The meat and poultry industry could soon see major changes in requirements for dealing with wastewater in operations, including updated effluent limitation guidelines (ELGs) for the first time since 2004 and new requirements for nitrogen and phosphorus removal. The EPA’s proposed rule, which was released in December 2023, would apply to both direct and certain indirect dischargers, with stricter standards for nitrogen and, for the first time, phosphorus. While a final rule is anticipated by August 2025, the exact requirements and affected facilities may still change as the EPA considers multiple regulatory options and ongoing industry feedback.
Processors are strongly advised to proactively assess their current wastewater management systems and budget for potential capital improvements, as compliance could require significant upgrades, including new treatment technologies and operational changes. The EPA has indicated that flexibility will be built into the rule, allowing facilities to choose among different technologies and operational strategies for compliance. Facilities should also consider the potential for increased costs and longer compliance timelines, as well as the need for trained operators and possible changes in production processes.
Chris Knodel, PE, industrial wastewater manager with 20 years in the wastewater industry, and Brian Chrisman, protein manufacturing development manager with 30 years in protein and food processing operations at Burns & McDonnell, share their perspectives on how the meat and poultry industry can prepare for the EPA’s revised wastewater standards.
What emerging regulatory guidance is influencing meat and poultry processors’ facility expansion efforts?
Chris Knodel: The EPA has proposed amending current wastewater regulations for meat and poultry processing facilities. These regulations would reduce nitrogen, phosphorus and organic matter in discharge water.
The new regulations, known as ELGs, are still in the proposal stage after more than six years of discussion. Our clients are seeking guidance as regulatory approval timelines remain uncertain. With the new administration, there is always the potential for change, so processors are advised to proactively assess their current wastewater management systems and budget for potential capital improvements.
Brian Chrisman: The new administration has not yet implemented any specific regulatory rollbacks impacting meat manufacturers. However, the Meat Institute has recently urged the administration to take action on several regulations, including the withdrawal of the EPA rule.
If the rule is approved, the rule would significantly impact many facilities by shifting them from relying on municipal treatment systems to adopting in-house or upstream pretreatment solutions. Our team is already working with processors to help them strategically balance facility upgrades while proactively preparing for stricter environmental regulations.
What are some key wastewater handling considerations for processors?
CK: Meat and poultry processing facilities typically fall into two wastewater handling categories:
- Directly discharged into the nation’s waters.
- Indirectly discharged into Publicly Owned Treatment Works (POTWs).
Addressing nutrient loading from meat processing facilities requires a comprehensive approach, with control at the source being an efficient strategy. Processors should evaluate options for reducing nutrient loads, particularly nitrogen and phosphorus, in their wastewater treatment processes.
This may involve upstream controls such as adjusting production processes and limiting sources like blood and certain cleaning agents. To effectively reduce pollutant discharge and meet proposed EPA standards, some facilities may need to segregate and manage high-salt waste streams while implementing new wastewater treatment technologies, including biological treatment and ion exchange technologies.
Meat and poultry products are among the largest sources of industrial nutrient pollution in the country. These include oil and grease, organic material, salts, ammonia, and significant quantities of nutrients such as nitrogen and phosphorus.
The primary sources of nitrogen and phosphorus in meat processing wastewater include blood and tissue residues, cleaning and sanitizing agents, animal waste, and processing byproducts like brine.
How can a plant’s overall operational efficiency foster regulatory compliance for meat processing operations?
BC: Implementing advanced processing technologies reduces water consumption while meeting evolving EPA standards. Some strategic approaches include:
- Optimizing cleaning and sanitation procedures to lower pollutant loads in wastewater.
- Exploring water reuse and recycling opportunities within the facility to decrease overall discharge volumes while advancing sustainability initiatives.
- Monitoring and collecting data regularly on wastewater quality to stay ahead of regulatory requirements.
- Implementing comprehensive microbiological testing programs to verify process control.
- Designing facilities with effective temperature control, ventilation and cleaning systems to uphold high standards for food safety.
Some operational impacts could involve upfront costs for system upgrades, increased operating expenses for water treatment, potential production process modifications, and following compliance timelines that could span three to five years post-finalization.
Additionally, estimated capital and operational expenditures for compliance could vary widely depending on facility size, existing conditions and current wastewater processes. Licensed operators trained in biological treatment systems would be necessary, and additional costs for treatment chemicals and power should be expected.
Conducting a feasibility study for modernizing operations can help processors:
- Evaluate current processes and identify necessary improvements.
- Explore collaborative solutions with public utilities or municipalities for pretreatment and compliance.
- Strategically plan capital investments and project execution to balance cost controls with accelerated regulatory timelines.
- Thoughtfully consider the right project delivery method for your business needs.
How do processors’ sustainability goals intersect with regulatory trends?
CK: From a water management perspective, investing in water conservation and treatment technologies can support both compliance and sustainability objectives. Implementing water reuse systems can save a significant amount of water per year, supporting regulatory compliance while reducing operational costs.
From a resource recovery perspective, biogas recovery offers a dual benefit: reducing emissions while offsetting energy consumption. Facilities with high-strength wastewater can leverage anaerobic digestion to produce biogas, which can then be used in combined heat and power (CHP) systems. This approach not only supports energy efficiency but also aligns with regulatory requirements.
Transitioning to renewable energy sources and improving energy efficiency are critical for reducing carbon emissions. Manufacturing facilities can adopt solar, wind or biogas-based energy systems to meet emerging sustainability regulations. Additionally, optimizing processes like heat exchange recovery maximizes energy use while lowering costs.
BC: Manufacturing companies facing mandatory facility upgrades must carefully balance cost controls with accelerated timelines — a challenge that intensifies under this potential rule. While speed to market remains a critical priority, protein processors now confront the added pressure of executing substantial, fast-tracked facility upgrades.
Additionally, the estimated capital and operational expenditures required for compliance are likely to vary significantly based on factors such as facility size, existing infrastructure and the current state of wastewater treatment processes. The licensed operator’s knowledge and experience will need to be accounted for in advanced biological treatment systems, which would be essential for meeting the new standards. The amended regulation would necessitate an additional level of treatment, leading to increased costs for treatment chemicals, energy consumption and overall system operation. These added expenses should be anticipated as part of the broader effort to achieve compliance with the updated requirements.
Leveraging innovative project delivery frameworks, like front-end planning (FEP) and the engineer-procure-construct (EPC) approach, allows manufacturers to confidently focus on bringing their products to the market faster while maintaining robust cost control and compliance with regulatory standards.
FEP offers long-term value by reducing risks, optimizing schedules and improving cost efficiency. When applied strategically, FEP can deliver predictable outcomes, resulting in cost savings and shorter timelines.
The EPC approach offers the ability for concurrent engineering and construction activities, enabling flexibility to meet evolving regulatory requirements while maintaining quality standards. Sustainable resource management in manufacturing requires a multifaceted approach that integrates water conservation, resource recovery, renewable energy adoption and efficient project delivery to achieve regulatory compliance while driving cost savings and sustainability goals.
Being proactive, staying informed and leveraging strategic project delivery approaches, as well as partnerships, allows meat processors to smoothly navigate upcoming challenges and maintain efficiency and compliance. For ongoing updates, stay connected with preferred partners, industry publications and regulatory agencies to anticipate and quickly respond to ongoing regulatory developments.
