, product, or process discussed in this report, or
represents that its use by such party would not infringe on privately owned rights.
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs Table of Contents
Table of Contents
Table of Contents i
List of Figures v
List of Tables vi
Abbreviations 9
Executive Summary ES-1
1 Introduction 1-1
1.1 Meat and Poultry Products Industry Facilities 1-1
1.2 Meat and Poultry Products Industry Damage Cases 1-2
1.3 Baseline and Regulatory Options Analyzed 1-5
1.4 Organization of the Environmental Assessment Report 1-8
2 Pollutants Found in MPP Wastewater 2-1
2.1 Nutrients 2-2
2.1.1 Ecological and Aquatic Resource Use Effects 2-5
2.1.2 Human Health and Aesthetic Effects 2-9
2.2 Oxygen Demand 2-6
2.2.1 Ecological and Aquatic Resource Use Effects 2-8
2.2.2 Human Health and Aesthetic Impacts 2-9
2.3 Total Suspended Solids 2-9
2.3.1 Ecological and Aquatic Resource Use Effects 2-11
2.3.2 Human Health and Aesthetic Impacts 2-12
2.4 Bacteria and Pathogens 2-12
2.4.1 Ecological and Aquatic Resource Use Effects 2-13
2.4.2 Human Health and Aesthetic Impacts 2-13
2.5 Total Dissolved Solids 2-14
2.5.1 Ecological and Aquatic Resource Use Effects 2-17
2.6 Metals 2-17
2.6.1 Ecological and Aquatic Resource Use Effects 2-18
2.6.2 Human Health and Aesthetic Impacts 2-19
2.7 Inorganic Toxics 2-19
2.7.1 Ecological and Aquatic Resource Use Effects 2-21
2.7.2 Human Health and Aesthetic Impacts 2-21
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs Table of Contents
2.8 pH 2-21
2.8.1 Ecological and Aquatic Resource Use Effects 2-22
2.8.2 Human Health and Aesthetic Impacts 2-23
2.9 Temperature 2-23
2.9.1 Ecological and Aquatic Resource Use Effects 2-24
2.9.2 Human Health and Aesthetic Impacts 2-25
2.10 Antimicrobials 2-25
2.10.1 Ecological and Aquatic Resource Use Effects 2-25
2.10.2 Human Health and Aesthetic Impacts 2-26
2.11 Other Pharmaceuticals and Hormones 2-26
2.11.1 Ecological and Aquatic Resource Use Effects 2-26
2.11.2 Human Health and Aesthetic Impacts 2-27
2.12 Surfactants 2-27
2.12.1 Ecological and Aquatic Resource Use Effects 2-27
2.12.2 Human Health and Aesthetic Impacts 2-27
2.13 Pesticides 2-27
2.13.1 Ecological and Aquatic Resource Use Effects 2-28
2.13.2 Human Health and Aesthetic Impacts 2-28
3 Water Quality Effects of Regulatory Options 3-1
3.1 Changes in Pollutant Loadings 3-1
3.2 Case Studies 3-1
3.2.1 Case Study Locations 3-2
3.2.2 Methodology 3-11
3.2.3 Results 3-11
3.3 Limitations and Uncertainty 3-15
4 Environmental Effects from Changes in Water Quality and Subsequent Pollutant Exposure 4-1
4.1 Overall Environmental Effects from Changes in Pollutant Loadings 4-1
4.2 Environmental Effects to Sensitive Environments 4-1
4.2.1 Impaired Waters 4-3
4.2.2 Fisheries 4-6
4.2.3 Endangered Species Habitat and Protected Areas 4-8
4.2.4 Priority Water Bodies 4-14
4.2.5 Recreational Areas 4-14
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs Table of Contents
4.2.6 Potential Improvements to Water Quality within Sensitive Environments 4-16
4.2.7 Limitations and Uncertainty 4-17
5 Human Health Effects from Changes in Pollutant Exposure 5-1
5.1 Pollutant Exposure via Recreation 5-1
5.1.1 Population in Scope of the Analysis 5-1
5.1.2 Level of Exposure 5-1
5.1.3 Health Effects from Changes in Pollutant Exposure via Recreation 5-2
5.2 Pollutant Exposure via the Drinking Water Pathway 5-2
5.2.1 Population in Scope of the Analysis 5-2
5.2.2 Health Effects from Changes in Pollutant Exposure via the Drinking Water Pathway 5-3
5.3 Pollutant Exposure via the Shellfish Consumption Pathway 5-3
5.3.1 Population in Scope of the Analysis 5-3
5.3.2 Level of Exposure 5-3
5.3.3 Health Effects from Changes in Pollutant Exposure via the Fish Consumption Pathway .5-3
6 Non-Water Quality Effects 6-1
6.1 Changes in Air Pollution 6-1
6.1.1 Effects from Changes in Air Pollution 6-2
6.2 Changes to Waste Management Practices 6-2
6.2.1 Effects from Changes in Waste Management Practices 6-3
7 Environmental Justice 7-1
7.1 Background 7-1
7.2 Environmental Justice Literature Review 7-3
7.2.1 Methodology 7-3
7.2.2 Results 7-4
7.3 Communities in Proximity to MPP Facilities and Outfalls 7-6
7.3.1 Methodology 7-6
7.3.2 Results 7-7
7.4 Communities Utilizing Water Resources Impacted by MPP Wastewater 7-9
7.4.1 Methodology 7-9
7.4.2 Results 7-10
7.5 Tribal Areas Affected by MPP Discharges 7-14
7.5.1 Methodology 7-14
7.5.2 Results 7-14
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs Table of Contents
7.6 Environmental Stressors 7-15
7.7 Community Outreach and Engagement 7-18
7.8 Conclusions 7-19
8 References 8-1
Appendix A: Nitrogen State Water Quality Criteria A-l
Appendix B: Case Study Water Quality Modeling B-l
SWAT Model Setup B-l
Representation of Point Source Discharges from Direct and Indirect Facilities B-2
Model Calibration B-4
Appendix C: Summary of Threatened and Endangered Species C-l
Appendix D: Impaired Waters Analysis D-l
Appendix E: Use of the Community Water Systems Service Boundaries Dataset E-l
Appendix F: EJ Literature Review Methodology, Sources and Search Terms F-l
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
List of Figures
Figure 1-1: Map of the MPP Facility Universe 1-2
Figure 3-1: Spatial Distribution of MPP Facilities and Gaging Stations in the Upper Pearl River
Watershed 3-4
Figure 3-2: Spatial Distribution of MPP facilities, Other Point Source Dischargers, and Gaging Stations in
the Double Bridges Creek Watershed 3-7
Figure 3-3: Spatial Distribution of MPP facilities, Other Point Source Dischargers, and Gaging Stations in
the Okatoma Creek Watershed 3-10
Figure 7-1: Distribution of MPP-Proximal Communities' Nearness to Traffic, Grouped by Discharge
Type and Across the MPP Facility Universe 7-16
Figure 7-2: Distribution of MPP-Proximal Communities' Exposure to Diesel PM levels, Grouped by
Discharge Type and Across the MPP Facility Universe 7-17
Figure 7-3: Distribution of MPP-Proximal Communities' Exposure to PM2 5, Grouped by Discharge Type
and Across the MPP Facility Universe 7-18
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
List of Tables
Table 1-1: Number of Facilities in MPP Industry by Process and Discharge Type 1-2
Table 1-2: Summary of Select Damage Cases with Documented Water Quality Impacts from MPP
Facilities 1-3
Table 1-3: Summary of Regulatory Options 1-7
Table 2-1: State WQC Category Definitions 2-1
Table 2-2: Existing Nutrient ELGs for the MPP Category (Note: there are currently no ELG limits for
phosphorus) 2-3
Table 2-3: Observed Nitrogen Concentrations in Sampled MPP Final Effluent at Select Sites, Compared
to MPP Universe Average Baseline Concentrations (mg/L) 2-3
Table 2-4: Observed Total Phosphorous Concentrations in Sampled MPP Final Effluent at Select Sites,
Compared to MPP Universe Average Baseline Concentrations (mg/L) 2-4
Table 2-5: Average State WQC for Phosphorus (mg/L) 2-4
Table 2-6: Observed Oxygen Demand Concentrations in Sampled MPP Final Effluent at Select Sites,
Compared to MPP Universe Average Baseline Concentrations (mg/L) 2-7
Table 2-7: Average State WQC for Oxygen Demand (mg/L) 2-7
Table 2-8: Observed Oil and Grease Concentrations in Sampled MPP Final Effluent at Select Sites,
Compared to MPP Universe Average Baseline Concentrations (mg/L) 2-8
Table 2-9: Average State WQC for Oil and Grease (mg/L) 2-8
Table 2-10: Observed Total Suspended Solids Concentrations in Sampled MPP Final Effluent at Select
Sites, Compared to MPP Universe Average Baseline Concentrations (mg/L) 2-11
Table 2-11: Total Suspended Solids State Average WQC (mg/L) 2-11
Table 2-12: Average Pathogen Data (CFU/lOOmL) 2-13
Table 2-13: Observed Total Dissolved Solids Concentrations in Sampled MPP Final Effluent at Select
Sites, Compared to MPP Universe Average Baseline Concentrations (mg/L) 2-15
Table 2-14: Observed Chloride Concentrations in Sampled MPP Final Effluent at Select Sites, Compared
to MPP Universe Average Baseline Concentrations (mg/L) 2-16
Table 2-15: Average State WQC for Chloride (mg/L) 2-16
Table 2-16: Chemical Addition Table Survey Response 2-16
Table 2-17: Observed Metal Concentrations in Sampled MPP Final Effluent at Select Sites, Compared to
MPP Universe Average Baseline Concentrations (mg/L) 2-18
Table 2-18: Observed Arsenic Concentrations in Sampled MPP Final Effluent at Select Sites (mg/L) .2-20
Table 2-19: Observed Free Chlorine Concentrations in Sampled MPP Final Effluent at Select Sites
(mg/L) 2-20
Table 2-20: Average State WQC for Chlorine (mg/L) 2-21
VI
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EA for Proposed Revisions to the Meat and Poultry Products ELGs List of Tables
Table 2-21: Observed pH in Sampled MPP Final Effluent at Select Sites (S.U.) 2-22
Table 2-22: Observed Temperature in Sampled MPP Final Effluent at Select Sites (°C) 2-24
Table 3-1: Summary of Changes to Annual Pollutant Loadings Compared to the Baseline 3-1
Table 3-2: Summary of SWAT Model Used to Estimate Water Quality Impacts of the Proposed Rule in
the Upper Pearl River Watershed 3-2
Table 3-3: Summary of Changes to Annual Pollutant Loadings Compared to the Baseline for Upper Pearl
River Watershed 3-5
Table 3-4: Summary of SWAT Model Used to Estimate Water Quality Impacts of the Proposed Rule in
the Double Bridges Creek Watershed 3-6
Table 3-5: Summary of Changes to Annual Pollutant Loadings Compared to the Baseline for Double
Bridges Creek Watershed 3-8
Table 3-6: Summary of SWAT Model Used to Estimate Water Quality Impacts of the Proposed ELG in
the Okatoma Creek Watershed 3-9
Table 3-7: Summary of Changes to Annual Pollutant Loadings Compared to the Baseline for Okatoma
Creek Watershed 3-11
Table 3-8: Summary of Percentage Changes to In-Stream Water Quality Modeling Estimates Compared
to the Baseline for Regulatory Option 1 3-12
Table 3-9: Summary of Percentage Changes to In-Stream Water Quality Modeling Estimates Compared
to the Baseline for Regulatory Option 2 3-13
Table 3-10: Summary of Percentage Changes to In-Stream Water Quality Modeling Estimates Compared
to the Baseline for Regulatory Option 3 3-14
Table 3-11: Summary of In-Stream Water Quality Modeling Concentration Estimates by Case Study
Watershed 3-15
Table 3-12: Limitations and Uncertainties in Estimating Water Quality Effects of Regulatory Options3-15
Table 4-1: Data Sources for Evaluating the Potential Environmental Effects to Sensitive Environments 4-2
Table 4-2: Number of Impaired Catchments Downstream of MPP Direct and Indirect Dischargers by
Parameter Group 4-3
Table 4-3: Direct Discharge Facilities with New Impairments by Parameter Group 4-4
Table 4-4: Percentage of Indirect Discharge Facilities with New Impairments by Parameter Group 4-5
Table 4-5: Commercially Available Fish and Shellfish Species Potentially Impacted by Dischargers 4-7
Table 4-6: Federally Owned Recreational Areas Potentially Impacted by MPP Direct Dischargers 4-8
Table 4-7: Threatened and Endangered Species Groups with Vulnerability Status 4-10
Table 4-8: Higher Vulnerability Threatened and Endangered Species Potentially Impacted by MPP Direct
Dischargers 4-10
Table 4-9: Priority Water Bodies Impacted by MPP Direct Dischargers 4-14
Table 4-10: PAD Areas Impacted by MPP Direct Dischargers 4-15
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EA for Proposed Revisions to the Meat and Poultry Products ELGs List of Tables
Table 4-11: Summary of Potential Improvements to Water Quality within Sensitive Environments 4-16
Table 4-12: Limitations and Uncertainties in Estimating Sensitive Environments Affected by the
Regulatory Options 4-17
Table 6-1: Estimated Incremental Changes in Air Pollutant Emissions (Tons/Year) 6-1
Table 6-2: Summary of Changes to Sludge Production Compared to the Baseline 6-3
Table 7-1: Demographics of Communities within One Mile of an MPP Facility 7-7
Table 7-2: Communities Within One Mile of Surface Waters Along the 25-mile Downstream Path from
an MPP Process Wastewater Outfall 7-8
Table 7-3: Comparison of the Demographics of All Communities Living Near Impacted Downstream
Waters to Those Impacted by Reduced Nutrient Loads Under Proposed Regulatory Options 7-11
Table 7-4: Comparison of All Drinking Water Service Areas Demographics to Those Impacted Under
Proposed Regulatory Options 7-12
Table 7-5: Demographics of Drinking Water Service Areas Directly Impacted by MPP Wastewater
Discharge and the Service Areas this Water is Sold to 7-12
Table 7-6: Demographics of Fisher Population Impacted by MPP Discharge and the Populations that
Would Benefit Under Proposed Options 7-14
Table 7-7: Direct and Indirect Discharge Facilities in General Proximity to Tribal Areas 7-15
Table 7-8: Environmental Stressors Facing Communities Near MPP Facilities 7-15
Table 7-9: Urban/Rural Designation of Communities Near MPP Facilities by Discharge Type 7-18
Appendix Tables
Table A-l: Average State WQC for Nitrogen (mg/L) A-l
Table B-l: Case Study Models Input Dataset Summary B-l
Table B-2: Summary of Relevant SWAT Hydrology and Water Quality Settings B-2
Table B-3: Case Study Calibration Locations and Statistics B-5
Table C - 1: Summary of Threatened and Endangered Species Affected by the Proposed Rule C-l
Table D-l: Comprehensive List of Pollutants Causing Impaired Waters D-l
Table F - 1: Environmental Justice Literature Boolean Search Terms by Group F-4
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Abbreviations
Abbreviations
Antimicrobial Resistant or Resistance AMR
Best Available Technology Economically Achievable BAT
Best Conventional Pollutant Control Technology BCT
Best Practicable Control Technology Currently Available BPT
Biochemical Oxygen Demand BOD
Bureau of Indian Affairs BIA
Carbonaceous Oxygen Demand CBOD
Chemical Oxygen Demand COD
Chronic Obstructive Pulmonary Disease COPD
Clean Water Act CWA
Code of Federal Regulations CFR
Colony Forming Units CFU
Common Identifier (NHD) COMID
Community Water Systems Service Boundaries CWSSB
Confined Animal Feeding Operation CAFO
Delaware River Basin Commission DRBC
Discharge Monitoring Report DMR
Disinfection Byproducts DBPs
Dissolved Air Flotation DAF
Dissolved Oxygen DO
Effluent Limitations Guidelines and Standards ELG
Endangered Species Act ESA
Enforcement and Compliance History Online ECHO
Environmental Protection Agency EPA
Fats, Oils, and Grease FOG
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs Abbreviations
Fourth Unregulated Contaminant Monitoring Rule UCMR 4
Harmful Algal Blooms HAB
Hydrologic and Water Quality System HAWQS
Hydrologic Unit Code HUC
Integrated Compliance Information System National Pollutant Discharge Elimination
System ICIS-NPDES
Kling-Gupta Efficiency KGE
Land Area Representation LAR
Maximum Contaminant Levels MCL
Meat and Poultry Products MPP
Methicillin-Resistant Staphylococcus aureus MRSA
Method Detection Limit MDL
National Hydrography Dataset NHD
National Pollutant Discharge Elimination System NPDES
National Rivers and Streams Assessment NRSA
New Source Performance Standards NSPS
National Oceanic and Atmospheric Administration NOAA
Nash-Sutcliffe Efficiency NSE
Non-governmental Organization NGO
Notice of Data Availability NODA
Office of Water OW
Personal Protective Equipment PPE
Pollutants of Concern POC
Pretreatment Standards for Existing Sources PSES
Pretreatment Standards for New Sources PSNS
Protected Areas Database PAD
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Abbreviations
Public Water Systems
PWS
Publicly Owned Treatment Works
POTW
Safe Drinking Water Information System
SDWIS
Soil and Water Assessment Tool
SWAT
Technical Development Document
TDD
The Assessment, Total Maximum Daily Load Tracking and Implementation System
ATTAINS
Threatened and Endangered
T&E
Total Dissolved Solids
TDS
Total Kjeldahl Nitrogen
TKN
Total Maximum Daily Load
TMDL
Total Nitrogen
TN
Total Organic Carbon
TOC
Total Phosphorus
TP
Total Suspended Solids
TSS
Toxics Release Inventory
TRI
Treatment in Place
TIP
Tribal Statistical Area
TSA
Trihalomethanes
THM
U.S. Fish & Wildlife Service
USFWS
U.S. Geological Survey
USGS
Wastewater Treatment Plant
WWTP
Water Quality Criteria
WQC
Waters of the United States
WOTUS
Zip Code Tabulation Areas
ZCTA
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Executive Summary
Executive Summary
The Environmental Protection Agency (EPA or the Agency) is proposing a regulation to revise the
technology-based effluent limitations guidelines and standards (ELGs) for the meat and poultry products
(MPP) point source category. The proposed rule would improve water quality and protect human health
and the environment by reducing the discharge of nutrients and other pollutants to the nation's surface
waters.
The MPP industry has an estimated 5,055 facilities across the country which engage in meat and/or
poultry slaughter, further processing, and/or rendering. The proposed rule requirements would reduce the
allowable amount of nutrients and other pollutants discharged from the MPP industry, both directly and
indirectly through Publicly Owned Treatment Works (POTWs). Importantly, this rule would also advance
progress on environmental justice goals.
This Environmental Assessment report summarizes the potential environmental and human health
impacts estimated to result from implementation of the proposed rule. EPA reviewed currently available
literature on the documented environmental and human health impacts of MPP wastewater discharges and
conducted modeling to characterize the impacts of MPP discharge to surface waters and downstream
environments at both local and regional scales. In particular, to help inform how the regulatory options
may improve water quality, EPA modeled the impacts of MPP discharges for baseline conditions (i.e.,
existing, pre-rule conditions) and following implementation of the regulatory options presented in the
proposed rule. The report also describes the environmental justice implications of the proposed rule.
Regulatory Options
EPA is considering a range of options in this proposed rulemaking. The options include more stringent
effluent limitations on total nitrogen (TN), new effluent limitations on total phosphorus (TP), updated
effluent limitations for other pollutants including ammonia, new pretreatment standards for indirect
dischargers, and revised production thresholds for some of the subcategories in the existing rule. EPA is
also requesting comment on potential effluent limitations on chlorides for high chloride waste streams,
establishing effluent limitations for E. coli for direct dischargers, and including modified limits for
indirect dischargers that discharge to POTWs that remove nutrients to the extent of the proposed MPP
ELG. Each option will result in different levels of pollutant reduction and costs.
EPA has identified three regulatory options that build on the current ELGs.
Option 1 is EPA's preferred option and builds on the existing ELGs by modifying or adding new
effluent limitation for large direct and indirect dischargers, respectively. Option 1 includes new TP
limits for large direct dischargers, more stringent TN limits for large direct dischargers, and new
conventional pollution limits (pretreatment standards) for large indirect dischargers. Large refers to
the existing rule production thresholds of greater than 50 million pounds per year of finished product
produced for meat further processors (Subparts F-I) and in terms of live weight killed for meat
slaughtering (Subparts A-D). For poultry slaughtering (Subpart K) large is greater than 100 million
pounds per year of live weight killed, greater than 7 million pounds per year of finished product
produced for poultry further processors (Subpart L), and 10 million pounds per year of raw material
processed for Tenderers (Subpart J).
ES-1
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Executive Summary
Option 2 would include the limits in Option 1, as well as add TN and TP limits for indirect
discharging processors exceeding the production thresholds defined above.
Option 3 would include the limits in Option 2 but lower the existing rule production thresholds1 of
Option 2, thereby applying the more stringent TN and TP limits and conventional limits to more
direct and indirect discharging facilities. Option 3 would also simplify the existing rule by utilizing
the same size thresholds for all subcategories.
Under Options 2 and 3, EPA is also considering an approach for indirect dischargers that would not
require indirect dischargers to meet nitrogen and phosphorus limits where the POTW that receives their
wastewater is able to (through its National Pollutant Discharge Elimination System [NPDES] permit)
meet these limits. For additional information on this approach please refer to the technical development
document (TDD) (U.S. Environmental Protection Agency, 2023p).
Environmental Effects of Changes to Pollutant Loadings
Nutrient pollution is one of the most widespread, costly, and challenging environmental problems
affecting water quality in the United States. Excess nitrogen and phosphorus in surface waters can lead to
a variety of problems, including eutrophication and harmful algal blooms, with impacts on drinking
water, recreation, and aquatic life. A wide range of human activities contribute to nutrient pollution from
both point and nonpoint sources, including wastewater discharges, stormwater discharges and runoff,
leaking septic systems, fertilizer runoff, and atmospheric deposition.
Publicly available data shows that MPP facilities discharge large amounts of nutrients, such as nitrogen
and phosphorus, compared to other industrial discharges. Pollutants in the wastewater from MPP indirect
dischargers, which are not regulated by the current ELG, can interfere with normal operations or pass
through POTWs. Research also shows communities near MPP facilities are more likely to experience
multiple environmental stressors exacerbated by MPP discharges than on average nationally. These
communities also tend to have higher proportions of minority and low-income households than the
national average.
Around 71 percent of MPP direct dischargers release process wastewater to water bodies listed as
impaired, with approximately 31 percent of the receiving waters impaired for algal growth, nutrients,
and/or oxygen depletion. Excess nutrients in aquatic environments, or eutrophication, is one of the most
documented causes of impairment in waters downstream from MPP facilities and can contribute to the
accelerated growth of bacteria and/or algae, reducing available dissolved oxygen (DO) and limiting the
ability of the water body to support aquatic life. Consequences include biodiversity loss, impacts to fish
development and reproduction, as well as fish kills from hypoxic, or deoxygenated, waters. Low DO
levels can also release toxic metals from sediments, further contaminating aquatic habitat. Often spurred
by eutrophication, some algal blooms release toxins into the water, which can result in sickness and/or
death in exposed terrestrial animals and people.
Excess nutrients can also impact human health through several pathways, both direct and indirect. High
nutrient levels in drinking water sources can lead to objectionable tastes and odors, and potentially
increase drinking water treatment costs to remove nitrates. High nitrate concentrations in drinking water
1 Economic analyses were used in determining the applicable production size thresholds.
ES-2
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Executive Summary
can lead to infant methemoglobinemia (blue baby syndrome), colorectal cancer, thyroid disease, and
neural tube defects. Drinking water quality can be impacted by several other pollutants present in MPP
wastewater, including pathogenic bacteria, suspended solids that harbor bacteria, and arsenic and heavy
metals. In terms of indirect health impacts, the growth of harmful algal and bacteria due to eutrophication
can potentially result in the contamination of shellfish with algal toxins or fecal coliforms. Adverse health
impacts from the consumption of contaminated shellfish can include paralytic, diarrhetic, amnesic, and
neurotoxic shellfish poisoning.
EPA estimates the preferred regulatory option would reduce pollutant discharges by nearly 97 million
pounds per year. This includes a reduction of nine million pounds of nitrogen discharges and eight million
pounds of phosphorus discharges. EPA predicts environmental and ecological improvements would result
under the preferred regulatory option, along with reduced impacts to wildlife and human health.
ES-3
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
1: Introduction
I Introduction
The Environmental Protection Agency (EPA or the Agency) is proposing a regulation to revise the
technology-based effluent limitations guidelines and standards (ELGs) for the meat and poultry products
(MPP) point source category. The proposed rule would improve water quality and protect human health
and the environment by reducing the discharge of nutrients and other pollutants to the nation's surface
waters.
EPA is considering a range of options in this proposed rulemaking. The options include more stringent
effluent limitations on total nitrogen (TN), new effluent limitations on total phosphorus (TP), updated
effluent limitations for other pollutants including ammonia, new pretreatment standards for indirect
dischargers, and revised production thresholds for some of the subcategories in the existing rule. EPA is
also requesting comment on potential effluent limitations on chlorides for high chloride waste streams,
establishing effluent limitations for E. coli for direct dischargers, and including modified limits for
indirect dischargers that discharge to publicly owned treatment works (POTWs) that remove nutrients to
the extent of the proposed MPP ELG. Each option will result in different levels of pollutant reduction and
costs.
1.1 Meat and Poultry Products Industry Facilities
The MPP point source category includes facilities "engaged in the slaughtering, dressing and packing of
meat and poultry products for human consumption and/or animal food and feeds. Meat and poultry
products for human consumption include meat and poultry from cattle, hogs, sheep, chickens, turkeys,
ducks and other fowl as well as sausages, luncheon meats and cured, smoked or canned or other prepared
meat and poultry products from purchased carcasses and other materials. Meat and poultry products for
animal food and feeds include animal oils, meat meal and facilities that render grease and tallow from
animal fat, bones and meat scraps." (See 40 CFR 432.1).
EPA estimates there are 5,055 facilities in total in the MPP industry: 3,879 (77 percent) are MPP
dischargers that either discharge their wastewater directly to surface waters (direct dischargers) or send
their wastewater to a POTW (indirect dischargers), and 1,176 (23 percent) are zero dischargers, which do
not discharge any wastewater to surface waters. These facilities either spray wastewater on agricultural
lands, known as land spraying, or discharge wastewater into septic tanks. EPA estimates that
approximately 441 facilities are land spraying over 16,000 million gallons of wastewater per year. Table
II summarizes the universe of regulated facilities by process and discharger type. Figure 1-1 shows the
geographical distribution of these facilities.
1-1
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
1: Introduction
Table 1-1: Number of Facilities in MPP Industry by Process and Discharge Type
Process
Number of Facilities
Direct Dischargers
Indirect Dischargers
Zero Dischargers
Total
Meat First
47
509
270
826
Meat Further
29
2,741
690
3,460
Poultry First
70
168
52
290
Poultry Further
6
169
119
294
Render
19
121
45
185
Total
171
3,708
1,176
5,055
Source: U.S. EPA Analysis, 2023
Figure 1-1: Map of the MPP Facility Universe
MPP Indirect Dischargers
US State Boundaries
1.2 Meat and Poultry Products Industry Damage Cases
The introduction of additional nutrient loads and other pollutants by MPP dischargers can generate
negative impacts on local ecosystems and potentially compromise overall ecosystem functions. As
detailed in later sections, pollutants can impact overall water quality, damage aquatic habitats and
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
1: Introduction
organisms, and affect human populations through decreased aesthetic value of surface waters, limitations
to recreational opportunities, as well as impact the quality of drinking water.
EPA evaluated various cases of damage to surface waters as a result of MPP facility effluent discharge.
Table 1-2 highlights several damage cases and documents impact sites where MPP effluent discharges are
believed to have led to detrimental consequences downstream for humans and wildlife. A study
conducted by the Environmental Integrity Project revealed that three quarters of the 98 MPP facilities
studied across the U.S. violated the Clean Water Act between 2016-2018. One third of the MPP facilities
studied had ten or more violations, with a total of 1,142 distinct violations for exceeding pollution limits
across all facilities (The Environmental Integrity Project, 2018).
Table 1-2: Summary of Select Damage Cases with Documented Water Quality Impacts from MPP Facilities
Year
Facility
Summary of Site Impacts
2007
Moyer
Packing Co./
JBS
A failure in the chlorination equipment at the onsite water treatment facility of the
Moyer Packing Co. plant resulted in a buildup of chlorine in nearby Skippack Creek,
Pennsylvania. The excess chlorine was either caused by a mechanical or operator issue,
causing either the overuse or chlorine or a failure to remove chlorine prior to discharge.
Moyer Packing Co. accepted responsibility for the failure. The incident resulted in the
death of thousands offish, primarily minnows, for up to 1.2 miles downstream. The JBS
company, which purchased the Moyer Packing Co. in 2008, upgraded the wastewater
treatment capabilities and paid $1.9 million in civil penalties and another $100,000 in
fines (MORNING CALL, 2007). Later, in 2012, JBS commissioned the Delaware River Basin
Commission (DRBC) to renew the National Pollutant Discharge Elimination System
(NPDES) permit for its wastewater treatment facility. As part of the process, the facility
conducted a study on temperature differences in discharge and the receiving water.
DRBC found that the facility was discharging effluent that was raising the receiving
waters ambient temperature by more than 5°F. Due to the exceedances, the facility
should have been required to produce a schedule by 2015 with plans to address the
elevated temperature issue by 2018 (Delaware River Basin Commission, 2011). However,
no evidence of this action being taken occurs, and enforcement and compliance history
online (ECHO) database information shows that the facility has continued to have serious
exceedances of nutrient and bacteria limits in 2020 and 2022 (U.S. Environmental
Protection Agency, 2023d).
2008
Kiryas Joel
Meat
Market
Corp.
The Kiryas Joel Meat Market Corporation facility failed to prevent untreated wastewater
spills into surface waters in New York from 2008 to 2012. Excess fats, oils, and grease
(FOG), carbonaceous biochemical oxygen demand (CBOD), and total suspended solids
(TSS) from the wastewater created operational issues at the POTW receiving the facility's
wastewater. The POTW faced issues with adequately treating water and subsequently
violated its permit as a result. Furthermore, the pollutant levels were such that the Clean
Water Act was violated. Corrective action and monetary damages were required by the
poultry company responsible as a result. One of the corrective actions implemented by
the processor was the installation of a salt reduction machine that eliminated 20 percent
of total dissolved solids (TDS) in discharge. ("Complaint, United States District Court
Southern District of New York v. Kiryas Joel Poultry Processing Plant Inc and Kiryas Joel
Meat Market Corp," 2014; "United States District Court Southern District of New York v.
Kiryas Joel Poultry Processing Plant Inc and Kiryas Joel Meat Market Corp," 2014).
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Table 1-2: Summary of Select Damage Cases with Documented Water Quality Impacts from MPP Facilities
Year
Facility
Summary of Site Impacts
2012
Pilgrim's
Pride
A Pilgrim's Pride MPP facility illegally dumped polluted wastewater into the middle
Suwanee River in Florida, a river that flows through the Suwanee River State Park, the
Suwanee River Wilderness Trail, and is frequently used for a variety of recreational
activities. Elevated levels of sulfates, nitrates, and/or chlorides were observed from 2012
to 2015, resulting in the allegations that nitrogen, biochemical oxygen demand (BOD),
and conductivity standards were exceeded. Pilgrim's Pride agreed to pay a $1.43 million
settlement, $1.3 million of which was used to create a Sustainable Farming Fund, which
helps to promote more sustainable agricultural practices on local family farms
(Environment America, 2017; National Environmental Law Center, 2017).
2012
Sioux-Preme
Packing Co.
The Sioux-Preme Packing Company in Sioux County, Iowa illegally discharged their
wastewater into a West Branch Floyd River tributary. The illegal discharge resulted in
elevated ammonia levels up to nine miles downstream of the facility and killed about
190,000 fish over an 11-mile stretch. Following the incident, the company hired a
contractor to pump and water from a pooled tributary to the affected stream to manage
the effects of the ammonia. The Iowa Department of Natural Resources led enforcement
actions and the Sioux-Preme Packing Co. was ultimately required to pay $54,000 in civil
penalties, as well as $23,000 in restitution for lost fish. (Eller, 2014; "Sioux County fish kill
traced to business," 2012; Staff, 2012)
2014
Tyson -
Monett,
Missouri
A leak of the amino acid food additive "Alimet" contaminated a holding tank at a Tyson
facility in Aurora, Missouri. The "Alimet" was removed and taken to a separate Tyson
wastewater treatment facility in Monett, Missouri where it was dumped into the
facility's wastewater treatment system. The acidic compound killed bacteria necessary to
reduce ammonia, resulting in wastewater released with excessive ammonia. The
excessive ammonia resulted in a fish kill in Clear Creek where the city sewage water
system discharges. A federal court sentenced the Tyson business unit to pay $2 million in
criminal fines, $500,000 in restitution of CWA violations, and serve two years of
probation. The lawsuit by the state of Missouri also required the business unit to pay
almost $163,000 for damaging natural resources, an additional $110,000 in civil
penalties, reimburse the Missouri Department of Natural Resources $11,000, and
reimburse the Missouri Department of Conservation over $36,000 for their expenses.
(Staff, 2018; Woodin, 2018)
2015
Cargill Meat
Solutions
An incident occurred at the Cargill Meat Solutions slaughterhouse in Beardstown, IL, now
owned by JBS. A 40-foot breach in the berm of a swine waste lagoon resulted in 29
million gallons of hog waste flowing into nearby ditches and waterways. The waste
ultimately ended up in Muscooten Bay and other nearby waterways after it was pumped
there by the Lost Creek Drainage District pumping station, which prevents flooding in
nearby farmland and residential areas. The pumped wastewater ultimately resulted in
the death of over 64,000 fish, including gamefish species. The plant was charged with a
$150,000 fine for unpermitted discharges and agreed to pay an additional $34,000 to the
Illinois Fish & Wildlife Fund (Jackson et al., 2016; The Environmental Integrity Project,
2018).
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs 1: Introduction
Table 1-2: Summary of Select Damage Cases with Documented Water Quality Impacts from MPP Facilities
Year
Facility
Summary of Site Impacts
2018
Mountaire
Slaughterho
use
The Mountaire Farms poultry company was sued for groundwater contamination as a
result of waste discharge practices at a facility in Sussex County, Delaware. The facility
sprayed poultry waste contaminated with nitrates and bacteria onto nearby farm fields,
where it subsequently seeped into the groundwater. The nitrates and bacteria reached
nearby wells and were associated with gastrointestinal illnesses in nearby residents. In
some cases, contaminated wells exceeded the nitrate drinking water standard of 10
mg/L The groundwater pollutants reached the Swan and Indian Rivers, where it limited
the ability of residents to enjoy recreational activities. Furthermore, the air pollution and
noxious odors caused by the waste produced aesthetic issues and negative health
impacts. As a result, Mountaire faced several lawsuits that were settled for $205 million,
with $65 million set aside for a fund for affected residents, and $140 million going
toward upgrading facilities to ensure environmental compliance. (Baird Mandalas
Brockstedt LLC et al., 2021; The Environmental Integrity Project, 2018)
2019
Tyson -
Hanceville,
Alabama
At a Tyson facility in Hanceville, Alabama, a pipe responsible for transporting partially
treated wastewater from one holding pond to another failed, resulting in a leak that
flowed into the Mulberry Fork of the Black Warrior River. The leak released pollutants
that caused taste and odor issues, but no adverse health outcomes, in local water
supplies. However, the leak caused hypoxic conditions 22 miles downstream of the leak.
The hypoxic conditions killed over 175,000 fish, which were found up to 40 miles
downstream. The state of Alabama reached a settlement with Tyson for over $3 million.
The Tyson Plant was charged with fixing the infrastructure responsible for the spill, as
well as providing compensation by making recreational investments into the affected
environment. (Alabama Attorney General, 2021; McCarthy, 2019)
1.3 Baseline and Regulatory Options Analyzed
EPA is proposing to revise or establish effluent limitations for the MPP industry. EPA has identified three
regulatory options that build on the current ELGs. In developing these regulatory options, EPA sought to
reduce pollutant discharges to surface waters, reduce and/or eliminate interference and pass-through at
POTWs receiving MPP wastewater, and minimize impacts to small businesses by establishing effluent
limits and pretreatment standards based on technologies that are available and affordable to the industry.
All options build on the existing ELGs and are based on four technologies: conventional pollutant (e.g.,
BOD, TSS, and oil and grease) removal by screening and dissolved air flotation (DAF), phosphorus
removal by chemical precipitation, nitrogen removal by full denitriflcation, and high chlorides removal by
side stream evaporation.2 Each option incrementally increases the number of facilities to which the
effluent limitations and/or pretreatment standards would apply.
Option 1 is EPA's preferred option and builds on the existing ELGs by adding new limits for large direct
and indirect dischargers. This option includes TP limits for large direct dischargers, more stringent TN
limits for large direct dischargers, and new conventional pollution limits (pretreatment standards) for
large indirect dischargers. Large refers to the existing rule production thresholds of greater than 50
million pounds per year of finished product produced for meat further processors (Subparts F-I) and in
terms of live weight killed for meat slaughtering (Subparts A-D). For poultry slaughtering (Subpart K)
2 EPA is taking comment on potential effluent limitations on chlorides for high chloride waste streams and it is not currently part
of the three regulatory options under consideration.
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
1: Introduction
large is greater than 100 million pounds per year of live weight killed, greater than 7 million pounds per
year of finished product produced for poultry further processors (Subpart L), and 10 million pounds per
year of raw material processed for Tenderers (Subpart J).
Option 2 would include the limits in Option 1, as well as add TN and TP limits for indirect discharging
processors exceeding the production thresholds defined above.
Option 3 would include the limits in Option 2, as well as apply the more stringent TN and TP limits and
conventional limits to more direct and indirect discharging facilities by adjusting the existing rule
production thresholds. Economic analyses, discussed in the Regulatory Impact Analysis (RIA) (U.S.
Environmental Protection Agency, 2023c), were used in determining the applicable production size
thresholds.
Under Options 2 and 3, EPA also considered an approach for indirect dischargers that would not require
indirect dischargers to meet TN and TP limits where the associated POTW that receives their wastewater
is willing and able to (through its NPDES permit) meet them. Additional details on the regulatory options
are available in the Technical Development Document (TDD) (U.S. Environmental Protection Agency,
2023p). Table 1-3 summarizes the various regulatory options as well as the applicable facilities.
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1: Introduction
Table 1-3: Summary of Regulatory Options
Option
Direct Dischargers
Indirect Dischargers
Technology Basis
Applicable Facilities
Technology Basis
Applicable Facilities
1
Adds to existing ELG: full
denitrification, chemical phosphorus
removal, filtration
> 50 million Ibs/yr of finished product
produced for meat further
processors, > 50 million Ibs/yr live
weight killed for meat slaughtering,
>100 million Ibs/yr of live weight
killed for poultry slaughtering, >7
million Ibs/yr of finished product
produced for poultry further
processors, >10 million Ibs/yr of raw
material processed for Tenderers.
