Winter 2019

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recognized for preserving and enhancing the water environment in the Pacific Island Region.

Craft Brewery Impact on Waste Water Treatment

By Chris Pasch and Ashley Lewis

Over the last five years municipalities across Texas have seen craft breweries setting up shop. These new businesses are generally welcomed by the community, but the wastewater generated by these breweries can pose potential problems, particularly for smaller municipalities with limited treatment capacity at their Water Resources Recovery Facility (WRRF) [The term water resource recovery facility is used because the Water Environment Federation (WEF; Alexandria, Va.) uses the term in place of wastewater treatment plant and other conventional names.

The name change reflects a changing paradigm in the water sector, focusing on resource recovery.] Potential problems include difficulty treating the high strength wastewater, regulating the new discharge within existing ordinances, and establishing permit limits through the municipality’s pretreatment program. Furthermore, brewers may be surprised to learn that their wastewater can be detrimental to WRRF processes and that their discharge may not comply with local pretreatment ordinances.
Surely these problems are preventable. A proactive approach to management of brewery wastewater should be a top priority for Texas utilities. This article provides a summary of the brewery business and a discussion of how utilities can prepare for handling and regulating brewery wastewater.

Cities Welcome the New Business
The significant growth in the craft brew business can be directly linked to a change in State law regulating small breweries. In 2013 the Texas Legislature passed a law allowing breweries to sell beer onsite and brewpubs to sell beer outside of their own facilities (i.e., in retail stores). This deregulation created opportunities and resulted in many new breweries being founded. According to the website, in August 2018, Texas had 244 brewpubs, brewpubs combined with a brewery, and microbreweries in operation. Two thirds of these breweries went into operation after 2013. Prior to 2013, there were 68 craft breweries in Texas Figure 1 presents the annual increase in the number of craft breweries since.
It is reasonable to assume that the craft brew business will continue to grow in Texas as new breweries launch and existing breweries expand their operations. Most cities would welcome a new brewery to town, and cities that do not yet have a local craft brewery may even consider copying the efforts of the City of Madras in Oregon. The City thirsts for a brewery to come to town and is promoting itself to potential brewers on the website
Real Ale Brewing Company is an example of a brewery’s significant impact on a small Texas town. Real Ale Brewing company picked the City of Blanco 24 years ago for the reliable water supply with the right water chemistry for its Real Ale beers such as Firemans #4. Real Ale owners, Gabriel Gregerman and husband Brad Farbstein, founded a small basement operation in 1996. The operation has grown significantly since and is now one of the largest breweries in Texas, employing over 50 people.

Real Ale partnered with the City of Blanco as the brewery expanded and wastewater discharges increased. When treatment capacity at the City’s WRRF was no longer able to handle the projected treatment needs, Real Ale invested over a million dollars in a pretreatment system. Business grew rapidly while the pretreatment facility was being designed and built. In the interim period, Real Ale had to divert high-strength wastewater to a haul-off tank, thereby reducing the biochemical oxygen demand (BOD) load to levels that the WRRF could treat.

In the Real Ale pretreatment system, the 100 to 110 degrees Fahrenheit waste stream is filtered and the solids are dewatered. The liquid waste is pumped to a settling tank and then to a pH balancing unit. The waste stream is seeded with commercially sourced bacteria to facilitate aerobic digestion in a lagoon system with a 21-day retention time. The pretreatment system also includes pH balancing equipment designed to treat spikes of 160-degree Fahrenheit caustic cleaning solution. The system routinely reduces the BOD to less than 200 milligrams per liter (mg/L) before discharging to the collection system. The City levies a surcharge on Real Ale when its discharge exceeds 200 mg/L BOD.

Brewery Wastewater Generation
The Reinheitsgebot, also called the “German Beer Purity Law”, is a regulation limiting the ingredients in beer in Germany. In its early version, the Gebot stipulated that beer was only to be brewed using water, malt and hops. Yeast was not known to exist in the 16th century and was added at a later date. These main ingredients are still used in making beer, however, many modern-day breweries add other ingredients. Since the primary ingredients are
organic and most of the ingredients do not end up in the beer, breweries discharge high-strength wastewater. Other chemicals and products used for brewing, cleaning, maintenance, and labeling are also discharged to the collection system, the combination can make for a complex waste stream that can be of concern to the utility.

