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Beer Disposal & Regulatory Considerations In Connecticut

Beer Disposal & Regulatory Considerations in Connecticut

As bars and restaurants across the country prepare to reopen, breweries are facing a new challenge: out-of-code beer.

According to an article in the Wall Street Journal, citing data from the Brewer’s Association, a million kegs of beer are expected to go out-of-code due to Coronavirus shutdowns.

This post has been written in collaboration with Connecticut Brewers Guild, Inc., and is intended to provide resources for brewers to dispose of out-of-code beer responsibly and in accordance with all applicable environmental regulations in the State of Connecticut.

Additional resources from the Brewer’s Association, Alcohol and Tobacco Tax and Trade Bureau (TTB), and other articles should be referenced when developing a plan for the disposal of out-of-code beer. The Brewer’s Association has updated their Best Practices for Disposal of Beer and TTB has updated their Beer Destruction FAQ addressing situations resulting from the Coronavirus.

Below are options for disposing out-of-code beer in Connecticut and corresponding environmental regulatory information and considerations.

Distillation for Hand Sanitizer

Out-of-code beer can be used as an ingredient to support the production of hand sanitizer. Some craft distilleries have transitioned to the production of hand sanitizer. Communicate directly with the craft distilleries to understand their needs and whether they are equipped to accept out-of-code beer.

There are no environmental regulations associated with transferring beer to distilleries for conversion into hand sanitizer; however, distilleries should evaluate how out-of-code beer may change their waste streams and wastewater discharges. Distilleries, like brewers, must continue to comply with discharge limits for wastewater sent to their local publically owned treatment works (POTW). Brewers should refer to the TTB and Brewers Association for regulations addressing the destruction of beer. The Brewers Association’s Best Practices for Disposal of Beer details exceptions to the distilled spirits plant/alcohol fuel plant regulations as well.

Food Waste-To-Energy

Biogas. It is produced by anaerobic digesters and is used to generate electricity. Quantum Biopower in Southington, CT operates the state’s only food waste-to-energy plant and produces biogas from food waste. The process uses natural biology to ferment food waste, in controlled conditions, producing biogas, which is used to generate electricity.  Quantum can accept any food waste including liquid wastes (i.e. out-of-code beer), as well as other waste streams that are typically produced by breweries and food waste producers.

In 2011, the State of Connecticut passed its food waste diversion mandate (Commercial Organics Recycling Law) which requires the reduction of the amount of food waste that gets landfilled or incinerated in Connecticut. Quantum has the ability to receive these materials, including bulk, aluminum can, and plastic bottle beverages.  In addition, brewers should refer to the TTB and Brewers Association for regulations addressing the destruction of beer and the tax implications.

Discharge to Sanitary Sewer

If you are considering discharging out-of-code beer to the sanitary sewer, it is important to contact State and local regulatory agencies, and develop a plan to comply with the applicable regulations and prevent impacts to your local POTW.

Spent beer is a high strength wastewater.  An unfiltered beer at 6% ABV has an average biological oxygen demand (BOD) of greater than 80,000 parts per million (ppm).  For comparison, residential sanitary wastewater has a typical BOD of 200 ppm.  If your POTW can handle the high BOD load, you may be able to discharge with minimal constraints, but you will likely be assessed a surcharge for the high BOD wastewater.  Otherwise, the POTW may require you to reduce the impacts by limiting the volume of beer discharged per day, and discharging at night or during periods when POTWs receive lower residential BOD loads.  If your local POTW is seeing a decreased usage rate and is operating at a BOD deficit, they may be willing to negotiate a reduced BOD surcharge

Other considerations for the discharge of beer to the sanitary sewer are pH and foaming.  State regulations require a discharge with a pH greater than 5, and prohibit discharges that cause foaming at the POTW.  Individual POTWs may have more stringent requirements for pH.

State regulations regarding wastewater discharges can be found on the State of Connecticut website under Section 22a-430.  The State of Connecticut issues both individual permits and general permits for wastewater discharges which provide specific requirements based on the type of wastewater generated.  Most brewers in Connecticut will fall under the General Permit for Miscellaneous Sewer Compatible Wastewaters (MISC GP).  Local ordinances may be available through your city/town website, or may available on a dedicated POTW or Sewer Authority website.

Alternative Carbon Source for POTWs

Breweries may also consider shipping the out of code beer to POTWs for use as an alternative carbon source in POTW treatment processes. By shipping out of code beer to the POTW, it allows the POTW to add the spent beer in a controlled manner based on their process needs.  POTWs require a source of carbon to in several areas of the treatment process to maintain efficient operation.  Under controlled conditions, the addition of a carbon source in specific areas of a POTW can be beneficial to their operation, specifically in the denitrification process.  A POTW in Montana has been experimenting with this process, and received an honorable mention from the EPA for their approach in 2019.  The work performed in Montana was focused on conventional waste products generated from breweries (e.g. spent grain), however this process may also apply to spent beer, and could be a mutual benefit to both brewers and POTWs.  If you are considering this option, it is important to discuss this with local POTWs to see if they can accept the spent beer for use in their treatment process.

There are waste disposal regulations that apply to shipping beer as a waste product, however there are exemptions to the waste regulations if the beer is considered a product and not a waste.  In addition, brewers should refer to the TTB and Brewers Association for regulations addressing the destruction of beer and the tax implications.

Contact Information

If you have any additional questions or concerns regarding disposal of out-of-code beer and would like to discuss local and state regulations, please reach out to the Connecticut Brewers Guild or Loureiro (info@loureiro.com).

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