Conventional pollution limits based
on screening/grit removal, DAF, and
dewatering/solids handling
> 50 million Ibs/yr of finished product
produced for meat further
processors, > 50 million Ibs/yr live
weight killed for meat slaughtering,
>100 million Ibs/yr of live weight
killed for poultry slaughtering, >7
million Ibs/yr of finished product
produced for poultry further
processors, >10 million Ibs/yr of raw
material processed for Tenderers.
2
Same technology as Option 1
Same facilities as Option 1
Screening/grit removal, DAF,
anaerobic lagoon (BOD
pretreatment), activated sludge
(nitrification and full denitrification),
chemical P removal, filter, and
dewatering/solids handling
Option 1 facilities plus
slaughterhouses producing >200
million Ibs/yr and Tenderers
processing >350 million Ibs/yr raw
material
3
Same technology as Option 1
Phosphorus limits for all direct
discharging facilities producing >= 10
million Ibs/yr, and phosphorus and
more stringent nitrogen limits to all
facilities producing >20 million Ibs/yr.
Same technology as Option 2
Conventional limits for facilities
producing >5 million Ibs/yr plus
nitrogen and phosphorus limits for all
facilities >30 million Ibs/yr
a. See TDD for a description of these technologies (U.S. Environmental Protection Agency, 2023p)
Source: U.S. EPA Analysis, 2023
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
1: Introduction
1.4 Organization of the Environmental Assessment Report
This document summarizes the potential environmental and human health effects estimated to result from
implementation of the proposed rule, including any effects to potential environmental justice communities.
The remainder of this report is organized as follows:
Chapter 2 provides an overview of the pollutants found in MPP wastewater.
Chapter 3 discusses water quality effects of the regulatory options in receiving waters and downstream of
MPP facilities.
Chapter 4 summarizes the environmental effects from expected changes in water quality under the
regulatory options.
Chapter 5 summarizes the human health effects from expected changes in water quality under the
regulatory options.
Chapter 6 summarizes the non-water quality effects of the regulatory options.
Chapter 7 discusses the environmental justice analyses and potential implications of the regulatory
options.
Several appendices provide additional details on selected aspects of analyses described in the main text of the
report.
This report is part of the supporting documentation for the rulemaking and complements the information
reflected in the following documents:
Technical Development Document for Proposed Effluent Limitations Guidelines and Standards for
the Meat and Poultry Products Point Source Category (U.S. Environmental Protection Agency,
2023p). This report summarizes the technical and engineering analyses supporting the proposed rule
including cost methodologies, pollutant removal estimates, non-water quality environmental impacts,
and calculation of the proposed effluent limitations.
Benefit and Cost Analysis for Proposed Effluent Limitations Guidelines and Standards for the Meat
and Poultry Products Point Source Category (BCA) (U.S. Environmental Protection Agency, 2023b).
This report summarizes the societal benefits and costs estimated to result from implementation of the
proposed rule.
Regulatory Impact Analysis for Proposed Effluent Limitations Guidelines and Standards for the
Meat and Poultry Products Point Source Category (U.S. Environmental Protection Agency, 2023m).
This report presents a profile of the meat and poultry processing industry, a summary of estimated
costs and impacts associated with the proposed rule, and an assessment of the potential impacts on
employment and small businesses.
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2 Pollutants Found in MPP Wastewater
Pollutants associated with MPP waste streams include nutrients (particularly various forms of nitrogen
(including ammonia) and phosphorus), organic matter (typically measured as BOD, CBOD, chemical
oxygen demand (COD)), oil and grease, solids, pathogens, inorganic anions, total organic carbon (TOC),
and metals.
The following sections introduce the main constituents of MPP industry waste streams, their presence in
the environment, including sampling3 or survey data gathered by EPA from MPP facilities4, as well as the
effects of their presence to the environment and human health. The regulatory options include treatment
technologies that focus on conventional pollutant (e.g., BOD, TSS, and oil and grease) removal by
screening and DAF, phosphorus removal by chemical precipitation, and nitrogen removal by full
denitrification. However, the treatment technologies may affect concentrations of other pollutants
associated with MPP waste streams that are discussed in this chapter.
Data on state water quality criteria (WQC) were also collected and aggregated to compare state pollution
limits with sampling data collected by EPA.5 During the WQC aggregation process, EPA classified
values by similar criteria categories. These categories are defined in Table 2-1 below. Additionally,
baseline concentration data, averaged across the MPP facility universe, were used to provide context to
the WQC and sampled data.6
Table 2-1: State WQC Category Definitions
Criteria Category
Definition
Agriculture
Includes irrigation and livestock watering
Aquatic life
Aquatic species natural environment
Aquatic life consumption
Human consumption of aquatic species
Drinking water source
Area in which water is sourced for further drinking water treatment
Effluent
Water leaving a point source
General/Unspecified
Unspecified water usage
Industrial water
Water to be used for industrial intake
Potable drinking water
Water to be consumed without further treatment
3 EPA collected and analyzed wastewater samples from six MPP facilities (seven total sampling sites) to characterize raw waste
streams, wastewater treatment systems, and treated effluent for pollutants found in MPP wastewater. The facilities sampled
were chosen based on the types of treatment technology that they employ, which are operated more stringently than existing
effluent limits. The data reflected in this report from this effort are summarized only for the samples taken at the final
effluent point for each facility. These data were collected during discrete sampling events and are not reflective of average
conditions. Abnormal wastewater operations affected sampling data for two facilities.
4 In preparation for updating the ELGs, EPA issued a questionnaire to MPP facilities engaged in meat and poultry slaughtering,
processing, and rendering activities. EPA developed two questionnaires to collect site-specific technical and economic
information: a Census Questionnaire and a Detailed Questionnaire. The Census Questionnaire was administered as a census
of the industry to confirm the list of facilities that fall within the MPP industry. A statistically representative subset of MPP
facilities were asked to answer a more extensive set of questions in the Detailed Questionnaire, including additional
questions on processing operations, wastewater generation, and financial information.
5 Data related to saline waters and lakes were not included as they are not covered under this ELG.
"To evaluate the effects of the regulatory options, EPA estimated the pollutant loading reductions that would result from
implementation of treatment under each regulatory option, accounting for any existing treatment in place for all facilities in
the MPP universe. Hie loadings were then converted into concentrations and averaged by pollutant.
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs 2: Pollutants Found in MPP Wastewater
Table 2-1: State WQC Category Definitions
Criteria Category
Definition
Recreation
Includes all recreation designations [e.g., primary, secondary)
Source: U.S. EPA Analysis, 2023
This chapter details the pollutant categories for which limits are proposed in the rule revision, pollutants
for which EPA has sampling data from MPP facilities, and other pollutants relevant to the MPP industry.
2.1 Nutrients
According to the 2002 TDD for the proposed MPP ELGs, nutrients such as organic nitrogen and
ammonia were widespread in MPP wastewater, originating from bone, soft tissue, blood, manure, and
cleaning compounds (U.S. EPA, 2004). Other researchers found that animal processing introduces
nutrients into the wastewater because animal tissue contains nitrogen and phosphorus (Milanovic et al.,
2015; Ziara et al., 2018). As a result, nutrient discharges from MPP facilities can be quite significant.
Ramires et al. (2019) and Potle et al. (2012) found that nitrogen levels from raw to pretreated swine
slaughterhouse wastewater can vary from tens to over one thousand mg/L. A detailed review of 2018
Discharge Monitoring Report (DMR) data conducted by EPA found that the MPP industry discharges the
most phosphorus loadings (lbs/year) across all industrial point source categories and the fifth-most
nitrogen loadings (lbs/year) across all industrial point source categories (U.S. EPA, 2020b). The
Environmental Integrity Project conducted a study of 98 MPP facilities across the US7 between the years
of 2016 - 2018 and found that three quarters of the facilities violated the Clean Water Act during this
time, while athird had ten or more violations, totaling 1,142 separate violations for exceeding pollution
limits (The Environmental Integrity Project, 2018). The average nitrogen loading rate of these facilities
was 331 pounds of nitrogen per day, roughly equivalent to the waste produced by a town of 14,000
people (The Environmental Integrity Project, 2018). Tyson Fresh Meats of Dakota City, Nevada releases
as much as 3,084 pounds of nitrogen per day into the Missouri River, a level approximately equal to the
waste load of 132,000 people (The Environmental Integrity Project, 2018). Both wastewater and sludge
resulting from wastewater treatment processes applied to fields leach nitrogen, phosphorus, and bacteria
into the ground and can pollute local bodies of water and well water (Cox et al., 2013; The Environmental
Integrity Project, 2018).
The current nutrient ELG limits for the MPP category are summarized in Table 2-2 by subcategory for
existing, non-small8 direct dischargers of ammonia (as N) or total nitrogen to surface water. There are
currently no ELG limits for phosphorus. Based on the applicability of the ELGs, a "first" processor refers
to a facility that conducts slaughtering and may conduct additional processing activities and includes
slaughterhouses and packinghouses. A ""further" processor refers to a facility that produces fresh or frozen
meat products from whole carcasses or cut-up meat and poultry.
7 Facilities were selected based on their discharge status and availability of monitoring in US EPA's ECHO database. All
facilities discharged more than 250,000 gallons of wastewater per day directly to surface waters.
8 The definition of non-small differs by subcategory, with thresholds of >50 million lb/year for meat first and further processors,
>100 million lb/year for poultry first facilities, and > 7 million lb/year for poultry further processors. For independent
renders, the threshold for raw product is 10 million lb/year.
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Table 2-2: Existing Nutrient ELGs for the MPP Category (Note: there are currently no ELG limits for
phosphorus)
Subcategory
Technology Basis
Final Rule Nutrient Limitations
Ammonia (as N)
Total Nitrogen
Daily
Maximum
Monthly
Average
Daily
Maximum
Monthly
Average
A-D: Meat First
Processors*
Best Practicable
Control Technology
Currently Available
(BPT)
8.0 mg/L
4.0 mg/L
NA
NA
Best Available
Technology
Economically
Achievable (BAT)
8.0 mg/L
4.0 mg/L
194 mg/L
134 mg/L
E: Small Meat
Further Processors
BPT and BAT
NA
NA
NA
NA
F-l: Meat Further
Processors*
BPT
NA
NA
NA
NA
BAT
8.0 mg/L
4.0 mg/L
194 mg/L
134 mg/L
J: Independent
Renderers*
BPT
NA
NA
NA
NA
BAT
0.14 lb per
1,000 lb of raw
material
0.07 lb per
1,000 lb of raw
material
194 mg/L
134 mg/L
K-L: Poultry First
and Further
Processors*
BPT
BAT
8.0 mg/L
8.0 mg/L
4.0 mg/L
4.0 mg/L
NA
147 mg/L
NA
103 mg/L
Source: U.S. Environmental Protection Agency, 2019a
EPA nitrogen sampling for each site are summarized in Table 2-3 below, and the data collected for total
phosphorus are summarized in Table 2-4 below.
Table 2-3: Observed Nitrogen Concentrations in Sampled MPP Final Effluent at Select Sites, Compared to MPP
Universe Average Baseline Concentrations (mg/L)
Ammonia
Nitrogen, Total
Sampling
Episode Report
Number
Min
Max
Average
Average
MPP
Universe
Baseline
Min
Max
Average
Average
MPP
Universe
Baseline
Episode 7010-A
ND
5.9
1.5
1.9
20.0
110.0
71.7
37.0
Episode 7010-B
ND
5.9
1.6
1.9
20.0
110.0
71.7
37.0
Episode 7011
ND
4.9
0.7
1.9
20.0
97.0
66.4
37.0
Episode 7012
ND
0.5
0.4
1.9
17.0
29.0
23.4
37.0
Episode 7013
ND
ND
ND
1.9
4.6
7.4
5.8
37.0
Episode 7014
ND
0.6
0.2
1.9
ND
180.0
19.9
37.0
Episode 7015
ND
ND
ND
1.9
30.0
37.0
34.0
37.0
Note: ND indicates samples for which the analyte was not detected. For values without a detected minimum, results were
assumed to have a value of 1/2 the reported method detection limit (MDL).
Source: U.S. EPA Analysis, 2023
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State-level WQC for nitrogen are summarized in Table A-l in Appendix A: Nitrogen State Water Quality
Criteria. Of the states with numeric TN criteria, the maximum limit allowed in effluent was 15 mg/L. All
but one of the six facilities (facility sampled during Episode 7013) have average TN effluent
concentrations that are higher than this maximum effluent criteria. Most of the facilities had effluent
concentrations between 20 to 72 mg/L and an average baseline concentration for the full MPP universe is
37 mg/L. The overall average state WQC limit for TN was around 6 mg/L across all criteria categories.
Notably, the same facility that did not have a higher average effluent concentration than the maximum
state effluent numeric criteria (facility sampled during Episode 7013) had less than 6 mg/L of TN in its
final effluent.
Table 2-4: Observed Total Phosphorous Concentrations in Sampled MPP Final Effluent at Select Sites,
Compared to MPP Universe Average Baseline Concentrations (mg/L)
Sampling Episode
Report Number
Minimum
Maximum
Average
Average MPP
Universe Baseline
Average State
Effluent WQCb
Episode 7010- A
ND
0.1
3.0E-2
24.5
1.8
Episode 7010- B
ND
0.1
0.3
24.5
1.8
Episode 7012
ND
0.9
1.2
24.5
1.8
Episode 7011
ND
4.0
1.5
24.5
1.8
Episode 7013
4.6
14.0
8.3
24.5
1.8
Episode 7014
ND
0.3
0.2
24.5
1.8
Episode 7015
ND
4.0E-2
2.0E-2
24.5
1.8
Note: ND indicates samples for which the analyte was not detected. For values without a detected minimum, results were
assumed to have a value of Zi the reported MDL.
b Describes the average phosphorus criteria states have for effluent from point sources.
Source: U.S. EPA Analysis, 2023
Only a few states have numeric criteria for total phosphorus across a variety of criteria categories.
Compared to the average state WQC criteria, only one facility had an average effluent concentration
greater than the criteria. This facility happens to be the same facility (facility sampled during Episode
7013) with the lowest total nitrogen concentrations of the sampled locations. The average baseline TP
concentration across the full universe of MPP facilities is much higher than the average state WQC, at
24.5 mg/L. The state WQC for other designated uses are described in Table 2-5. Five of the seven
facilities sampled also had higher average phosphorus effluent concentrations than the mean designated
use criteria for aquatic life, drinking water source, general/ unspecified, and recreation.
Table 2-5: Average State WQC for Phosphorus (mg/L)
Criteria Category
Average Criteria Value (mg/L)
Aquatic life
0.05
Drinking water source
0.05
Effluent
1.83
General/ Unspecified
0.08
Recreation
0.04
Note: Different states have criteria related to total phosphorus and phosphorus, which were considered equal for the
purposes of generating an average limit applicable to phosphorus.
Source: U.S. EPA Analysis, 2023
The forms of nitrogen, ammonia and nitrate, and phosphorus are of concern in surface waters because, in
excess, they can lead to adverse environmental impacts like eutrophication, fish kills, reduced
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biodiversity, and impact human health and wellness by contributing to objectionable tastes and odors,
increased drinking water treatment costs, and growth of toxic organisms.
According to a 2023 EPA report on state progress toward adopting numeric nutrient water quality criteria
for nitrogen and phosphorus, only 24 states and five territories have EPA-approved TN or TP criteria for
at least one water body type (U.S. Environmental Protection Agency, 2023n). Of these, no states have
a complete set of N and P criteria for all water types (including lakes/reservoirs, rivers/streams, and
estuaries), though four territories do. Sixteen states have some waters with N and/or P criteria, three states
have one water type with N and/or P criteria and five states plus one territory have two or more water
types with N and/or P criteria. While the number of states implementing more comprehensive N and P
WQC have increased over the last 20 years, 27 states remain without any numeric TN and TP EPA-
approved criteria (U.S. Environmental Protection Agency, 2023n).
According to the 2018-19 National Rivers and Streams Assessment (NRSA), around 43.6 percent of
sampled river and stream miles were rated poor based on total nitrogen levels and 41.8 percent of sampled
river and stream miles were rated poor based on total phosphorus levels (U.S. EPA, 2019c). Total
nitrogen assessments between the 2008-09 and 2018-19 NRSAs have shown no improvement, with the
same percentage of river and stream miles rated poor between 2008-09 as between 2018-19. While total
phosphorus levels have seen an overall improvement between 2008-2009 and 2018-2019, well over a
third of all river and stream miles are still in poor condition from TN and TP pollution. In other words,
nutrient impairments remain a widespread issue (U.S. EPA, 2019c).
2.1.1 Ecological and Aquatic Resource Use Effects
Ammonia is of environmental concern because it exerts a direct oxygen demand on the receiving water as
it is broken down, thereby reducing dissolved oxygen (DO) levels and the ability of a water body to
support aquatic life. In particular, low DO (hypoxia) can increase the availability of ammonia and
hydrogen sulfide, reducing the habitability for most aquatic life, including game fish (U.S. EPA, 2000).
Low DO levels can also cause the release of toxic metals from sediments, contaminating aquatic habitats
(H. Li et al., 2013). The unionized form of ammonia can also be toxic to aquatic life as high
concentrations can reduce or reverse diffusive gradients and cause the buildup of ammonia in internal
tissues and blood (U.S. Environmental Protection Agency, 2013).
Excessive amounts of ammonia and other forms of nitrogen can lead to eutrophication, or nutrient over
enrichment, of surface waters (S. Li et al., 2018). Eutrophication is the most documented impact of
nutrient pollution. Excess nutrients in surface water can also cause algal blooms, which depress oxygen
levels and contribute further to eutrophication (National Estuarine Experts Workgroup, 2010, S. Li et al.,
2018).
With nitrogen, phosphorus loads also contribute to eutrophication and reduced DO levels (U.S EPA,
2001, Michael A Mallin et al., 2020). Phosphorus commonly occurs as phosphate and is the nutrient that
generally controls the growth of algae and aquatic plants, as it is often more limited than nitrogen.
Phosphorus can also cause hypoxia by over stimulating bacterial growth (Michael A Mallin et al., 2020).
Thus, both nitrogen and phosphorus loads contribute to eutrophication and reduced oxygen levels (U.S
EPA, 2001).
Harmful algal blooms (HABs), often resulting from eutrophication, can intensify water quality
deterioration, decrease freshwater zooplankton richness, and reduce plankton diversity (Amorim et al.,
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2021). Algal blooms can harm ecosystems both by inducing hypoxia and by reducing the availability of
light in the water column (National Estuarine Experts Workgroup, 2010). The resulting low oxygen
availability can interrupt nutrient cycling and create more favorable conditions for excess algal growth.
Excess algal growth can further deprive the water of dissolved oxygen. These factors can destabilize
cultivated fish and shellfish stocks in addition to native aquatic life, causing bottom habitat destruction
and fish kills (Cloern, 2001; U.S. EPA, 2023g). A loss in species richness can negatively impact
ecosystem functions. Harmful algal blooms, such as cyanobacteria which produce toxic metabolites called
cyanotoxins, can also sicken and kill terrestrial animals like dogs and livestock when they consume
contaminated water (Backer 2002).
Excess nutrients can also be toxic to plants and aquatic organisms (Bustillo-Lecompte, Mehrvar, et al.,
2016; Backer, 2002). Raw and pretreated swine slaughterhouse wastewater has been shown to be toxic
when applied to terrestrial plants due in part to nutrient imbalance (Ramires et al., 2019), which suggests
potential impacts of land application of treated wastewater. Excess nutrients can be particularly harmful
to certain aquatic species. Potle et al. (2012) found that diluted slaughterhouse wastewater still shows
ecotoxicity to the relatively sturdy fish species Lebistes reticulatus. This research performed a toxicity
test on model fish in different concentrations of wastewater and found good statistical correlation between
the fish mortality and increased wastewater concentration. As discussed in Section 1.2, the Sioux-Preme
Packing Company illegally discharged their wastewater into a West Branch Floyd River tributary that
resulted in elevated ammonia levels up to nine miles downstream of the facility and killed about 190,000
fish over an 11-mile stretch (Eller, 2014; "Sioux County fish kill traced to business," 2012; Staff, 2012).
Similarly, excess ammonia discharged by a Tyson wastewater treatment facility in Monett, Missouri
resulted in a fish kill in Clear Creek (Staff, 2018; Woodin, 2018). Additionally, the ingestion of excess
nitrate via water is a concern for livestock, particularly ruminants, and can lead to nitrate poisoning
(Olson, 2022).
2.2 Oxygen Demand
The nutrients and organic matter from fresh blood and offal contribute to high oxygen demand in MPP
facility effluent. Biochemical oxygen demand, a measure of the oxygen-consuming requirements of
decaying matter, from food processing wastewater often exceeds that of domestic sewage by as much as
five times (Mittal, 2004). In raw MPP wastewater, BOD and COD, an estimate of total organic content,
can be several thousand mg/L (Mittal, 2004; Yordanov, 2010). For facilities sampled by EPA, average
raw wastewater BOD concentrations ranged from 938 -10,084 mg/L. Even when MPP wastewater has
undergone some level of primary treatment (e.g., equalization, suspended solids removal), BOD and COD
can still be hundreds to thousands of mg/L when piped to a POTW (Hamawand et al., 2017; Yordanov,
2010). As discussed in Section 1.2, a Pilgrim's Pride facility in Live Oak, Florida was implicated with
violations of permitted discharge limits after exceeding the daily maximum and maximum monthly
average of carbonaceous biochemical oxygen demand in their wastewater (National Environmental Law
Center, 2017; U.S. District Court Middle District of Florida, 2018).
Data from EPA's 2022 MPP facility sampling efforts collected for BOD, CBOD, and COD for each site
are summarized in Table 2-6 below. None of the facilities sampled had higher average BOD
concentrations than the average BOD WQC limit for effluent of 33.8 mg/L, and most were well below the
criteria. Although there are not WQC for COD, the COD concentrations in sampled final effluent were
also below the hundreds to thousands of mg/L discussed in the literature. The average baseline
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concentrations across the MPP universe for BOD, CBOD and COD were 39.2, 37.6, and 130.0 mg/L,
respectively. Notably, the average baseline concentration for BOD is larger than the average BOD
effluent WQC.
Table 2-6: Observed Oxygen Demand Concentrations in Sampled MPP Final Effluent at Select Sites, Compared to
MPP Universe Average Baseline Concentrations (mg/L)
Sampling Episode
Report Number
BOD
Min
Max
Average
Average State
Effluent WQC
CBOD
Min
Max
Average
COD
Min
Max
Average
Episode 7010- A
NA
NA
NA
33.8
NA
NA
NA
41.0
82.0
55.6
Episode 7010- B
ND
ND
ND
33.8
ND
ND
ND
41.0
84.0
55.6
Episode 7011
ND
ND
ND
33.8
ND
ND
ND
53.0
86.0
62.0
Episode 7012
ND
3.0
1.0
33.8
ND
2.7
1.4
25.0
53.0
35.0
Episode 7013
5.3
16.7
10.7
33.8
6.9
14.4
10.7
41.6
84.0
55.9
Episode 7014
ND
3.3
1.2
33.8
ND
3.0
1.0
9.6
24.4
17.2
Episode 7015
ND
2.8
0.5
33.8
ND
2.7
0.7
ND
20.0
14.3
Note: ND indicates samples for which the analyte was not detected. NA Indicates samples for which the dissolved oxygen
depletion requirement was not met and thus the test was not valid. For values without a detected minimum, results were
assumed to have a value of 1/2 the reported MDL
3 Describes the average BOD criteria states have for effluent from point sources
Source: U.S. EPA Analysis, 2023
Ranges of state WQC for BOD and DO based on designated use are summarized in Table 2-7. A few
states have BOD criteria for drinking water sources, aquatic life, agriculture, and recreation, but the value
is the same at 5 mg/L.9 All but one of the sampled facilities have effluent concentration lower than the
state average criteria for agriculture, aquatic life, drinking water source, and recreational uses. Final
effluent concentrations above 5 mg/L were observed at the facility sampled during Episode 7013, which
is the same sampling episode noted in Section 2.1.
Table 2-7: Average State WQC for Oxygen Demand (mg/L)
Criteria Category
BOD
Dissolved Oxygen
Agriculture
5.00
3.50
Aquatic life
5.00
5.49
Drinking water source
5.00
-
Effluent
33.75
4.00
Industrial water
-
0.20
Recreation
5.00
5.00
Source: U.S. EPA Analysis, 2023
Other MPP processing byproducts contributing to high oxygen demand are fats, oils, and grease (FOG).
These components form a thin film on surface water, inhibiting oxygen mixing with the water, and
exacerbate low oxygen supply. FOG can also diminish the efficiency of wastewater treatment, as they are
difficult to break down in water, and can inhibit some wastewater treatment processes (Mittal, 2004).
Several states maintain qualitative, aesthetic limits on FOG (e.g., not allowing any visible residue on
surface water). Two states specifically banned visible FOG residue from being present at drinking water
9 Aquatic life water quality criteria for DO vary widely, with many state criteria averages spanning a range of 2-7 mg/L. General
water quality criteria for DO followed a similar trend, varying from 2.5-7mg/L across states with numeric water quality
criteria for DO.
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intake sites and 12 states banned visible residue from being present in surface water more generally. Data
from EPA's 2022 MPP facility sampling efforts collected for oil and grease for each site are summarized
in Table 2-8 below.
Table 2-8: Observed Oil and Grease Concentrations in Sampled MPP Final Effluent at Select Sites, Compared
to MPP Universe Average Baseline Concentrations (mg/L)
Sampling Episode
Report Number
Minimum3
Maximum
Average
Average MPP
Universe
Baseline
Average State
General/Unspecified
WQC
Episode 7010- A
ND
28.0
4.9
139.8
8.8
Episode 7010- B
ND
28.0
5.4
139.8
8.8
Episode 7011
ND
32.0
5.3
139.8
8.8
Episode 7012
ND
3.8
1.3
139.8
8.8
Episode 7013
ND
6.6
1.1
139.8
8.8
Episode 7014
ND
0.7
0.2
139.8
8.8
Episode 7015
ND
ND
ND
139.8
8.8
Note: ND indicates samples for which the analyte was not detected. For values without a detected minimum, results were
assumed to have a value of Zi the reported MDL
a Describes the average oil and grease criteria states have for general or unspecified water body uses
Source: U.S. EPA Analysis, 2023
State WQC on oil and grease were largely qualitative, though some states did have numeric criteria,
summarized in Table 2-9. As shown, there were no criteria related specifically to wastewater effluent so
the general criteria was used as a comparison point for the sampled data. While average observed data
across the sampling episodes was lower than the general average state criteria of 8.8 mg/L, some of the
maximum sample values were greater (facilities sampled during Episodes 7010 and 7011) by up to four
times the average criteria (Table 2-8). The average baseline oil and grease concentrations across facilities
in the full MPP universe at 139.8 mg/L are much higher than the average state WQC at 8.8 mg/L and the
maximum sample values at the facilities sampled during Episodes 7010 and 7011.
Table 2-9: Average State WQC for Oil and Grease (mg/L)
Criteria Category
Average Criteria Value
(mg/L)
Number of States not Allowing Visible
Residue
Aquatic life
7.63
1
Drinking Water Source
-
2
Recreation
10.00
0
Unspecified/General
8.75
12
Source: U.S. EPA Analysis, 2023
2.2.1 Ecological and Aquatic Resource Use Effects
Low DO levels in receiving water, also known as hypoxia, could result in abrupt and significant losses in
aquatic life (U.S. EPA, 2023g). As discussed in Section 1.2, a pipe failure at a Tyson poultry processing
facility in Alabama killed approximately 175,000 fish. The wastewater largely contained organic poultry
material, which caused an increase in decomposing organic matter as well increased levels of bacteria
present, depriving the fish of oxygen. Depressed DO was detected 22 miles downstream from the leak
accident (Alabama Attorney General, 2022; The Associated Press, 2020; McCarthy, 2019). Similarly, a
Tyson facility in Hanceville, Alabama had equipment failure that resulted in a leak that caused hypoxic
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conditions 22 miles downstream. The hypoxic conditions killed over 175,000 fish, which were found up
to 40 miles downstream (Alabama Attorney General, 2021; McCarthy, 2019).
In addition to abrupt and large-scale losses of aquatic life, hypoxia can also cause physiological,
developmental, growth, and reproductive abnormalities in fish. Low oxygen availability can interrupt
nutrient cycling and lead to excess algal growth, which could further deprive the water of oxygen. These
factors can destabilize cultivated fish and shellfish stocks in addition to native aquatic life (U.S. EPA,
2023g).
2.2.2 Human Health and Aesthetic Impacts
Depletion of dissolved oxygen can cause the death of many aquatic organisms, which can cause a foul
smell and unpleasant scene, as well as lead to potential pathogen accumulation (Mittal, 2004). Fish kills
caused by hypoxia or toxins can have widespread impacts, including declines in local fish populations,
subsequent die-offs of benthic organisms, and adverse impacts to ecosystems structure and function as a
whole (Landsberg et al., 2009). Impacts to the structure and function of aquatic communities or
populations could have negative health consequences for subsistence fishers if fish kills occur in areas
relied upon for subsistence resources.
2.2.3 Human Health and Aesthetic Effects
HABs, developed in response to excess nutrients, can be harmful to human health. Exposure to toxins
produced from HABs can cause skin rashes, liver and kidney damage, neurological issues, gastrointestinal
symptoms or respiratory problems (Backer, 2002). In addition to direct consumption of contaminated
drinking water, exposure to these compounds can occur via consumption of contaminated aquatic life,
skin contact with contaminated water, or inhalation of aerosolized toxins or noxious compounds (Berdalet
et al., 2016). High algal biomass, as a result of eutrophication, can also clog and corrode drinking water
intake pipes, and increase the volume of chemicals needed to purify the water (Nordin, 1985).
Pollutants discharged by MPP facilities to surface waters may not always be removed adequately during
treatment at drinking water treatment plants. They may also interact with chemicals used in drinking
water treatment processes and form harmful disinfection byproducts (DBPs). For example,
eutrophication, due to nutrient enrichment, and dense algae can lead to the formation of trihalomethanes
(THMs) as drinking water disinfection byproducts (U.S.EPA, 2000). THMs are carcinogenic compounds
that can pose a serious threat to human health if consumed (U.S. EPA, 2000).
Drinking water exceeding the nitrate-nitrite maximum contaminant level (MCL) (at or below 10 and 1
mg/L for nitrate and nitrite, respectively) could result in serious health consequences for consumers.10
High nitrate concentrations in drinking water can lead to infant methemoglobinemia, colorectal cancer,
thyroid disease, and neural tube defects (U.S. EPA, 2000; Ward et al., 2018). Ward et al. (2018) also cites
the need for future studies on the linkage between nitrate ingestion and cancers of the thyroid, ovary, and
kidney, and the adverse reproductive outcomes of spontaneous abortion, preterm birth, and small for
10 Public drinking water supplies are subject to maximum contaminant level goals (MCLGs) as well as legally enforceable MCLs
(U.S. EPA, 2023c). MCLGs are the level of a contaminant in drinking water below which there is no known or expected risk
to health, and MCLs are the legally enforceable maximum contaminant levels permitted for drinking water. MCLs are set as
close to MCLGs as feasible, using best available treatment technology (U.S. EPA, 2023c). Some THMs, like
bromodichloromethane and bromoform have an MCLG of zero (U.S Environmental Protection Agency, 2023c).
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gestational age births. EPA reviewed data from the Safe Drinking Water Information System (SDWIS) on
59 unique Public Water Systems (PWS) that source water from surface waters downstream from MPP
direct dischargers and had some form of violation relevant to the nitrates rule. The analysis revealed that
from amongst these PWS, one PWS had 10 violations of the nitrate MCL between 2004 to 2011. Elevated
phosphorus levels in drinking water also carry risks, as concentrations greater than 1.0 mg/L could
interfere with the coagulation process in drinking water treatment plants, reducing treatment efficiency.
Water body aesthetics can also be impacted by excess nutrient levels. Ammonia in wastewater has a
strong odor (Baskin-Graves et al., 2019b; The Environmental Integrity Project, 2018). Backer et al.
(2006) notes that high concentrations of algal blooms can result in "foul-smelling, rotting algal mats." In
addition to odor, this biomass can alter the clarity of the water, making it harder to see through and
aesthetically less desirable (U.S. EPA, 2000). Algal blooms can even have an impact on the taste and
smell of drinking water (Backer et al., 2006).
Excess nutrients can also have indirect human health and economic productivity effects. Phosphorus
enrichment can stimulate survival and reproduction of fecal bacteria in aquatic ecosystems, which could
pollute shellfish beds and pose a danger to human recreation (Michael A Mallin et al., 2020. Some algal
species of HABs may also produce potent toxins that can accumulate in fish and shellfish that feed on
those algae, resulting in adverse health impacts in human consumers like paralytic, diarrhetic, amnesic, or
neurotoxic shellfish poisoning (Hoagland et al., 2002; U.S. EPA, 2015b).
2.3 Total Suspended Solids
Livestock slaughtering and cleaning can generate high TSS concentrations by introducing large amounts
of blood and offal into the waste stream (Mittal, 2004). TSS concentrations vary greatly across studies in
raw and pretreated MPP wastewater, ranging from hundreds to thousands of mg/L (Mittal, 2004;
Yordanov, 2010). For facilities sampled by EPA, average raw wastewater TSS concentrations ranged
from 241-7,648 mg/L. As an additional example, TSS in pretreated MPP wastewater samples sent to
municipal treatment facilities ranged from 300-2,800 mg/L in an Ontario, Canada survey (Bustillo-
Lecompte, Mehrvar, et al., 2016).
Both TSS and solids can interfere with wastewater treatment processes. For example, as discussed in
Section 1.2, the Kiryas Joel poultry pretreatment kosher processing facility in Orange County, New York
discharged wastewater with high levels of TSS, CBOD, and FOG to a downstream POTW, causing
operational difficulties at the POTW and Clean Water Act violations. This facility also had elevated TDS
and salinity levels in its sampled wastewater, which are discussed further in Section 2.5.
Data from EPA's 2022 MPP facility sampling efforts collected for TSS are summarized in Table 2-10
below. While most sample sites stay well below the average state effluent criteria, one facility's TSS
effluent concentration is up to three orders of magnitude larger than the effluent criteria, larger than
average baseline TSS concentrations across all facilities in the MPP universe, and in line with some of the
raw and pretreated effluent concentrations cited in the literature (Bustillo-Lecompte, Mehrvar, et al.,
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2016; Mittal, 2004; Yordanov, 2010).11 The average baseline TSS concentrations across facilities in the
full MPP universe at 227 mg/L are much higher than the average state WQC at 37.5 mg/L.
Table 2-10: Observed Total Suspended Solids Concentrations in Sampled MPP Final Effluent at Select Sites,
Compared to MPP Universe Average Baseline Concentrations (mg/L)
Sampling
Episode Report
Number
Minimum
Maximum
Average
Average MPP
Universe
Baseline
Average State
Effluent WQCa
Episode 7010- A
2.5
4.5
3.2
227.0
37.5
Episode 7010- B
2.5
4.5
3.2
227.0
37.5
Episode 7011
0.5
2.0
1.0
227.0
37.5
Episode 7012
1.6
3.9
3.0
227.0
37.5
Episode 7013
17.6
28.5
23.0
227.0
37.5
Episode 7014
1.5
ll,000.0b
1,840.0
227.0
37.5
Episode 7015
ND
1.6
0.8
227.0
37.5
Note: ND indicates samples for which the analyte was not detected. For values without a detected minimum, results were
assumed to have a value of Zi the reported MDL
a Describes the average criteria for TSS states have for effluent from point sources
b Denotes the possibility of a lab error. There was a duplicate sample taken with a concentration of two mg/L. Removing this
potentially erroneous value from the summary would result in maximum and average values of 13.6 and 5.9 mg/L,
respectively.
Source: U.S. EPA Analysis, 2023
The average state TSS WQC for other designated uses are described in Table 2-11. State WQC on TSS
range based on designated use, but all of the facilities (save the facility noted above) had effluent
concentrations below all of the TSS criteria. By contrast, the average baseline concentration across MPP
facilities is greater than all of the TSS criteria.
Table 2-11: Total Suspended Solids State Average WQC (mg/L)
Criteria Category
Average Criteria Value (mg/L)
Aquatic life
59.50
Effluent
37.50
General/Unspecified
38.33
Source: U.S. EPA Analysis, 2023
2.3.1 Ecological and Aquatic Resource Use Effects
Total suspended solids impact aquatic life through a variety of mechanisms (Kjelland et al., 2015). Effects
of exposure to low or high levels of suspended solids vary by species and life history strategies. Changes
in TSS can change the behaviors and movement of aquatic life as well as lead to sublethal levels of stress.
Foraging efficiency can also be altered, further increasing physiological stress. Such stresses can impact
reproduction and have community-level impacts as reproductive impacts accumulate. Changes in
organisms that fulfill important ecosystem functions, such as key food sources, top predators, or habitat
modifiers could lead to indirect impacts on other species as well.
Specifically, elevated TSS can interfere with the life cycle of aquatic organisms at multiple trophic levels
by increasing turbidity and thereby reducing light penetration in water and altering aquatic habitats. A
11 The maximum TSS concentration at this sample site may be a reporting error as a duplicate sample was taken with a
concentration of two mg/L.
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reduction in light penetration can lead to a decrease in primary production, driven by photosynthetic
microorganisms and aquatic plants, reducing the food supply for secondary producers that consume them
(Chapman et al., 2017). Additionally, increased suspended sediment can reduce the suitability of
spawning habitat by smothering spawning sites (Kjelland et al., 2015) thereby hindering the development
of fish eggs, larvae and juveniles (Wood et al., 1997). For adult fish, an abundance of suspended solids
can trap heat and harm species adapted to lower temperatures (U.S. EPA, 2012a), clog fish gills, and
reduce oxygen transport (Mittal, 2004). Salmonoid fish are particularly susceptible to lifecycle disruption
from TSS, as a reduction in food from the lower trophic levels could harm its most sensitive life stages
(Chapman et al., 2017).
2.3.2 Human Health and Aesthetic Impacts
Solids and suspended solids may also harbor pathogenic organisms and certain toxins can sorb to fine
particulates in TSS(U.S. EPA, 2021; Mittal, 2004; U.S. EPA, 2012a). The effects of increased pathogens
are described in more detail in Section 2.4. Additionally, research found positive correlations between
increased turbidity in drinking water and gastrointestinal illness in some settings and across some
turbidity ranges (Mann et al., 2007).
2.4 Bacteria and Pathogens
Bacteria and pathogens enter the MPP effluent stream from the blood, excrement, and offal of slaughtered
livestock (The Environmental Integrity Project, 2018). Microorganisms may also be introduced from
rinsing the hide and carcass, which could have retained bacteria from the farm, holding areas, processing
equipment, and/or facility floor (Mittal, 2004). As a result, meat processing wastewater can contain
millions of viable bacteria from a wide taxonomic range, including total coliform, fecal coliform,
Streptococcus, and Salmonella species (Mittal, 2004). Bacteria not eliminated through disinfection
processes in the MPP effluent streams are then introduced to downstream municipal water treatment
facilities or receiving waters (Savin et al., 2020; Bustillo-Lecompte & Mehrab, 2016). Additionally, the
meat sludge byproduct in effluent can provide the nutrients needed for the long-term survival and
proliferation of some microorganisms (Baskin-Graves et al., 2019b).
