Breweries and distilleries, both large and small, are subject to various environmental regulations due to the materials they handle and the processes they use. From storing hazardous materials to managing wastewater and stormwater runoff, breweries and distilleries must navigate a range of compliance challenges to operate responsibly. This guide provides an overview of the essential aspects of environmental compliance in the brewing and distilling industry, including hazardous material storage (Tier II reporting), stormwater management, and sustainability reporting.
Overview:
Breweries and distilleries typically store various chemicals and hazardous materials, such as cleaning agents, sanitizers, solvents, compressed gases (e.g., CO2), and even ingredients like ethanol. The presence of these materials in certain quantities triggers the requirement for Tier II reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA).
Key Requirements:
Determine Reporting Thresholds: Tier II reporting is required if your facility stores hazardous chemicals above specific thresholds:
Extremely Hazardous Substances (EHS): 500 pounds or the chemical's Threshold Planning Quantity (TPQ), whichever is lower.
Other Hazardous Chemicals: 10,000 pounds is the general threshold.
Chemical Inventory: Keep an updated inventory of all hazardous materials stored on-site. Each material’s Safety Data Sheet (SDS) should be readily available, as it provides necessary information for the Tier II report, including chemical name, classification, and storage conditions.
Annual Reporting: Submit a Tier II report to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local fire department annually by March 1st for the previous calendar year.
Best Practices:
Implement Proper Storage: Store hazardous chemicals in clearly labeled containers and in designated storage areas with secondary containment to prevent spills.
Regular Inventory Audits: Conduct monthly inventory audits to track the quantities of hazardous materials and update your records, ensuring accurate and timely Tier II reporting.
Employee Training: Train employees on the proper handling and storage of hazardous materials and the importance of compliance with Tier II reporting requirements.
Overview:
The brewing and distilling processes generate wastewater that contains organic materials, cleaning agents, and residual alcohol. Discharging this wastewater into public water systems without proper treatment can lead to environmental issues and violations of local water quality regulations.
Key Requirements:
Obtain Permits: Before discharging wastewater, breweries and distilleries typically need to obtain a wastewater discharge permit from their local water authority or Publicly Owned Treatment Works (POTW). This permit outlines the specific limits for pollutants and the acceptable characteristics of wastewater discharge.
Pre-Treatment: Some facilities may be required to pre-treat their wastewater to remove solids, reduce biochemical oxygen demand (BOD), and neutralize pH levels before discharging it into the sewage system.
Best Practices:
Install Pre-Treatment Systems: Consider installing a wastewater pre-treatment system, such as a settling tank, pH adjustment unit, or filtration system, to reduce pollutants before discharge.
Regular Monitoring: Test wastewater regularly to monitor pollutant levels and ensure compliance with permit conditions.
Implement Water Conservation Measures: Reduce the volume of wastewater by optimizing cleaning processes, using high-efficiency equipment, and reusing water where possible.
Overview:
Stormwater runoff from breweries and distilleries can pick up contaminants, such as spilled chemicals, oils, cleaning agents, and organic waste, as it flows over outdoor storage areas, loading docks, and parking lots. This runoff can eventually enter local waterways, leading to environmental pollution.
Key Requirements:
Stormwater Pollution Prevention Plan (SWPPP): If your facility discharges stormwater into a municipal storm sewer or directly into waterways, you may be required to obtain a National Pollutant Discharge Elimination System (NPDES) permit and develop a Stormwater Pollution Prevention Plan (SWPPP). This plan identifies potential sources of stormwater pollution and outlines Best Management Practices (BMPs) to control pollutants.
Best Practices:
Implement BMPs: Incorporate BMPs into your operations, such as using spill kits, covering storage areas, regularly cleaning loading docks, and properly disposing of waste.
Routine Inspections: Conduct regular inspections of stormwater drainage systems, storage areas, and loading docks to identify potential sources of contamination and take corrective actions promptly.
Employee Training: Train staff on the importance of stormwater management and proper spill response procedures to minimize the impact of any accidental releases.
Overview:
Breweries and distilleries produce various types of waste, including spent grains, yeast, packaging materials, and chemical waste. Properly managing these wastes is crucial for environmental compliance.
Key Requirements:
Hazardous Waste: Certain waste products, such as chemical residues from cleaning or laboratory processes, may be classified as hazardous waste under the Resource Conservation and Recovery Act (RCRA) and require special handling, storage, and disposal practices.
Solid Waste: Organic waste, such as spent grains, may be managed as solid waste or can be repurposed as animal feed or compost, provided it complies with local regulations.
Best Practices:
Waste Segregation: Separate hazardous waste from non-hazardous waste and label containers clearly to avoid cross-contamination and ensure proper disposal.
Waste Reduction: Implement waste reduction strategies, such as recycling packaging materials, repurposing spent grains, and optimizing production processes to minimize waste generation.
Licensed Disposal Services: Partner with licensed waste disposal companies to handle the transportation and disposal of hazardous waste in compliance with regulations.
Overview:
In addition to regulatory compliance, many breweries and distilleries are adopting sustainability practices to reduce their environmental footprint. Sustainability reporting allows these businesses to track their progress and communicate their commitment to responsible production to customers, investors, and the community.
Key Elements of Sustainability Reporting:
Resource Usage: Track and report water and energy consumption to identify areas for efficiency improvements.
Waste Management: Monitor waste generation, recycling rates, and waste reduction initiatives.
Carbon Footprint: Calculate and report greenhouse gas (GHG) emissions from brewing and distilling operations, transportation, and energy use.
Best Practices:
Set Measurable Goals: Establish specific sustainability goals, such as reducing water usage by 10% annually or achieving zero waste to landfill.
Use Recognized Frameworks: Utilize established sustainability reporting frameworks, such as the Global Reporting Initiative (GRI) or B Corp certification, to structure your reports and align with industry standards.
Transparency: Share sustainability reports publicly to demonstrate your commitment to environmental stewardship and engage with stakeholders.
Breweries and distilleries face unique environmental compliance challenges due to their use of chemicals, water-intensive processes, and potential impact on local ecosystems. By implementing best practices for hazardous material storage, wastewater and stormwater management, and waste disposal, as well as adopting sustainability reporting, your facility can operate efficiently while meeting regulatory requirements and contributing to a healthier environment.
Need Help Navigating Compliance? Our team of environmental compliance experts can assist you in developing tailored solutions for your brewery or distillery, ensuring you meet all regulatory obligations while enhancing your sustainability efforts.
This guide offers breweries and distilleries a comprehensive understanding of essential environmental compliance aspects, along with practical solutions to address these challenges.