Typical Wastewater Composition
Most often BOD and pH from the brewery waste discharge are the primary concern to the utility. Temperature can also be a concern because hot water can be dangerous to maintenance personnel working in the collection system. Additionally, the brew process requires a lot of water. Only a tenth to a quarter of water used may be used for the good stuff and the rest is discharged. The primary constituents of brewery wastewater include the following:
• Wort Liquid extracted from the mashing process.
• Beer When the good stuff goes bad and needs to be wasted.
• Trub Solids composed mainly of heavy fats, coagulated proteins, and inactive yeast.
• Propylene glycol Used to control temperature during fermentation cooling of beer. Could be in discharge due to leak.
• Label glue Used in bottling operation, the clean-up wastewater can be high in BOD.
• Defoamer Used to control foam during the fermentation process.
• Cleaner Caustic, Phosphoric Acid, Nitric Acid, Peracetic Acid, Quaternary Ammonium Compounds
• Detergents Soap

Hydrogen sulfide may also be detected in brewery wastewater. Hydrogen sulfide will form when brewery wastewater undergoes anaerobic digestion, the digestion is typically not intentional. Hydrogen sulfide is primarily a problem to the breweries because of its corrosivity, however, corrosion can lead to unexpected discharges from the brewery when equipment fails and pipes disintegrate. Hydrogen sulfide can also cause corrosion and odor problems inside the collection system.

Discharge of Acid
Passivation is the treatment of stainless steel with acid to form a protective surface oxide layer and can prevent contamination of the beer by iron, which can ruin the taste. Passivation is required for new equipment, but some breweries use periodic passivation as a cleaning procedure to remove rust spots, free-iron deposits, beerstone, hard water scale, and other mineral deposits.

Brewery Impact on the Utility Operation
Breweries operate in a batch mode, resulting in fluctuating wastewater flows from the brewery into the collection system and to the WRRF. The utility operating a smaller treatment plant will need to understand the business cycle of the brewery and the magnitude of high-strength waste loads and determine whether these loads can be treated adequately. Large metropolitan WRRFs have the capacity to treat the high-strength waste from a typical craft brew operation. Independent of size, WRRFs may have issues with other wastes from the breweries.
Corrosion due to the brewery wastewater containing corrosive chemicals used by the brewery or due to the formation of hydrogen sulfide would most likely occur in the collection system. Periodic inspection of the sewer line, manholes, and lift stations downstream of a brewery discharge may be necessary to identify maintenance issues.

Communication as Prevention
Clearly communicating utilities’ position and local discharge restrictions can be beneficial in preventing unnecessary problems. Brewers may not understand the potential negative impact of their waste on wastewater treatment processes and the expense associated with treating a high-strength waste stream. The utility personnel may have an appreciation of the final brew product but may not appreciate the complexity of the brew process. Establishing good communication lines can serve to identify potential problems and potential solutions before they problems ever occur.
An option to consider is to invite the brewer to the WRRF and explain the treatment processes. Both the brew master and the wastewater treatment operator depend on microorganisms to function well to achieve the desired final product. A brewer will likely understand and appreciate the complexities of the biological wastewater treatment processes more so than many dischargers and will grasp the need to protect the processes, and the difficulty to recover from a disrupted process. Furthermore, it will be advantageous for utility personnel to visit the brewery to gain an understanding of the operation and assess the potential impact on the WRRF.
Communication can be used to educate the brewer on:

• Need to meet requirements in local ordinance for discharges of non-domestic wastewater.
• Need for surcharges to treat high-strength wastes.
• Need to prepare a plan to prevent slug loads from entering the collection system because a slug load can disrupt the treatment process.
• Need to control pH to limit corrosion and other undesirable chemical reactions in the collection system.
• Need to control temperature and pH to protect utility maintenance personnel and the collection system.
• Need to control discharge flow, especially when the municipality’s collection system is already near capacity.
• Need to protect the WRRF processes. A disrupted WRRF can harm the environment and can be costly to both utility and the brewery.

Regulating Breweries’ Discharges to the Collection System
City ordinances regulate the discharge of non-domestic wastewater to the collection system. The ordinance will restrict the discharge of high and low pH wastewater. The ordinance may have narrative restrictions that apply to breweries. An example of a narrative restriction applicable to breweries is the prohibition of a discharge to the collection system that causes interference of the wastewater treatment processes. The ordinance may also include BOD and TSS limits. Brewers have been surprised to learn, some after starting their operation, that the municipality has uniform concentration limits for BOD and TSS of 200 or 250 mg/L, each, and have no provisions for surcharges.

Over 70 utilities in Texas have an approved industrial pretreatment program. The Texas Commission on Environmental Quality (TCEQ) may require development of a pretreatment program when the utility meets the following conditions:
• Design flow greater than 5 million gallons per day
• Industry discharges pollutants to collection system that can either pass through the treatment plant or interfere with wastewater treatment process
• At least one industrial user discharging to collection system meets the U.S. Environmental Protection Agency (EPA) definition of categorical industrial users (CIUs). [Breweries are not CIUs.]