Prevalent bacteria in MPP wastewater include Escherichia coli (E. coli), Giardia (e.g., Giardia lamblia),
Enterococcus, Salmonella ssp., Campylobacter (e.g., Campylobacter jejuni), and Staphylococcus
(including S. aureus and Methicillin-resistant Staphylococcus aureus [MRSA]) (Mittal, 2004; The
Environmental Integrity Project, 2018; Baskin-Graves et al., 2019b). The presence of these bacteria could
also be indicative of the presence of additional enteric pathogens like Ascaris sp., Cryptosporidium
parvum, and enteric viruses (Mittal, 2004). Therefore, drinking water providers are required to adhere to
MCLs for fecal coliforms and E. coli, which are considered indicators of the presence of pathogenic
microorganisms. No more than five percent of samples may test positive for total coliform in a month.
Total coliforms include fecal coliforms, E. coli, and some nonpathogenic microorganisms. Total coliform
tests indicate the need for testing for fecal coliform or E. coli. For water systems that collect fewer than
40 routine samples per month, no more than one sample can be total coliform-positive per month (U.S.
EPA, 2023h).
Table 2-12 summarizes the presence of bacteria in MPP facility effluent from several data sources,
including DMR data, data from EPA's 2022 MPP facility sampling efforts, and data from the Detailed
Questionnaire.
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Table 2-12: Average Pathogen Data (CFU/lOOmL
Data Source
E. coli
Fecal Coliform
Discharge Monitoring Report Average
6.85
15.63
Sampling Episode Report Average
7.01
17.60
Detailed Questionnaire Average
2.66
36.19
Average Across Data Sources
5.51
23.14
Source: U.S. EPA Analysis, 2023
State WQC on bacteria and pathogens range based on designated use, water body type, and bacteria and
pathogen type. For example, most states have different WQC for primary contact (e.g., swimming) versus
secondary contact (e.g., boating or paddling) recreation, whether the standard applies to marine or fresh
water, and for different pathogens. About 10 states have rules for drinking water sources, 11 states have
criteria for aquatic life and fishing, and a few (around five or less) have regulations about the allowable
bacteria levels in effluent. In general, the most common maximum criteria range for E. coli in recreation-
designated waters was between 126 - 410 CFU/100 mL. The most common maximum criteria range for
Enterococci in recreation-designated waters was around 35 - 130 CFU/100 mL. These align with EPA's
2012 federal Recreational Water Quality Criteria recommendations (U.S. Environmental Protection
Agency, 2012b). Effluent criteria range from 125- 406 CFU/100 mL. Many states used different metrics
to establish their criteria, such as geometric means and statistical threshold values, and several had
temporal parameters (like single sample versus monthly average sample) specifying how the samples
should be measured. Typically, singular grab sample criteria are substantially greater than monthly
averages to allow for influxes from storm events and other acute occurrences.
2.4.1 Ecological and Aquatic Resource Use Effects
The additional bacteria introduced through MPP effluent could alter the microbial ecology of receiving
waters. Research conducted on the Great Lakes showed that storm water and sewage pipe system
overflows foster the growth of microbial organisms that would otherwise have a low relative abundance
in the natural environment, an effect that could be intensified in smaller water bodies (J. C. Fisher et al.,
2015).
Nutrient-induced algal blooms can also create a favorable environment for bacterial proliferation. Ma et
al. (2014) found a symbiotic relationship between algae and bacteria where they can increase each other's
growth rate in the initial stages of introduction to the environment.
2.4.2 Human Health and Aesthetic Impacts
Bacteria and pathogens that are introduced to groundwater or surface water can cause infection through
drinking water, ingestion of a crop or food, or recreating in contaminated waters (U.S. EPA, 2021a;
Mittal, 2004). Even if introduced in low levels, they may proliferate if given a favorable, nutrient-rich
environment (Mittal, 2004). Some of the bacteria introduced to receiving waters via slaughter effluent -
like E. coli, Enterococci, Salmonella, and Campylobacter- can cause serious illness in humans.
Nonpathogenic E. coli is common in the digestive systems of humans and other animals; however, certain
strains are pathogenic in humans. One such strain (0157:H7) is present in the feces of cattle and has been
found in excretion rates up to 10s CFU/g. This strain can cause serious infection with as few as 10 cells
(Mittal, 2004). Some strains of E. coli cause diarrhea/bloody diarrhea, vomiting and stomach pains and
cramps, while others could lead to kidney failure if not properly treated (Cleveland Clinic, 2020).
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Pathogenic E. coli have been found in treated wastewater effluent, though waterborne outbreaks are not as
prevalent as foodborne cases (U.S. EPA, 2009b).
Like E. coli, Enterococci are bacteria commonly found in the intestinal tracts of warm-blooded animals.
In addition to the diarrhea and stomach cramps that E. coli causes, enterococci can cause diseases of the
skin, eyes, ears and respiratory tract (U.S. EPA, 2022b). Enterococci are also a common cause of urinary
tract infections, bacteremia, and infective endocarditis. On occasion, they can cause intra-abdominal
infections and meningitis. This genus possesses an intrinsic resistance to some antibiotics, and infections
should be treated promptly to avoid the high morbidity and mortality associated with them (Said et al.,
2022). Antibiotic resistance is covered in more detail in Section 2.10.
Approximately 1.35 million Salmonella infections are reported in the U.S. each year, along with 26,500
hospitalizations, and 420 deaths (Centers for Disease Control and Prevention, n.d.). Salmonella infection
carries similar symptoms to E. coli and Enterococci (i.e., diarrhea, fever, and stomach cramps), but can
cause diarrheal infection so severe that hospitalization is required. In a small number of cases, infection
can spread from the intestines to the bloodstream to other parts of the body, and cause death unless treated
promptly (Centers for Disease Control and Prevention, n.d.).
Campylobacter is estimated to be the number one cause of bacterial diarrheal illness in the U.S. (Centers
for Disease Control and Prevention, 2019). Symptoms of infection often include bloody diarrhea, fever,
nausea, and stomach cramps. While infection persists for at least a week without treatment, some
complications following infection include irritable bowel syndrome, temporary paralysis, and arthritis
(Centers for Disease Control and Prevention, 2019).
Other human health impacts resulting from exposure to bacteria in MPP effluent can include toxic shock
syndrome, folliculitis, skin infections, and MRSA infection (Baskin-Graves et al., 2019b). Additionally,
antimicrobial resistant (AMR) strains of bacteria pose a serious potential threat to human health (Um et
al., 2016). This topic is explored further in Section 2.10.
Aesthetically, bacterial proliferation can lead to foul smells from the release of sulfurous and nitrogenous
compounds. These noxious odors are described as smelling of rotting eggs and cabbage, respectively, and
are a chronic nuisance for nearby residents (Baskin-Graves et al., 2019b). These fumes have also been
reported to trigger asthma attacks, watering eyes, and other health problems when contamination reaches
residential drinking water wells (The Environmental Integrity Project, 2018).
2.5 Total Dissolved Solids
Total dissolved solids (TDS) are a combination of sodium, chloride, minerals, and organic molecules that
are naturally present in water or are the result of human activity, like industrial effluent discharges (U.S.
Geological Survey, 2019; Weber-Scannell et al., 2007). TDS is a measurement of inorganic salts, organic
matter, and other dissolved materials in water (Weber-Scannell et al., 2007). Salinity is a common term
used to describe the dissolved salt content of water (U.S. Geological Survey, 2019).
Increased TDS and chloride concentrations in MPP wastewater can result from some meat processing and
preservation methods that use salt (Reid Engineering Company, 2012). Food-grade salt may be added
during meat and poultry processing and preservation, particularly in koshering and curing processes. This
may lead to some facilities discharging relatively high concentrations of chlorides and TDS (compared to
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ambient freshwater), as these compounds are not removed in conventional wastewater treatment systems
(Reid Engineering Company, 2012). A study found high chloride and TDS loads in pretreated wastewater
samples from the Kiryas Joel kosher poultry processing facility in New York and discussed removal
achievable with different treatment options (Reid Engineering Company, 2012). Sampled outfalls
upstream from this facility showed Na, CI, and TDS concentrations of 135 mg/L, 150 mg/L, and 248
mg/L, respectively, while concentrations downstream increased to 1,170 mg/L, 1,800 mg/L, and 3,324
mg/L, respectively (Reid Engineering Company, 2012). This facility was found to have violated the CWA
by allowing their pretreatment facility to overflow into storm drains when it should have been conveyed
to the receiving POTW, as discussed in Section 1.2. Additionally, excess salt passed through the receiving
POTW, contributing to the in-stream TDS levels.
Elevated levels of salinity and TDS can also affect water treatment efficiency. For example, due to the
high organic waste composition of meat processing wastewater, some facilities may use a sequencing
batch reactor (SBR) to treat their wastewater (Sadaf et al., 2022). A study by Wu et al., 2018 explored the
relationship between TDS concentrations and treatment efficiency and found that TDS concentrations
higher than 3,000 mg/L resulted in a 20 percent reduction in nutrient removal efficiency for facilities that
use SBRs. The effects of elevated nutrient levels are discussed in more detail in Section 2.1.
Data from EPA's 2022 MPP facility sampling efforts collected for TDS are summarized in Table 2-13
below. There are no WQC associated with TDS, but the average sampling data are elevated and within a
range that could cause harm to aquatic organisms, as discussed in the following section. The average
baseline TDS concentrations across facilities in the full MPP universe are generally much higher than the
average sampling data at 3,568.2 mg/L compared to the average sampled values ranging from 645-2,240
mg/L. As mentioned above, these levels are within a range that could cause harm to aquatic organisms.
Table 2-13: Observed Total Dissolved Solids Concentrations in Sampled MPP Final Effluent at Select Sites,
Compared to MPP Universe Average Baseline Concentrations (mg/L)
Sampling Episode
Report Number
Minimum
Maximum
Average
Average MPP
Universe Baseline
Episode 7010- A
1,400.0
1,800.0
1,670.0
3,568.2
Episode 7010- B
1,400.0
1,800.0
1,670.0
3,568.2
Episode 7011
1,800.0
2,700.0
2,240.0
3,568.2
Episode 7012
1,600.0
1,800.0
1,660.0
3,568.2
Episode 7013
710.0
800.0
740.0
3,568.2
Episode 7014
620.0
740.0
660.0
3,568.2
Episode 7015
610.0
700.0
645.0
3,568.2
Source: U.S. EPA Analysis, 2023
Data from EPA's 2022 MPP facility sampling efforts collected for chloride for each site are summarized
in Table 2-14 below. Most sample data are below the average state WQC for general or unspecified water
body uses, though one facility's average chloride concentrations were greater than the average state
criteria and the average baseline concentrations across all MPP facilities. Three facility's maximum
chloride concentrations were greater than the average state criteria. The average baseline chloride
concentrations across facilities in the full MPP universe are only slightly higher than the average state
WQC.
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Table 2-14: Observed Chloride Concentrations in Sampled MPP Final Effluent at Select Sites, Compared to
MPP Universe Average Baseline Concentrations (mg/L)
Sampling Episode
Report Number
Minimum
Maximum
Average
Average MPP
Universe
Baseline
Average State
General/Unspecified
WQC
Episode 7010-A
270.0
340.0
311.0
397.0
342.3
Episode 7010- B
270.0
350.0
311.0
397.0
342.3
Episode 7011
250.0
430.0
374.0
397.0
342.3
Episode 7012
510.0
555.0
526.0
397.0
342.3
Episode 7013
216.0
241.0
227.0
397.0
342.3
Episode 7014
80.5
119.0
89.1
397.0
342.3
Episode 7015
125.0
144.0
135.0
397.0
342.3
a Describes the average chlorides criteria states have for general or unspecified water body uses
Source: U.S. EPA Analysis, 2023
State WQC for chloride range based on criteria category, summarized in Table 2-15. Average criteria
values varied widely between states in almost all criteria categories. While no effluent-specific average
chloride criteria were identified, some of the concentrations observed in the sampling data are higher than
the criteria for other criteria categories, where one facility's average chloride concentrations are greater
than almost all of the criteria across the criteria categories.
Table 2-15: Average State WQC for Chloride(mg/L)
Criteria Category
Average WQC
Agriculture
250.00
Aquatic life
527.04
Aquatic life consumption
250.00
Drinking water source
244.90
General/Unspecified
342.33
Potable drinking water
351.67
Source: U.S. EPA Analysis, 2023
Responses to the Detailed Questionnaire indicate that a wide variety of chemicals are added to wastewater
for treatment purposes, and as there is general alignment with pollutants contributing to TDS
concentrations, these additives are discussed here. Thirty-four percent of respondents reported adding at
least one water treatment chemical to facility wastewater. In particular, some salts and chlorides are
mentioned as chemical additives. Table 2-16 describes the most commonly added chemicals for
wastewater treatment as documented by the Detailed Questionnaire.
Table 2-16: Chemical Addition Table Survey Response
Chemical Added
Response Frequency
Use in Treatment
Polymer3
208
Settling/Thickening
Sodiumb
137
pH control
Sulfuric acid
87
pH control
Coagulant
85
Settling/Thickening
Chloride0
71
Multiple
Sodium hydroxide
59
pH control
Causticd
51
pH control
Nalco
38
Settling/Thickening
Magnesium hydroxide
32
pH control
Lime6
25
Multiple
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Table 2-16: Chemical Addition Table Survey Response
Chemical Added
Response Frequency
Use in Treatment
Note: Some of the compounds listed represent a group of compounds, with further specification listed as a footnote. The
values in the "Response Frequency" column are inclusive of all delineations in the group of compounds. Additionally, 77
compounds listed were iron enriched.
a: Polymer, Cationic/ Anionic Polymers mentioned, but none significantly more mentioned than others.
b: Sodium Bisulfide and Thiosulfate, were some compounds mentioned, with sodium hydroxide having the most at 59.
c: Ferric Chloride (62 mentions), with Aluminum Chloride having 12 mentions.
d: Caustic- Commodity, Caustic Nutroxide, with Caustic soda being the most mentioned at 27.
e: Hydrated lime, with Lime Slurry being the most mentioned at 15.
Source: U.S. EPA Analysis, 2023
2.5.1 Ecological and Aquatic Resource Use Effects
TDS can harm aquatic communities by elevating salinity levels and the specific conductivity of receiving
waters, which could limit biodiversity, exclude less salt-tolerant species, cause acute or chronic effects at
specific life stages, and create a more suitable habitat for the proliferation of invasive species (Weber-
Scannell et al., 2007).
TDS can cause toxic changes in the salinity and ion composition of water, which can kill and impair some
aquatic species (Weber-Scannell et al., 2007). A literature review conducted by Weber-Scannell et al.
(2007) indicated that the diversity of aquatic species in general may decline as increases in TDS occurs
and aquatic life salinity thresholds are exceeded. One study cited in this review analyzed lethal salt
concentrations for zooplankton and found the threshold for C. diibict to range from 735 to 835 mg/L and
the lethal threshold for D. magna to be between 1,000 and 5,015 mg/L (Hoke et al., 1992).
Altering the original salinity levels of a waterway can also allow for the proliferation of invasive species.
A study by Richburg et al., 2001 explored the decrease of richness, evenness, and total plant cover due to
the increase of a salt-tolerant, non-native reed plant (Phragmites).
One study by Corsi et al., 2010 investigated effects of salt pollution on freshwater species in Wisconsin.
The study found that chloride concentrations higher than 1,610 and 2,940 mg/L can provoke adverse
responses, including mortality, reduced weight and survival, and inhibited reproduction in some
zooplankton and freshwater minnows, like C. dubia and P. promelas, respectively.
2.6 Metals
Metals such as cobalt, copper, iron, manganese, selenium, and zinc may be added to animal feed as
growth promoters, additives to combat disease, and to stimulate egg production. Some livestock need
copper supplements in their diet in concentrations around 8 parts per million (ppm); however, most
broiler diets contain levels of 125 to 250 ppm (P. Gerber et al., 2008). An estimated five to 15 percent of
the feed additives are absorbed into animal tissues, and the rest is excreted in manure. These metals can
then enter the effluent stream through excrement and processing waste, including wasted body parts from
cleaning operations (P. Gerber et al., 2008). Several heavy metals have been detected in raw
slaughterhouse wastewater globally including lead, iron, manganese, and copper (Akan et al., 2010; M. D.
Gerber et al., 2017; Yaakob et al., 2018).
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Conventional wastewater treatment technologies are not designed to effectively remove heavy metals (Ida
et al., 2021); however, enhanced treatment can remove certain metals. For example, zinc, iron, and copper
in wastewater can be efficiently removed by algae under the right conditions (Jais et al., 2017). As a
result, heavy metal presence in both partial and fully treated MPP wastewater varies by facility depending
on treatment technologies in place. M. D. Gerber et al. (2017) found zinc in treated swine slaughterhouse
wastewater, while levels of hexavalent chromium (chromium VI) and aluminum in tertiary-treated
slaughterhouse wastewater were low (Milanovic et al., 2015). In industrial sludge from pretreated meat
processing wastewater metals including copper, lead, and zinc were found at low concentrations (de Sena
et al., 2009).
Several metals were identified in the literature as being potentially present in MPP facility effluent and
particularly harmful to humans and the environment; these are described in the sections below. Data from
EPA's 2022 MPP facility sampling efforts collected for various metals found in MPP facility effluent are
summarized in Table 2-17 below. The table also provides the average baseline pollutant concentration
across the MPP universe for metals that were found in the literature, identified in sampling, and
modeled.12 In comparison to federal criteria13, no sampled values were greater than any of the federal
criteria for aquatic life or human health-related designated uses. The average baseline metal
concentrations across facilities in the full MPP universe are greater than average sampled values in each
case, with baseline values for iron (26.8 mg/L) orders of magnitude larger than the average sampled
values (0.1 mg/L).
Table 2-17: Observed Metal Concentrations in Sampled MPP Final Effluent at Select Sites, Compared to MPP
Universe Average Baseline Concentrations (mg/L)
Metal
Percentage of
Sampling Sites with
Metals Presence
Minimum
Maximum
Average
Average MPP
Universe
Baseline
Aluminum
100%
0.1
0.3
0.2
0.7
Copper
100%
6.0E-03
5.4E-03
4.2E-03
0.1
Iron
85%
0.2
0.2
0.1
26.8
Lead
57%
ND
3.2E-04
1.4E-04
1.4E-02
Manganese
100%
2.5E-02
4.9E-02
3.1E-02
0.2
Zinc
100%
3.2E-02
2.8E-02
1.9E-02
0.3
Note: ND indicates samples for which the analyte was not detected. For values without a detected minimum, results were
assumed to have a value of Zi the reported MDL.
Source: U.S. EPA Analysis, 2023
2.6.1 Ecological and Aquatic Resource Use Effects
Wastewater effluent containing heavy metals poses a significant threat to receiving water, as the metals
can accumulate in sediment and organic matter faster than they are able to be broken down (Verma et al.,
2013). While some metals are necessary for biochemical processes in living organisms, metals like lead
12 Additional metals beyond those presented in Table 2-17 were sampled for and modeled. Only the sampling results for metals
identified from the literature were included in this section. EPA modeled metals meeting its pollutant of concern criteria,
which included sampled values 10 times the baseline value threshold and were present in more than 10 percent of untreated
process wastewater samples at greater than five times the baseline value. Additional detail on metals modeled in the analysis
may be found in the TDD (U.S. Environmental Protection Agency, 2023o).
13 State WQC were not readily available for summary as few states provide discrete numeric criteria.
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can be highly noxious in the environment. Metal toxicity can be detrimental at the metabolic level,
disrupting nucleic acid and protein structure, as well as cellular respiration in aquatic life (Okereafor et
al., 2020).
Copper can cause significant aquatic impacts (Amoatey et al., 2019) and has been found to be particularly
harmful to primary producers14, even at low concentrations. Copper can also decrease the respiratory,
growth, osmotic potential, chlorophyll production, and germination rates in plants like Myriophyllum
alterniflorum (an aquatic plant) and Lactuca sativa (a common garden variety lettuce). In some diatoms,
copper has been documented to alter the metabolism, cell proteins and membrane structures (Amoatey et
al., 2019).
Metals may also bioaccumulate or bioconcentrate in aquatic life. Metals do not decompose, and they are
not processed in aquatic organisms, leading to a concentration stored in tissue. While some metals are
biologically essential for aquatic life, metals like lead may cause behavioral and endocrine disturbances
and high levels can be lethal (Jakimska et al., 2011).
Some metals could have implications for land applied MPP industrial sludge. M. D. Gerber et al. (2017)
found that zinc in both raw and treated effluents from swine slaughterhouses may impair the germination
of lettuce and cucumber if used for agricultural purposes. By contrast, in research by Ramires et al., 2019,
copper, zinc, manganese, iron from raw and partially treated swine slaughterhouse wastewater did not
show phytotoxicity on lettuce, radish, and rice plants.
2.6.2 Human Health and Aesthetic Impacts
Humans can be harmed by high concentrations of heavy metals present in drinking water or food, which
can damage lipids, proteins, enzymes, and DNA (Jan et al., 2015). Chronic exposure to high levels of
copper in drinking water can lead to liver damage and gastrointestinal symptoms like abdominal pain,
cramps, nausea, diarrhea, and vomiting (National Institutes of Health, 2022). Exposure to lead can lead to
abnormal growth and development in children and lead and cadmium can lead to abnormal bone
metabolism.
Heavy metals are not metabolized by animal tissue and tend to bioaccumulate as a result. Human
consumption of high trophic organisms (e.g., fish that are higher in the food chain) may result in greater
exposure to the bioaccumulated metals. Heavy metals are known to accumulate in human tissue as well,
causing long-term health impacts. Manganese, for example, can also accumulate in the human body,
specifically in the mitochondria of cells where it disrupts the process of cellular respiration (Briffa et al.,
2020).
2.7 Inorganic Toxics
In addition to heavy metals, inorganic toxics like acids, arsenic, and chlorine can also be present in meat
processing effluent. For example, Bustillo-Lecompte et al. (2015) found that alkalines and acids can be
introduced into wastewater effluent through treatment processes. Also, arsenic is frequently present in
MPP wastewater and industrial sludge, even after treatment, due to its addition to sanitizers in the
14 Primary producers are organisms that synthesize organic compounds from carbon dioxide using photosynthesis.
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cleaning process (de Sena et al., 2009). Arsenic was detected in wastewater industrial sludge after three
separate treatment processes (de Sena et al., 2009).
Data from EPA's 2022 MPP facility sampling efforts collected for arsenic are summarized in Table 2-18
below. Samples were generally in the same order of magnitude and no observed concentrations were
greater than federal aquatic life criteria (0.15 [chronic]-0.34 [acute] mg/L) or the criteria for drinking
water (0.01 mg/L); however, all samples were greater than the criteria for aquatic organism consumption
(1.4 E"4 mg/L) (U.S. Environmental Protection Agency, 2023j;U.S. Environmental Protection Agency,
2023i; U.S. Environmental Protection Agency, 2023k).
Table 2-18: Observed Arsenic Concentrations in Sampled MPP Final Effluent at Select Sites (mg/L)
Sampling Episode Report
Number
Minimum
Maximum
Average
Episode 7010- A
4.72E-4
6.62E-4
5.66E-4
Episode 7010- B
4.3E-4
8.51E-4
6.46E-4
Episode 7011
ND
3.32E-4
2.7E-4
Episode 7012
4.72E-4
6.62E-4
5.66E-4
Episode 7013
1.88E-3
3.19E-3
2.62E-3
Episode 7014
ND
2.74E-4
1.65E-4
Episode 7015
4.29E-4
5.28E-4
4.62E-4
Note: ND indicates samples for which the analyte was not detected. For values without a detected minimum, results were
assumed to have a value of Zi the reported MDL
Source: U.S. EPA Analysis, 2023
Free chlorine is widely used in water disinfection and is important for removing bacteria and pathogens
from treated water (Qin et al., 2018). In drinking water, free chlorine levels are considered normal within
0.8 to 2.2 mg/L and levels should be kept below four to five mg/L (Zhou et al., 2021). Data from EPA's
2022 MPP facility sampling efforts collected for free chlorine are summarized in Table 2-19. Levels
reported in sampling are below the threshold of concern (Zhou et al., 2021), but half of the average
observed concentrations were at or above the state average WQC for general or unspecified water body
uses by a small margin.
Table 2-19: Observed Free Chlorine Concentrations in Sampled MPP Final Effluent at Select Sites (mg/L)
Sampling Episode
Report Number
Minimum
Maximum
Average
Average State
General/Unspecified
WQC
Episode 7010- A
0.04
0.11
0.09
0.06
Episode 7010- B
0.04
0.11
0.09
0.06
Episode 7011
0.03
0.07
0.06
0.06
Episode 7012
0.03
0.12
0.07
0.06
Episode 7013
0.00
0.04
0.02
0.06
Episode 7014
0.00
0.08
0.04
0.06
Episode 7015
0.01
0.05
NA
0.06
Note: NA indicates where there was no free chlorine average calculated because at least one of the free chlorine
measurements resulted in no reading
a Describes the average chlorine criteria states have for general or unspecified water body uses
Source: U.S. EPA Analysis, 2023
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Most of the 15 states with criteria for free chlorine have implemented it for aquatic life protection while
fewer states have criteria for drinking water and general or unspecified water body uses. Aquatic life
criteria for chlorine varied widely, with limits clustered in a bimodal distribution, falling either below
0.02 mg/L or above 10 mg/L. The state WQC for chlorine are summarized in Table 2-20 below, by
criteria category.
Table 2-20: Average State WQC for Chlorine (mg/L)
Criteria Category
Average WQC
Aquatic life
3.78
Drinking water source
4.00
General/Unspecified
0.06
Potable drinking water
0.01
Source: U.S. EPA Analysis, 2023
2.7.1 Ecological and Aquatic Resource Use Effects
Arsenic can affect aquatic species" short-term survival as well as long-term effects on the ecological
composition of aquatic communities (Chi et al., 2017). Arsenic contamination can result in significant
decreases in density, biomass, and biodiversity of aquatic communities, especially organisms on lower
trophic levels. Chlorine does not readily persist in solution, and at low concentrations does not have
extensive impacts on aquatic life (The Chlorine Institute, 1999). However, excessive concentrations can
damage aquatic plants and animals, especially sensitive membranes (The Chlorine Institute, 1999). As
discussed in Section 1.2, a failure in the chlorination equipment at the onsite water treatment facility of
the Moyer Packing Co. plant resulted in a buildup of chlorine in nearby Skippack Creek, Pennsylvania.
The excess chlorine resulted in a fish kill of thousands of fish, primarily minnows, for up to 1.2 miles
downstream (MORNING CALL, 2007). Additionally, chlorine readily forms other toxic pollutants such
as chloride ions or THM (Parveen et al., 2022). See Section 2.8 for a discussion on acids and pH.
2.7.2 Human Health and Aesthetic Impacts
The most common types of cancer caused by arsenic include skin cancer, lung cancer and angiosarcoma
of the liver, though several other kinds have also been reported (U.S. National Research Council, 1999).
High concentrations of arsenic can also lead to reproductive effects, including a significant reduction in
infant birthweight (Witkowska et al., 2021). Additionally, overabundance of free chlorine can be harmful
to human health, and have the potential to create disinfection byproducts like THMs (Zheng et al., 2015).
Excessively high concentrations of free chlorine can lead to an unpleasant odor and taste, accelerate pipe
corrosion rate, and impose potential health risks (Qin et al., 2018; Water Resources Mission Area, 2019).
Corrosion of drinking water pipes could create additional human health concerns by releasing toxic
metals and allowing for a buildup of pathogens and contaminants harmful to human health (Pelley, 2016).
For example, the release of iron from pipes can stimulate the growth of harmful bacteria, such as
Legionella, and decrease the effectiveness of disinfectants.
2.8 pH
The pH of slaughterhouse wastewater typically ranges from 4.9 to 8.1. Fluctuations in pH within this
range can affect the efficiency of wastewater treatment (Bustillo-Lecompte & Mehrab, 2016). Such
fluctuations can occur from the addition of organic acids in the wastewater process or by the feed given to
livestock prior to slaughter (Ziara et al., 2018; U.S. Department of Justice, 2017). According to research
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by Jais et al., 2017, raw and pretreated wastewater are acidic, with pH < 7 for swine slaughterhouse
effluent globally and pH between 4.4 and 6.3 for cattle slaughterhouse effluent in the United States (Ziara
et al., 2018).
Data from EPA's 2022 MPP facility sampling efforts collected for pH are summarized in Table 2-21
below. Generally, the sampled effluent values range from neutral to basic, with only two facilities
recording a slightly acidic value.
Table 2-21: Observed pH in Sampled MPP Final Effluent at Select Sites (S.U.)
Sampling Episode Report Number
Minimum
Maximum
Episode 7010- A
7.1
9.4
Episode 7010- B
7.1
9.4
Episode 7011
7.7
8.2
Episode 7012
6.8
7.8
Episode 7013
7.5
7.8
Episode 7014
6.9
7.1
Episode 7015
7.2
7.3
Note: Average pH was not calculated due to logarithmic scale.
Source: U.S. EPA Analysis, 2023
2.8.1 Ecological and Aquatic Resource Use Effects
Some meat processing procedures can alter the pH of effluent, which can have serious consequences for
aquatic communities. Shifts in pH that create acidic conditions can have both lethal and sublethal effects,
depending on the extent of acidification (U.S. EPA, 20231). Small changes in pH may only impact pH
intolerant species, however, continual decrease in pH will impact a wider range of species and processes.
Acid-sensitive species of invertebrates and fish suffer from reduced reproductive success and loss at pH
of 6.5 to 6. A further decrease in pH from 6 to 5.5 begins to decrease reproduction in a wider range of
finfish, creates marked losses in aquatic invertebrates, and accumulation of filamentous algae. Shifts in
pH from 5.5 to 5 may lead to the loss of important game fishes, important non-game fishes, decrease in
the total biomass of invertebrates and zooplankton, continued accumulation of filamentous algae, and
inhibition of the nitrification process. A decrease in pH to 4.5 leads to loss of most fishes, except for
specific acid-tolerant species, declines in organic matter decomposition, decreased nutrient cycling, loss
of additional aquatic insects, crustaceans and plankton, and inability of acid-sensitive amphibians to
reproduce. Acidic water can also lead to the dissolution of aquatic invertebrate shells made of calcium
carbonate (U.S. EPA, 20231).
Increases in pH above neutral can be problematic with prolonged exposure. Increased pH can damage
sensitive outer tissues in aquatic organisms, such as gills, eyes, skin, and sensory epitheliums (U.S. EPA,
20231). Disruption of these tissues leads to decreased efficiency in movement, feeding, reproduction, and
survival. Elevated pH also shifts ammonia concentrations from the ionized ammonium NH4+ form to
unionized ammonia NH3 form; the percentage of ammonia in NH3 form is two orders of magnitude larger
at a pH of 9 compared to a pH of 7. Increased ammonia concentrations exhibit more acute toxicity and
can impact biological processes. See Section 2.1 for a detailed discussion of the impacts of ammonia on
aquatic life.
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In addition to causing fish kills, pH fluctuation can be detrimental to lower trophic organisms. One study
conducted in Colorado found that benthic invertebrates were sensitive to changes in pH and were often
adversely impacted in different life stages (Courtney et al., 1998).
2.8.2 Human Health and Aesthetic Impacts
The pH of a water body has the capacity to both directly and indirectly affect human health. When too
high or too low, pH changes can directly cause irritation of skin, eyes, and mucus membranes during
primary contact recreation. Consumption of acidic water with sufficiently low pH levels can lead to dental
erosion overtime (Reddy et al., 2016).
The pH of water is also a major determinant of its corrosivity, which can lead to numerous other negative
human health impacts (Water Resources Mission Area, 2018). For example, corrosive water can lead to
the leaching of heavy metals, such as lead, from water distribution network pipes (Goldhaber, 2022). As a
result, direct effects of pH on human health are difficult to determine due to the close association of pH
with heavy metals, that have important health impacts (Fawell et al., 2007). Basic water pH can increase
the chemical stability and reduce the bioavailability of some heavy metals, while more acidic conditions
can increase the likelihood of higher heavy metal pollution levels (Zhai et al., 2016). See Section 2.6 for a
discussion of effects of the presence of heavy metals on human health.
Proper pH levels are important for adequate disinfection of water, as changes in pH can impact the
effectiveness of certain disinfection techniques against pathogens (Fawell et al., 2007). For instance, it is
preferable for pH to be under 8.0 to ensure effective disinfection through chlorination. Ineffective
disinfection can lead to accumulation of pathogens and increased risk of infectious disease. See Section
2.4 for a discussion of the effects of the presence of elevated bacteria and pathogens on human health.
2.9 Temperature
Biological treatment of wastewater requires the maintenance of wastewater temperature to certain levels
to promote bacteria activity and degradation of pollutants. In some areas of the country, final effluent
temperatures exceed receiving stream temperatures, potentially impacting aquatic organism growth and
reproduction. Elevated levels of TSS can also influence water temperature. With higher TSS, water will
heat more rapidly and retain heat, which could harm aquatic organisms adapted to lower temperatures
(U.S. EPA, 2012a).
The JBS Souderton, Inc. facility, discussed in Section 1.2, was required to conduct a study focusing on
the temperature difference of the facility effluent and receiving water, noting that discharge of wastewater
must not increase the ambient temperatures of the receiving waters by more than 5°F or result in stream
temperatures exceeding 87°F (30.6°C). The commissioned temperature study (completed in 2014) found
that the facility was unable to meet the 5°F maximum receiving water temperature increase, reporting the
facility's discharges to increase water temperature by 6.79°F and 15.49°F. Based on the requirements set
forth by the DBRC, this facility should have been required to produce a compliance schedule by 2015 that
would ensure the facility at least begin to address the temperature problem no later than 2018 (Delaware
River Basin Commission, 2011). There is no evidence that this facility is meeting the proposed
temperature limits based on review of more recent compliance information (U.S. Environmental
Protection Agency, 2023d). In a broader example, the state of Wisconsin requires that the temperature of
the water of a state not be artificially raised or lowered at a rate that causes detrimental health impacts to
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fish and aquatic life (Wisconsin State Legislature, n.d.). Because of this requirement, MPP facilities in
Wisconsin have temperature limits in their NPDES permits. For example, Abblyand Foods Abbotsford
plant has atemperature effluent maximum of 85° F (29.44 °C) (State ofWisconsin DNR, 2015).
Data from EPA's 2022 MPP facility sampling efforts collected for temperature are summarized in Table
2-22 below. The average sampled effluent temperature ranged from 19.2 to 28.3°C, which are below the
temperature limit examples noted above. However, a few of the facilities had maximum effluent
temperature that exceeded DRBC's and Abbyland Food Abbotsford plant's specified temperature
thresholds.15 The impacts of temperature changes from effluent are highly dependent on the receiving
aquatic environment, as discussed further in the next section.
Table 2-22: Observed Temperature in Sampled MPP Final Effluent at Select Sites (°C)
Sampling Episode Report
Number
Minimum
Maximum
Average
Episode 7010- A
26.2
31.6
28.3
Episode 7010- B
26.2
31.6
28.3
Episode 7011
26.8
30.8
28.1
Episode 7012
28.1
30.7
29.8
Episode 7013
19.8
22.5
21.1
Episode 7014
18.0
22.8
20.5
Episode 7015
18.3
20.0
19.2
Source: U.S. EPA Analysis, 2023
2.9.1 Ecological and Aquatic Resource Use Effects
Water temperature changes the solubility of both carbon dioxide and oxygen in water, affecting all
organisms dependent on dissolved oxygen for respiration (Bowes, 1984). While the oxygen saturation
capacity of water is impacted by other variables such as barometric pressure and salinity, the amount of
DO generally decreases in a water body as temperature increases. With other factors being held constant,
an increase in temperature would decrease the amount of DO. The rate of respiration in aquatic plants
varies by temperature, possibly leading to changes in growth and reproduction of macrophytes. Changes
in respiration rates also interact with DO and carbon dioxide levels, changing the amounts of these gases
given off by aquatic vegetation and phytoplankton.
Temperature fluctuations can also affect dormancy and activity, including reproduction, in aquatic species
(Tipton et al., 2012). Temperature changes impact aquatic invertebrates" emergence and timing of
reproductive events (Nordlie et al., 1981). As ectotherms, amphibians and fish are reliant on their
environment for temperature regulation, which affects activity levels and dormancy periods (W. L. Fisher
et al., 2012; Tipton et al., 2012). Temperature plays a crucial role in fish physiology and can affect the
presence or absence of a species in an area (Tonn et al., 1990). Temperature also directly impacts fish
growth and bioenergetics (Rosenfeld, 2003). Various fish species are often only found in water of certain
temperatures, and different species often have different lethal temperatures that kill either through
excessive temperature or lack of dissolved oxygen (Karvonen et al., 2010).
15 The temperatures noted by DRBC and Abbyland Foods examples are site specific and only used here as a reference point for
the sampled effluent temperature.
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Temperature fluctuations can also affect the survivability of fungal diseases like Chytridiomycosis, a
lethal fungal parasite that affects amphibians (Tipton et al., 2012). Higher temperatures can also boost the
rate of disease spread through the weakening of host species, likely by means of physiological stress
(Karvonen et al., 2010).
2.9.2 Human Health and Aesthetic Impacts
Longer windows of warmer water increase the potential for algal blooms, which create serious potential
health hazards, as discussed in Section 2.1. Furthermore, warmer water temperatures are likely to boost
the survival of pathogens capable of causing infections in humans (Coffey et al., 2019). See Section 2.4
for a discussion of the effects of the presence of elevated bacteria and pathogens on human health.
Aesthetically, warmer water may decrease aesthetic value as larger amounts of aquatic vegetation and
algae accumulate. Increased algal growth and decreased clarity may decrease the visual appeal of water
for recreational purposes.
2.10 Antimicrobials
Wastewater and sludge from meat processing may contain antimicrobial compounds, as well as bacteria
with antimicrobial resistance (AMR) genes (Martins Da Costa et al., 2006), as antimicrobials, including
antibiotics and disinfection products, are used throughout livestock rearing and slaughtering. Antibiotics
can be introduced into the animal's feed or injected into the animal during rearing (U.S. Food and Drug
Administration, 2021). Antibiotics then enter the effluent stream through animal excrement and
processing waste (North American Meat Institute, 2016).
Antibiotics may not be completely removed from wastewater during treatment (Kiimmerer, 2009). These
compounds may not always be removed by natural conditions and municipal wastewater treatment; many
antibiotics are not biodegradable under aerobic conditions (Kiimmerer, 2009). Common antibiotics in
MPP effluent mentioned in the literature include tetracyclines, fluoroquinolones, macrolides,
sulfonamides (Shao et al., 2009; North American Meat Institute, 2016; Carvalho et al., 2013).
Antibiotics are also known to promote AMR in bacteria present in wastewater and receiving surface
waters (Martins Da Costa et al., 2006). In cattle slaughterhouses in particular, the percentage of antibiotic
resistant genes in E. coli may not be reduced by wastewater treatment. One study investigating AMR in
Portugal, found that bacterial isolates displayed resistance to tetracycline (85.7 percent), erythromycin
(45.7 percent), nitrofurantoin (34.0 percent) and rifampicin (17.8 percent) in poultry slaughter wastewater
(Martins Da Costa et al., 2006). The study also reported that resistance to three or more antimicrobial
classes was observed in 37.1 percent of sampled bacteria. While this study found that some AMR
enterococci were removed in wastewater treatment, more than 4.4 x 105 CFU/100 mL were still present in
the facility's treated wastewater effluent. Additionally, E. coli isolates for tetracycline resistance in water
samples were collected upstream and downstream of a poultry processing wastewater outfall. It was
found that tetracycline resistance in E. coli was more prevalent downstream of the outfall and that
improved wastewater treatment practices mitigated these changes (Anderson et al., 2014).
