You might want to investigate how maildrop implements this.  From
http://www.flounder.net/~mrsam/maildrop/:

  Unlike procmail, maildrop will not read a 10 megabyte mail message
  into memory. Large messages are saved in a temporary file, and are
  filtered from the temporary file. Temporary files are saved in the
  user's home directory. If the standard input to maildrop is a file,
  and not a pipe, a temporary file will not be necessary.

A similar approach has been suggested[1] for TMDA in the past.

Footnotes: 
[1]  http://mla.libertine.org/tmda-users/2002-07/msg00186.html
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