Utilities with a TCEQ approved industrial pretreatment programs regulate breweries through the authority of the pretreatment program. Pretreatment programs in Texas use different approaches to regulate breweries, ranging from issuing permits with discharge limits to only monitoring the brewery discharge for the assessment of surcharges. The same approaches used by approved programs can be used by all utilities. The following summarizes the responses of an informal survey among members of the WEAT Pretreatment Knowledge Committee and other industrial pretreatment coordinators in Texas.

Sme Texas utilities regulate breweries by issuing permits with concentration-based discharge limits. Limits are typically specified for BOD, TSS, and metals.

A maximum discharge temperature may be specified and an upper and lower pH as well.

An advantage of regulating through permit is that it is specific to the permittee and spells out very clearly what is expected of the permittee, reducing the chance of a misunderstanding. Furthermore, it could provide advantageous when a utility enforces on a brewery for noncompliance. The informal survey did not identify any utility where a brewery was in persistent noncompliance. However, a large brewery in Pennsylvania proved an unfortunate example to the brewing industry when continued noncompliance with the utilities pretreatment permit resulted in an EPA enforcement case against the brewery and a multimillion dollar fine.

Passivation Notification
For the protection of sanitation workers and the collection system, at least one Texas utility requires breweries to notify the pretreatment program coordinator at least 72-hours prior to passivating the stainless-steel brew tanks. Passivation, which is not unique to breweries, requires strong acids. Nitric acid, phosphoric acid, and citric acid are typical ingredients in the passivation process. Passivation must be followed by a neutralization step prior to discharge to discharge to the collection system.

[Passivation is also used in the metal plating industry and the term is used in the definition for metal finishing CIUs. This has led some pretreatment program coordinators wondering whether breweries that employ passivation need to be classified as CIU. However, at this time there has been no additional guidance from the EPA to say that breweries would fall under the Metal Finishing regulations and would therefore be a CIU.]

Maximum and Minimum pH Limits
City ordinances include pH limitations. At least one utility specifically requires that breweries must install pretreatment equipment to achieve an effluent discharge with a pH of no lower than 5.0 and no higher than 10.0.

Best Management Practices
At least one utility outlined best management practices (BMPs) specifically for small breweries. BMPs include solids management, pH control, prevention of high-strength slug loads, temperature control to below 150-degrees Fahrenheit, and prevention of discharge from a spill.

Discharge Monitoring
Several utilities monitor the brewery discharge and assess surcharges for high-strength wastewater. At least one utility assesses the monitoring data to determine whether a brewery should be permitted.

The craft brew industry has seen significant growth in Texas and growth is likely to continue. Municipalities have welcomed these new businesses and breweries have generally been very good neighbors. Benjamin Franklin is quoted as saying “an ounce of prevention is worth a pound of cure.” Realizing that this quotation may be misunderstood within the context of this article, it nevertheless holds true as it pertains to preparing for and working with existing or new craft breweries coming to town.

The author thanks Brad Farbstein, owner of Real Ale Brewing, for sharing his extensive experience and Joseph Fielding, City of Dallas. Manager III – Pretreatment Operations for review of draft. Author would like to thank the following individuals for sharing information about their pretreatment programs: Tammy Y. West, City of Austin, Pretreatment Compliance Supervisor; Joe Gildersleeve, City of Arlington Water Utilities, Water Resource Services Manager; Michelle Taylor, City of Garland, Pretreatment Compliance Specialist; Heather Goins, City of Denton, the Pretreatment Program Manager; Carrie Weir, City of Temple, Deputy Utility Director.

• Brewers-Association-Benchmarking-Report.pdf,
• City of Madras, Start a Brewery in Madras,
• D.G. Yuengling and Son, Inc. Clean Water Act Settlement, Washington, DC, (June 23, 2016)
• Real Ale Brewing Company,
• Brewery Wastewater Design,

About the Authors
Chris Pasch is a Senior Project Manager with Alan Plummer Associates, Inc. with over 25 years of experience. Chris assists clients with permit renewals and amendments, pretreatment program modifications, and technically based local limits development. Chris also assists clients in response to whole effluent toxicity test failures, and when permittees need to develop site-specific water quality standards. Chris is member of the WEAT Central Texas Section, the WEAT Pretreatment Knowledge Committee, the WEAT Government Affairs Committee, and the NELAC Whole Effluent Toxicity Expert Committee.

Ashley Lewis is a Project Scientist with Alan Plummer Associates, Inc. with 3 years of experience. Ashley assists clients with permit renewals and amendments, geographic information systems (GIS) projects, and technically based local limits development. Ashley is currently assisting several clients in revising technically based local limits. Ashley is member of the WEAT Central Texas Section and the WEAT Pretreatment Knowledge Committee.



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Hawai‘i Water Environment Association
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