2.10.1 Ecological and Aquatic Resource Use Effects
Antibiotics can come into contact with humans and animals through surface waters (Savin et al., 2020).
These antimicrobial compounds in facility effluent can cause harm to native flora and fauna. Native
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microbial communities may be particularly at risk from foreign antimicrobials, in particular populations
of microbiota in soil that aid plants in nutrient uptake (Pinto et al., 2022). Bacteria with AMR genes, like
AMR enterococci, can persist longer in the environment, increasing their chances of causing illness in an
animal host.
2.10.2 Human Health and Aesthetic Impacts
AMR strains pose a serious potential threat to human health. Humans can be exposed to AMR strains of
bacteria via the consumption of contaminated water (Um et al., 2016). The continued use of antimicrobial
drugs in livestock can increase the risk of drug-resistant bacterial infection in humans, which would
compromise the efficacy of antimicrobial treatment (Martins Da Costa et al., 2006).
Antimicrobial substances, including antibiotics, may also reduce the efficiency of some wastewater
treatment processes. Any treatment systems reliant on aerobic bacteria to digest effluent waste could
observe microbial inhibition, thereby reducing the rate at which sludge digestion occurs (Kummerer,
2009). Additionally, increased prevalence of antimicrobial substances could increase the resiliency of
biofilms in water distribution pipes. These films could harbor pathogenic microorganisms and could lead
to incidence of water-borne disease as well as the proliferation of other water quality-compromising
bacteria (Pinto et al., 2022).
2.11 Other Pharmaceuticals and Hormones
In addition to drugs used to ward off infection, pharmaceuticals like beta-agonists, beta-blockers, diuretics
and sedatives are also administered to animals and enter the effluent stream through animal excrement
and processing waste (Shao et al., 2009). Hormones like estrogen, 17-B-cstradiol and testosterone may
also be administered to livestock via feed, and can be persistent in excrement (P. Gerber et al., 2008).
Pharmaceuticals have been detected during effluent pretreatment and partial treatment phases (Ziara et al.,
2018; Zahedi et al., 2021). Discharge of such pharmaceuticals via wastewater effluent may contribute to
their presence in drinking water supplies throughout the U.S (Bexfield et al., 2019). Shallow wells with
recent groundwater recharge are the most likely drinking water source to contain these compounds.
2.11.1 Ecological and Aquatic Resource Use Effects
Pharmaceuticals and synthetic hormones can cause significant disruption to aquatic communities
(Kayode-Afolayan et al., 2022). Pharmaceutical pollution, even in low concentrations, can lead to
physical, behavioral and cognitive changes in aquatic organisms leading to negative repercussions in
evolutionary and ecological processes (Pinto et al., 2022). Some pharmaceuticals can bioaccumulate and
become concentrated in organic tissue, causing metabolic stress and induced starvation. Additionally,
some pharmaceuticals may suppress immune response functions in fish (Kayode-Afolayan et al., 2022).
Pharmaceuticals may also alter the nutrient exchange interactions between plants and microbiota (Pinto et
al., 2022).
The release of hormones from poultry fecal waste in slaughter wastewater into surface waters can cause
harm in exposed wildlife (P. Gerber et al., 2008). Persistence of steroidal pharmaceuticals like estrogen,
progestins, and glucocorticoids in water can cause endocrine and hormonal disruption in fish. This could
cause the feminization of male fish, impair the reproductive process, and influence fish behavior and
feeding patterns (Kayode-Afolayan et al., 2022).
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2.11.2 Human Health and Aesthetic Impacts
Current research suggests pharmaceutical pollution at commonly detected levels is unlikely to have
adverse impacts on human health (Bexfield et al., 2019; A. Kumar et al., 2010; de Jesus Gaffney et al.,
2015). While this is currently the case, these studies note that further research is needed to close some
knowledge gaps, and that pharmaceutical compounds in the future could lead to different impacts than
those studied currently (A. Kumar et al., 2010;).
2.12 Surfactants
Surfactants are a compound used in the formation of many industrial products including detergents,
pharmaceuticals, pesticides and more (Badmus et al., 2021). In the meat processing industry, surfactants
are a significant component of many of the detergents used in cleaning (Bustillo-Lecompte & Mehrab,
2016). Surfactants added in the cleaning process can be persistent in wastewater and removal rates vary
depending on treatment efficiency (Badmus et al., 2021); it is estimated that surfactant concentrations in
industrial wastewater may be as much as 300 mg/L (Bustillo-Lecompte & Mehrab, 2016; Badmus et al.,
2021). Additionally, surfactants can disrupt some wastewater treatment methods that are reliant on
microbial digestions, as they may reduce microbial abundance and interrupt the biochemical reactions in
activated sludge (Paun et al., 2021).
2.12.1 Ecological and Aquatic Resource Use Effects
Commercially available surfactants can pose a threat to aquatic environments. Some types of surfactants
can cause biological alterations to wildlife, facilitate eutrophication, and increase the overall toxicity of
receiving water (Badmus et al., 2021). Surfactants can destabilize aqueous flora and fauna populations by
harming the ability of some aquatic biota, including native microbiota, to deal with environmental stress,
reproduction, and growth processes (Badmus et al., 2021). Surfactants can also increase the overall
toxicity of receiving water through increased solubility of contaminants and increased eutrophication rates
(Badmus et al., 2021; Siyal et al., 2020).
2.12.2 Human Health and Aesthetic Impacts
Human health can also be affected by surfactant exposure, as some surfactants can cause skin irritation,
respiratory problems, and may disrupt internal metabolic processes (Badmus et al., 2021). Additionally,
high concentrations of surfactants can give water an unpleasant taste and odor, even producing foams in
surface waters in large amounts (Siyal et al., 2020).
2.13 Pesticides
Pesticides include a vast range of chemicals, including herbicides, insecticides, and fungicides, that are
used to control vegetative, insect, and fungal pests, respectively (N. Kumar et al., 2012). Pesticides may
be present in livestock feed, and in pest control operations in processing facilities (James C. Acton, 2001).
Topically applied pesticides to livestock could also result in effluent contamination from residue left on
hides introduced during processing and cleaning. Beef cattle production includes the use of numerous
topical pesticides with no time limitation between application and slaughter (Kansas State University,
n.d.) Likewise, poultry producers apply a variety of pesticides to chicken houses and litter without
needing to remove the birds prior to or during application (Hoelscher, n.d.).
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2.13.1 Ecological and Aquatic Resource Use Effects
Pesticides can move beyond their initial application site and linger in surface waters (Stackpoole et al.,
2021). Research has shown that these chemicals have extensive toxicity to aquatic life. In addition to the
negative effects on taxa analogous to their intended targets (i.e.. insecticides and non-target invertebrates),
pesticides can affect other aquatic life. Polluted food sources can result in the uptake and bioaccumulation
of pesticides in other organisms such as fish, birds, and mammals (Amenyogbe et al., 2021). Continued
exposure can lead to elevated probabilities of disruption of endocrine and immune systems. Furthermore,
continual pesticide pollution could increase the chances of harmful changes in growth, enzymes, blood
chemical levels, and chromosomes.
2.13.2 Human Health and Aesthetic Impacts
Human health can potentially suffer from exposure to pesticides as well. The toxicity of pesticides varies
greatly, with low doses of some being potent enough to create severe health implications, while others are
less toxic and may only present health impacts under prolonged exposure (N. Kumar et al., 2012).
Pesticide exposure may lead to acute, chronic, or allergic conditions. Health implications of acute
pesticide poisoning include numbness, difficulty breathing, slowed heartbeat, lack of coordination,
cramps, and blurred vision. Chronic illnesses present after prolonged exposure when pesticides have
accumulated in the body of slowly damaged tissues over time. In particular, prolonged exposure can lead
to impaired memory, delayed reaction times, lack of concentration, confusion, and headaches. Pesticide
exposure can also lead to allergic responses through sensitization, potentially leading to life-threatening
shock, asthma, sores, blisters, rashes, and irritation of the eyes and nose.
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3 Water Quality Effects of Regulatory Options
To evaluate the effects of the regulatory options, EPA estimated the pollutant loading reductions that
would result from implementation of treatment under each regulatory option, accounting for any existing
treatment in place. EPA conducted this analysis primarily for combined MPP process wastewater. EPA
conducted a separate analysis on high chlorides wastewater (as a segregated waste stream) to provide
context for the potential effluent limitation on chlorides that they are taking comment on. This section
summarizes the changes in pollutant loads (refer to the TDD for details) and outlines the approach EPA
used to evaluate the effects of these changes on receiving and downstream waters, based on select case
studies.
3.1 Changes in Pollutant Loadings
For the combined MPP process waste stream, EPA estimated pollutant loads for the four wastewater
treatment technology systems described in the regulatory options. For the MPP high chlorides waste
stream, EPA estimated pollutant loads based on evaporation technology for both direct and indirect
dischargers with a high chlorides waste stream segregated from other wastewaters. EPA estimated
baseline pollutant loadings using the facility flows and the effluent pollutant concentrations associated
with the treatment in place (TIP). Wastewater treatment installed across the industry varies and some
facilities already operate treatment consistent with one of the technology systems included in the
proposed rule regulatory options. Target effluent concentrations were calculated for the pollutants found
in MPP wastewater for each technology system, as well as any treatment currently in place at a facility.
Table 3-1 summarizes the total, industry-level changes to annual pollutant loadings for the specific
pollutants found in MPP wastewater covered by the proposed rule under each regulatory option,
compared to the baseline.
Table 3-1: Summary of Changes to Annual Pollutant Loadings Compared to the Baseline
Regulatory
Option
Changes in Annual Pollutant Loadings (millions lbs/year or millions CFU/year)
TN
TP
TSS
BOD
Oil and
Grease
Chlorides3
Fecal
Coliform3
1
-8.87
-7.68
-54.39
-9.28
-16.44
-476.96
-574,994,322
2
-44.82
-16.11
-81.81
-56.95
-28.72
-476.96
-574,994,322
3
-76.18
-19.56
-93.31
-89.75
-43.38
-476.96
-574,994,322
a Chlorides and fecal coliform have the same removal under each option.
Source: U.S. EPA Analysis, 2023
As shown, annual pollutant loading reductions increase with each regulatory option for nutrients and
conventional pollutants (TSS, BOD, and oil and grease). Annual pollutant reductions estimated for
chlorides and fecal coliform are the same across regulatory options as they represent potential effluent
limitations beyond the three options.
3.2 Case Studies
EPA used a series of case studies to help demonstrate the water quality effects of the proposed
rulemaking. These case studies, which are conducted at a relatively fine spatial scale, model the effects of
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changes in pollutant discharges from select facilities to immediate receiving waters and waters directly
downstream.
3.2.1 Case Study Locations
Case study locations were chosen based on the contributions of NPDES-permitted dischargers, areas of
existing impairment, and availability of observed data to facilitate model calibration. Regarding NPDES-
permitted discharger contributions, EPA prioritized watershed locations that contained one or more direct
dischargers with significant nutrient loads and were upstream or headwater locations.16 Watersheds with
previously documented water quality impairments or published total maximum daily loads (TMDLs)
were also prioritized, especially if the impairments are due to common pollutants from the MPP industry,
such as nutrients, pathogens, organic enrichment {i.e., BOD), or sediment. Availability of observed data
was the largest limiting factor for case study location selection. Watershed locations with monitoring
stations close to the pour point of the watershed, with multi-year continuous flow records and water
quality time series data, were prioritized. After consideration of these factors, EPA identified three case
study locations: the Upper Pearl River watershed, the Double Bridges Creek watershed, and the Okatoma
Creek watershed. The following subsections provide additional context for the three case study locations.
Upper Pearl River Watershed
The Upper Pearl River watershed model is in central Mississippi, upstream from the Barnett Reservoir in
Jackson, MS. The watershed covers most ofhydrologic unit code (HUC) 03180001, terminating at HUC
03180001140603, upstream of the portion of the HUC8 that drains to the Pearl River mainstem. Primary
land uses within the watershed include forests (24.4 percent of the watershed area), pastureland (23.7
percent), and riparian wetlands (18.1 percent). Table 3-2 provides summary information on the Soil and
Water Assessment Tool (SWAT) model developed for the Upper Pearl River (S. L. Neitsch et al., 2011).
Table 3-2: Summary of SWAT Model Used to Estimate Water Quality Impacts of the Proposed Rule in the Upper
Pearl River Watershed
Model Characteristics
Watershed Total
Total watershed area (square miles)3
5,143.76
Number of HUC14 subbasins and reach segments modeled
244
Hydrologic Response Units (HRUs)b
9,612
a The watershed area is based on the SWAT model and reflects cumulative drainage to the outlet at HUC14 03180001140603.
b In SWAT, a hydrologic response unit is the smallest spatial unit modeled. By default, HRUs are developed by lumping together
areas with the same combination of land use, soil, and slope within a given subbasin, as these areas are expected to respond
similarly hydrologically.
Source: U.S. EPA Analysis, 2023
The watershed contains three NPDES-permitted MPP facilities in three separate HUC 12s:
Tyson Farms, Inc., Carthage Processing Plant (MS0026140), discharging to Cobbs Creek in HUC
031800010707. This facility engages in poultry slaughter and may perform other operations with
poultry or poultry byproducts (further processing or rendering).
10 An initial filter for "significant nutrient loads" was 100 kg/day.
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Tyson Farms, Inc., dba River Valley Animal Foods (MS0046931), discharging to Tallabogue
Creek, then Shockaloo Creek in HUC 031800011001, which drains into the Pearl River's
tributary, Tuscolameta Creek. This facility renders material into animal feeds.
Peco Foods, Inc. (MS0002615), discharging to Sipsey Creek in HUC 031800010903, which
drains into the Pearl River's tributary, Tuscolameta Creek. This facility engages in poultry
slaughter and may perform other operations with poultry or poultry byproducts (further
processing or rendering).
The watershed also contains several indirect MPP dischargers: Central Snacks, Inc., Pearl River Foods
LLC, and Koch Foods.17 Pearl River Foods LLC and Central Snacks, Inc. discharge their wastewater to
the Carthage POTW, a facility conducting secondary treatment.18 EPA assumes that Koch Foods
discharges their wastewater to the Forest Industrial Wastewater Pretreatment, which is assumed to
discharge to the Forest POTW based on proximity.19 The Forest POTW conducts tertiary or advanced
treatment.
The watershed has several flow and water quality monitoring stations on the Pearl River mainstem,
including multiple stations on the Pearl River and Tuscolameta Creek and one immediately downstream
from the Tyson Farms facility in Carthage, MS. See Figure 3-1 below for the spatial distribution of the
facilities and gage stations.
17 EPA excluded the Tyson Foods Forest Processing Plant from this analysis, as EPA confirmed it as a zero discharger.
18 Primary treatment allows solids to settle and be removed from wastewater. Secondary treatment uses biological processes to
further purify wastewater. Advanced or tertiary treatment takes place downstream from secondary treatment and includes
any treatment used to obtain high-quality effluent to meet discharge limits or for reuse.
19 EPA was unable to confirm this connection with existing permit information.
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Figure 3-1: Spatial Distribution of MPP Facilities and Gaging Stations in the Upper Pearl River Watershed
O
A
~
Tyson Farms
Inc, Carthage
Processing Plant
Pearl River
Central Snacks, Inc.
Tyson Farms Inc,
DBA River Valley
Animal Foods
Koch Foods
MPP Direct Dischargers
MPP Indirect Facilities
Other Point Sources
River Gages
Rivers and Streams
Impaired Waters
HUC14 Boundaries
0 2.5 5 10 Miles
1 i i i I i i i I
Peco
In 2021, MPP facilities accounted for 79 percent of all TN point source discharges in the Upper Pearl
watershed. Two of the three MPP direct dischargers listed above are in the Tuscolameta Creek sub-
watershed. This sub-watershed has six other point source dischargers, including a major POTW
(MS0020362, Forest, MS Wastewater Treatment Plant |WWTP|). In 2021, the two MPP dischargers that
ultimately send effluent into Tuscolameta Creek contributed 59 percent of TN from all point source loads
in the sub-watershed, with the POTW accounting for most of the remaining loads.
The Pearl River mamstem and its tributaries, the Tuscolameta, Tallabogue, and Shockaloo Creeks, were
all 303(d)-listed for water quality impairments in the 2000s. A nutrient and organic enrichment TMDL
was issued in 2009 for Tuscolameta Creek, Tallabogue Creek, and Shockaloo Creek, and a fecal colifonn
TMDL was issued specifically for Shockaloo Creek, which receives MPP discharges from the Tyson
Fanns, River Valley Animal Foods facility (Mississippi Department of Environmental Quality, 2008;
Mississippi Department of Environmental Quality, 2009). According to the Assessment, Total Maximum
Daily Load Tracking and Implementation System (ATTAINS) data (as of 2023), sections of the 25-mile
downstream flow path for Tyson Farms, Inc., Carthage, and Peco Foods, Inc. were classified as impaired,
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with the latter listed as impaired for nutrients, dissolved oxygen and sediment. EPA did not identify more
recent TMDLs for this region. The 303(d) list and ATTAINS data are maintained separately and
differences exist between these datasets for the Upper Pearl River watershed.
The Upper Pearl River watershed also overlaps with the species habitat for one threatened and
endangered species, the Northern Long-Eared Bat (Mvotis septentrionalis). The Northern Long-Eared Bat
relies on aquatic resources both directly for drinking water and indirectly for food when not hibernating.
Foraging activity can occur near water and various groups of insects with ties to aquatic habitats help
comprise the species diet (U.S. Fish and Wildlife Service, 2022). Northern Long-Eared Bats have low
fecundity and each female only produces a single offspring at a time. A lack of adequate water and prey
supplies near roosting sites can decrease reproductive success and threaten populations due to slow rates
of reproduction. Changes in water quality that influence toxicity or prey availability could exacerbate
conservation concerns that are primarily driven by disease, habitat loss, and climate change. This species
is considered lower vulnerability in the context of this analysis (see Section 4.2.3 for more information on
the vulnerability classification of various species).
Under the preferred option (regulatory option 1), annual TN loadings for direct dischargers are reduced by
over 337,000 lbs/year across the facilities and annual TP loadings for direct dischargers are reduced by
almost 300,000 lbs/year across the facilities. Only one direct discharger (Tyson Farms, DBA River Valley
Animal Foods) will have reduced annual TSS loadings. Annual CBOD loadings for direct dischargers are
reduced by nearly 60,000 lbs/year across the facilities. For indirect dischargers, there are no expected
nutrient loading reductions due to the proposed production size thresholds under Option 1. Only one
indirect discharger (Koch Foods) will have reduced conventional pollutants (TSS and CBOD). For
facilities included in this case study watershed, loadings changes do not differ under regulatory options 1
and 2. However, for two of the indirect dischargers, there are increased loadings reductions for nutrients
and conventional pollutants under regulatory option 3. Notably, the Central Snacks facility will not
experience any loadings reductions across any of the regulatory options. Table 3-3 summarizes the
expected changes in annual pollutant loadings for each of the dischargers within the Upper Pearl River
watershed across the regulatory options.
Table 3-3: Summary of Changes to Annual Pollutant Loadings Compared to the Baseline for Upper Pearl River
Watershed
Facility
Discharge
Type
Regulatory
Option
Changes in Annual Pollutant Loadings (lbs/year)
TN
TP
TSS
CBOD
Tyson Farms, Inc.,
Carthage Processing
Plant
Direct
1
-191,938
-113,041
0
-33,642
2
-191,938
-113,041
0
-33,642
3
-191,938
-113,041
0
-33,642
Tyson Farms, DBA
River Valley Animal
Foods
Direct
1
-43,877
-125,221
-1,861,145
-4,203
2
-43,877
-125,221
-1,861,145
-4,203
3
-43,877
-125,221
-1,861,145
-4,203
Peco Foods
Direct
1
-101,710
-59,901
0
-17,827
2
-101,710
-59,901
0
-17,827
3
-101,710
-59,901
0
-17,827
Central Snacks
Indirect
1
0
0
0
0
2
0
0
0
0
3
0
0
0
0
Pearl River Foods LLC
Indirect
1
0
0
0
0
2
0
0
0
0
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Table 3-3: Summary of Changes to Annual Pollutant Loadings Compared to the Baseline for Upper Pearl River
Watershed
Facility
Discharge
Regulatory
Changes in Annual Pollutant Loadings (lbs/year)
Type
Option
TN
TP
TSS
CBOD
3
-29,701
-669
-5,232
-48,936
1
0
0
-406,879
-45,294
Koch Foods
Indirect
2
0
0
-406,879
-45,294
3
-45,417
-7,616
-413,343
-81,369
Source: U.S. EPA Analysis, 2023
Double Bridges Creek Watershed
The Double Bridges Creek watershed model is in southern Alabama, approximately 10 miles due north of
the Florida state line. The watershed covers 11 HUC14 subbasins and terminates at HUC
03140201110404, upstream of the portion of the creek that drains to the Choctawhatchee River mainstem.
Primary land uses within the watershed include forests (29.3 percent of the watershed area), riparian
forests (17.0 percent), and pastureland (13.4 percent). Table 3-4 provides summary information on SWAT
model developed for Double Bridges Creek.
Table 3-4: Summary of SWAT Model Used to Estimate Water Quality Impacts of the Proposed Rule in the
Double Bridges Creek Watershed
Model Characteristics
Watershed Total
Total watershed area (square miles)3
246.47
Number of HUC14 subbasins and reach segments modeled
11
HRUs
492
a The watershed area is based on the SWAT model and reflects cumulative drainage to the outlet at HUC14 03140201110404.
Source: U.S. EPA Analysis, 2023
The watershed contains two poultry processing facilities that directly discharge wastewater:
Pilgrim's Pride Corp., Enterprise (AL0003697), discharging through multiple outfalls to Double
Bridges Creek via Little Double Bridges Creek inHUC12s 031402011102, 031402011103 and
031402011104. The facility engages in poultry slaughter and may perform other operations with
poultry or poultry byproducts (further processing or rendering).
Wayne Farms LLC-Enterprise Processing (AL0028860), discharging to the Pea River to HUC 12s
031402011102, 031402020403, 031402020506 and 031403030305. The facility engages in poultry
slaughter and may perform other operations with poultry or poultry byproducts (further processing or
rendering).
The Double Bridges Creek watershed does not contain any indirect dischargers. The Pilgrim's Pride
facility falls within the Little Double Bridges Creek watershed. This sub-watershed has no other point
source contributions. The Wayne Farms facility and most of its outfalls are not located in the Double
Bridges Creek watershed; however, one of its process wastewater outfalls discharges to Double Bridges
Creek (HUC 03140201110202). There are two additional point source contributors in the headwater
HUCs 03140201110201 (New Brockton WWTP) and 03140201110203 (Enterprise WWTP 2). Across
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EA for Proposed Revisions to the Meat and Poultry Products ELGs 3: Water Quality Effects of Regulatory Options
the four point source contributors, the MPP facilities contributed 99.6 percent and 99.5 percent of the TN
and TP loads to the larger Double Bridges Creek watershed in 2021.
The watershed has three monitoring stations downstream of the Pilgrim's Pride facility. The Water
Quality Portal provides data for some water quality sampling sites throughout the watershed, including
sites along Double Bridges Creek and one immediately downstream from the Pilgrim's Pride facility in
Coffee County, AL. See Figure 3-2 below for the spatial distribution of the facilities and gaging stations
described above.
Figure 3-2: Spatial Distribution of MPP facilities, Other Point Source Dischargers, and Gaging Stations in the
Double Bridges Creek Watershed20
MPP Indirect Facilities
MPP Direct Dischargers
River Gages
Other Point Sources
Impaired Waters
Rivers and Streams
HUC14 Boundaries
3 Miles
4th
A
O
~
There are several stream segments within the watershed that have been listed as impaired. However, none
of these segments receive discharge or are downstream of MPP facilities. Double Bridges Creek at Coffee
County Road 636, was 303(d)-listed for water quality impairments in 2008. Double Bridges Creek at
Coffee County Road 655 was included on the 303d list in 2020 for li coli impairments. The impaired
segment of Double Bridges Creek at Coffee County Road 636 is located in the same HUC14 as the
2a The impaired stream segments in Figure 3-2 were generated based on text descriptions from the 303(d) list.
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Pilgrim's Pride facility; however, this segment does not receive discharge from the facility. According to
ATTAINS data gathered in 2023, the downstream flow path immediately following the MPP facility has
not been assessed, though many major neighboring streams have been. The 303(d) list and ATTAINS
data are maintained separately and differences exist between these datasets for Double Bridges Creek.
The Double Bridges Creek watershed also overlaps with the species habitat of five high vulnerability
clam species that are considered threatened and endangered: the fuzzy pigtoe, chowtaw bean, tapered
pigtoe, southern sandshell, and southern kidneyshell. These species of freshwater bivalves, like other
freshwater mussels, rely on their aquatic environment for habitat, reproduction, and food. Bivalves
reproduce by releasing sperm into flowing waters, from which females siphon it for internal fertilization
(Gatenby et al., 2023). Freshwater mussels create stability, improve water quality, and protect aquatic
ecosystems by filtering multiple gallons of water per day. (Gatenby et al., 2023). Declines in water quality
or excess pollution can bioaccumulate in these species and have both acute and chronic affects capable of
impacting whole populations. Because of the critical role these species fulfill, population declines mean a
positive feedback loop where increasingly less water is being filtered by freshwater bivalves, leaving
more pollutants for other individuals to endure. The decline of mussel populations indicates poor
environmental health that could be negatively impacting other species (National Wildlife Health Center,
2019). See Section 4.2.3 for more information on the vulnerability classification of various species.
Under the preferred option (regulatory option 1), annual TN loadings for direct dischargers are reduced by
nearly 300,000 lbs/year across the facilities. Only one direct discharger (Pilgrim's Pride Corp.,
Enterprise) will have reduced annual TP loadings and reduced annual TSS loadings, due to production
size thresholds under the proposed rule options. Because of this, EPA expects loading reductions to be the
same across all options in this case study. Annual CBOD loadings for direct dischargers are reduced by
nearly 50,000 lbs/year across the facilities. Due to production size thresholds under the proposed rule,
EPA expects loading reductions to be the same across all options in this case study watershed. Table 3-5
summarizes the expected changes in annual pollutant loadings for each of the dischargers within the
Double Bridges Creek watershed across the regulatory options.
Table 3-5: Summary of Changes to Annual Pollutant Loadings Compared to the Baseline for Double Bridges
Creek Watershed
Facility
Discharge
Regulatory
Changes in Annual Pollutant Loadings (lbs/year)
Type
Option
TN
TP
TSS
CBOD
Pilgrim's Pride Corp.,
Enterprise
1
-104,540
-50,881
-302,255
-15,143
Direct
2
-104,540
-50,881
-302,255
-15,143
3
-104,540
-50,881
-302,255
-15,143
Wayne Farms LLC-
Enterprise Processing
1
-190,153
0
0
-33,329
Direct
2
-190,153
0
0
-33,329
3
-190,153
0
0
-33,329
Source: U.S. EPA Analysis, 2023
Oka to ma Creek Watershed
The Okatoma Creek watershed model is in southern Mississippi, approximately 10 miles northwest of
Hattiesburg. The watershed covers 35 HUC14 subbasins and terminates at HUC 03170004070803,
joining with the Bouie River mainstem. Primary land uses within the watershed include forests (28.0
percent of the watershed area), pastureland (25.5 percent), and riparian forests (22.6 percent). Table 3-6
provides summary information on SWAT model developed for Okatoma Creek.
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Table 3-6: Summary of SWAT Model Used to Estimate Water Quality Impacts of the Proposed ELG in the
Okatoma Creek Watershed
Model Characteristics
Watershed Total
Total watershed area (square miles)3
733.17
Number of HUC14 subbasins and reach segments modeled
35
Hydrologic Response Units
1,515
a The watershed area is based on the SWAT model and reflects cumulative drainage to the outlet at HUC14 03170004070803.
Source: U.S. EPA Analysis, 2023
The watershed contains one poultry processing facility: Sanderson Farms, Inc. (MS0002089), discharging
to Blakely Creek-Okatoma Creek in HUC12 031700040704. This facility engages in poultry slaughter
and may perform other operations with poultry or poultry byproducts (further processing or rendering).
The watershed also contains one indirect MPP discharger, Polk's Meat Products Inc, Magee, which sends
its wastewater to the Magee POTW for secondary treatment. There are eight other point source
contributors throughout the entire watershed. In 2021, Sanderson Farms contributed 78.6 percent of TN
and 58 percent of TP point source loads.
The watershed has 12 U.S. Geological Survey (USGS) gaging stations downstream of the Sanderson
Farms facility. The Water Quality Portal provides data for several water quality sampling sites throughout
the watershed, including several on the Okatoma Creek mainstem ranging from approximately seven to
17 miles downstream of the facility. See Figure 3-3 below for the spatial distribution of the facilities and
gaging stations described above.
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Figure 3-3: Spatial Distribution of MPP facilities, Other Point Source Dischargers, and Gaging Stations in the
Okatoma Creek Watershed
MPP Indirect Facilities
MPP Direct Dischargers
O Other Point Sources
A OkatomaStations
Impaired Waters
Rivers and Streams
I I HUC14 Boundaries
N
AO 1 2 4 Miles
Okatoma Creek was 303(d)-listed for a water quality impairment in 2013. A pH TMDL was issued for
Okatoma Creek in Simpson and Covington Counties from the confluence with Roger Creek to the
Mississippi watershed boundary 4107 near Gin Branch, the portion of the creek that receives MPP
discharges from the Sanderson Farms facility. The exact cause of the pH impairment is unknown, but it is
suspected to be a combination of acidic soil and point source discharges (Mississippi Department of
Environmental Quality, 2013).
Under the preferred option (regulatory option 1), annual TN loadings for direct dischargers are reduced by
nearly 100,000 lbs/year/facility, annual TP loadings for direct dischargers are reduced by about 45,000
Ibs/years/facility, annual TSS loadings for direct dischargers are reduced by nearly 300,000
Ibs/year/facility, and annual CBOD loadings for direct dischargers are reduced for almost 15,000
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lbs/year/facility. For indirect dischargers, there are no expected loading reductions due to production level
thresholds under the preferred option. For facilities included in this case study watershed, loadings
changes do not differ under regulatory options 1 and 2. However, for the indirect discharger, there are
increased loadings reductions for nutrients and conventional pollutants under regulatory option 3. Table
3-7 summarizes the expected changes in annual pollutant loadings for each of the dischargers within the
Okatoma Creek watershed across the regulatory options.
Table 3-7: Summary of Changes to Annual Pollutant Loadings Compared to the Baseline for Okatoma Creek
Watershed
Facility
Discharge
Regulatory
Changes in Annual Pollutant Loadings (lbs/year)
Type
Option
TN
TP
TSS
CBOD
1
-93,035
-45,281
-268,991
-13,476
Sanderson Farms, Inc.
Direct
2
-93,035
-45,281
-268,991
-13,476
3
-93,035
-45,281
-268,991
-13,476
Polk's Meat Products,
Inc.
1
0
0
0
0
Indirect
2
0
0
0
0
3
-29,701
-669
-5,232
-48,936
Source: U.S. EPA Analysis, 2023
3.2.2 Methodology
To evaluate the potential water quality impacts of the proposed rule, EPA developed models of the
selected case study watersheds using the Hydrologic and Water Quality System (HAWQS) 2.0 and
SWAT. The model delineates subbasins and reaches at the resolution of 14-digit HUCs. Additional
details on model setup, including calibration results, can be found in Appendix B: Case Study Water
Quality Modeling.
EPA estimated changes in point source discharges from MPP facilities for TN, TP, TSS, and CBOD
expected under the proposed rule and applied these changes to the existing point source loads represented
in the SWAT models.21 EPA ran the models for a 9-year period which reflects observed weather in 2005-
2013 (2003-2013, with a two-year warm-up period) and was chosen to reflect effects under varying
hydrologic conditions for the case study locations, including normal, wet, and dry conditions.22
3.2.3 Results
The following tables summarize average percentage changes over the nine-year modeling period between
the baseline and various regulatory options. The tables provide percentage changes for receiving HUC14s
for direct and indirect discharges as well as percentage changes at the watershed outlet.
Overall, reductions in pollutant in-stream concentrations under the preferred option (regulatory option 1)
range from over 80 percent to less than one percent across pollutants and case study models, with the
21 In some instances, the existing point source loads estimated from 2021 Discharge Monitoring Report data were lower than the
estimated changes in point source discharges from MPP facilities. In other instances, there were no existing point source
loads for the specified pollutant. In both instances, EPA zeroed out loadings between the baseline and scenario model rims.
For more information on the estimated loadings changes, please see the TDD.
11 Normal, wet, and dry hydrologic conditions were determined based on the distribution of precipitation from 2004-2020. Dry
years were defined as those that fall within the 25th percentile while wet years were defined as those that fall within the 75th
percentile.
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effects being more pronounced in the immediate receiving waters and less pronounced as one moves
farther downstream from an MPP discharger (Table 3-8). The largest percent change in water quality
improvements are in the Upper Pearl River watershed, in alignment with the large annual pollutant
loadings changes within the watershed reflected in Table 3-3. However, although there are more modest
percentage reductions for TN and TP in receiving waters in the Okatoma Creek watershed, the percentage
changes at the watershed pour point are less diluted. In particular, average percent reductions for TN and
TP concentrations (averaged over the 9-year modeling period) at the watershed pour point for the
Okatoma Creek watershed are about 15 and 25 percent, respectively. This is in comparison to nutrient
loading reductions of less than 10 percent at the watershed pour point of the other two case study models,
including the Upper Pearl River watershed where average pollutant reductions for TP were over 70
percent.
Table 3-8: Summary of Percentage Changes to In-Stream Water Quality Modeling Estimates Compared to the
Baseline for Regulatory Option 1
Watershed
HUC14
Description
Average Percentage Changes (9-year
period) in Pollutant Concentrations (%)
TN
TP
TSS
CBOD
Upper Pearl River
03180001070703
MPP Discharge Location (Tyson
Farms Inc, Carthage Processing
Plant)
-39.1
-75.6
0.0
-3.2
03180001090305
MPP Discharge Location (Peco
Foods, Inc.)
0.0
0.0
0.0
0.0
03180001090406
Receiving POTW; Forest POTW
0.0
0.0
-7.8
0.0
03180001100107
MPP Discharge Location (Tyson
Farms Inc., DBA River Valley
Animal Foods)
0.0
0.0
0.0
0.0
03180001140504
Receiving POTW; Carthage POTW
-10.7
-10.3
0.0
-1.1E-02
03180001140603
Watershed Pour Point
-7.4
-6.2
-3.1E-04
-1.6E-03
Double Bridges
Creek
03140201110202
MPP Discharge Location (Wayne
Farms LLC)
0.0
0.0
0.0
0.0
03140201110401
MPP Discharge Location (Pilgrim's
Pride Corp)
-2.8
-5.7
-0.6
0.0
03140201110404
Watershed Pour Point
-2.7
-5.7
-0.4
0.0
Okatoma Creek
03170004070204
Receiving POTW; Magee
0.0
0.0
0.0
0.0
03170004070404
MPP Discharge Location; Farthest
Downstream (Sanderson Farms)
-22.5
-43.1
-0.8
0.0
03170004070803
Watershed Pour Point
-15.3
-25.1
-0.1
0.0
Source: U.S. EPA Analysis, 2023
As shown in Table 3-9, the average percentage changes are the same across regulatory options 1 and 2 for
the case study watersheds. This is because the production size thresholds are the same under these options
and none of the indirect discharging facilities exceed the threshold that would require nutrient limits
under option 2. This is in alignment with the estimated loadings changes reflected in Table 3-3, Table 3-5,
and Table 3-7.
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Table 3-9: Summary of Percentage Changes to In-Stream Water Quality Modeling Estimates Compared to the
Baseline for Regulatory Option 2
Watershed
HUC14
Description
Average Percentage Changes (9-year
period) in Pollutant Concentrations (%)
TN
TP
TSS
CBOD
Upper Pearl River
03180001070703
MPP Discharge Location (Tyson
Farms Inc, Carthage Processing
Plant)
-39.1
-75.6
0.0
-3.2
03180001090305
MPP Discharge Location (Peco
Foods, Inc.)
0.0
0.0
0.0
0.0
03180001090406
Receiving POTW; Forest POTW
0.0
0.0
-7.8
0.0
03180001100107
MPP Discharge Location (Tyson
Farms Inc., DBA River Valley
Animal Foods)
0.0
0.0
0.0
0.0
03180001140504
Receiving POTW; Carthage POTW
-10.7
-10.3
0.0
-1.1E-02
03180001140603
Watershed Pour Point
-7.4
-6.2
-3.1E-04
-1.6E-03
Double Bridges
Creek
03140201110202
MPP Discharge Location (Wayne
Farms LLC)
0.0
0.0
0.0
0.0
03140201110401
MPP Discharge Location (Pilgrim's
Pride Corp)
-2.8
-5.7
-0.6
0.0
03140201110404
Watershed Pour Point
-2.7
-5.7
-0.4
0.0
Okatoma Creek
03170004070204
Receiving POTW; Magee
0.0
0.0
0.0
0.0
03170004070404
MPP Discharge Location; Farthest
Downstream (Sanderson Farms)
-22.5
-43.1
-0.8
0.0
03170004070803
Watershed Pour Point
-15.3
-25.1
-0.1
0.0
Source: U.S. EPA Analysis, 2023
Compared to average percentage reductions under regulatory option 1, percentage reductions under
regulatory option 3 are generally larger for the Upper Pearl River and Okatoma Creek watersheds. The
pattern is the same though, with higher average percentage reductions in receiving HUC14s in the Upper
Pearl River watershed, but less diffuse reductions at the watershed pour point for the Okatoma Creek
watershed. The average percentage reductions are the same across all three regulatory options for the
Double Bridges Creek watershed. This is in line with the loading reductions estimated for each facility
summarized in Table 3-7.
Regulatory option 3 results in the largest overall nutrient reduction at each watershed pour point. For the
Upper Pearl River watershed, these nutrient reductions could have implications on the impaired waters
within the watershed, specifically those listed as impaired for nutrients and oxygen depletion. The Upper
Pearl River watershed also overlaps with habitat for the endangered northern long-eared bat. Nutrient
reductions to waters within their habitat can influence toxicity and prey availability, contributing to
habitat suitability for the critical species. Similarly, nutrient reductions in the Double Bridges Creek
watershed could have important implications for the five endangered higher vulnerability clam species
whose habitat overlaps with the watershed. See Section 4.2.3 for more information on the vulnerability
classification of the endangered species potentially affected by this rulemaking.
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Table 3-10: Summary of Percentage Changes to In-Stream Water Quality Modeling Estimates Compared to the
Baseline for Regulatory Option 3
Watershed
HUC14
Description
Average Percentage Changes (9-year
period) in Pollutant Concentrations (%)
TN
TP
TSS
CBOD
Upper Pearl River
03180001070703
MPP Discharge Location (Tyson
Farms Inc, Carthage Processing
Plant)
-39.1
-75.6
0.0
-3.2
03180001090305
MPP Discharge Location (Peco
Foods, Inc.)
