New EPA ELGs May Signal Big Changes for Meat and Poultry Processors

Prepare for Expected Updates to Protein Industry Regulations

On the heels of a detailed 2021 study of meat and poultry processors, the U.S. Environmental Protection Agency is expected to release significant changes to Effluent Limitations Guidelines, or ELGs, for the protein industry. The EPA last touched these regulations in 2004, updating the original ruling made in 1974, but the agency says they only apply to about 180 of the estimated 5,300 meat and poultry facilities in the United States today, hinting new regulations will be more restrictive.

To understand more about what could be coming and what you can do to prepare, we sat down with Project Manager Brian Mulinix, who specializes in industrial wastewater treatment for food processors. 

What could the new EPA ELG requirements look like? 

We don’t know exactly, but we know this would be a big change for the industry. Right now, the regulations only apply to larger facilities that directly discharge wastewater to surface waters. New regulations will likely expand existing guidelines for direct dischargers and establish pretreatment standards to both small facilities and facilities that discharge indirectly through publicly owned treatment works, or POTWs. Three significant impacts expected include: 

  1. Significantly reduced total nitrogen effluent limits for direct dischargers
  2. New total phosphorus effluent limits for direct dischargers
  3. New requirements for indirect dischargers focusing on screening, flow equalization, improved grease removal and nutrient removals

This won’t happen overnight. After the EPA releases its proposal, which could come as soon as late 2023, there will be a period for responses. The EPA will make any revisions and release a final ruling, which will lay out a transition or “ramping up” period before facilities must comply. Usually that revolves around the discharge permit cycle and when facilities need to apply for new or reissued permits. 

What could these requirements mean for the industry?

We think this could really disrupt the industry. Many of these plants would have to revamp a lot of what they’ve done for years, and it would likely be costly. That could mean adding or expanding pretreatment systems and expanding or adding processes to reduce the contaminants. Many processors we work with have old and outdated equipment and will need to look at completely new wastewater treatment plants.

This could keep the industry busy for the next 10-20 years. I would say about 5% to 10% of the plants out there right now would be equipped for these new regulations, and that’s mostly because they are already complying with stricter state or local regulations. For example, processors in the Chesapeake Bay in the mid-Atlantic are working within very low standards for nitrogen and phosphorus in their effluents. 

What should meat and poultry processors be doing now? 

Without knowing the exact endpoint of the EPA’s ruling, they can start by understanding their current systems and having a plan in place to address regulations when they are released. That means beginning at a conceptual level and identifying avenues to reduce or treat contaminants in their wastewater. 

In many cases, this type of work is what we’ve been doing at HDR for many years, and the regulations would force us to take it to another level in terms of water quality. Stringent wastewater treatment is our team’s bread and butter. 

To prepare industry clients for the upcoming regulations, we’re conducting engineering studies, analysis and testing that gives clients an idea of potential costs and timelines for any modifications. We’re answering questions for industry clients like, “What is the capacity of this system? Can we do more with what we have? How many years does this system have left?” We can also help design and implement plans. That could look like completely new pretreatment options — for example, anaerobic digestion — or helping through compliance and operation services.

Brian Mulinix Industrial Wastewater Project Manager at HDR
Industrial Wastewater Project Manager
Matt Bokenkroger | Food & Beverage Practice Lead
Industrial Water/Wastewater Lead