0.0
0.0
0.0
0.0
03180001090406
Receiving POTW; Forest POTW
-43.0
-13.8
-7.8
0.0
03180001100107
MPP Discharge Location (Tyson
Farms Inc., DBA River Valley
Animal Foods)
0.0
0.0
0.0
0.0
03180001140504
Receiving POTW; Carthage POTW
-12.3
-10.6
0.0
-1.1E-02
03180001140603
Watershed Pour Point
-9.6
-7.3
-3.1E-04
-1.6E-03
Double Bridges
Creek
03140201110202
MPP Discharge Location (Wayne
Farms LLC)
0.0
0.0
0.0
0.0
03140201110401
MPP Discharge Location (Pilgrim's
Pride Corp)
-2.8
-5.7
-0.6
0.0
03140201110404
Watershed Pour Point
-2.7
-5.7
-0.4
0.0
Okatoma Creek
03170004070204
Receiving POTW; Magee
-21.3
-7.2
0.0
0.0
03170004070404
MPP Discharge Location; Farthest
Downstream (Sanderson Farms)
-25.8
-44.9
-0.8
0.0
03170004070803
Watershed Pour Point
-17.5
-26.1
-0.1
0.0
Source: U.S. EPA Analysis, 2023
The following table (Table 3-11) summarizes average and maximum nutrient concentrations over the
nine-year modeling period at the watershed pour point for each of the case study watersheds. The table
focuses on nutrient concentration changes across the regulatory options as they differed by more than one
percent across the options (compared to changes in CBOD and TSS concentrations which were minimal
or nonexistent). Total nitrogen average and maximum concentrations across the nine-year modeling
period within the Upper Pearl River and Okatoma Creek watershed pour points are below the average
state numeric criteria for TN (six mg/L). However, TN average and maximum concentrations within the
Double Bridges Creek watershed pour point are greater than both the average numeric criteria across all
criteria categories and the average effluent numeric criteria (15 mg/L), even after nutrient reductions from
the implementation of the regulatory options. Similarly, TP average and maximum concentrations across
all the case study watershed pour points are greater than the average state numeric criteria for designated
uses like recreation (0.04 mg/L) and aquatic life (0.05 mg/L), taking into consideration nutrient reductions
from the implementation of the regulatory options. For the Double Bridges Creek watershed pour point,
TP average and maximum concentrations are also greater than the average state effluent numeric criteria
(1.83 mg/L).
CBOD and TSS concentrations did not vary much across the regulatory options, but baseline
concentrations at the case study watershed pour points do exceed average state criteria. Average baseline
CBOD concentrations are consistently greater than the average state BOD criteria for designated uses like
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recreation and aquatic life (5 mg/L) across the case study watershed pour points.23 Average baseline
CBOD concentrations for the Upper Pearl River watershed pour point and maximum baseline CBOD
concentrations for the Double Bridges Creek and Okatoma Creek watershed pour points are also greater
than the average state BOD effluent criteria (33.75 mg/L). Average and maximum TSS concentrations
across all of the case study watershed pour points are greater (by at least an order of magnitude) than
average state TSS criteria for both effluent (37.5 mg/L) and aquatic life (59.5 mg/L).
Table 3-11: Summary of In-Stream Water Quality Modeling Concentration Estimates by Case Study Watershed
Watershed Pour
Point
Regulatory
Option
Total Nitrogen Concentrations
(mg/L)
Total Phosphorus Concentrations
(mg/L)
Average
Maximum
Average
Maximum
Upper Pearl River
(03180001140603)
Baseline
1.68
4.52
0.42
1.37
Option 1
1.56
4.48
0.40
1.36
Option 2
1.56
4.48
0.40
1.36
Option 3
1.52
4.47
0.40
1.36
Double Bridges
Creek
(03140201110404)
Baseline
17.50
41.93
4.09
9.92
Option 1
17.02
40.75
3.86
9.34
Option 2
17.02
40.75
3.86
9.34
Option 3
17.02
40.75
3.86
9.34
Okatoma Creek
(03170004070803)
Baseline
1.65
5.85
0.15
0.46
Option 1
1.38
4.24
0.11
0.24
Option 2
1.38
4.24
0.11
0.24
Option 3
1.33
4.10
0.11
0.23
3.3 Limitations and Uncertainty
The methodologies and data used in the estimation of the environmental effects of the regulatory options
involve limitations and uncertainties. Table 3-11 summarizes the limitations and uncertainties and
indicates the direction of the potential bias. Uncertainties associated with some of the input data are
covered in greater detail in other documents.
Table 3-12: Limitations and Uncertainties in Estimating Water Quality Effects of Regulatory Options
Uncertainty/Limitation
Effect on Water
Quality Effects
Estimation
Notes
Model estimates are uncertain for
some water quality parameters
based on model calibration
Uncertain
Water quality calibration for some of the case study
models and parameters could not be completed or
did not meet target values due to missing data (see
Appendix B: Case Study Water Quality Modeling for
additional detail).
Model estimates are uncertain
based on the locations assumed for
direct and indirect discharges from
MPP facilities
Uncertain
Some direct and indirect discharge locations were
assumed based on proximity.
Source: U.S. EPA Analysis, 2023
23 CBOD is a component of BOD so the BOD state criteria were used as a reference for an upper bound for CBOD
concentrations.
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4: Environmental Effects
4 Environmental Effects from Changes in Water Quality and
Subsequent Pollutant Exposure
The regulatory options are expected to reduce pollutant loadings associated with nutrients (nitrogen and
phosphorus), TSS, oil and grease, and BOD. The Agency is seeking comment on additional technology
that would reduce E. coli and chlorides loadings from MPP facilities. Reducing discharges of these
pollutants to surface water can have a variety of environmental effects, including reduced fish kills;
improved propagation, survival and growth of aquatic organisms, including threatened and endangered
(T&E) species; and improved habitat conditions for fresh- and saltwater plants, invertebrates, fish and
amphibians, as well as terrestrial wildlife and birds that prey on aquatic organisms exposed to MPP
facility pollutants. These ecological improvements have the potential to benefit commercial, recreational,
and subsistence fisheries and fishing areas, and enhance recreational activities. The following analyses
identify the locations of potential impacts to waters downstream of MPP discharge locations, but they do
not differentiate between regulatory options in terms of the scope of affected waters or the degree of
improvements to those waters.
4.1 Overall Environmental Effects from Changes in Pollutant Loadings
Increases in ammonia and the presence of harmful algal blooms (HABs) can lead to odor and water
clarity issues affecting recreation and aesthetics (Backer et al., 2006; Baskin-Graves et al., 2019b; U.S.
Environmental Protection Agency, 2000). Additionally, excessive amounts of phosphorus, ammonia, and
other forms of nitrogen can lead to low DO levels (Michael A Mallin et al., 2020), which may, in turn,
lead to the release of toxic metals from sediments and contamination of surface waters and aquatic
habitats (Zhang, 2016). By decreasing discharges of nitrogen and phosphorus, the regulatory options
could reduce occurrence of HABs and the release of toxic metals from water body sediments and improve
water clarity, odor, and DO levels.
Elevated total suspended solids can reduce the amount of light reaching aquatic plants and algae (Muncy
et al., 1979), reducing the ability of macrophytes to grow and altering the habitat, cover, and food
resources for other aquatic organisms. Increased BOD can significantly alter community composition in
aquatic ecosystems by depleting available DO, creating stressful anerobic conditions, and suffocating
aquatic organisms (Penn et al., 2009). Oil and grease can also inhibit oxygen mixing with the water,
exacerbating low oxygen supply and contributing to anerobic conditions. Total suspended solids, BOD,
and oil and grease all have the capacity to harm aquatic life. As such, reducing discharges of these
conventional pollutants can improve conditions for aquatic species.
4.2 Environmental Effects to Sensitive Environments
Due to limited data and models, the analysis focuses on evaluating the overlap between potentially
impacted areas and sensitive environments and does not explicitly model the environmental effects of the
regulatory options on these environments (e.g., the scope of affected waters or the degree of
improvements to those waters). To evaluate the sensitive environments potentially affected by the
regulatory options, EPA first identified the receiving waters and downstream path of MPP discharges
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whose locational information could be determined.24 Some MPP discharge locations could not be
identified with available data sources (Detailed and Census Questionnaires, ECHO database, and
HAWQS point source database), which resulted in a smaller universe in this chapter than what is
represented elsewhere in this document and in associated rulemaking documents.25 EPA identified the
downstream path from MPP dischargers as National Hydrography Dataset (NHD) Plus Version 2 stream
segments that are within 25 stream miles downstream26 of the point where the MPP discharge occurs as
well as the segment directly upstream from the discharge location. Each identified stream segment has the
length of the segment and the cumulative sum of the distance from the discharging stream segment. EPA
used this geospatial dataset representing affected stream segments in the following analyses to identify the
sensitive environments impacted by MPP facility discharges. Table 4-1 summarizes the data sources used
for analyses in the following sections.
Table 4-1: Data Sources for Evaluating the Potential Environmental Effects to Sensitive Environments
Analysis
Data Name
Summary
Data Source
Impaired Waters
ATTAINS Database
Impaired status for waters assessed
through the 303(d) and 305(b) process.
EPA
Fisheries
Essential Fish Habitat
Mapper
Habitat location for commercially fished
species.
National Oceanic and
Atmospheric
Administration (NOAA)
National Hunting and
Fishing Units
Locations where recreational fishing is
allowed on USFWS owned public lands.
United States Fish &
Wildlife Service
(USFWS)
Aquaculture
Locations for marine commercial
shellfishing areas along the Atlantic
coast.
NOAA
Endangered
Species Habitat and
Protected Areas
ECOS Threatened &
Endangered Species
Active Critical
Habitat
Habitat locations for threatened and
endangered species.
USFWS
Priority Water
Bodies
Wild and Scenic
Rivers
Rivers designated as Wild and Scenic.
United States Forest
Service
Great Lakes
Boundaries
Full extent of the Great Lakes.
Great Lakes
Commission
Chesapeake Bay
Boundaries
Full extent of the Chesapeake Bay.
Chesapeake BayTMDL
Medium Resolution
Shoreline
Boundary of marine waters for the
conterminous U.S.
NOAA
24 Downstream paths were identified for both direct discharge and indirect discharge facilities. Although indirect dischargers send
their wastewater to POTWs, the indirect dischargers downstream path was approximated based on the location of the
indirect discharger and only used for the impaired waters analysis.
25 The Agency was unable to determine locational information for one direct discharge facilities (one percent of all direct
discharge facilities) and 368 indirect discharge facilities (a little over 10 percent of indirect discharge facilities).
20 Due to the varying lengths of stream segments in the NHD dataset, some downstream paths are shorter than 25 miles and some
are longer than 25 miles. This downstream distance was used to be inclusive of most reported distances of nutrient impacts
stemming specifically from MPP wastewater releases. The shortest distance reported was 1.2 miles (MORNING CALL,
2007) and the longest was 45 (Alabama Attorney General, 2021; McCarthy, 2019).
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Table 4-1: Data Sources for Evaluating the Potential Environmental Effects to Sensitive Environments
Analysis
Data Name
Summary
Data Source
Estuary Boundaries
Boundary of estuaries with national
significance
National Estuary
Program
Recreational Areas
Protected Areas
Database
Publicly accessible areas aggregated
across federal, state, and local
jurisdictions.
USGS
Source: U.S. EPA Analysis, 2023
4.2.1 Impaired Waters
Impaired waters are those that do not meet water quality criteria for their designated uses and discharges
from MPP facilities can contribute to these water quality impairments. EPA used the ATTAINS database
to identify which downstream flowpaths from both direct and indirect MPP dischargers overlap with
waters identified as impaired. For the indirect facilities, EPA did not have adequate data to determine the
indirect discharger to POTW connection, so EPA assumed the location of the facility was a good proxy
for the location of the discharge and the downstream flowpath was generated from this point. The
ATTAINS Assessment Unit Catchment Associations27 spatial dataset was used to identify the overlap
between upstream and downstream segments associated with MPP dischargers, and stream segments with
existing impairments. The ATTAINS Assessment Attribute Summary Table28 provided information on
the specific pollutants/pollutant groups associated with the impairment. EPA subset the attribute summary
table to only consider pollutants known to be present in MPP wastewater. Table 4-2 summarizes the list
of pollutant impairment parameter groups as well as the number of impaired catchments within the 25-
mile downstream flowpath of MPP direct and indirect dischargers.29 Although a variety of pollutants are
the cause of impairments downstream of MPP dischargers, some of the most frequent causes of
impairments align with the pollutants covered by the proposed rule. Pathogens are the most common
cause of impairments downstream from both MPP direct and indirect dischargers with approximately 41
percent of direct dischargers and 28 percent of indirect dischargers with a pathogen impairment at any
point downstream. Nutrients (nitrogen and phosphorus) are the second most common cause of
impairments downstream of MPP direct dischargers and fifth most common cause of impairments
downstream of MPP indirect dischargers. Oxygen depletion is the fourth most common cause of
impairment downstream of MPP direct and indirect dischargers.
Table 4-2: Number of Impaired Catchments Downstream of MPP Direct and Indirect Dischargers by Parameter
Group
Parameter group
Number of Catchments Downstream
from Direct Dischargers
Number of Catchments Downstream
from Indirect Dischargers
Algal Growth
9
497
Chlorine
1
3
Mercury
263
2,512
Nutrients
295
2,633
27https://gispub.epa.gov/arcgis/rest/services/OW/ATTAINS_Assessment/MapServer/3
28 https://gispub.epa.gOv/arcgis/rest/services/OW/ATTAINS_Assessment/MapServer/4
29 Appendix D: Impaired Waters Analysis contains a complete list of pollutants evaluated in the impaired waters analysis.
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Table 4-2: Number of Impaired Catchments Downstream of MPP Direct and Indirect Dischargers by Parameter
Group
Parameter group
Number of Catchments Downstream
from Direct Dischargers
Number of Catchments Downstream
from Indirect Dischargers
Oil & Grease
1
62
Other Cause
50
189
Other Metals
123
2,006
Oxygen Depletion
245
2,070
Pathogens
589
6,168
pH/Acidity/Caustic Conditions
58
723
Radiation
38
26
Solids (Chlorides & Sulfates)
106
832
Toxic Inorganics
11
153
Toxic Organics
8
248
Turbidity
112
997
Unknown Impairment
152
1,520
Source: U.S. EPA Analysis, 2023
Table 4-3 and Table 4-4 summarize the percentage of direct and indirect dischargers, respectively, with a
new impairment (in comparison to impairments in the catchments upstream of MPP discharges) in the
catchment directly receiving the MPP discharge or in a catchment along the 25-mile downstream
flowpath as well as the minimum, average, and maximum distances to the impaired catchments from the
MPP discharge. Pathogens, nutrients, and oxygen depletion are the most common sources of new
impairments downstream of MPP direct discharges with 19 percent of direct dischargers with a new
pathogen impairment downstream, 14 percent with a new oxygen depletion impairment downstream, and
13 percent with a new nutrient impairment downstream.
Table 4-3: Direct Discharge Facilities with New Impairments by Parameter Group
Facilities with
Facilities with
Minimum
Average
Maximum
Receiving
Impairment
Distance to
Distance to
Distance to
Parameter
Group
Water
Downstream
Downstream
Downstream
Downstream
Impairment
(% of Direct
Impairment
Impairment
Impairment
(% of Direct
Discharge
Facilities)
Discharge
Facilities)
(miles)
(miles)
(miles)
Algal Growth
-
1 (1%)
16.61
20.80
24.20
Chlorine
-
-
8.32
8.32
8.32
Mercury
-
6 (4%)
0.26
12.60
27.35
Metals other
-
6 (4%)
0.28
12.04
25.34
than Mercury
Nutrients
-
20 (13%)
0.26
12.23
27.32
Oil & Grease
-
-
13.87
13.87
13.87
Other Cause
-
2 (1%)
1.37
10.60
24.96
Oxygen
1 (1%)
22 (14%)
0.34
11.08
35.05
Depletion
Pathogens
1 (1%)
29 (19%)
0.03
12.21
29.35
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Table 4-3: Direct Discharge Facilities with New Impairments by Parameter Group
Facilities with
Facilities with
Minimum
Average
Maximum
Receiving
Impairment
Distance to
Distance to
Distance to
Parameter
Group
Water
Downstream
Downstream
Downstream
Downstream
Impairment
(% of Direct
Discharge
Facilities)
(% of Direct
Discharge
Facilities)
Impairment
(miles)
Impairment
(miles)
Impairment
(miles)
pH/Acidity/Caus
-
0.26
9.89
24.96
tic Conditions
6 (4%)
Radiation
-
1 (1%)
0.37
10.38
25.34
Solids (Chlorides
-
11 (7%)
0.34
10.29
35.05
& Sulfates)
Toxic Inorganics
-
1 (1%)
0.37
7.85
23.03
Toxic Organics
-
-
1.37
5.42
13.78
Turbidity
-
10 (7%)
0.03
12.63
32.60
Unknown
-
15 (10%)
0.21
13.68
27.30
Impairment
Source: U.S. EPA Analysis, 2023
Pathogens, nutrients, and oxygen depletion are also the most common sources of new impairments
downstream of MPP indirect dischargers, with similar percentages of new impairments downstream of an
indirect discharger (19 percent with a new pathogen impairment downstream, 11 percent with a new
oxygen depletion impairment downstream, and 11 percent with a new nutrient impairment downstream).
Indirect dischargers have a greater diversity of new impairment pollutant groups for the receiving
catchments, which may be due to the greater number of indirect dischargers overall.
Table 4-4: Percentage of Indirect Discharge Facilities with New Impairments by Parameter Group
Parameter Group
Facilities with
Receiving Water
Impairment (% of
Indirect Discharge
Facilities)
Facilities with
Impairment
Downstream (% of
Indirect Discharge
Facilities)
Minimum
Distance to
Downstream
Impairment
(miles)
Average Distance
to Downstream
Impairment
(miles)
Maximum
Distance to
Downstream
Impairment
(miles)
Algal Growth
6 (0.3%)
58 (3.0%)
0.03
12.56
28.87
Chlorine
-
1 (0.1%)
1.16
5.40
8.32
Mercury
35 (2.0%)
183 (9.0%)
0.03
13.00
30.05
Metals other than
Mercury
27 (1.0%)
172 (9.0%)
0.03
11.79
28.32
Nutrients
28 (1.0%)
215 (11.0%)
0.01
11.50
33.55
Oil & Grease
4 (0.2%)
8 (0.4%)
0.01
7.91
25.18
Other Cause
2 (0.1%)
29 (1.5%)
0.12
12.18
26.92
Oxygen Depletion
28 (1.0%)
210 (11.0%)
0.01
10.93
31.07
Pathogens
79 (4.0%)
373 (19.0%)
0.01
11.97
34.71
pH/Acidity/Caustic
Conditions
6 (0.3%)
85 (4.0%)
0.09
12.54
35.65
Radiation
-
1 (0.1%)
0.48
14.04
27.01
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Table 4-4: Percentage of Indirect Discharge Facilities with New Impairments by Parameter Group
Parameter Group
Facilities with
Receiving Water
Impairment (% of
Indirect Discharge
Facilities)
Facilities with
Impairment
Downstream (% of
Indirect Discharge
Facilities)
Minimum
Distance to
Downstream
Impairment
(miles)
Average Distance
to Downstream
Impairment
(miles)
Maximum
Distance to
Downstream
Impairment
(miles)
Solids (Chlorides &
Sulfates)
7 (0.4%)
79 (4.0%)
0.05
11.37
29.14
Toxic Inorganics
4 (0.2%)
21 (1.0%)
0.48
13.15
35.65
Toxic Organics
15 (0.8%)
34 (2.0%)
0.05
11.33
28.78
Turbidity
7 (0.4%)
83 (4.0%)
0.03
12.39
33.55
Unknown
Impairment
11 (0.6%)
136 (7.0%)
0.01
12.65
34.86
Source: U.S. EPA Analysis, 2023
4.2.2 Fisheries
Discharges from MPP facilities can impact fisheries through reductions in water quality like low
dissolved oxygen and increased bacteria loading. Fish and shellfish are commercially harvested from
marine waters and, to a certain extent, in the Great Lakes. Commercial and recreational fishing and
shellfishing potentially affected by MPP discharges includes aquaculture leases for fish, crustaceans,
mollusks, and aquatic plants and recreational shellfishing areas along the Atlantic and Gulf Coasts with
MPP facilities discharging to the Albemarle Sound, Chesapeake Bay, Delaware Bay, and Gulf of Mexico.
Nutrient discharges from MPP facilities can cause eutrophication and the formation of HABs, which have
the potential to negatively impact both commercial and subsistence harvesting of fish and shellfish. HABs
have occurred in the Great Lakes and coastal areas across the country (Hoagland et al., 2002; Makarewicz
et al., 2006; Islam et al., 2004; Jin et al., 2008; V. L. Trainer et al., 2007; U.S. Environmental Protection
Agency, 2015a). HABs can cause fish kills, habitat loss leading to lower ecosystem carrying capacity,
losses of subsistence fishing, commercial fishery closures, increased costs of processing harvested
shellfish, and reduced consumer demand due to the perception of risk (Hoagland et al., 2002; Suddleson
et al., 2021; V. L. Trainer et al., 2007; U.S. Environmental Protection Agency, 2015a). Serving as an
illustrative example as there are not MPP dischargers in this area, subsistence fishers were heavily
impacted after the closure of a recreational razor clam fishery in 2003 due to domoic acid from HABs
throughout the Washington and Oregon coast (U.S. Environmental Protection Agency, 2015a).
Subsistence fishing may also be reduced due to bans on the harvesting of contaminated shellfish or
concerns related to the risk of shellfish poisoning caused by fecal bacteria.
Improved water quality due to reduced discharges of pollutants, specifically nutrients, from MPP
dischargers would enhance aquatic life habitat and potentially reduce the frequency of toxic HAB
formation. This has the potential to contribute to reproduction and survival of commercially harvested
species and larger fish and shellfish harvests and reduce the risk of shellfish poisoning, thereby benefiting
subsistence, commercial, and recreational fishers.
Table 4-5 summarizes potential impacts to commercially fished species" habitat ranges from 16 unique
direct MPP dischargers whose downstream path intersects with commercially fished species" habitat
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ranges.3" The table includes the number of MPP facilities that affect each species" habitat as well as a
summary of the distance from the closest discharge to the impacted habitat. One MPP direct discharger
has a commercially harvested oyster bed about seven miles downstream from its discharge location. The
expected reductions in pathogens, nutrients, and BOD from this rulemaking could improve the habitats of
these 25 commercially fished species and commercially harvested oyster, potentially resulting in
improvements in commercial fishing and harvesting opportunities. The minimum distance for the
majority of the potentially affected commercially fished species is less than four miles, suggesting that
these species are more likely to be affected by water quality improvements from the associated direct
dischargers. In particular, habitat ranges for coastal migratory pelagic species, red drum, reef fish, and
shrimp are located downstream from at least seven different MPP direct dischargers, some of which are
within three miles of the MPP discharge.
Table 4-5: Commercially Available Fish and Shellfish Species Potentially Impacted by Dischargers
Common Name
Minimum Distance (miles)
Number of Unique Direct
Dischargers
Atlantic Butterfish
0.97
4
Atlantic Herring
0.97
4
Black Sea Bass
0.97
5
Bluefish
0.97
6
Clearnose Skate
0.97
6
Coastal Migratory Pelagics
2.43
7
Little Skate
0.97
4
Longfin Inshore Squid
0.97
2
Monkfish
21.84
1
Oyster
6.95
1
Red Drum
2.43
7
Red Hake
0.97
4
Reef Fish
2.43
7
Sand Tiger Shark
3.90
3
Sandbar Shark
3.90
3
Scup
0.97
2
Shrimp
2.43
7
Silver Hake
21.84
1
Skipjack Tuna
3.90
1
Smoothhound Shark Complex (Atlantic Stock)
9.32
2
Snapper Grouper
0.76
3
Spiny Dogfish
21.84
1
Summer Flounder
0.97
6
Windowpane Flounder
0.97
5
Winter Skate
0.97
6
30 Commercial fishing impacts are based on the habitat ranges of commercially fished species because nationally consistent data
were not available for areas that are actively commercially fished.
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Table 4-5: Commercially Available Fish and Shellfish Species Potentially Impacted by Dischargers
Common Name
Minimum Distance (miles)
Number of Unique Direct
Dischargers
Yellowtail Flounder
21.84
1
Source: U.S. EPA Analysis, 2023
Table 4-6 summarizes potential impacts to federally owned recreational fishing areas from 11 unique
direct MPP dischargers whose downstream path intersects with federally owned recreational fishing
areas.31 The table includes the number of MPP facilities that affect the recreational areas as well as the
distance from the closest discharge to the potentially impacted areas. Of the 11 direct dischargers, three
also affect federally owned recreational shellfishing areas. Similar to the commercial fishing areas, the
expected reductions in pathogens, nutrients, and BOD from this rulemaking could improve the quality of
habitat in the recreational fishing and shellfishing areas and potentially increase opportunities for
recreational and subsistence fishing at these sites. In contrast to the commercially fished species" ranges
(less than four miles), the minimum distance for the majority of the potentially affected recreational
fishing and shellfishing areas is greater than four miles and there are fewer direct dischargers affecting
each recreational area. However, Bogue Chitto National Wildlife Refuge and Little River National
Wildlife Refuge are located within three miles downstream of at least one MPP direct discharger and
would likely see water quality improvements under the regulatory options.
Table 4-6: Federally Owned Recreational Areas Potentially Impacted by MPP Direct Dischargers
Unit Name
Fishing Type
Minimum Distance
(miles)
Number of Unique
Direct Dischargers
Bogue Chitto National Wildlife Refuge3
Both
1.68
2
Driftless Area National Wildlife Refuge
Finfish
8.67
1
Holla Bend National Wildlife Refuge
Finfish
6.49
1
Little River National Wildlife Refuge
Finfish
2.84
1
Meredosia National Wildlife Refuge
Finfish
13.06
1
Patoka River National Wildlife Refuge
Finfish
21.88
1
Port Louisa National Wildlife Refuge
Finfish
4.83
2
Prime Hook National Wildlife Refuge3
Both
16.87
1
St. Catherine Creek National Wildlife
Refuge
Finfish
16.35
1
3 These areas are also federally owned recreational shellfishing areas.
Source: U.S. EPA Analysis, 2023
4.2.3 Endangered Species Habitat and Protected Areas
For threatened and endangered species (T&E species), even minor changes to reproductive rates and
mortality may represent a substantial portion of annual population growth. Water pollution can also affect
T&E species indirectly by damaging food webs and decreasing ecosystem function and stability as a
whole. By reducing discharges of MPP facility pollutants to T&E habitats, the regulatory options have the
potential to improve the survivability of some T&E species living in these habitats. Due to the variation in
31 The recreational fisheries analysis only includes national wildlife refuges because data on state or local recreation areas used
for recreational fishing were not available nationally.
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life history and function of T&E species, reduced pollutant exposure do not necessarily guarantee
recovery success or maximum recovery. However, improvements in water quality through reduced
pollutant discharges has the potential to assist in recovery efforts by easing pollutant strain on T&E
species.
To assess the potential effects of the regulatory options on T&E species, EPA first compiled data on all
habitat ranges available for all species currently listed under the Endangered Species Act (ESA, 16 U.S.C.
1531-1544). Due to limitations on the available data and models necessary to quantitatively estimate
population changes due to the effects of the proposed rule, EPA identified and quantified the T&E species
whose habitat, and therefore wellbeing, may be impacted by the proposed rule. To do so, EPA obtained
the geographical distribution of T&E species from Environmental Conservation Online System
Threatened & Endangered Species Active Critical Habitat Report.32 This database includes only species
protected under the ESA. Additional species may be considered threatened or endangered by scientific
organizations, but are not protected by the ESA (e.g., the American Fisheries Society). EPA constructed a
screening database using the spatial data on species habitat ranges and all NHD reaches downstream from
directly discharging MPP facilities. Species upstream of MPP dischargers were also identified to account
for potential movement and other mechanisms in which effluent could affect species upstream of MPP
facilities. EPA identified 86 species upstream of MPP direct dischargers. Only one species, a flowering
plant, the Dwarf-flowered heartleaf (Hexastylis naniflora), occurred upstream of a facility but did not also
occur downstream. This database included all T&E species whose habitat ranges intersect reaches
immediately receiving or downstream of directly discharging MPP facilities. The initial analysis
identified a total of 112 T&E species. During the time of this analysis, the U.S. Fish & Wildlife service
published a final rule delisting 21 species from the ESA due to extinction (U.S. Fish & Wildlife Service,
2023). Of these delisted species, four species of bivalves initially included in this analysis, the green
blossom (Epioblasma torulosa gubernaculum), tubercle blossom (Epioblasma torulosa torulosa), turgid
blossom (Epioblasma turgidula), and upland combshell (Epioblasma metastriata), are no longer included
in the results due to their removal from the ESA. Appendix C: Summary of Threatened and Endangered
Species contains a full list of all T&E species identified in the analysis.
EPA then classified these species according to their potential vulnerability to water pollution based on a
review of the species life history data. For the purpose of this analysis, species were classified as follows:
Higher vulnerability - species living in aquatic habitats for several life history stages and/or species
that obtain a majority of their food from aquatic sources.
Moderate vulnerability - species living in aquatic habitats for one life history stage and/or species that
obtain some of their food from aquatic sources.
Lower vulnerability - species whose habitats overlap bodies of water, but whose life history traits and
food sources are terrestrial.
32 https://ecos.fws.gov/ecp/report/table/critical-habitat.html
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Threatened and endangered species vulnerability was based on aquatic life stages or food sources. Other
ecological mechanisms, additional threats to T&E species, and population parameters of the species
themselves are not factored into the evaluation of species vulnerability.
Table 4-7 summarizes the numbers of species within each group and vulnerability class. There are 108
total species included in this analysis, with the majority (75) of those species having a higher vulnerability
to water quality impacts. Bivalves and fishes make up over half of the number of species potentially
affected by the proposed rule and both have a higher vulnerability to water quality impacts.
Table 4-7: Threatened and Endangered Species Groups with Vulnerability Status
Group
Vulnerability
Species Count
Lower
Moderate
Higher
Amphibians
1
1
2
4
Birds
6
3
0
9
Bivalves
0
0
45
45
Crustaceans
0
0
3
3
Fishes
0
0
15
15
Insects
4
0
0
4
Mammals
7
1
1
9
Reptiles
10
0
6
16
Snails
0
0
3
3
Totals
28
5
75
108
Source: U.S. EPA Analysis, 2023
The high vulnerability species are most likely to benefit from the water quality improvements associated
with the proposed rule as they live in aquatic habitats for several life stages or obtain a majority of their
food from aquatic sources. For this reason, EPA focused on these species for a more detailed presentation
of the species potentially benefiting from water quality improvements under the regulatory options. Table
4-8 provides a list of the high-vulnerability species along with the river miles affected by MPP direct
discharges that intersect their habitat and the distance between the T&E species habitat and the closest
upstream direct discharger. The Agency notes that while the more detailed presentation focuses on the
subset of high-vulnerability species, water pollution may also be a factor in the decline and recovery of
species with moderate or lower vulnerability.
Table 4-8: Higher Vulnerability Threatened and Endangered Species Potentially Impacted by MPP Direct
Dischargers
Common Name
Scientific Name
Group
River Miles
of Habitat
Minimum Distance
(miles)
Rabbitsfoot
Quadrula cylindrica
cylindrica
Bivalves
358.23
0.87
Bog turtle
Glyptemys muhlenbergii
Reptiles
339.96
0.81
Gulf sturgeon
Acipenser oxyrinchus
(=oxyrhynchus) desotoi
Fishes
229.83
0.81
Sheepnose Mussel
Plethobasus cyphyus
Bivalves
224.86
0.56
Spectaclecase (mussel)
Cumberlandia monodonta
Bivalves
217.59
0.36
Snuffbox mussel
Epioblasma triquetra
Bivalves
195.36
0.61
Scaleshell mussel
Leptodea leptodon
Bivalves
172.85
0.06
Ouachita rock pocketbook
Arcidens wheeleri
Bivalves
158.03
2.08
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Table 4-8: Higher Vulnerability Threatened and Endangered Species Potentially Impacted by MPP Direct
Dischargers
Common Name
Scientific Name
Group
River Miles
of Habitat
Minimum Distance
(miles)
Ringed map turtle
Graptemys oculifera
Reptiles
137.39
0.92
Clubshell
Pleurobema clava
Bivalves
130.61
1.04
Fat pocketbook
Potamilus capax
Bivalves
123.45
2.10
Pallid sturgeon
Scaphirhynchus albus
Fishes
109.71
6.13
Pink mucket
(pearlymussel)
Lampsilis abrupta
Bivalves
102.50
0.87
Black warrior (=Sipsey
Fork) Waterdog
Necturus alabamensis
Amphibians
100.87
0.58
Flattened musk turtle
Sternotherus depressus
Reptiles
100.87
0.58
Southern clubshell
Pleurobema decisum
Bivalves
99.45
0.87
Ovate clubshell
Pleurobema perovatum
Bivalves
98.26
0.58
Southern Sandshell
Hamiota australis
Bivalves
90.74
0.46
Tapered pigtoe
Fusconaia burkei
Bivalves
89.79
0.46
Choctaw bean
Obovaria choctawensis
Bivalves
89.79
0.46
Fuzzy pigtoe
Pleurobema strodeanum
Bivalves
89.79
0.46
Southern kidneyshell
Ptychobranchus jonesi
Bivalves
89.79
0.46
Madison Cave isopod
Antrolana lira
Crustaceans
89.00
0.41
Higgins eye (pearlymussel)
Lampsilis higginsii
Bivalves
88.76
0.36
West Indian Manatee
Trichechus manatus
Mammals
83.81
1.01
Fanshell
Cyprogenia stegaria
Bivalves
76.97
1.04
Inflated heelsplitter
Potamilus inflatus
Bivalves
69.75
2.53
Slabside Pearlymussel
Pleuronaia dolabelloides
Bivalves
65.86
0.61
Orangefoot pimpleback
(pearlymussel)
Plethobasus cooperianus
Bivalves
58.78
1.04
Topeka shiner
Notropis topeka (=tristis)
Fishes
56.39
2.20
Triangular Kidneyshell
Ptychobranchus greenii
Bivalves
55.50
0.58
Littlewing pearlymussel
Pegiasfabula
Bivalves
52.88
0.61
Rush Darter
Etheostoma phytophilum
Fishes
50.90
0.58
Orangenacre mucket
Hamiota perovalis
Bivalves
50.90
0.58
Cahaba shiner
Notropis cahabae
Fishes
50.90
0.58
Alabama moccasinshell
Medionidus acutissimus
Bivalves
49.99
0.58
American alligator
Alligator mississippiensis
Reptiles
49.81
1.65
Dark pigtoe
Pleurobema furvum
Bivalves
47.86
2.08
Winged Mapleleaf
Quadrula fragosa
Bivalves
47.39
2.84
Rough pigtoe
Pleurobema plenum
Bivalves
42.03
2.10
Yellow-blotched map turtle
Graptemys flavimaculata
Reptiles
39.31
0.45
Pearl darter
Percina aurora
Fishes
37.38
1.03
Rayed Bean
Villosa fabalis
Bivalves
35.36
1.08
Ring pink (mussel)
Obovaria retusa
Bivalves
33.32
1.04
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4: Environmental Effects
Table 4-8: Higher Vulnerability Threatened and Endangered Species Potentially Impacted by MPP Direct
Dischargers
Common Name
Scientific Name
Group
River Miles
of Habitat
Minimum Distance
(miles)
Curtis pearlymussel
Epioblasma florentina curtisii
Bivalves
27.44
0.87
Leopard darter
Percina pantherina
Fishes
27.07
11.25
Relict darter
Etheostoma chienense
Fishes
26.67
0.69
Peppered chub
Macrhybopsis tetranema
Fishes
26.39
5.27
Copperbelly water snake
Nerodia erythrogaster
neglecta
Reptiles
25.36
2.04
Neosho Mucket
Lampsilis rafinesqueana
Bivalves
25.25
5.29
Plicate rocksnail
Leptoxis plicata
Snails
23.56
14.30
Slenderclaw crayfish
Cambarus cracens
Crustaceans
20.82
0.92
Suwannee moccasinshell
Medionidus walkeri
Bivalves
19.03
8.45
Bull trout
Salvelinus confluentus
Fishes
18.70
12.92
Finelined pocketbook
Hamiota altilis
Bivalves
16.76
14.68
Cape Fear shiner
Notropis mekistocholas
Fishes
16.15
0.78
Fluted kidneyshell
Ptychobranchus subtentus
Bivalves
15.68
6.70
Oval pigtoe
Pleurobema pyriforme
Bivalves
15.52
7.86
Bayou darter
Etheostoma rubrum
Fishes
14.80
1.39
Southern pigtoe
Pleurobema georgianum
Bivalves
14.70
15.67
Roanoke logperch
Percina rex
Fishes
12.37
3.39
Dromedary pearlymussel
Dromus dromas
Bivalves
12.04
1.07
Birdwing pearlymussel
Lemiox rimosus
Bivalves
9.35
1.07
Snail darter
Percina tanasi
Fishes
9.35
1.07
Cumberland monkeyface
(pearlymussel)
Theliderma intermedia
Bivalves
9.35
1.07
Shiny pigtoe
Fusconaia cor
Bivalves
8.06
1.02
Gulf moccasinshell
Medionidus penicillatus
Bivalves
7.86
7.86
Painted rocksnail
Leptoxis taeniata
Snails
7.86
24.66
Anthony's riversnail
Athearnia anthonyi
Snails
5.58
16.67
Finerayed pigtoe
Fusconaia cuneolus
Bivalves
5.58
16.67
Yellowfin madtom
Noturus flavipinnis
Fishes
5.58
16.67
Ozark Hellbender
Cryptobranchus alleganiensis
bishopi
Amphibians
4.10
14.24
Oyster mussel
Epioblasma capsaeformis
Bivalves
0.83
16.67
Atlantic pigtoe
Fusconaia masoni
Bivalves
0.24
8.71
Benton County cave
crayfish
Cambarus aculabrum
Crustaceans
0.08
1.14
Source: U.S. EPA Analysis, 2023
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4: Environmental Effects
The average minimum distance from an MPP facility to the habitat of a threatened or endangered species
is slightly over three miles. Approximately 59 percent of direct dischargers are upstream from a highly
vulnerable species habitat.33
The majority of the higher vulnerability species impacted by MPP direct dischargers are bivalves (45 of
75 total species) and of the top 10 species with the largest number of habitat catchments downstream of
MPP facilities, seven are bivalve species. Bivalves fulfill vital ecological roles as ecosystem engineers
(Hancock et al., 2019). Freshwater bivalves are crucial filter feeders, removing metals, sediment, excess
nutrients, and bacteria from surrounding water (Upper Midwest Environmental Sciences Center, 2020).
Healthy populations of freshwater bivalves help improve water quality and overall river/lake health by
improving habitat for other aquatic invertebrates as well as finfish. Species in which pollutants
bioaccumulate may face detrimental or lethal effects at lower pollution levels overtime. For example,
bivalves feed by filtering large amounts of water and face extended exposure to pollutants over longer
time spans compared to other species. As a result, populations of these species may suffer over time as
negative effects of chronic exposure add up. Such cumulative effects on these species could further
negatively impact local ecosystems by disrupting the filtering function provided by bivalves (Hancock et
al., 2019).
Several ecologically and culturally important species inhabit waters downstream of MPP dischargers and
face increased conservation risks resulting from MPP effluent in addition to other factors contributing to
their conservation. Keystone species are species that have a disproportionate impact on the ecosystems in
which they inhabit, and whose removal would have widespread implications on the ecosystem as a whole.
Important keystone species potentially impacted by MPP facility discharge is the American Alligator
(Alligator mississippiensis) and various bivalve species (National Wildlife Federation, n.d.; National
Wildlife Health Center, 2019). American alligators are ecologically important predators that help
maintain balanced prey populations. They also create habitat for various other species by creating
burrows that are used by other species for shelter, breeding, and water (National Wildlife Federation,
n.d.). Bivalves are also ecologically important, serving as filterers that remove contaminants from the
surrounding water. Two of the four higher-vulnerability species with the greatest overlap between their
habitat and catchments downstream of MPP direct dischargers are both bivalves: the Sheepnose mussel
(Plethobasus cyphyus) and Rabbitsfoot (Quadrula cylindrica cylindrica). The Sheepnose mussel faces
additional risk due to the cumulative impact of multiple facilities discharging throughout its range. As
many as 17 different MPP direct dischargers release wastewater to various Sheepnose mussel habitat
areas, while 16 different direct dischargers release wastewaters to various Rabbitsfoot habitat areas. As
important ecosystem engineers, impacts to bivalves such as these two species will create further
detrimental impacts on a wide variety of other species that rely on them. MPP direct dischargers also have
potential impacts to indicator species like the Bog turtle (Glyptemys muhlenbergii), which serve as
indicators of the overall health of mountain bogs in the eastern United States. This habitat type is in rapid
decline and supports other endangered species and migratory birds (The Nature Conservancy, 2020).
Wastewater from 15 distinct MPP direct dischargers impacts the range of habitat for G. muhlenbergii.
Accumulation of effluent from numerous dischargers could pose heightened risk to Bog turtles, which
33 EPA also conducted the analysis for lower and moderately vulnerable species. Approximately 50 percent of MPP direct
discharge facilities are upstream of a moderate vulnerability species, and approximately 94 percent (nearly the entire MPP
universe of direct dischargers) are upstream of a lower vulnerability species habitat.
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4: Environmental Effects
utilize aquatic habitats for feeding and reproduction (U.S. Fish & Wildlife Service, 2022). The West
Indian Manatee (Trichechns manatus) also faces potential impacts from MPP direct dischargers and is an
economically important keystone and flagship species commonly used as a symbol of megafauna
conservation and coastal conservation efforts. As a large, charismatic species, manatees drive ecotourism
in coastal areas, such as Florida, and help manage aquatic vegetation, such as hydra, in their environment
(Solomon et al., 2004). In addition to revenue from ecotourism, the natural control of aquatic vegetation
mitigates the need to spend money manually dredging waterways to remove aquatic vegetation (Solomon
et al., 2004).
4.2.4 Priority Wa ter Bodies
Discharges from MPP facilities can impact the water quality and aesthetic (e.g., clarity, odor) of priority
water bodies. EPA conducted an analysis to determine which MPP facilities directly affect priority water
bodies. EPA identified priority water bodies, or water bodies with national significance, as the
Chesapeake Bay, the Great Lakes, National Wild and Scenic Rivers, areas included in the National
Estuary Program, or a marine coastal water.34 Any direct discharge facility with a downstream flowpath35
that intersected a priority water body boundary is deemed to have an influence on that water body for the
purposes of this analysis. Table 4-9 summarizes the number of MPP facilities that affect priority waters.
There are 17 unique facilities that affect priority waters, representing a relatively small proportion of MPP
direct dischargers (ten percent). There are eight MPP direct dischargers that affect marine coastal waters.
The average minimum distance from a discharger to any priority water body is around four miles
although two MPP direct dischargers are within two miles of a marine coastal water and five MPP direct
dischargers are within one mile of a National Estuary Program water.36 The expected reductions in
nutrients and pathogens from this rulemaking may reduce the incidence of HABs, oxygen depletion, and
other negative water quality and aesthetic impacts which may improve the quality and aesthetics of these
priority water bodies.
Table 4-9: Priority Water Bodies Impacted by MPP Direct Dischargers
Priority Water
Minimum Distance (miles)
Number of Dischargers
Chesapeake Bay
7.7
1
Great Lakes
8.3
3
Marine
1.0
8
National Estuary Program
0.1
10
Source: U.S. EPA Analysis, 2023
4.2.5 Recreational Areas
Discharges from MPP facilities can impact recreational uses of water bodies through reductions in water
quality and changes to aesthetics (e.g., water clarity and odor). For example, impacts from nitrates,
phosphorus, E. coli, and fecal coliforms to contact recreation areas are highlighted in the Black Warrior
River Keeper's comment letter regarding the 2019 draft NPDES permit for the Tyson Blountsville facility
34 The boundaries for Wild and Scenic rivers are provided by the US Forest Service (https://www.rivers.gov/). The boundaries for
the Great Lakes were taken from the Great Lakes Commission (https://www.glc.org/greatlakesgis). The boundaries for the
Chesapeake Bay were taken from the Chesapeake Bay TMDL segments (https://data-
chesbay.opendata.arcgis.com/datasets/9631adafc6f64165ac27b6a758fe7edc_25/about). Shoreline boundaries for marine
waters were taken from NOAA's medium resolution shoreline (https://shoreline.noaa.gov/data/datasheets/medres.html)
35 Hie downstream flowpath distance is set to 25 river miles, based on distances of fish kills from discharge locations.
30 No MPP direct dischargers discharge to a Wild and Scenic River.
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
4: Environmental Effects
(Black Warrior Riverkeeper, 2019). To determine the potential impacts to recreational areas, EPA used
the USGS's Protected Areas Database (PAD)37. PAD is a national inventory of terrestrial and marine
protected areas relating to the preservation of natural, recreational, and cultural uses, which is compiled at
a national level.38 EPA reviewed the domain types included in the PAD dataset to identify areas within
the dataset have applicable recreational uses. Table 4-10 lists the descriptions of the areas deemed to have
recreational uses along with the number of unique dischargers to those areas and distance summaries.
Approximately 92 percent of MPP direct dischargers affect an area with potential for recreation. Local
parks, conservation easements, and state conservation areas have the highest number of unique
dischargers affecting them, indicating a large overlap between the location of MPP direct dischargers and
these recreation area types. Local parks include riverfronts, golf courses, and athletic facilities like
baseball fields. State conservation areas include wildlife management areas, historic landmark areas, and
hunting grounds. Conservation easements include restored natural areas, emergency watershed protection
areas, and reserves designated for hunting purposes through wildlife conservation organizations like
Ducks Unlimited. The average minimum distance from an MPP discharger to a PAD area is 6.07 miles,
although 27 recreational areas have dischargers less than a mile upstream, 15 of which are local parks. At
that distance, the discharge could influence recreational activities at the associated recreational areas, such
as beach closures due to high in-stream bacterial counts. The Dardanelle Recreation Area and Dardanelle
Lake, near Little Rock, Arkansas, stand out as particularly susceptible to impacts from MPP direct
dischargers. Dardanelle Recreation Area receives wastewater from four distinct MPP direct dischargers.
Lake Dardanelle sustains robust recreational fisheries, as well as popular picnic, camping, and boating
amenities (U.S. Army Corps of Engineers, 2023). The compounding effect of multiple sources of effluent
could lead to increased damage to aquatic ecosystems and increased human exposure to pollutants during
recreational activities.
Table 4-10: PAD Areas Impacted by MPP Direct Dischargers
Domain Description
Number of Dischargers
Minimum Distance (miles)
Conservation Area
3
7.12
Conservation Easement
65
0.85
Federal Other or
Unknown Designation
2
16.83
Forest Stewardship Easement
1
22.74
Historic or Cultural Area
5
16.56
Historic or Cultural Easement
6
6.17
Local Conservation Area
18
2.77
Local Other or Unknown
7
3.06
Local Park
77
0.16
Local Recreation Area
31
3.75
Local Resource Management Area
2
2.35
Marine Protected Area
2
8.26
National Forest
8
2.32
National Public Lands
4
7.71
National Recreation Area
1
23.63
National Wildlife Refuge
16
1.68
Native American Land Area
9
2.84
Private Conservation
17
2.88
37 https://www.usgs.gov/programs/gap-analysis-project/science/protected-areas
38 The PAD but may not include all local or state-owned public lands.
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs 4: Environmental Effects
Table 4-10: PAD Areas Impacted by MPP Direct Dischargers
Domain Description
Number of Dischargers
Minimum Distance (miles)
Private Other or Unknown
2
16.75
Private Park
7
0.97
Private Recreation or Education
10
3.57
Recreation Management Area
13
0.06
Recreation or Education Easement
4
2.28
Research or Educational Area
1
16.87
Resource Management Area
7
0.69
Special Designation Area
2
6.40
State Conservation Area
51
0.44
State Historic or Cultural Area
3
1.30
State Other or Unknown
8
0.03
State Park
15
1.46
State Recreation Area
21
0.27
State Resource Management Area
30
1.27
Wilderness Study Area
2
16.11
Source: U.S. EPA Analysis, 2023
4.2.6 Potential Improvements to Water Quality within Sensitive Environments
The regulatory options are expected to reduce pollutant loadings associated with nutrients (nitrogen and
phosphorus), TSS, oil and grease, and BOD. Improved water quality due to reduced discharges of
pollutants from MPP dischargers has the potential to improve sensitive environments downstream of
these dischargers. To assess the potential effect of this rule on sensitive environments, EPA first identified
MPP direct dischargers with expected load reductions and then identified any downstream sensitive
environments from those dischargers (Table 4-11). EPA assumed that all sensitive environments
downstream from any facility with load reductions would see improvements for the purposes of this
analysis.
Table 4-11: Summary of Potential Improvements to Water Quality within Sensitive Environments
Types of Sensitive Environments
Affected Sensitive Environments Under the
Regulatory Options (Count and Percentage)
Option 1
Option 2
Option 3
Number of Recreational Areas with Improvements
448 (58%)
448 (58%)
493 (64%)
Number of T&E Species with Improved Habitat
95 (88%)
95 (88%)
97 (90%)
Number of Priority Waterbodies with Improvements
3 (75%)
3 (75%)
3 (75%)
Number of Tribes in General Proximity to Waters with
Improvements
8 (11%)
12 (17%)
23 (33%)
Number of Tribes with Improvements to Potential
Subsistence Fishing Areas
34 (69%)
34 (69%)
34 (69%)
Number of Commercially Fished Species with Improved
Habitat
24 (96%)
24 (96%)
24 (96%)
Number of Aquaculture Areas with Improvements
0 (0%)
0 (0%)
0 (0%)
Number of Federal Recreational Fishing Areas
with Improvements
6 (67%)
6 (67%)
6 (67%)
Total Stream Miles of Impaired Waters with
Improvements Downstream of Direct Dischargers
925.45 (63%)
925.45 (63%)
963.70 (66%)
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs 4: Environmental Effects
Table 4-11: Summary of Potential Improvements to Water Quality within Sensitive Environments
Types of Sensitive Environments
Affected Sensitive Environments Under the
Regulatory Options (Count and Percentage)
Option 1
Option 2
Option 3
Total Stream Miles of Impaired Waters with
Improvements Downstream of Indirect Dischargers
130.07 (1%)
700.23 (6%)
3,462.40 (29%)
Source: U.S. EPA Analysis, 2023
The number of priority waterbodies, fishing areas potentially used for subsistence fishing by tribes39,
commercially fished species" habitat, aquaculture areas, and federal recreational fishing areas do not
change under the various regulatory options. The number of recreational areas, threatened and endangered
species" habitat, and impaired waters downstream of direct dischargers with improvements increases
slightly under regulatory option three but are the same between regulatory options 1 and 2. The number of
tribes in general proximity to waters with improvements and impaired waters downstream from indirect
dischargers with reduced pollutant loads increases between each regulatory option.
4.2.7 Limita tions and Uncertainty
The methodologies and data used in the estimation of the sensitive environments potentially affected by
the regulatory options involve limitations and uncertainties. Table 4-11 summarizes the limitations and
uncertainties and indicates the direction of the potential bias. Uncertainties associated with some of the
input data are covered in greater detail in other documents.
Table 4-12: Limitations and Uncertainties in Estimating Sensitive Environments Affected by the Regulatory
Options
Uncertainty/Limitation
Effect on Water Quality
Effects Estimation
Notes
Use of the full universe of
To the extent that some options affect a
affected reaches without
Overestimate
smaller universe of reaches, then benefits are
differentiation between
overstated by using the full universe in
regulatory options
relevant analyses.
The connection between indirect dischargers
and the POTWs those facilities send their
wastewater to were not explicitly defined. EPA
assumed that indirect discharger locations
Downstream path for indirect
were a good proxy for the location of
dischargers were generated from
associated POTW outfalls and generated the
the facility location rather than
downstream flowpath from the facility
the receiving POTW location
Uncertain
location rather than the POTW location.
In some cases, the varying stream segment
lengths in the NHD dataset meant that the
terminal stream segment length exceeds the
Variation in 25-mile downstream
25-mile target length. In these cases, the
path based on varying NHD
length of the flowpath potentially
stream segment lengths
Overestimate
overestimates impacts.
39 Potential impacts to tribes and tribally owned lands are discussed in Section 7.5.
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4: Environmental Effects
Table 4-12: Limitations and Uncertainties in Estimating Sensitive Environments Affected by the Regulatory
Options
Uncertainty/Limitation
Effect on Water Quality
Effects Estimation
Notes
Use of National Wildlife Refuges
data in place of consistent state
or local data
Underestimate
The recreational fisheries analysis only
includes national wildlife refuges because data
on state or local wildlife/recreation areas used
for recreational fishing was not available
nationally. As a result, impacts are likely
underestimated as state and local areas are
not assessed
Definition of T&E species
vulnerability
Uncertain
Threatened and endangered species
vulnerability was based on aquatic life stages
or aquatic food utilization. Other ecological
mechanisms, additional threats to T&E
species, and population parameters of these
species themselves are not factored into the
evaluation of species vulnerability.
Change in T&E species
populations in response to the
regulatory options
Uncertain
Data and models necessary to quantitatively
estimate population changes are unavailable.
Therefore, EPA used the methodology
described in Section 4.2.3 as a screening-level
analysis to estimate whether the regulatory
options could contribute to a change in the
habitat and recovery of T&E species
populations.
Only those T&E species listed as
threatened or endangered under
the ESA are included in the
analysis
Underestimate
The databases used to conduct this analysis
include only species protected under the ESA.
Additional species may be considered
threatened or endangered by scientific
organizations, but are not protected by the
ESA [e.g., the American Fisheries Society).
Use of commercial fish habitat
data in place of commercial
fishing areas
Overestimate
Commercial fishing impacts are based on the
habitat ranges of commercially fished species
because data was not available for areas that
are actively commercially fished. This
methodology may overestimate the impacts to
commercial fishing areas.
Use of USGS PAD data in place of
consistent state or local data
Underestimate
The impacts to recreational areas are based on
USGS' PAD dataset which is compiled at a
national level, but may not include all local or
state-owned public lands. This methodology
may underestimate the impacts to public
recreational areas.
Assumption of universal
improvements downstream of
any facility with loadings changes
Overestimate
In the potential improvements to water
quality analysis, EPA assumes that any
sensitive environment downstream from a
discharger with loadings changes will improve.
This likely overestimates the impacts of the
loading changes.
Source: U.S. EPA Analysis, 2023
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5: Human Health Effects
5 Human Health Effects from Changes in Pollutant Exposure
Pollutants present in MPP wastewater discharges and covered under the ELG (e.g., pathogenic E. coli,
nitrogen, and phosphorus) can cause a variety of adverse human health effects. EPA expects the
regulatory options to reduce human health risk by reducing pollutant discharges to surface waters and the
resulting ambient pollutant concentrations in the receiving and downstream reaches. This will help to
reduce human exposure to MPP pollutants in surface water via three exposure pathways: (1) primary
contact recreation in waters affected by MPP discharges, (2) consumption of drinking water sourced from
surface waters affected by MPP discharges, and (3) consumption of shellfish taken from waters affected
by MPP discharges. EPA was unable to estimate baseline pollutant exposure relevant to human health or
changes in levels of pollutant exposure due to limitations of the available data and models. As a result,
this section qualitatively describes the anticipated human health effects of the regulatory options,
informed by the overlap between reaches affected by MPP discharges and population exposure pathways.
When discussing populations exposed to pollutant exposure via the three exposure pathways, EPA has
considered all individuals potentially impacted by MPP discharges, but they do not differentiate between
regulatory options in terms of the scope of affected waters or the degree of improvements to those waters.
5.1 Pollutant Exposure via Recreation
Untreated bacteria and pathogens from MPP direct dischargers may affect the safety of surface water used
for primary contact recreation. The proposed rule requests comment on adding E. coli as a regulated
pollutant (to be used as an indicator for proper disinfection) for MPP direct dischargers. This regulatory
change may lead MPP direct dischargers to better disinfect their wastewater and reduce the risk of human
exposure to E. coli and other pathogenic microorganisms; this, in turn, may lead to the avoidance of
pathogenic E. co/z-related health effects.
HABs, which can develop in response to excess nutrients (e.g., nitrogen and phosphorus) may also be of
concern. The regulatory options would lead to reductions in nutrients loadings from MPP facilities and, as
a result, reduced occurrence of HABs and incidence of HAB-related illnesses.
5.1.1 Popula tion in Scope of the Analysis
The populations most likely to be affected by reduced pollutant exposure via recreation are those that visit
affected recreational areas and priority water bodies (Section 4.1). Approximately 204 million people live
within 100 miles of a recreational area potentially impacted by an MPP direct discharger. The 100-mile
buffer was chosen based on an approximate two-hour drive to recreational areas surrounding affected
waters, identified by Viscusi et al. (2008).40
5.1.2 Level of Exposure
The level of pollutant exposure is dependent on the type of recreation. EPA's Water Quality Standards
Handbook classifies recreational uses into primary contact and secondary contact recreation (U.S. EPA,
2017). Primary contact recreation involves the potential for ingestion of, or immersion in, water and
includes activities like swimming and surfing. Secondary contact recreation is when immersion is
40 This buffer distance may underestimate the potentially exposed population as it does not account for national travel to
landmark recreational areas.
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unlikely and includes activities like boating and paddling. Populations that partake in primary contact
recreation will have a higher level of pollutant exposure than those partaking in secondary contact
recreation or without any direct contact with water.
5.1.3 Health Effects from Changes in Pollutant Exposure via Recreation
If ingested during primary contact recreation, pathogens associated with poultry and livestock (e.g.,
Salmonella, enterococci, E. coli, Campylobacter sp., and Cryptosporidium sp.) can cause adverse health
effects (U.S. EPA, 2009b). These pathogens can cause gastrointestinal illness and lead to symptoms such
as diarrhea, abdominal pain, nausea, chills, and fever. Exposure to harmful HAB toxins through primary
and secondary contact recreation (i.e., ingestion and inhalation) can cause skin rashes, liver and kidney
damage, neurological issues, gastrointestinal symptoms or respiratory problems (Backer, 2002; World
Health Organization, 2021). There is also evidence that populations can be exposed to toxins from HABs
via inhalation just from being in close proximity to affected waters without any direct (primary or
secondary contact) contact with the water (Schaefer et al., 2020).
5.2 Pollutant Exposure via the Drinking Water Pathway
Pollutants discharged by MPP dischargers to surface waters may affect the quality of water used for
public drinking water supplies. This can be due to the pollutants not being removed adequately during
treatment at drinking water treatment plants and/or the formation of disinfection byproducts (DBPs) when
contaminants in the source water interfere or react during drinking water treatment. People may then be
exposed to either the pollutants or DBPs in treated water through ingestion, potentially incurring adverse
health effects. Human health effects of DBPs are described in more detail in Chapter 2. The regulatory
options would reduce discharges of nitrogen, reducing the formation of harmful DBPs. Additionally, EPA
is requesting comment on additional effluent limitations for E. coli, which may lead to improved
disinfection at MPP direct dischargers, preventing E. coli contamination.
5.2.1 Popuia tion in Scope of the Analysis
EPA determined that 198 different Public Water Systems (PWS) would be affected by the regulatory
options, including 41 PWS with surface water intakes downstream from MPP facilities directly
discharging into surface water (directly affected PWS), 150 PWS that purchase water from the 41 directly
affected PWS (indirectly affected PWS), and 7 PWS with surface water intakes downstream from
facilities directly discharging into surface water and that purchase water from a direct intake facility
("both" affected PWS).
EPA used a tiered combination of the U.S. Community Water Systems Service Boundaries, v2.4.0
(CWSSB)41, zip code tabulation areas (ZTCAs), and county boundaries to identify service areas for PWS.
Appendix E: Use of the Community Water Systems Service Boundaries Dataset provides additional
information on the use of these datasets. The 97 different PWS serve approximately 1,450,000 people,
across 19 states.
41 https://www.hydroshare.org/resource/bllb8982eebd4843833932fD85f71d92/
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5.2.2 Health Effects from Changes in Pollutant Exposure via the Drinking Water Pathway
Exposure to high levels of nitrogen in drinking water can lead to infant methemoglobinemia, colorectal
cancer, thyroid disease, and neural tube defects (Ward et al., 2018; U.S. Environmental Protection
Agency, 2000). Eutrophication (due to nutrient enrichment) and dense algae can lead to the formation of
trihalomethanes as DBPs. Trihalomethanes are carcinogenic compounds that can pose a serious threat to
human health if consumed (U.S. Environmental Protection Agency, 2000). Human exposure to E. coli
through inadequate disinfection of drinking water can lead to adverse health effects such as abdominal
cramps, vomiting, diarrhea, and fever (U.S. Environmental Protection Agency, 2009a).
5.3 Pollutant Exposure via the Shellfish Consumption Pathway
Pollutants discharged by MPP facilities may affect human health through the consumption of
contaminated shellfish and, to a potentially lesser degree, contaminated fish. The regulatory options may,
through reductions in nutrient discharges at MPP facilities, prevent human exposure to contaminated
shellfish and reduce the incidence of shellfish-borne illness.
5.3.1 Popuia tion in Scope of the Analysis
The populations most likely to be affected by reduced pollutant exposure via the shellfish consumption
pathway are those that visit and fish within recreational and commercial fishing areas. EPA found that 16
percent of MPP direct dischargers discharged to 11 recreational and 16 commercial fishing/shellfishing
areas. Approximately 36 million people live within 100 miles (atypical driving distance for a one-day
recreational trip) of the 11 recreational shellfishing locations.42
5.3.2 Level of Exposure
The level of pollutant exposure is dependent on fish ingestion rates for different subpopulations. Several
studies have reported incidents of shellfish poisoning among subsistence fishers (Adams et al., 2016;
Kibler et al., 2022; V. Trainer et al., 2014). Subsistence fishers are more susceptible to shellfish poisoning
due to higher consumption rates of self-caught fish and shellfish and lowered awareness of shellfish bed
closures and consumption advisories. For example, subsistence harvesting of shellfish is common in
coastal Alaska (Ouzinkie, Kodiak, and Old Harbor) despite paralytic shellfish poisoning risks due to
recurrent toxic Alexandrium blooms (Kibler et al., 2022).43 Among these locations, paralytic shellfish
poisoning incidents were found to be three times higher for residents of Old Harbor compared to Kodiak
due, in part, to differences in exposure to advisory information. In addition, according to EPA's Exposure
Factors Handbook (U.S. Environmental Protection Agency (U.S. EPA), 2015), different race groups may
consume self-caught fish and shellfish at different rates.
5.3.3 Health Effects from Changes in Pollutant Exposure via the Fish Consumption Pathway
Phosphorus discharged by MPP facilities can stimulate survival and reproduction of fecal bacteria in
aquatic ecosystems, which can pollute shellfish beds and lead to shellfish-borne diseases (Michael A
Mallin et al., 2020; Oliveira et al., 2011; Wittman et al., 1995). Additionally, fish and shellfish that feed
42 EPA assumed that individuals living in proximity to recreational fishing/shellfishing areas would be most likely to consume
shellfish from the associated recreational area. The assumption was not made for commercial fishing/shellfishing areas as
radial proximity would not likely translate to consumption.
43 The toxic Alexandrium blooms were not linked to MPP discharges.
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on some algal species of HABs can accumulate potent toxins, resulting in paralytic, diarrhetic, amnesic,
or neurotoxic shellfish poisoning (Hoagland et al., 2002; U.S. Environmental Protection Agency, 2015b).
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6 Non-Water Quality Effects
The proposed rule focuses on implementing limits on MPP wastewater discharges, but the regulatory
options are also expected to have direct and indirect non-water quality effects based on changes to
wastewater management practices. The elimination or reduction of one form of pollution may create or
aggravate other environmental problems. Sections 304(b) and 306 of the Clean Water Act require EPA to
consider non-water quality environmental impacts (including energy requirements) associated with ELGs.
EPA expects the regulatory options to affect air pollution, directly through changes in process-related
emissions as well as indirectly through changes in electricity and/or fuel consumption to operate treatment
systems or to truck waste for disposal. EPA also expects the regulatory options to affect terrestrial
environments through changes in on-site waste management practices, including changes to the frequency
of land application for waste management. While EPA has assessed non-water quality environmental
impacts of the proposed options as required by statute, EPA was unable to estimate the effects of changes
in these impacts on affected populations due to limitations of the available data and models. Therefore,
impacts from non-water quality effects are discussed qualitatively.
6.1 Changes in Air Pollution
MPP facilities use energy when operating processing equipment, operating facility buildings, and
operating wastewater treatment systems. EPA evaluated whether there would be an associated change in
the incremental energy requirements compared to baseline based on equipment added to the plant system
or in consumed fuel. Incremental energy requirements vary depending on the regulatory option evaluated
and the current operations of the facility.
The proposed rule can affect air pollution through three main mechanisms: (1) CO2, NOx, SO2, and PM2.5
emissions associated with changes in energy requirements at MPP facilities and associated POTWs, (2)
transportation-related air pollutant emissions (CO2, NOx, and SO2) associated with changes in trucking
requirements to transport waste to landfills, and (3) wastewater treatment-related emissions of methane
(CH4) at MPP facilities and associated POTWs.
All of the regulatory options will increase emissions, with incremental increases for CO2 and methane
(see Table 6-1). The increases in CO2 are driven by emission changes associated with changes in energy
requirements at MPP facilities and associated POTWs. The increases in methane are driven by
wastewater treatment-related emissions at MPP facilities and associated POTWs, especially the treatment
technologies that help to reduce nutrient concentrations.
Table 6-1: Estimated Incremental Changes in Air Pollutant Emissions (Tons/Year)
Category
CH4
CO2
NOx
SO2
Option 1
Energy use
2.2
26,600
15.7
16.6
Transportation
0.03
960
2.2
0.003
Option 2
Energy use
8.2
98,400
57.7
61.2
Transportation
0.1
2,490
5.6
0.01
Option 3
Energy use
11.8
142,000
83.4
88.2
Transportation
0.1
3,030
6.8
0.01
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Table 6-1: Estimated Incremental Changes in Air Pollutant Emissions (Tons/Year)
Category
CH4
CO2
NOx
SO2
a. Positive values indicate a net increase in emissions.
Source: EPA Analysis, 2023
6.1.1 Effects from Changes in Air Pollution
CO2 and CH4 are greenhouse gases that EPA has determined endanger public health and welfare through
their contribution to climate change. NOx, and SO2 are known precursors to PM2.5, a criteria air pollutant
that has been associated with a variety of adverse health effects, including premature mortality and
hospitalization for cardiovascular and respiratory diseases (e.g., asthma, chronic obstructive pulmonary
disease [COPD], and shortness of breath). Furthermore, changes in NOx can impact changes in local
ground-level ozone (O3) concentrations and, accordingly, resulting human exposure (U.S. EPA, 2020a).
Research has linked both short-term and prolonged exposure to ozone to additional adverse respiratory
health effects, including the exacerbation of respiratory diseases associated with PM2.5, respiratory
infections, inflammation, and changes in lung function (U.S. EPA, 2020c).
Changes in PM2.5 and ozone connect to negative effects in human welfare, economics, climate, and
ecology (U.S. EPA, 2020a). Air pollution (e.g., PM2.5) can also create a haze that affects visibility (U.S.
EPA, 2020a).
Ozone exposure can also negatively impact vegetation through physiological interactions, leading to
decreases in plant growth (U.S. EPA, 2020c). In addition to the negative impacts of PM2.5, ozone can
negatively alter plant growth (e.g., biomass accumulation, reproduction, and quality) impact ecosystem
services, crop production yield, water cycling, and carbon sequestration (U.S. EPA, 2020c). Furthermore,
climate processes, such as radiative forcing44, can be impacted by changes in particulate matter (U.S.
EPA, 2019b).45 Impacts to ecosystem services, crop yields, and climate will likely yield additional
economic and health impacts.
6.2 Changes to Waste Management Practices
Waste management practices at MPP facilities commonly include land application of organic and
inorganic materials (Baskin-Graves et al., 2019a, 2019b). The regulatory options may affect the quantity
and quality of industrial sludge generated in the wastewater treatment process that are sold and applied to
terrestrial environments (e.g., as fertilizer for farmers). As discussed in Section 1.2, the Mountaire Farms
poultry company was sued for groundwater contamination as a result of waste discharge practices at a
facility in Sussex County, Delaware. The facility sprayed poultry waste contaminated with nitrates and
bacteria onto nearby farm fields, where it subsequently seeped into the groundwater system. The nitrates
and bacteria reached nearby wells and were associated with gastrointestinal illnesses in nearby residents.
Some contaminated wells exceeded the nitrates health limit of 10 mg/L. The groundwater pollutants also
reached the Swan and Indian Rivers, where it limited the ability of residents to enjoy recreational
44 Radiative forcing quantifies the resulting net change in the radiation budget of the planet based on a change in atmospheric
components that capture or reflect solar radiation, such as greenhouse gases, particulate matter, or clouds (U.S. EPA, 2019b)
45 Although a causal relationship exists between particulate matter and climatic effects, there is a high degree of uncertainty
associated with quantifying the effect of PM on climate. Furthermore, climate effects resulting from changes in particulate
matter exhibit both regional heterogeneity and complex feedback loops, making it difficult to determine net effects of
particulate matter. (U.S. Environmental Protection Agency, 2019b)
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activities. Furthermore, the air pollution and noxious odors caused by the waste produced aesthetic issues
and negative health impacts. (Baird Mandalas Brockstedt LLC et al., 2021; The Environmental Integrity
Project, 2018)
Table 6-2 includes estimates of changes in sludge production compared to the baseline for the different
regulatory options.46 The preferred regulatory option (option 1) would increase sludge production by
approximately 384,359 lbs per year. The estimates are based on the concentrations of BOD entering the
biological part of the treatment system after pretreatment (i.e., screening, DAF).
Table 6-2: Summary of Changes to Sludge Production Compared to the Baseline
Option 1
Option 2
Option 3
Sludge Production (tons/year)
384,359
995,804
1,213,782
Source: U.S. EPA Analysis, 2023
6.2.1 Effects from Changes in Waste Management Practices
Changes in the practice of land application of materials including, but not limited to, blood, bodily fluids,
pathogens, and excreta could have a variety of impacts on the immediate and surrounding environment
(Ozdemir et al., 2020). Furthermore, solid waste management practices can result in health and economic
impacts in addition to environmental issues. Effects are not limited to the property on which waste is
disposed, because contaminants can percolate into groundwater, accumulate in waterways, and cause air,
soil, and water pollution elsewhere (Baskin-Graves et al., 2019b; Fears, 2021; Metcalf et al., 2014). In
other words, environmental impacts in nearby areas may be changed by on-site practices due to the ability
of contaminants to be transported elsewhere through groundwater or runoff. Pollution from waste
management can depend on a facility's scale of operations as studies have found that waste from some
producers did not necessarily correspond to increases in nitrogen and phosphorous levels. (O'Bryan et al.,
2017; Rothrock et al., 2019)
The environmental impacts of changes in waste management can include hypoxic/anoxic conditions,
eutrophication, fish kills, and high ammonia levels in nearby water bodies (J. Burkholder et al., 2007; J.
M. Burkholder et al., 2006; Michael A. Mallin et al., 2006). Trace elements such as copper, zinc,
selenium, iron, and manganese are often added to poultry diets to increase weight gain. However, portions
of these elements are not absorbed and are passed on through waste products. These elements are only
required by crops in minute quantities. According to (Williams et al., 1999) the repeated application of
poultry waste has been connected to increased copper and zinc crop toxicity.
The health impacts of changes in waste management result from both chemical and biological
contamination. Sludge and wastewater deposited on fields may contain both pathogens and potentially
harmful compounds, such as ammonia (ML), nitrates, and dihydrogen sulfide (FbS) (Baskin-Graves et
al., 2019a, 2019b; "Cuppels v. Mountaire Corporation," 2021). Harmful pollutants can be transported by
groundwater to wells or drinking water sources and exposed to residents ("Cuppels v. Mountaire
Corporation," 2021; Fears, 2021). Exposure to and ingestion of these pollutants in sufficient
concentrations is reported to cause respiratory issues, gastrointestinal issues including enteritis, nervous
system impairment, multiple cancers, and death. Contamination of viral Avian Influenza, Salmonella, and
40 EPA was not able to model environmental impacts of changes in land application rates as the location and rates of land
application can vary by facility and over time.
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Campylobacter bacteria are common in poultry by-products (P. Gerber et al., 2008; P. J. Gerber et al.,
2023). Pathogenic contamination can cause irritation, infection, cognition loss, and other severe health
problems.
Waste management also can be a nuisance or have economic impacts on nearby residents. There have
been cases of "sludge farms" where NH3 and H2S created repulsive odors so strong that nearby residents
were forced to remain indoors ("Cuppels v. Mountaire Corporation," 2021). The nuisance odors and
contamination could also result in the devaluation of property.
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7: Environmental Justice
7 Environmental Justice
EPA analyzed the distribution of impacts of this regulatory action across all potentially affected
communities and sought input from stakeholders representing communities with potential environmental
justice (EJ) concerns.
This analysis has been conducted as part of the Environmental Assessment alongside other non-statutorily
required analyses, such as water quality impacts, with the discussion of quantified benefits to specific
communities and community groups included in the BCA. This analysis is intended to provide the public
with a discussion of the potential distributional impacts of this proposal and the outreach to communities
potentially experiencing disproportionate impacts. The analysis does not form a basis or rationale for any
of the actions EPA is proposing in this rulemaking.
EPA reviewed the current literature on the impacts of MPP operations on communities with EJ concerns
to inform this analysis. Then, EPA conducted multiple proximity analyses to identify the socioeconomic
characteristics of communities living near MPP facilities (within one mile) and those expected to be
impacted by discharges from MPP facilities via relevant exposure pathways. As exposure to MPP
wastewater differs based on the discharge type, EPA compared sociodemographic and environmental
indicator trends between communities proximal to direct and indirect discharging facilities.
EPA also analyzed how benefits from water quality improvements may accrue to population groups using
impacted water resources under proposed rule options as compared to all impacted communities. EPA
determined the populations served by drinking water treatment facilities whose source water may be
impacted by MPP wastewater discharge and assessed trends in potential benefits distribution. This
analysis found that low-income individuals and/or those identifying as Black are more likely to benefit
from improved drinking water source water quality under all proposed rule options when compared to the
national average. EPA also analyzed the socioeconomic characteristics of populations who may fish in
MPP impacted surface waters that are downstream of process wastewater outfalls and the subset that may
benefit under each proposed rule option. Individuals who may fish in waters impacted by MPP discharge
are more likely to be low income compared to the national average. This likelihood increases slightly in
populations predicted to benefit from improved fishing habitat.
7.1 Background
This chapter helps to address the following Executive Orders (EOs): Executive Order 12898: Federal
Actions to Address Environmental Justice in Minority Populations and Low-Income Populations;
Executive Order 14008: Tackling the Climate Crisis at Home and Abroad; and Executive Order 14096:
Revitalizing Our Nation's Commitment to Environmental Justice for All.
Each Federal agency must make the achievement of environmental justice part of its mission "by
identifying and addressing, as appropriate, disproportionately high and adverse human health or
environmental effects of its programs, policies, and activities on minority populations and low-income
populations." Section 2-2 of E.O. 12898 provides that each Federal agency must conduct its programs,
policies, and activities that substantially affect human health or the environment in a manner that ensures
such programs, policies, and activities do not have the effect of (1) excluding persons (including
populations) from participation in; or (2) denying persons (including populations) the benefits of; or (3)
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subjecting persons (including populations) to discrimination under, such programs, policies, and activities
because of their race, color, or national origin.
E.O. 14008 calls on Federal agencies to make achieving environmental justice part of their missions "by
developing programs, policies, and activities to address the disproportionately high and adverse human
health, environmental, climate-related and other cumulative impacts on disadvantaged communities, as
well as the accompanying economic challenges of such impacts/' It also declares a policy "to secure
environmental justice and spur economic opportunity for disadvantaged communities that have been
historically marginalized and overburdened by pollution and under-investment in housing, transportation,
water and wastewater infrastructure and health care.'' Under E.O. 13563 (76 FR 3821, January 21, 2011),
Federal agencies may consider equity, human dignity, fairness, and distributional considerations, where
appropriate and permitted by law. E.O. 14008 directs Federal agencies to develop programs, polices and
activities to address the disproportionate health, environmental, economic, and climate impacts on
disadvantaged, historically marginalized and overburdened communities. Similarly, E.O. 14096 re-
emphasizes the commitment of the Executive branch to include the achievement of environmental justice
in the mission of each agency and to evaluate the impacts of regulations and other Federal activities on
communities with environmental justice concerns. E.O. 14096 places a responsibility on Federal agencies
to "identify, analyze, and address disproportionate and adverse human health and environmental effects
(including risks) and hazards of Federal activities, including those related to climate change and
cumulative impacts of environmental and other burdens with environmental justice concerns[.]"
Additionally, E.O. 14096 suggests improved environmental justice analyses through "disaggregating
environmental risk, exposure, and health data by race, national origin, income, socioeconomic status, age,
sex, disability, and other readily accessible and appropriate categories.'' The Agency has reflected this
suggestion by disaggregating the following proximity analysis by race and ethnicity.
The Agency defines "environmental justice" as the fair treatment and meaningful involvement of all
people regardless of race, color, national origin, or income with respect to the development,
implementation, and enforcement of environmental laws, regulations, and policies.47 The Agency defines
the term "fair treatment" to mean both that no people should bear disproportionate burdens of
environmental harms and risks, and that the distribution of reduction in risk from EPA actions does not
exclude particular communities. The incorporation of environmental justice into EPA rulemaking is
guided by two EPA documents: (1) Technical Guidance for Assessing Environmental Justice in
Regulatory Analysis48 and (2) Guidance on Considering Environmental Justice During the Development
of Regulatory Action.49 The Technical Guidance for Assessing Environmental Justice in Regulatory
47 EPA (2022). Learn About Environmental Justice, https://www.epa.gov/environmentaliustice/learn-about-environmental-
justice. Accessed February 10,2022.
48 EPA (2016). Technical Guidance for Assessing Environmental Justice in Regulatory Analysis.
https://www.epa.gOv/sites/production/files/2016-06/documents/eitg 5 6 16 v5.1.pdf.
49 EPA (2018). Guidance on Considering Environmental Justice During the Development of Regulatory Actions.,
https://www.epa.gov/sites/default/files/2015-06/documents/considering-ei-in-rulemaking-guide-final.pdf.
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Analysis50 establishes the expectation that analysts conduct the highest quality environmental justice
analysis feasible in support of rulemakings, recognizing that what is possible will be context-specific.
When assessing the potential for disproportionately high and adverse health or environmental impacts of
regulatory actions on historically underserved and overburdened communities, EPA strives to answer
three broad questions:
1. Is there evidence of potential environmental justice concerns in the baseline (the state of the
world absent the regulatory action)? Assessing the baseline will allow EPA to determine
whether pre-existing disparities are associated with the pollutant(s) under consideration (e.g.,
are the effects of the pollutant(s) more concentrated in some population groups?).
2. Is there evidence of potential environmental justice concerns for the regulatory option(s)
under consideration? Specifically, how are the pollutant(s) and its (their) effects distributed
for the regulatory options under consideration? And,
3. Do the regulatory option(s) under consideration exacerbate or mitigate environmental justice
concerns relative to the baseline?51
It is not always possible to quantitatively assess all three questions. For instance, in some regulatory
contexts it may only be possible to quantitatively characterize the baseline due to data and modeling
limitations.
7.2 Environmental Justice Literature Review
To inform the direction of the EJ analysis, EPA reviewed the current literature on the impacts of MPP
operations on different populations. This review focused primarily on MPP facility discharges of
pollutants found in process wastewater to surface waters.
7.2.1 Methodology
Searches were restricted to U.S. studies, data research, and other literature from the 2005 (the year of
promulgation of the prior ELG revision) and forward. Literature that solely described political issues,
legal analysis, or activism around the impacts of meat packing and processing facilities was excluded.
Studies on the negative health impacts of consuming processed meats were also excluded. See Appendix
F for search terms and literature relevance criteria.
This search yielded 57 references, of which 21 were relevant for summarizing wastewater discharges and
impacts on communities with concerns in the U.S. The majority of relevant references did not discuss
particular population groups of concern but indicated that communities proximate to the waterways into
which MPP wastewater is discharged are likely differentially impacted. Twelve of the relevant studies
discussed demographics including race, rural communities, and low economic status.
50 U.S. EPA. 2016. Technical Guidance for Assessing Environmental Justice in Regulatory Actions.
https://www.epa.gov/sites/default/files/2016-06/documents/ejtg_5_6_l 6_v5.1 .pdf.
51 Differential impacts on population groups of concern can only be identified in relation to a comparison group. A comparison
group can be defined in multiple ways, for instance in terms of individuals with similar socioeconomic characteristics
located at a broader geographic level or with different socioeconomic characteristics within an affected area. The goal is to
select a comparison group that allows one to identify how the effects of the regulation vary by race, ethnicity, and income
separate from other systematic differences across groups or geographic areas.
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7.2.2 Results
The relevant literature reviewed in this effort suggests that communities and surrounding watersheds in
close proximity to MPP facilities are at particular risk to pollutant exposure, and that these facilities are
often located in rural, low-income communities (The Environmental Integrity Project, 2018; Pelton, 2018;
Winders et al., 2021). While it is known that pollutants from MPP wastewater can cause dead zones52 in
the local environment, bacterial infections, gastrointestinal problems, miscarriages, birth defects,
cognitive impairment in children, and asthma, few studies investigate the prevalence of such impacts in
local communities.
Routes of Exposure
MPP facilities that directly discharge wastewater are required to hold NPDES permits that provide them
with limits on the amount of waste they can release, and those above specified production thresholds are
regulated nationally through ELGs. Facilities in the U.S. dispose of wastewater in three primary
mechanisms, typically after some treatment: the wastewater is piped directly into waterways, sprayed
onto land, or sent to a nearby town or county wastewater treatment plant (The Environmental Integrity
Project, 2018). Solids resulting from on-site wastewater treatment are either rendered into usable products
or land applied as fertilizer, composted, or landfilled (either on-site or off-site). Many facilities use a
combination of these methods to dispose of their waste (The Environmental Integrity Project, 2018;
Winders et al., 2021). In areas of porous soil or significant rainfall, land applied waste products can enter
groundwater and flow into waterways (Shinn, 2019).
Affected Demographics
MPP facilities are often located in rural areas, with multiple large facilities often in the same county or
region (Winders et al., 2021; The Environmental Integrity Project, 2018). The construction of new
facilities in regions with preexisting industrial facilities compounds the environmental burden on the local
environment and communities. Communities surrounded by clusters of MPP facilities are often
overburdened and underserved and particularly vulnerable to CWA violations (Baskin-Graves et al.,
2019a, 2019b). In 2021, EPA found that "74% of [meat and poultry processing] facilities that directly
discharge to surface waters are within one mile of census block groups with demographic or
environmental characteristics of concern53" (U.S. Environmental Protection Agency, 2021b). The
Environmental Integrity Project found that half of the communities surrounding some of the largest
slaughterhouses in the U.S.54 contain at least 30 percent of residents living below the poverty line, which
is over twice the national level. A third of the facilities are located in towns with over 30 percent people
of color55 (The Environmental Integrity Project, 2018). These findings were corroborated by Hall et al. in
2021, who completed a hot spot analysis and applied zero-inflated regression modeling to determine
52 Areas of insufficient dissolved oxygen concentration to support some aquatic life.
53 The 80th percentile was used as a threshold value for identifying environmental and demographic characteristics of concern
and/or communities of concern, as based on recommendations in the EJSCREEN Technical Guidance at the time of the
analysis (U.S. Environmental Protection Agency, 2023e).
54 Facilities were selected based on their discharge status and availability of monitoring in US EPA's ECHO database. All
facilities discharged more than 250,000 gallons of wastewater per day directly to surface waters.
55 The national average for people of color in a CBG is 41.1 % (ACS 2017-2021).
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whether communities with a high proportion of low-income and people of color were more likely to have
a higher density concentrated animal feeding operations (CAFOs) and MPP facilities. Hall et al. found
that for every one percent increase in people of color in the Eastern Shore of Maryland, there was a 0.04
percent increase in the number of MPP facilities (Hall et al., 2021).
Studies found that the majority of MPP workers in southern facilities are women of color, and in rural
communities, meat and poultry processing is often one of the few stable jobs available to community
members (Gray, 2014; Winders et al., 2021). On the other hand, MPP workers face hazardous conditions
in the processing facilities and have a higher frequency of musculoskeletal disorders and greater exposure
to pathogens and chemicals associated with MPP waste and wastewater (Gao, 2016; The Environmental
Integrity Project, 2018).
These studies suggest that MPP facilities and their wastewater discharge impact population groups of
concern to a greater extent than the rest of the U.S. population.
Health Effects
Pathogens from wastewater and sludge applied to soil can migrate into groundwater by surface, wind, or
biological vectors (Mittal, 2004). Exposure to biosolids or resources contaminated by their application as
well as resulting air pollution can make it difficult for nearby residents to work outside and cause long-
term health effects, including bacterial infections, gastrointestinal problems, miscarriages, birth defects,
cognitive impairment in children, and asthma (Winders et al., 2021; The Environmental Integrity Project,
2018). Additionally, MPP facilities can release ammonia, nitrate, nitrite, bleach and/or peracetic acid,
which can be lethal to workers if excessively exposed or inhaled, and degrade local waterways when
released (Environment America Center, 2020; U.S. Government Accountability Office, 2016).
While the MPP facility workforce is most directly impacted by pollutants from facilities, the health of
surrounding communities can also be negatively affected by their proximity to the facilities. As stated
previously, communities living near MPP facilities are more likely to have EJ concerns than the average
community (Winders et al., 2021; The Environmental Integrity Project, 2018). Nitrates released to local
waterways may impact individuals drinking from water sources downstream or proximate to MPP
facilities. For example, elevated nitrogen levels can negatively impact human health, causing
methemoglobinemia, or blue baby syndrome, in infants, and colorectal and other cancers when present in
drinking water (Environment America Center, 2020). In Delaware, waste from five MPP facilities in
Sussex County led to gastrointestinal problems, asthma, watering eyes, and reduced quality of life due to
the intense smell of the waste, which is sprayed via an irrigation system on local fields and causes local
air and water pollution. Nitrates in drinking water and nearby monitoring wells downstream of the
Mountaire facilities in Sussex County exceeded the 10 mg/liter health limit. Community members are
also unable to swim in local recreational sites approximately two miles downstream of the facilities,
including Swan Creek and the Indian River (The Environmental Integrity Project, 2018). Workers are
particularly vulnerable to pathogen exposure, which they may transport into their communities, such as
Campylobacter sp., which is known to cause gastrointestinal illness (U.S. Government Accountability
Office, 2016).
Although the articles that investigate antibiotic resistance from MPP facilities do not specifically discuss
population groups of concern, they characterize downstream populations and those whose water is
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impacted by MPP activities as high-risk. In addition to inorganic waste and typical pathogens, workers
and proximate communities are also exposed to antibiotic resistant bacterial strains via workers who
transport pathogens out of the facilities (Hatcher et al., 2017). Workers may carry these bacteria in their
nasal passages or on belongings transferred to and from work and can bring them into their homes and
communities. Hatcher et al. (2017) found that workers at an industrial hog processing facility in North
Carolina had a higher load of antibiotic-resistant Staphylococcus aureus compared to control community
members.
MPP wastewater discharge can also act as a source of bacteria harboring antibiotic resistance genes,
promoting transfer of these genes to downstream bacterial populations. Anderson et al. demonstrated that
poultry processing facilities release fecal indicator bacteria (FIB) and other bacteria in their wastewater
discharge, some of which house antibiotic resistance genes. Resistance to tetracycline, which is used to
treat a wide range of bacterial infections in humans, was of notable presence in these bacterial
communities. However, a change in wastewater management practices between 2011 and 2012 resulted in
the clearing of these antibiotic-resistant bacteria (Anderson et al., 2014), suggesting that improved
wastewater management can reduce or reverse the presence of antibiotic-resistant bacteria in downstream
waterways (Anderson et al., 2014).
Limitations in the Literature
The health effects of slaughterhouse pollutants on local populations have not been researched in depth in
most countries, including the U.S. Available literature generally investigates MPP plant worker health and
exposure, or population groups of concern's additional exposure from nearby CAFOs.
7.3 Communities in Proximity to MPP Facilities and Outfalls
EPA conducted a series of proximity analyses to identify the environmental and socioeconomic
characteristics of nearby communities that are expected to be impacted by discharges from MPP facilities
via relevant exposure pathways. The results of these analyses informed the community outreach approach
and clarified observations from the literature, described in the previous section.
7.3.1 Methodology
EPA used the EJSCREENBatch R package to perform a series of proximity analyses of communities
potentially impacted by MPP facilities and wastewater exposure through multiple pathways. (U.S.
Environmental Protection Agency, 2022a). This package reports environmental indicators from
EJSCREEN Version 2.2 and sociodemographic characteristics by block group from the five-year 2017 -
2021 American Community Survey for each facility and for all affected facilities in aggregate within a
specified distance buffer (U.S. Environmental Protection Agency, 2023a, U.S. Census Bureau, 2021).
EPA first examined the characteristics of communities located within a one-mile radius of each MPP
facility using facility coordinates.56 This distance was used to understand localized impacts of MPP
56 These analyses were completed prior to the finalization of the MPP facility universe and are limited to the facilities for which
EPA has coordinate information available. Therefore, facility counts do not necessarily align with others in the rulemaking
documents.
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facility operations on surrounding communities while also providing for a substantial buffer outside of
MPP facility properties.
EPA then conducted an analysis of communities located on the downstream flowpath of process
wastewater outfalls. The nearest NHD Common Identifier (COMID), or surface water segment and
catchment area, was identified for each facility, then the 25-mile downstream flowpath was determined.
For indirect dischargers, it was assumed that the receiving POTW's outfall was in the same COMID. This
downstream distance was used to be inclusive of most reported distances of nutrient impacts stemming
specifically from MPP wastewater releases. The shortest distance reported was 1.2 miles (MORNING
CALL, 2007) and the longest was 45 (McCarthy, 2019). A buffer distance of one mile was used to
capture populations living in close proximity to these potentially impacted surface waters.
There are two facilities in the U.S. that discharge process wastewater both directly and indirectly to a
POTW. For these analyses, these two facilities were treated as direct dischargers.
7.3.2 Results
Demographic and Racial/Ethnic Groups Screening
EPA found that approximately 26,679,321 people live within one mile of an MPP facility, and that the
vast majority of this population lives near an indirect discharging facility, or one that discharges its
wastewater to a POTW instead of a surface water (direct discharging facility). Overall, EPA found that
communities within this distance from MPP facilities have greater proportions of low-income individuals
and individuals identifying as Asian, Black, and/or Hispanic than the national average (Table 7-1). When
communities were parsed between those neighboring direct and indirect discharging facilities, some
patterns in proportions of racial/ethnic groups shifted. In communities near direct discharging facilities,
people identifying as Native Hawaiian/Pacific Islander exceeded the national average, though the percent
is quite small (0.3% compared to 0.2%), whereas the percent of individuals identifying as Black and/or
Hispanic remained above the national average and people identifying as Asian increased when
communities near indirect dischargers were considered. The percent of individuals identified as low-
income increased in communities near direct dischargers relative to when all communities were
considered.
Table 7-1: Demographics of Communities within One Mile of an MPP Facility
All MPP Facilities
Direct Dischargers
Indirect Dischargers
National
Demographics
Total Population
26,679,321
266,172
26,413,100
NA
Facility Count
3,232
175
3,057
NA
Percent Low-Income
37.9% (1.3)
38.4% (1.3)
37.9% (1.3)
29.8%
Percent Under 5 years
old
6.25% (1.1)
6.37% (1.1)
6.25% (1.1)
5.9%
Percent w/Less than HS
Education
18.4% (1.6)
18.9% (1.6)
18.4% (1.6)
11.6%
Percent Over 64 years
old
13.2% (0.8)
15.1% (0.9)
13.2% (0.8)
16.1%
Percent Experiencing
Linguistic Isolation
7.1% (1.3)
5.6% (1.1)
7.1% (1.3)
5.1%
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Table 7-1: Demographics of Communities within One Mile of an MPP Facility
All MPP Facilities
Direct Dischargers
Indirect Dischargers
National
Racial/Ethnic Groups
Percent Black
15.9% (1.3)
10.5% (0.9)
15.9% (1.3)
12.2%
Percent American
Indian/Alaska Native
0.3% (0.5)
0.5% (0.8)
0.3% (0.5)
0.6%
Percent Asian
8.6% (1.5)
2.7% (0.5)
8.7% (1.5)
5.6%
Percent Native
Hawaiian/Pacific
Islander
0.2% (1.0)
0.3% (1.5)
0.2% (1.0)
0.2%
Percent Hispanic
33.0% (1.8)
25.6% (1.4)
33.0% (1.8)
18.4%
Percent White57
38.7% (0.7)
57.8% (1.0)
38.5% (0.6)
59.4%
Note: Bolded values exceed the national average. Ratios of each percentage to the national average percentage are shown in
parentheses.
Abbreviations: NA, not applicable.
Source: U.S. EPA Analysis, 2023
To understand demographic trends in communities living near potentially impacted surface waters, EPA
examined communities located within one mile of a surface waterbody downstream of an MPP process
wastewater outfall (Table 7-2). These communities were also found to have greater proportions of low-
income individuals, as well as people identifying as Black, Asian, and/or Hispanic compared to the
national average.
Table 7-2: Communities Within One Mile of Surface Waters Along the 25-mile Downstream Path from an MPP
Process Wastewater Outfall
Downstream Receiving Water
Proximity
National
Demographics
Total Population
60,657,658
NA
Facility Count
3,232
NA
Percent Low-Income
32.3% (1.1)
29.8%
Percent Under 5 years old
6.9% (1.2)
5.9%
Percent w/Less than HS Education
6.0% (0.5)
11.6%
Percent Over 64 years old
13.5% (0.8)
16.1%
Percent Experiencing Linguistic Isolation
14.7% (2.9)
5.1%
Racial/Ethnic Groups
Percent Black
13.7% (1.1)
12.2%
Percent American Indian/Alaska Native
0.3% (0.5)
0.6%
Percent Asian
7.0% (1.2)
5.6%
Percent Native Hawaiian/Pacific
Islander
0.2% (0.8)
0.2%
Percent Hispanic
24.1% (1.3)
18.4%
Percent White
51.3% (0.9)
59.4%
Note: Bolded values exceed the national average. The ratios of percentages to the national average are shown in parentheses.
57 A person having origins in any of the original peoples of Europe, the Middle East, or North Africa. This may include persons
also identifying as Hispanic. (U.S. Census Bureau, 2022)
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Source: U.S. EPA Analysis, 2023
7.4 Communities Utilizing Water Resources Impacted by MPP Wastewater
EPA assessed the socioeconomic characteristics of communities downstream of a process wastewater
outfall, as well as those served by PWS whose source waters are impacted by MPP wastewater
discharges. EPA determined which downstream waters would receive lower nutrient loads under each
proposed option based on the applicability of production thresholds to the associated facility. In a similar
manner, EPA also determined which public drinking water systems may experience improvements in
source water quality due to implementation of proposed rule options. For these downstream areas and
drinking water service areas, EPA analyzed the sociodemographic characteristics of the impacted
populations.
EPA also analyzed the socioeconomic characteristics of populations who may fish in MPP impacted
surface waters that are downstream of process wastewater outfalls. EPA then determined which of these
waterbodies would receive reduced pollutant loads, and therefore improved fish habitat, under each
proposed rule option and assessed the demographics of these fisher populations.
7.4.1 Methodology
EPA identified communities served by PWSs either with a source water intake within 25 miles
downstream of an MPP wastewater outfall (direct PWS) or buying water from a direct PWS (buying
PWS) using SDWIS 2022 Q4 data. EPA identified 40 direct and 158 buying PWSs that are potentially
impacted by MPP wastewater discharge, for a total of 198 PWSs.
Instead of using a proximity-based approach based on distance buffers, EPA determined the area served
by each PWS. Specifically, the drinking water service area was determined using a multi-tiered approach
based on availability, first using service areas (SA) identified in the Hydroshare dataset (SimpleLab EPIC,
2022), then 2022 TIGER zip code tabulated areas (ZCTAs), and finally county boundaries. Forty-one of
the 198 water systems included in the MPP analysis do not have a match with the CWSSB dataset. For
the 41 PWS without a match in the CWSSB dataset EPA attempted to use the ZCTA to identify service
areas related to the ZIP code from the SDWIS database. EPA identified 16 PWS with a SDWIS ZIP code
outside of the state served. In these instances, the county boundary was used for the service area. For
more details on the development of this methodology, refer to Section 5.2.1 of this document.
The potential fisher population impacted by MPP wastewater was estimated by identifying CBGs within
the surrounding 50 miles of each 25-mile reach downstream of an MPP process wastewater outfall58. Of
these communities, 5% were estimated to rely on subsistence fishing59.
To understand which communities using impacted water resources may benefit from cleaner water under
a revised MPP ELG, EPA determined which MPP facilities would be subject to stricter limits under the
proposed options. Then EPA analyzed the populations in SAs or fishing areas associated with these MPP
58 The 50-mile buffer distance is based on observations of fishers' behavior and practices have made similar observations in
terms travel distance (e.g., Sohngen et al., 2015 and Sea Grant - Illinois-Indiana, 2018).
59 Data are not available on the share of the fishing population that practices subsistence fishing. EPA assumed that 5 percent of
people who fish practice subsistence fishing, based on the assumed 95th percentile fish consumption rate for this population
in EPA's Exposure Factors Handbook (see U.S. Environmental Protection Agency, 2011).
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facilities as a proxy for those who may benefit from the implementation of the proposed options. Briefly,
Option 1 (the preferred option), builds on the existing ELG by implementing stricter total nitrogen limits
and adding phosphorus limits for large direct discharging facilities. Option 1 also requires that large
indirect discharging facilities adopt pretreatment standards for BOD, oil and grease and TSS. Option 2
further expands on Option 1 by adding nutrient pretreatment standards for the same subset of indirect
discharging facilities captured in Option 1. Option 3 is more inclusive of non-large MPP facilities,
expanding the number of facilities that would be required to comply to the above changes. For a more
detailed description of these options, please refer to Section 1.3 of this document.
7.4.2 Results
Downstream Communities
Over 60 million people live within one mile of stream or river potentially impacted from MPP wastewater
discharge, Of this population, 1.3 million, 8.9 million, and 22.1 million people would be impacted by
reduced nitrogen and phosphorus loads under proposed rule options 1 through 3, respectively (Table 7-3).
While options 1 and 2 apply to the same facilities, only direct discharging facilities would be required to
further reduce nutrient dischargers under option 1, whereas all affected facilities regardless of discharge
type would be required to reduce nutrient discharge under option 2. Under all rule options, these
benefitting populations have higher fractions of low-income individuals and those identifying as Hispanic
when compared to the national average. Under option 3, the proportion of individuals identifying as Black
and/or Asian are also greater than the national average.
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Table 7-3: Comparison of the Demographics of All Communities Living Near Impacted Downstream Waters to
Those Impacted by Reduced Nutrient Loads Under Proposed Regulatory Options
All
Option 1
Options 2
Option 3
National
Communities
Demographics
Total Population
60,657,658
1,302,124
8,851,333
22,063,987
NA
Facility Count
3,232
126
617
1,154
NA
Percent Low-
Income
32.3% (1.1)
34.2% (1.1)
33.1% (1.1)
33.5% (1.1)
29.8%
Percent Under 5
years old
6.9% (1.2)
4.7% (0.8)
4.9% (0.8)
6.2% (1.1)
5.9%
Percent w/Less
than HS Education
6.0% (0.5)
6.1% (0.5)
6.2% (0.5)
6.1% (0.5)
11.6%
Percent Over 64
years old
13.5% (0.8)
13.1% (0.8)
13.4% (0.8)
14.3% (0.9)
16.1%
Percent
Experiencing
Linguistic Isolation
14.7% (2.9)
15.0% (2.9)
14.6% (2.9)
14.5% (2.8)
5.1%
Racial/Ethnic Groups
Percent Black
13.7% (1.1)
12.0% (1.0)
12.1% (1.0)
14.3% (1.2)
12.2%
Percent American
Indian/Alaska
Native
0.3% (0.5)
0.4% (0.7)
0.4% (0.7)
0.3% (0.5)
0.6%
Percent Asian
7.0% (1.2)
3.1% (0.6)
5.5% (1.0)
5.9% (1.1)
5.6%
Percent Native
Hawaiian/Pacific
Islander
0.2% (0.8)
0.1% (0.7)
0.2% (0.9)
0.2% (1.0)
0.2%
Percent Hispanic
24.1% (1.3)
18.9% (1.0)
22.2% (1.2)
24.4% (1.3)
18.4%
Percent White
51.3 % (0.9)
62.1% (1.0)
56.1% (0.9)
51.4% (0.9)
59.4%
Note: Bolded values exceed the national average. The ratios of percentages to the national average are shown in
parentheses.
Source: U.S. EPA Analysis, 2023
Drinking Water Service Areas
EPA estimated that 7,595,010 people are served by a PWS whose source water is downstream of an MPP
process wastewater outfall. EPA found that these communities have greater proportions of individuals
identifying as Black individuals, 1.6 times the national average (Table 7-4). The percentage of low-
income individuals was found to be greater in SAs whose source waters are directly downstream of an
MPP outfall (direct SAs) than in SAs buying water from direct PWSs (Table 7-5). The populations of
SAs impacted by the rule display very similar demographic characteristics as the SA population as a
whole, regardless of the proposed option, although the population potentially receiving benefits is greatest
under option 3.
Because preferred option 1 and proposed option 2 address the same MPP facilities, the population served
by affected PWSs is same under these options, and therefore the results are presented together. These
options would affect 75.1% of total population served by MPP-impacted PWSs. The proportion of these
communities that identify as low-income and/or Black increases relative to the total population served by
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impacted PWS, and these trends are most pronounced in communities served by direct SAs. The
proportion of low-income individuals in buying SAs does not exceed the national average under these
options. It is of note, however, that because nutrient removal would be required for more facilities under
option 2, affected SAs are expected to benefit further from higher quality source water under this option.
Under proposed option 3, 82.7% of the population served by MPP-impacted PWSs is expected to benefit
from improved source water. Benefits are expected to accrue at a higher rate to low-income individuals,
and this fraction of these communities is the highest compared to the total population living in impacted
SAs. Individuals identifying as Black are also expected to benefit relatively more and make up a larger
portion of the population relative than the entire SA population.
Table 7-4: Comparison of All Drinking Water Service Areas Demographics to Those Impacted Under Proposed
Regulatory Options
All SAs
Options 1 & 2
Option 3
National
Demographics
Total Population
7,595,010
5,703,141
6,281,466
NA
Facility Count
51
40
44
NA
Percent Low-Income
29.1% (1.0)
31.2% (1.0)
30.5% (1.0)
29.8%
Percent Under 5 years old
6.0% (1.0)
6.1% (1.0)
6.3% (1.1)
5.9%
Percent w/Less than HS Education
10.9% (0.9)
10.9% (0.9)
11.4% (1.0)
11.6%
Percent Over 64 years old
16.2% (1.0)
15.9% (1.0)
16.3% (1.0)
16.1%
Percent Experiencing Linguistic
Isolation
3.3% (0.6)
3.6% (0.7)
3.9% (0.8)
5.1%
Racial/Ethnic Groups
Percent Black
19.4% (1.6)
22.7% (1.9)
22.1% (1.8)
12.2%
Percent American Indian/Alaska
Native
0.3% (0.5)
0.3% (0.5)
0.3% (0.5)
0.6%
Percent Asian
4.6% (0.8)
4.7% (0.8)
4.2% (0.8)
5.6%
Percent Native Hawaiian/Pacific
Islander
0.0% (0)
0.0% (0)
0.0% (0)
0.2%
Percent Hispanic
9.1% (0.5)
9.4% (0.5)
10.8% (0.6)
18.4%
Percent White
69.0% (1.2)
65.1% (1.1)
65.6% (1.1)
59.4%
Note: Bolded values exceed the national average. The ratios of percentages to the national average are shown in parentheses.
Source: U.S. EPA Analysis, 2023
Table 7-5: Demographics of Drinking Water Service Areas Directly Impacted by MPP Wastewater Discharge and
the Service Areas this Water is Sold to
All SAs
Options 1 & 2
Option 3
National
Direct SAs
Buying SAs
Direct SAs
Buying SAs
Direct SAs
Buying SAs
Demographics
Total Population
3,456,622
2,924,156
3,042,663
2,550,567
3,453,635
2,859,514
NA
Facility Count
28
23
21
19
23
21
NA
Percent Low-
income
36.9% (1.2)
23.9% (0.8)
37.5% (1.3)
23.7% (0.8)
36.3% (1.2)
23.4% (0.8)
29.8%
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Table 7-5: Demographics of Drinking Water Service Areas Directly Impacted by MPP Wastewater Discharge and
the Service Areas this Water is Sold to
All SAs
Options 1 & 2
Option 3
National
Direct SAs
Buying SAs
Direct SAs
Buying SAs
Direct SAs
Buying SAs
Demographics
Percent Under 5
years old
6.3% (1.1)
5.9% (1.0)
6.3% (1.1)
5.8% (1.0)
6.6% (1.1)
5.9% (1.0)
5.9%
Percent w/Less
than HS Education
12.8% (1.1)
10.5% (0.9)
12.9% (1.1)
8.5% (0.7)
13.2% (1.1)
9.4% (0.8)
11.6%
Percent Over 64
years old
15.1% (0.9)
17.0% (1.1)
14.9% (0.9)
17.2% (1.1)
15.5% (1.0)
17.3% (1.1)
16.1%
Percent
Experiencing
Linguistic Isolation
4.6% (0.9)
2.1% (0.4)
4.7% (0.9)
2.2% (0.4)
5.3% (1.0)
2.2% (0.4)
5.1%
Racial/Ethnic Groups
Percent Black
28.4% (2.3)
9.6% (0.8)
31.2% (2.6)
15.2% (1.2)
27.9% (2.3)
13.7% (1.1)
12.2%
Percent American
Indian/Alaska
Native
0.4% (0.7)
0.2% (0.3)
0.3% (0.6)
0.3% (0.4)
0.3% (0.4)
0.2% (0.4)
0.6%
Percent Asian
4.5% (0.8)
3.7% (0.7)
4.6% (0.8)
4.2% (0.8)
4.5% (0.8)
3.9% (0.7)
5.6%
Percent Native
Hawaiian/Pacific
Islander
0.0% (0)
0.0% (0)
0.0% (0.2)
0.0% (0.2)
0.0% (0.2)
0.0% (0.2)
0.2%
Percent Hispanic
12.1% (0.7)
7.1% (0.4)
11.9% (0.6)
6.3% (0.3)
13.7% (0.7)
6.2% (0.3)
18.4%
Percent White
57.9% (1.0)
81.3% (1.4)
54.9% (0.9)
75.2% (1.3)
57.5% (1.0)
77.2% (1.3)
59.4%
Note: Bolded values exceed the national average. The ratios of percentages to the national average are shown in parentheses.
Source: U.S. EPA Analysis, 2023
Fisher Populations
EPA estimated that around 13 million people live within 50 miles of a surface waterbody impacted by
MPP wastewater discharge (25 miles downstream), which represents the population that may be willing
to travel to these waterbodies to fish6". EPA found that these communities have greater proportions of
low-income individuals than the national average (Table 7-6). It is estimated that 5% of this population
may rely on subsistence fishing. As preferred option 1 and proposed option 2 apply to the same set of
MPP facilities, the downstream areas and therefore surrounding populations that would benefit from
surface water quality improvements is the same under both rule options. However, EPA expects that the
water quality of fish habitat to be further improved under option 2, therefore resulting in additional
benefits individuals fishing in these areas. Under all proposed options, benefiting communities had a
o0 The 50-mile buffer distance is based on Studies of observations of fishers' behavior and practices have made similar
observations in terms travel distance (e.g., Sohngen et al., 2015 and Sea Grant - Illinois-Indiana, 2018).
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larger proportion of low-income individuals compared to the potential fisher population as a whole and
the national average. The fraction of the total population that would benefit under Options 1 and 2
increases marginally under Option 3 (63.8% to 64.2%).
Table 7-6: Demographics of Fisher Population Impacted by MPP Discharge and the Populations that Would
Benefit Under Proposed Options
Total Fisher
Options 1 & 2
Option 3
National
Population
Demographics
Total Population
13,244,292
8,454,966
8,499,407
NA
Est. Population relying on
subsistence fishing
662,215
422,748
424,970
NA
Facility Count
146
103
106
NA
Percent Low-Income
30.6% (1.0)
33.9% (1.1)
33.9% (1.1)
29.8%
Percent Under 5 years old
5.7% (1.0)
6.0% (1.0)
6.0% (1.0)
5.9%
Percent w/Less than HS
Education
12.3% (1.1)
12.7% (1.1)
12.7% (1.1)
11.6%
Percent Over 64 years old
16.1% (1.0)
15.7% (1.0)
15.7% (1.0)
16.1%
Percent Experiencing
Linguistic Isolation
3.7% (0.7)
2.1% (0.4)
2.1% (0.4)
5.1%
Racial/Ethnic Groups
Percent Black
9.1% (0.7)
10.3% (0.8)
10.3% (0.8)
12.2%
Percent American
Indian/Alaska Native
0.5% (0.8)
0.5% (0.8)
0.5% (0.8)
0.6%
Percent Asian
5.1% (0.9)
1.3% (0.2)
1.3% (0.2)
5.6%
Percent Native
Hawaiian/Pacific Islander
0.2% (1.0)
0.1% (0.5)
0.1% (0.5)
0.2%
Percent Hispanic
11.1% (0.6)
9.0% (0.5)
9.0% (0.5)
18.4%
Percent White
50.5% (0.9)
51.7% (0.9)
51.7% (0.9)
59.4%
Note: Bolded values exceed the national average. The ratios of percentages to the national average are shown in parentheses.
Source: U.S. EPA Analysis, 2023
7.5 Tribal Areas Affected by MPP Discharges
7.5.1 Methodology
EPA conducted two proximity analyses to determine potential impacts to tribal areas and waters that may
support tribal subsistence fishing. The general proximity analysis identified any tribal area within five
miles of an MPP direct or indirect discharger. Impacts to areas that may support tribal subsistence fishing
were estimated by identifying tribal areas within 50 miles of any part of the 25-mile downstream flowpath
for MPP direct dischargers only.
7.5.2 Results
The majority of federally recognized tribal areas lie to the west of the Mississippi River while the
majority of MPP direct dischargers lie east of the Mississippi River. MPP indirect dischargers are more
evenly distributed across the conterminous US. This geographic distribution between the MPP
dischargers and the tribal land areas result in 10 unique direct dischargers that discharge in the general
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proximity (within five miles) of seven unique tribal lands and 135 unique indirect dischargers that
discharge in the general proximity of 66 unique tribal lands (Table 7-7).
Table 7-7: Direct and Indirect Discharge Facilities in General Proximity to Tribal Areas
Discharge Type
Number of
Facilities
Number of Tribes
Direct
10
7
Indirect
135
66
Source: U.S. EPA Analysis, 2023
There are 50 unique MPP direct dischargers whose downstream flowpath is within 50 miles of 46 unique
tribal areas. The average minimum distance downstream between a discharger and a potential subsistence
fishing area is about two miles.
7.6 Environmental Stressors
Environmental stressors anticipated to shift under the proposed options were also evaluated for MPP-
proximal communities (Table 7-8). EPA estimates that PM 2.5 will increase under options 2 and 3 due to
an increase in emissions from increased wastewater treatment. Diesel PM and traffic volume near
facilities are also estimated to rise as industrial sludge generation from treatment changes will increase
under all options, resulting in increased trucking for offsite land application. For details on these
estimates, refer to Section 6 of this document and Section 12 of the TDD.
When looking at all MPP proximal communities, PM 2.5 exposure, diesel PM exposure, and traffic
proximity indicators all exceeded the national average, with traffic proximity more than double that of the
average person's proximity. For communities near direct dischargers, only traffic proximity exceeded the
national average and was notably lower when compared to the average for all dischargers and indirects
and downstream receiving waters.
Table 7-8: Environmental Stressors Facing Communities Near MPP Facilities
Population-weighted
indicators
Facility Proximity
All MPP Facilities
Direct Dischargers
Indirect Dischargers
National Average
PM2.5
8.6(1.1)
8.1 (1.0)
8.6(1.1)
8.1
Diesel PM
0.5 (1.7)
0.2 (0.7)
0.5 (1.7)
0.3
Traffic Proximity
539.6 (2.6)
277.2 (1.4)
542.3 (2.7)
203.7
Note: Bolded values exceed the national average. The ratios of percentages to the national average are shown in
parentheses.
Abbreviations: PM, particulate matter.
To better understand how environmental risks from these stressors may differ between populations
proximal to direct and indirect facilities, histograms of the population count in indicators bins for
individual stressors were generated.
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs 7: Environmental Justice
Communities near direct discharging facilities were more likely to be exposed to lower traffic levels, with
a large majority under a score of 250 and none with a score greater than 5,00061. The distribution of
traffic proximity for individuals near indirect dischargers followed a more normal distribution.
Figure 7-1: Distribution of MPP-Proximal Communities' Nearness to Traffic, Grouped by Discharge Type and Across
the MPP Facility Universe
6e-Ki6 ~
4e+0Q- ......................................... i
2e+0S~ MWWWMi jWWWWWl MWWWMi
0e+-00 - =ss^^
As some traffic near these facilities and their neighboring communities is due to trucks hauling product,
material for rendering, and/or solids generated from wastewater treatment, EPA then looked at the
distribution of diesel PM 2.5 exposure for MPP proximal communities. The majority of people living near
a direct discharging MPP facility are exposed to less than 0.25 |ig/nr\ while those living near indirect
dischargers are more likely to be exposed to higher levels (Figure 7-2).
61 The proximity score assigned by EJSCREEN is based on the traffic within a search radius of 500 meters (or further if none is
found in that radius) from a CBG. Traffic volume is weighted by proximity with closer traffic given heavier weight, and
distant traffic given less weight. (U.S. EPA. 2023. EJSCREEN Technical Documentation).
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Figure 7-2: Distribution of MPP-Proximal Communities' Exposure to Diesel PM levels, Grouped by Discharge
Type and Across the MPP Facility Universe
<0.25
0.25-0.5
0 5-0.75
0.71-1 1-1.25
Diesel PM Levels
1.25-1.5
1.5-1.75
1.75-2
Interestingly, the distribution of PM 2.5 exposure followed a normal distribution across communities,
regardless of the type of MPP wastewater discharge (Figure 7-3). This finding suggests that not all
impacted environmental stressors differ with MPP discharge type.
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
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Figure 7-3: Distribution of MPP-Proximal Communities' Exposure to PM2.5, Grouped by Discharge Type and
Across the MPP Facility Universe
1e+07-
5e+06 -
1e+05-
0e+00-
These differences in distribution of environmental risk indicators may be because indirect discharging
facilities are by definition connected to a sewerage system, which are generally more accessible in
urbanized areas. To understand if rurality was a potential factor in environmental stressor trends for MPP
proximal communities, EPA determined which MPP-proximal CBGs are designated as being in an urban
area according to the Census (U.S. Census Bureau, 2020). For CBGs near direct dischargers, 24.6% and
75.4% were considered rural and urban, respectively (Table 7-9). CBGs near indirect dischargers were
even more likely to be considered urban (96.7%). This finding directly contrasts with the suggestions
from the literature review that MPP facilities are primarily located in rural areas.
Table 7-9: Urban/Rural Designation of Communities Near MPP Facilities by Discharge Type
Discharge Type
Urban/ Rural
Facility Count
CBG Count
Direct
Rural
51
164
Urban
124
504
Indirect
Rural
361
1,070
Urban
2696
31,247
Source: U.S. EPA Analysis, 2023
7.7 Community Outreach and Engagement
Due to the large percentage of potential communities with potential EJ concerns who could be affected, as
identified in the results of the screening analysis, EPA used a wide-reaching approach to community
engagement to maximize awareness of the rulemaking and the potential impacts of the proposed policy
options. EPA Office of Water (OW) presented an overview of the rulemaking and its potential interest to
communities to the Office of Environmental Justice and External Civil Rights management team, which
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included EJ National Program and Regional managers, on May 30th, 2023. EPA OW also presented a
rulemaking overview and held a discussion session with participants of the National Environmental
Justice Community Engagement Call on June 20th, 2023, which had over 200 attendees. A recording of
this presentation and the subsequent conversation is available through the National Environmental
Community Engagement website through the following link:
https://www.voutube.com/watch?v=Me8FThUP5PE&feature=voutu.be. Tribal consultation is discussed
in greater detail in the RIA (U.S. Environmental Protection Agency, 2023m).
7.8 Conclusions
Overall, EPA found that communities within one mile of an MPP facility have greater proportions of low-
income individuals and individuals identifying as Asian, Black, and/or Hispanic than the national average.
In communities neighboring direct discharging facilities, people identifying as Native Hawaiian/Pacific
Islander slightly exceeded the national average, whereas the percent of individuals identifying as Black,
Asian, and/or Hispanic remained above the national average in indirect-proximal communities and
increased from when all MPP-proximal communities were considered. These findings suggest that MPP
wastewater discharge disproportionately impacts communities with EJ concerns.
These results are further supported by the analysis of environmental impact indicators distribution among
MPP-proximal communities. When EPA considered environmental indicators predicted to change under
the proposed rule options (traffic proximity, PM 2.5, and diesel PM 2.5), the results suggested that impact
for all three indicators was on average heightened in MPP-proximal communities compared to national
averages. Individuals living near indirect discharging facilities are even more likely to experience these
stressors, with average traffic proximity more than double the national average.
EPA also determined which communities are located in rural and urban areas, finding that most
communities are located in urban areas, regardless of the discharge status of the nearby MPP facility.
Communities proximal to indirect discharging facilities are substantially more likely to be in urban areas,
which is expected given that sewered areas are more frequently located in urban centers. These results run
counter to the suggestions made by the literature that MPP facilities are frequently in rural areas.
EPA identified communities living near waters downstream of MPP wastewater outfalls and analyzed
sociodemographic trends in populations impacted by reduced nutrient pollution under each proposed rule
option. Under preferred option 1 and proposed option 2, impacted communities are comprised of a higher
proportion of individuals of low-income status and/or those identifying as Hispanic than on average
nationally, although 6.8 times more people live in areas affected under option 2. Under option 3, impacted
communities are also comprised of a greater proportion of people identifying as Black, Asian, and/or
Hispanic than the national average.
To further understand which communities may be affected by potential pollution reductions, EPA
identified populations served by public water systems whose source water may be impacted by MPP
wastewater discharge. Sociodemographic trends in communities who may receiving cleaner drinking
water under each rule option were also determined. When analyzing community characteristics for all
impacted SAs, EPA found that these communities have greater proportions of individuals identifying as
Black, 1.6 times the national average. For buying SAs, the proportion of low-income individuals was 1.2
times the national average and people were 2.3 times more likely to identify as Black. These trends held
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for directly impacted SAs under all options but was less consistent in the populations of buying SAs. In
general, service areas affected by the proposed rule display very similar demographic characteristics as
the MPP universe as a whole, regardless of the proposed option, although the population potentially
receiving benefits is greatest under Option 3.
EPA also conducted proximity analyses to assess potential impacts on tribal areas and waters potentially
supporting subsistence fishing. The results indicate that federally recognized tribal areas are much more
likely to be in general proximity to a MPP indirect facility discharger than a direct facility, and that 50
direct dischargers are upstream of waters potentially supporting tribal subsistence fishing.
Lastly, EPA analyzed sociodemographic trends in communities that may participate in recreational or
subsistence fishing as well as the subset of this population that would benefit under the proposed rule
options. Under all options, the proportion of the community that is considered low-income increases
marginally relative to the total fishing population and exceeds the national average. The fraction of the
total population that would benefit under options 1 and 2 increases marginally under option 3. It is of note
that the additional benefits to these communities under option 2 due to an increase in facilities with
nutrient limits was not captured in this analysis.
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8: References
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U.S. Food and Drug Administration. (2021). Summary Report on Antimicrobials Sold or Distributed for
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Appendix A
Appendix A: Nitrogen State Water Quality Criteria
Table A-l below describes the state water quality criteria for different nitrogen species, categorized by
designated use.
Table A-l: Average State WQC for Nitrogen (mg/L)
State
Lower
Limit
Upper
Limit
Average
Limit
Pollutant
Name
Designated Use
Water
Type
Notes
Nebraska
0.08
4.85
2.47
Ammonia
Aquatic life
Freshwater
Depends on pH
and
temperature. 30-
day average.
Warmwater
Virginia
0.08
4.90
2.49
Ammonia
Aquatic life
Freshwater
Depends on
whether early
life are present;
also depends on
pH and
temperature
Maryland
0.18
6.67
3.42
Ammonia
Aquatic life
Freshwater
Varies by pH,
where fish early
life stages may
be present
Utah
0.18
10.80
5.49
Ammonia
Aquatic life
Freshwater
Depends on pH
Iowa
0.18
10.80
5.49
Ammonia
Aquatic life
pH and
temperature
dependent
Maryland
0.44
10.8
5.62
Ammonia
Aquatic life
Freshwater
Varies by pH,
where fish early
life stages are
absent
Ohio
1.10
13.00
7.05
Ammonia
Aquatic life
Freshwater
Warmwater
habitat,
modified
warmwater
habitat, and
limited resource
water outside
mixing zone.
Varies by pH and
temperature;
outside mixing
zone
Nebraska
0.27
48.86
24.57
Ammonia
Aquatic life
Freshwater
Depends on pH
and
temperature.
One hour
average.
Warmwater.
Missouri
0.80
48.8
24.80
Ammonia
Aquatic life
Freshwater
Depends on cold
vs cool and
A-l
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Appendix A
Table A-l: Average State WQC for Nitrogen (mg/L)
State
Lower
Limit
Upper
Limit
Average
Limit
Pollutant
Name
Designated Use
Water
Type
Notes
warm water
fisheries & pH
Maryland
0.89
48.8
24.84
Ammonia
Aquatic life
Freshwater
Varies by pH and
whether
salmonids are
present/absent
Iowa
0.89
48.8
24.85
Ammonia
Aquatic life
pH dependent
Utah
0.89
48.8
24.85
Ammonia
Aquatic life
Freshwater
Depends on pH
Kansas
0.27
51.00
25.64
Ammonia
Aquatic life
Dependent on
pH and
temperature
Virginia
0.27
51.00
25.64
Ammonia
Aquatic life
Freshwater
Depends on
whether trout
are present; also
depends on pH
and temperature
South
Dakota
**
**
**
Ammonia
Aquatic life
Freshwater
Alabama
5.00
5.00
5.00
Ammonia
Effluent Limit
Arkansas
0.18
48.80
24.49
Ammonia
Effluent Limit
Range
dependent on
pH, temperature
and fish
presence
Indiana
5.00E-4
0.03
0.01
Ammonia
General/
Unspecified
Dependent on
temperature and
PH
Illinois
15.00
15.00
15.00
Ammonia
General/
Unspecified
Florida
**
**
**
Ammonia
General/
Unspecified
In no case shall
nutrient
concentrations
of a body of
water be altered
so as to cause an
imbalance in
natural
populations of
aquatic flora or
fauna
Tennessee
**
**
**
Ammonia
General/
Unspecified
Minnesota
0.02
0.04
0.03
Ammonia
Human
Consumption
Freshwater
Chronic;
Ammonia,
unionized as N
Utah
4.00
4.00
4.00
Nitrate
Aquatic life
Freshwater
Utah
4.00
4.00
4.00
Nitrate
Drinking Water
Source
Freshwater
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Appendix A
Table A-l: Average State WQC for Nitrogen (mg/L)
State
Lower
Limit
Upper
Limit
Average
Limit
Pollutant
Name
Designated Use
Water
Type
Notes
Kansas
10.00
10.00
10.00
Nitrate
Drinking Water
Source
Drinking water
supply
Minnesota
10.00
10.00
10.00
Nitrate
Drinking Water
Source
Freshwater
South
Dakota
10.00
10.00
10.00
Nitrate
Drinking Water
Source
Freshwater
Utah
10.00
10.00
10.00
Nitrate
Drinking Water
Source
Freshwater
Virginia
10.00
10.00
10.00
Nitrate
Drinking Water
Source
Freshwater
New York
20.00
20.00
20.00
Nitrate
Effluent Limit
Groundwat
er
Montana
5.00
7.50
6.25
Nitrate
General/
Unspecified
Groundwat
er
Depends on
discharge/treat
ment type
Iowa
10.00
10.00
10.00
Nitrate
General/
Unspecified
North
Ca rolina
10.00
10.00
10.00
Nitrate
General/
Unspecified
Surface
water
Illinois
10.00
10.00
10.00
Nitrate
(LAKE) General/
Unspecified
Colorado
10.00
100
55.00
Nitrate
General/
Unspecified
Florida
10.00
10.00
10.00
Nitrate
Potable
drinking water
Utah
4.00
4.00
4.00
Nitrate
Recreation
Freshwater
South
Dakota
50.00
88.00
69.00
Nitrate
Recreation
Freshwater
Minnesota
100.00
100.00
100.00
Nitrate +
Nitrite
Agriculture
Freshwater
Nebraska
100.00
100.00
100.00
Nitrate +
Nitrite
Agriculture
Freshwater
Minnesota
10.00
10.00
10.00
Nitrate +
Nitrite
Drinking Water
Source
Freshwater
Nebraska
10.00
10.00
10.00
Nitrate +
Nitrite
Drinking Water
Source
Freshwater
Pennsylvan
ia
10.00
10.00
10.00
Nitrate +
Nitrite
Drinking Water
Source
Freshwater
Kansas
10.00
100.00
55.00
Nitrate +
Nitrite
Drinking Water
Source
Drinking water
supply and
agriculture
New York
20.00
20.00
20.00
Nitrate +
Nitrite
Effluent Limit
Groundwat
er
New Jersey
2.00
2.00
2.00
Nitrate +
Nitrite
General/
Unspecified
Pineland
waters
Indiana
10.00
10.00
10.00
Nitrate +
Nitrite
General/
Unspecified
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Appendix A
Table A-l: Average State WQC for Nitrogen (mg/L)
State
Lower
Limit
Upper
Limit
Average
Limit
Pollutant
Name
Designated Use
Water
Type
Notes
Iowa
10.00
10.00
10.00
Nitrate +
Nitrite
General/
Unspecified
Minnesota
1.00
1.00
1.00
Nitrite
Drinking Water
Source
Freshwater
Nebraska
1.00
1.00
1.00
Nitrite
Drinking Water
Source
Freshwater
New York
2.00
2.00
2.00
Nitrite
Effluent Limit
Groundwat
er
Indiana
1.00
1.00
1.00
Nitrite
General/
Unspecified
Iowa
1.00
1.00
1.00
Nitrite
General/
Unspecified
Colorado
1.00
10.00
5.50
Nitrite
General/
Unspecified
Utah
0.40
0.80
0.60
Total
Nitrogen
Aquatic life
Freshwater
New York
10.00
10.00
10.00
Total
Nitrogen
Effluent Limit
Groundwat
er
Montana
10.00
15.00
12.50
Total
Nitrogen
Effluent Limit
This threshold
allows for < 1
million gallons
per day. Monthly
average
Missouri
0.40
0.84
0.62
Total
Nitrogen
(LAKE) General/
Unspecified
Freshwater
Depends on lake
ecoregion
Colorado
0.43
0.91
0.67
Total
Nitrogen
General/
Unspecified
Georgia
3.00
4.00
3.50
Total
Nitrogen
(LAKE) General/
Unspecified
Freshwater
** indicates that the state had a WQC for nitrogen, but the values were not presented as discrete values (e.g., as a part of an
equation)
Source: U.S. EPA Analysis, 2023
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Appendix B
Appendix B: Case Study Water Quality Modeling
This section describes the methodology used to analyze the potential hydrologic and water quality effects
in response to the proposed ELG for the MPP industry.
SWAT Model Setup
EPA used HAWQS 2.0 to develop the initial SWAT models and extract data necessary to characterize the
watersheds. HAWQS is a web-based interface that streamlines the development of SWAT watershed
models by providing pre-loaded input data and modeling support capabilities for setting up models,
running simulations, and processing outputs (HAWQS System 2.0 and Data to model the lower 48
conterminous U.S using the SWAT model, 2023). SWAT is a commonly used public domain semi-
distributed mechanistic watershed model that is used to evaluate the effects of land management and
agricultural practices on water, sediment, and chemical fluxes across a wide range of watershed sizes,
land uses, and physiographic provinces (S.L. Neitsch et al., 2011). HAWQS provides pre-loaded national
input data necessary to develop SWAT watershed models at subbasin resolutions that range from the 14-
digit HUC (HUC14) to the 8-digit HUC (HUC8).
For the case studies described in Section 3.2, EPA developed watershed models with HUC 14 subbasins
using the HAWQS 2.0 interface (see Section 3.2 for details on the case study models). Table B-l
summarizes the pre-processed input datasets available within the HAWQS framework that were used in
developing these case study models.
Table B-l: Case Study Models Input Dataset Summary
Input Dataset
Source
Specifications
Weather
Parameter-elevation Regressions on Independent Slopes Model
(PRISM)
1981-2020
(gridded)
Soil
USDA National Resources Conservation Service (NRCS) Soil Survev
2018
Geographic (SSURGO) Database
USDA NRCS State Soil Geographic (STATSGO) Database
2018
Land Use
National Land Cover Database (NLCD)
2016
USDA National Agricultural Statistics Service (NASS) Cropland Data
2014-2017
Laver (CDL)
USDA NASS Fields
2006-2010
U.S. Fish and Wildlife Service (FWI) National Wetlands Inventory
2018
(NWI)
Aerial Deposition
National Atmospheric Deposition Program (NADP)
1980 - 2020
(monthly)
Watershed
Boundaries
EPA NHDPIus v2
2019
Stream Networks
EPA NHDPIus v2
2019
Elevation
USGS National Elevation Dataset (NED)
2018 (10-meter
DEM)
Point Sources
EPA Hypoxia Task Force (HTF)
2019
EPA Integrated Compliance Information System National Pollutant
2019
Discharge Elimination System (ICIS-NPDES)
EPA MPP Census Questionnaire
2023
B-l
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs Appendix B
Table B-l: Case Study Models Input Dataset Summary
Input Dataset
Source
Specifications
Management
Data
USDA NRCS crop management zone data
2010
Ponds, Potholes,
and Reservoirs
U.S. Armv Corps of Engineers (USACE) National Inventory of Dams
2018
(NID)
EPA NHDPIus v2
2019
Crop Data
USDA NASS CDL
2014 - 2017
Wetlands
FWS NWI
2018
Water Use
USGS Water Use in the United States
2015
Source: U.S. EPA Analysis, 2023
SWAT also allows the user to choose among hydrology and water quality settings that determine how
various SWAT processes are modeled. Table B-2 summarizes the relevant setting specifications used in
the case study HAWQS/SWAT models.
Table B-2: Summary of Relevant SWAT Hydrology and Water Quality Settings
SWAT Process
Associated SWAT File
Specifications
Potential evaporation
basins, bsn
Penman/Monteith method
Water routing
basins, bsn
Variable travel time
Curve number (CN) calculation
basins.bsn
Calculates daily CN value as a function of soil moisture
Instream sediment model
basins.bsn
Bagnold model
Source: U.S. EPA Analysis, 2023
Representation of Point Source Discharges from Direct and Indirect Facilities
HAWQS 2.0 includes default point source data to represent loadings not associated with land areas, such
as permitted discharges from publicly owned treatment systems (POTWs) or industrial facilities,
including MPP dischargers. The point source dataset used for the case study models includes data for
flows, nitrogen, phosphorus, fecal coliform, E. coli, CBOD, and TSS by subbasin (HUC14). The
parameters follow the standard SWAT model input data format for annual average discharges
(reccnst.dat):62
Flow: (FLO) in cubic meters per day
Nitrogen: nitrate (N03), nitrite (N02), ammonia (NH3), and organic nitrogen (ORGN), all in
kilograms per day
Phosphorus: mineral phosphorus (MINP) and organic phosphorus (ORGP) in kilograms per day
02 For the case study models, the most complete dataset was used for each discharger. For example, if monthly measured loadings
or concentrations are available, these values were used directly within the SWAT model. The Upper Soldier Creek case
study included monthly point source data from 2021 DMRs forMS0046931 andMS0002615, requiring the standard SWAT
model input data format for monthly discharges (recmon.dat).
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Appendix B
Pathogens: E. coli (BACTP), and fecal coliform (BACTLP) in colony forming units (CFU) per 100
mL63
Organic enrichment: CBOD (CBOD) in kilograms per day
Sediment: TSS (SED) in metric tons (Mton) per day
Default point source data included in HAWQS 2.0 reflect 2019 annual average loadings from permitted
point source dischargers. The scope includes discharges covered by NPDES individual permits from
POTW and non-POTW facilities, whether they are classified as minor or major. Point source data for
MPP direct dischargers was updated to reflect 2021 loadings from permitted dischargers.64 Point source
estimates were derived from the sources described below.
EPA ICIS-NPDES Discharge Monitoring Reports (DMRs) - ICIS-NPDES is an information
management system that tracks permit compliance and enforcement status of facilities regulated by
the NPDES permit program. DMRs are part of facilities' compliance verification process. These
datasets include reported outfall flows and loadings or concentrations from NPDES-permitted
facilities. In particular, the datasets include NPDES and outfall identifiers, geographic coordinates,
parameters monitored, monitoring frequencies, statistical bases applied to report the values, and
measured values in standardized units. The DMR data are formatted as monthly measurements
adjusted to DMR value standard units at each NPDES facility outfall.
EPA ECHO Water Pollutant Loading Tool, Hypoxia Task Force (HTF) Nutrient Modeling Dataset -
Total nutrient loads for all relevant NPDES-permitted point source facilities are summarized in a
national dataset from EPA's ECHO Water Pollutant Loading Tool, Nutrient Modeling (HTF Search).
This dataset reports annual total nitrogen (TN) and total phosphorus (TP) loads. The annual nutrient
loading values include both 1) aggregated TN and TP loads from facilities reporting nutrient
concentrations in DMRs and 2) modeled data where EPA imputed loads for facilities without DMR-
reported nutrient data using Typical Pollutant Concentrations (TPCs) applied to facilities based on
Standard Industrial Classification (SIC) code, flow class, and season. DMR data for 2019 and 2021
were extracted for nutrients, pathogens, BOD, TSS, and flows, where available.
The primary data source (HTF or DMR) determined the process by which the point source data were
summarized. The HTF dataset served as the primary basis for annual nutrient loadings; for nutrients,
DMR data were used secondarily to distribute total nutrient loadings across discharge outfalls and nutrient
species. For pathogens (E. coli and fecal coliform), BOD, and TSS, the primary data source was DMR.
The DMR data were used in combination with permit and facility characteristics to estimate total loadings
and concentrations across discharge outfalls. External outfalls associated with NPDES-permitted
dischargers were georeferenced to the HUC14s based on the outfall coordinates. The HAWQS 2.0
63 E. coli was mapped to persistent bacteria and fecal coliform was mapped to less persistent bacteria based on review of the
documentation of the pathogen modeling routines and past model applications
64 Nineteen MPP direct dischargers were not represented by the combined HTF and DMR data. Within the water quality models,
the MPP Census Questionnaire was used for locational information and the baseline loadings described in Chapter 3 were
used to represent discharges from these facilities.
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Appendix B
technical documentation has additional details on the development of the point source data (U.S.
Environmental Protection Agency, 2023f).
Model Calibration
SWAT parameters in initial models reflect default values from SWAT, as modified where applicable
during HAWQS calibration (U.S. Environmental Protection Agency, 2023f). As noted in the HAWQS 2.0
technical documentation, however, only a subset of watersheds in HAWQS have been calibrated, and
even for those that were calibrated, calibration occurred at coarser HUC scales. As a result, the agency
conducted a separate calibration of each case study model referenced in Section 3.2.
The SWAT calibration procedure involved four main steps:
1) Collect observed data within the case study modeling locations;
2) Run the model in "calibration mode" and iteratively adjust model parameters so that the
predicted monthly streamflow and loadings time series approximate observed streamflow and
loadings within the bounds of uncertainties of model inputs and estimates developed directly
from observed data (using the USGS' Load Estimator [LOADEST]). Models were first
calibrated to match observed flow time series, and then sequentially to match observed TSS,
TN, and TP loadings time series;
3) Run the statistical tests in SWAT's Calibration and Uncertainty Program (SWAT-CUP) to
produce the calibration statistical metrics; and
4) Finalize the calibration parameters and update the project database and input files for further
scenario analysis.
The HAWQS 2.0 technical documentation has additional details on calibration procedures. Table B-3
summarizes the observed data locations and associated calibration statistical metrics for the various case
study models.
The Upper Pearl River case study model was only calibrated for flow as there was insufficient observed
data to conduct a calibration for water quality. The agency conducted a qualitative comparison of
observed water quality data to model estimates and found that observed data matched the timing and
order of magnitude of model estimates.
The Double Bridges Creek case study model was calibrated sufficiently for flow and total nitrogen, but
model estimates were uncertain for total phosphorus (low Kling-Gupta efficiency (KGE) value and
negative Nash-Sutcliffe efficiency (NSE) value).
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Appendix B
Table B-3: Case Study Calibration Locations and Statistics
Case Study
Model
Observed Data
Location
Time Period of
Calibration
Calibrated
Parameter
Calibration Statistics (NSE, PBIAS, KGE)
NSE
PBIAS
KGE
Upper Pearl River
02481880
1983-2020
Flow
0.78
-11.2
0.77
02482000
1983-2020
Flow
0.78
-2.1
0.74
02483000
1983-2020
Flow
0.83
-11.8
0.76
02482550
1983-2020
Flow
0.76
2.8
0.70
02483500
1997-2020
Flow
0.79
-6.6
0.78
Double Bridges
Creek
21AWIC-1457
2014-2017
TN
0.26
31.4
0.62
TP
-2.02
6.4
0.00
2362240
2005-2020
Flow
0.76
-9.1
0.84
Okatoma Creek
21MSWQ_WQX-
02472820
2008-2015
TN
0.69
17.7
0.77
TKN
0.64
29.4
0.61
N03
0.09
9.5
0.59
NH4
0.63
6
0.66
TP
-0.01
33.9
0.54
TSS
0.6
-18.4
0.64
2472850
2005-2020
Flow
0.83
-5.6
0.9
Source: U.S. EPA Analysis, 2023
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Appendix C
Appendix C: Summary of Threatened and Endangered Species
Table C - 1 contains a complete list of threatened and endangered species potentially impacted by MPP
direct dischargers. The tables provided in Chapter 4 focus on those species which have a classification of
"higher" vulnerability, which is defined as having multiple life history stages in aquatic settings or
requiring aquatic resources for most of their food resources. The table below includes species of all
vulnerability levels. The degree to which a species could be potentially impacted by the regulatory option
relies upon the vulnerability and exposure of the species, the type of pollutant, the amount of pollutants,
and the mechanisms of impact.
Table C -1: Summary of Threatened and Endangered Species Affected by the Proposed Rule
Scientific Name
Common Name
Vulnerability
Group
Acipenser oxyrinchus
(=oxyrhynchus) desotoi
Gulf sturgeon
Higher
Fishes
Alligator mississippiensis
American alligator
Higher
Reptiles
Antrolana lira
Madison Cave isopod
Higher
Crustaceans
Arcidens wheeleri
Ouachita rock pocketbook
Higher
Bivalves
Athearnia anthonyi
Anthony's riversnail
Higher
Snails
Bom bus affinis
Rusty patched bumble bee
Lower
Insects
Bufo houstonensis
Houston toad
Moderate
Amphibians
Calidris canutus rufa
Red knot
Lower
Birds
Cambarus aculabrum
Benton County cave crayfish
Higher
Crustaceans
Cambarus cracens
Slenderclaw crayfish
Higher
Crustaceans
Canis lupus
Gray wolf
Lower
Mammals
Caretta caretta
Loggerhead sea turtle
Lower
Reptiles
Charadrius melodus
Piping Plover
Moderate
Birds
Chelonia mydas
Green sea turtle
Lower
Reptiles
Coccyzus americanus
Yellow-billed Cuckoo
Lower
Birds
Corynorhinus (=Plecotus)
townsendii ingens
Ozark big-eared bat
Lower
Mammals
Corynorhinus (=Plecotus)
townsendii virginianus
Virginia big-eared bat
Lower
Mammals
Cryptobranchus alleganiensis
bishopi
Ozark Hellbender
Higher
Amphibians
Cumberlandia monodonta
Spectaclecase (mussel)
Higher
Bivalves
Cyprogenia stegaria
Fanshell
Higher
Bivalves
Dermochelys coriacea
Leatherback sea turtle
Lower
Reptiles
Dromus dromas
Dromedary pearlymussel
Higher
Bivalves
Drymarchon couperi
Eastern indigo snake
Lower
Reptiles
Epioblasma capsaeformis
Oyster mussel
Higher
Bivalves
Epioblasma florentina curtisii
Curtis pearlymussel
Higher
Bivalves
Epioblasma triquetra
Snuffbox mussel
Higher
Bivalves
Eretmochelys imbricata
Hawksbill sea turtle
Lower
Reptiles
Etheostoma chienense
Relict darter
Higher
Fishes
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Appendix C
Table C -1: Summary of Threatened and Endangered Species Affected by the Proposed Rule
Scientific Name
Common Name
Vulnerability
Group
Etheostoma phytophilum
Rush Darter
Higher
Fishes
Etheostoma rubrum
Bayou darter
Higher
Fishes
Fusconaia burkei
Tapered pigtoe
Higher
Bivalves
Fusconaia cor
Shiny pigtoe
Higher
Bivalves
Fusconaia cuneolus
Finerayed pigtoe
Higher
Bivalves
Fusconaia masoni
Atlantic pigtoe
Higher
Bivalves
Glyptemys muhlenbergii
Bog turtle
Higher
Reptiles
Gopher us polyphemus
Gopher tortoise
Lower
Reptiles
Graptemys flavimaculata
Yellow-blotched map turtle
Higher
Reptiles
Graptemys oculifera
Ringed map turtle
Higher
Reptiles
Grus americana
Whooping crane
Moderate
Birds
Hamiota altilis
Finelined pocketbook
Higher
Bivalves
Hamiota australis
Southern Sandshell
Higher
Bivalves
Hamiota perovalis
Orangenacre mucket
Higher
Bivalves
Lampsilis abrupta
Pink mucket (pearlymussel)
Higher
Bivalves
Lampsilis higginsii
Higgins eye (pearlymussel)
Higher
Bivalves
Lampsilis rafinesqueana
Neosho Mucket
Higher
Bivalves
Laterallus jamaicensis ssp.
jamaicensis
Eastern Black rail
Lower
Birds
Lemiox rimosus
Birdwing pearlymussel
Higher
Bivalves
Lepidochelys kempii
Kemp's ridley sea turtle
Lower
Reptiles
Leptodea leptodon
Scaleshell mussel
Higher
Bivalves
Leptoxis plicata
Plicate rocksnail
Higher
Snails
Leptoxis taeniata
Painted rocksnail
Higher
Snails
Lycaeides melissa samuelis
Karner blue butterfly
Lower
Insects
Lynx canadensis
Canada Lynx
Lower
Mammals
Macrhybopsis tetranema
Peppered chub
Higher
Fishes
Medionidus acutissimus
Alabama moccasinshell
Higher
Bivalves
Medionidus penicillatus
Gulf moccasinshell
Higher
Bivalves
Medionidus walkeri
Suwannee moccasinshell
Higher
Bivalves
Mycteria americana
Wood stork
Moderate
Birds
Myotis grisescens
Gray bat
Moderate
Mammals
Myotis septentrionalis
Northern Long-Eared Bat
Lower
Mammals
Myotis sodalis
Indiana bat
Lower
Mammals
Necturus alabamensis
Black warrior (=Sipsey Fork)
Waterdog
Higher
Amphibians
Neonympha mitchellii mitchellii
Mitchell's satyr Butterfly
Lower
Insects
Nerodia erythrogaster neglecta
Copperbelly water snake
Higher
Reptiles
Nicrophorus americanus
American burying beetle
Lower
Insects
Notropis cahabae
Cahaba shiner
Higher
Fishes
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Appendix C
Table C -1: Summary of Threatened and Endangered Species Affected by the Proposed Rule
Scientific Name
Common Name
Vulnerability
Group
Notropis mekistocholas
Cape Fear shiner
Higher
Fishes
Notropis topeka (=tristis)
Topeka shiner
Higher
Fishes
Noturus flavipinnis
Yellowfin madtom
Higher
Fishes
Numenius borealis
Eskimo curlew
Lower
Birds
Obovaria choctawensis
Choctaw bean
Higher
Bivalves
Obovaria retusa
Ring pink (mussel)
Higher
Bivalves
Pegiasfabula
Littlewing pearlymussel
Higher
Bivalves
Percina aurora
Pearl darter
Higher
Fishes
Percina pantherina
Leopard darter
Higher
Fishes
Percina rex
Roanoke logperch
Higher
Fishes
Percina tanasi
Snail darter
Higher
Fishes
Picoides borealis
Red-cockaded woodpecker
Lower
Birds
Pituophis melanoleucus lodingi
Black pinesnake
Lower
Reptiles
Pituophis ruthveni
Louisiana pinesnake
Lower
Reptiles
Plethobasus cooperianus
Orangefoot pimpleback
(pearlymussel)
Higher
Bivalves
Plethobasus cyphyus
Sheepnose Mussel
Higher
Bivalves
Pleurobema clava
Clubshell
Higher
Bivalves
Pleurobema decisum
Southern clubshell
Higher
Bivalves
Pleurobema furvum
Dark pigtoe
Higher
Bivalves
Pleurobema georgianum
Southern pigtoe
Higher
Bivalves
Pleurobema perovatum
Ovate clubshell
Higher
Bivalves
Pleurobema plenum
Rough pigtoe
Higher
Bivalves
Pleurobema pyriforme
Oval pigtoe
Higher
Bivalves
Pleurobema strodeanum
Fuzzy pigtoe
Higher
Bivalves
Pleuronaia dolabelloides
Slabside Pearlymussel
Higher
Bivalves
Potamilus capax
Fat pocketbook
Higher
Bivalves
Potamilus inflatus
Inflated heelsplitter
Higher
Bivalves
Ptychobranchus greenii
Triangular Kidneyshell
Higher
Bivalves
Ptychobranchus jonesi
Southern kidneyshell
Higher
Bivalves
Ptychobranchus subtentus
Fluted kidneyshell
Higher
Bivalves
Quadrula cylindrica cylindrica
Rabbitsfoot
Higher
Bivalves
Quadrula fragosa
Winged Mapleleaf
Higher
Bivalves
Rana sevosa
Dusky gopher frog
Lower
Amphibians
Salvelinus confluentus
Bull trout
Higher
Fishes
Scaphirhynchus albus
Pallid sturgeon
Higher
Fishes
Setophaga chrysoparia
Golden-cheeked warbler
Lower
Birds
Sistrurus eaten at us
Eastern Massasauga (=rattlesnake)
Lower
Reptiles
Sternotherus depressus
Flattened musk turtle
Higher
Reptiles
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Appendix C
Table C -1: Summary of Threatened and Endangered Species Affected by the Proposed Rule
Scientific Name
Common Name
Vulnerability
Group
Theliderma intermedia
Cumberland monkeyface
(pearlymussel)
Higher
Bivalves
Trichechus manatus
West Indian Manatee
Higher
Mammals
Villosa fabalis
Rayed Bean
Higher
Bivalves
Zapus hudsonius preblei
Preble's meadow jumping mouse
Lower
Mammals
Source: U.S. EPA Analysis, 2023
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Appendix D
Appendix D: Impaired Waters Analysis
Table D-l contains a complete list of pollutants evaluated in the impaired waters analysis. This list is
specific to pollutants known to be found in or related to impacts associated with MPP wastewater and is
therefore not a complete list of all impairment types tracked in the ATTAINS database. Chapter 4
includes summaries that classify individual pollutants together under common groupings based on their
functional properties, allowing for a more expedient understanding of impaired waters. Functional
groupings, such as nutrients, are helpful as similar pollutants are likely to create similar effects, such as
algal overgrowth. However, specific contaminants could have more nuanced impacts, and a complete list
of pollutants assists in a better understanding of impaired waterways. For reference, there are 1,868 total
unique catchments within 25 miles of an MPP direct discharger.
Table D-l: Comprehensive List of Pollutants Causing Impaired Waters
Name
Number of Catchments
Escherichia coli (£. coli)
421
Phosphorus (total)
181
Dissolved Oxygen
160
Fecal coliform
144
Sedimentation (siltation)
100
Nutrients
77
Arsenic
70
Mercury in Fish Tissue
66
Mercury Fish Consumption Advisory
64
Sulfate
57
Habitat Alterations
48
Turbidity
43
PH
40
Nitrate/Nitrite/ Nitrite/Nitrate as N
36
Uranium
31
Enterococcus
26
Biological integrity
26
Zinc
24
Iron
24
Benthic Macroinvertebrate Bioassessments
21
Ammonia (total)
20
Methyl Parathion
12
Endosulfan
12
Chlorpyrifos
12
Atrazine
12
Benthic Macroinvertebrates
8
Ammonia (unionized)
4
Pathogens
3
Alteration in streamside or littoral vegetative covers
3
Aluminum
2
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Appendix D
Table D-l: Comprehensive List of Pollutants Causing Impaired Waters
Name
Number of Catchments
Dissolved Oxygen (critical)
1
Stream modification
1
Source: U.S. EPA Analysis, 2023
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Appendix E
Appendix E: Use of the Community Water Systems Service Boundaries
Dataset
The CWSSB dataset uses a 3-tiered approach to assign more specific boundaries to PWS service areas.
Tier 1 includes all PWS with explicit water service boundaries provided by states. Tier 2 assigns a
boundary based on a match with a TIGER place name. Any PWS not in tier 1 or 2 is assigned a circular
boundary around provided water system centroids based on a statistical model trained on explicit water
service boundary data.
About 60 percent of PWS are defining service areas with a much higher specificity (Tier 1 and 2 service
area boundaries) than what we had done for prior rulemakings. For these prior rulemakings, we identified
service areas at the specificity of individual zip code tabulation areas (ZCTA) using a combination of a
crosswalk of PWS to supplied ZIP codes available through the Fourth Unregulated Contaminant
Monitoring Rule (UCMR 4) and ZIP codes associated with the PWS from the Safe Drinking Water
Information System (SDWIS) database. Forty-one of the 198 water systems included in the MPP analysis
do not have a match with the CWSSB dataset. For the 41 PWS without a match in the CWSSB dataset
EPA attempted to use the ZCTA to identify service areas related to the ZIP code from the SDWIS
database. EPA identified 16 PWS with a SDWIS ZIP code outside of the state served. In these instances,
the county boundary was used for the service area.
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Appendix F
Appendix F: EJ Literature Review Methodology, Sources and Search
Terms
Methodology
The goal of this search was to discover literature that described the environmental impact of MPP
facilities on communities exhibiting EJ characteristics of concern, focusing primarily on the pollution of
water and water-impacted resources by these facilities. Searches were restricted to U.S. studies, data
research, and other literature from the year 2005 and forward. Literature that solely described political
issues, legal analysis, or activism around this issue was eliminated, as was literature that solely described
the impacts of animal feeding operations. Studies on the negative health impacts of consuming processed
meats were also excluded.
A great number of search results were eliminated for poor applicability, or failure to fit geographic
requirements. Many were also discarded for exclusive focus on occupational-health type workplace
injuries to slaughterhouse and meat packing/processing workers. Finally, many results were held back for
inclusion in the concurrent animal feeding resource search. The most directly applicable resources tended
to come from non-governmental organizations (NGOs).
Sources Used
Scopus - Major academic abstracts database, containing approximately 36,000+ peer reviewed titles and
81 million documents. Searches of 300 results and under were reviewed manually. Note, as an abstracts-
only database Scopus searches are limited to matches on specific fields such as abstracts, titles, and
author-provided keywords. Full text searching is not possible.
Dimensions - This is a major academic abstracts database that was added as a check against Scopus for
the purposes of this search. Dimensions contains 129,000,000+ publications as of July 2022, not counting
other record types. It is larger than Scopus, but it is less capable of extremely fine-tuned searches. While
every item identified by Dimensions was also findable in Scopus, the different weighting algorithms of
the two databases meant that different results were prioritized in each database and some resources
located in Dimensions were not initially identified by Scopus.
Google Scholar - Used as an additional backup for academic searches. As in previous topical searches for
this contract, the first 10 pages of results were reviewed. Additional pages were reviewed until at least
three pages with no relevant results had been reviewed.
Hein Online - Legal database containing legal journals, case law, and other legal commentary. This
resource was useful from legal/property zoning perspective, and it uncovered some useful articles in the
realm of nuisance odor and noise complaints, from the perspectives of both the packing/processing
facilities and their residential neighbors. However, much of this material was more suited to the
companion search on animal feeding and its impacts upon EJ communities and was saved for that
purpose.
News sources- Documents in major news publications and online news sources that included the key
search terms were searched. Sources included:
ProPublica
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Appendix F
New York Times
Wall Street Journal
Local news sources
Grey literature- Documents from research forums, nonprofit groups, and institutions were identified.
These sources included:
Center for Economic Policy and Research
Environmental Integrity Project
Earth Justice
Environmental America Center
Environmental Protection Agency and U.S. Department of Justice Reports
Trade Publications- A low level of coverage for this topic in trade publications. The majority of water-
cleanliness articles were concerned with capturing and removing contaminants purely in order to re-use
the water for other slaughterhouse activities.
A large group of potential sources were identified initially by the EPA, and further sources were
identified over the course of follow up. We initially reviewed the sources' websites directly, looking at
pages such as Publications or Resources and reviewing the contents. We also employed Google Advanced
Search, searching individual domains for small groups of top-level terms from the keywords list. Sources
researched are listed below:
National Cattlemen's Beef Association
American Association of Meat Processors
Niche Meat Processor Assistance Network
US Poultry and Egg Association
National Pork Producers Council
North American Meat Institute
Water Environment Federation
WaterOnline
WaterWorld
Water Conditioning & Purification International Magazine
Water & Wastes Digest
Engineering News Record
Following the standards used in the peer-reviewed literature searches, we looked for items from 2005 and
later that included analyses, best practices, data, methodologies, research, studies, and tools used in the
US. We found that the majority of these sources did not offer any content that fit these requirements, but
we did locate a small number of items in WaterOnline and Water & Wastes Digest.
Search terms
Search terms were determined by EPA. They were grouped into categories and constructed into a series
of Boolean-logic searches that paired segments of group 1 terms with segments of group 2 terms in
succession.
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Appendix F
Terms from group 3 were added as modifiers when needed. This was particularly necessary when
performing searches using terms in groups 1A and ID, which frequently yielded several thousand hits on
first attempt. For example, the query [("animal harvest" OR "meat curing" OR "meat dressing" OR "meat
processing" OR "meat products" OR "meat smoking" OR slaughtering) AND ("education" OR "low
income" OR "median household income" OR poverty OR "socioeconomic status" OR "disadvantaged
community")] generated 2,764 hits in Scopus. This was reduced to 7 with the addition of the modifier
[AND ("Drinking water contamination" OR "odors" OR "occupational hazards" OR "fish kills" OR
"subsistence fishing" OR "recreational area contamination"). This is also an example of a search where
the initial query was first cut down into smaller concurrent searches to prevent overlooking valuable
resources. See Table F - 1 for the Boolean search terms used by group.
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EAfor Proposed Revisions to the Meat and Poultry Products ELGs
Appendix F
Table F -1: Environmental Justice Literature Boolean Search Terms by Group
Group 1
A
B
C
D
Animal harvest
Halal
Beef processing
Packinghouse
Meat curing
Kosher
Ham processing
Slaughterhouse
Meat dressing
Luncheon meat
Pork processing
Abbatoir
Meat processing
Pet food
Poultry processing
Meat products
sausage
Poultry products
Meat smoking
Slaughtering
Group 2
A
B
C
D
E
F
Disproportionate
impacts
Communities of color
education
Environmental equity
Human health
Water quality
Differential exposure
Vulnerable
population
Low income
Environmental justice
immunocompromised
effluent
Differential risk
Childhood exposure
Median household
income
Geographic equity
mortality
Water treatment
Exposure pathway
Social vulnerability
poverty
Water insecurity
susceptibility
Environmental impact
assessment
elderly
Socioeconomic status
underserved
Health impact assessment
racial
Disadvantaged
community
ethnicity
Racial equity
minority
sociodemographic
rural
Group 3
A
B
C
Nitrogen
E. coli
Drinking water contamination
phosphorous
Antibiotic resistance
odors
nutrients
Animal antibiotics
Occupational hazards
Oxygen demand
Suspended solids
Fish kills
Fecal coliforms
Dissolved solids
Subsistence fishing
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Appendix F
Table F -1: Environmental Justice Literature Boolean Search Terms by Group
Recreational area
contamination
Source: U.S. EPA Analysis, 2023
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