August Mack Newsletter | October, 2019

Environmental Considerations for Craft Breweries
by Shawn Woll

Humans have been brewing beer for thousands of years. The Code of Hammurabi, dating to 1750 BCE, detailed laws that regulated how beer was to be produced and sold. The Catholic monks of Europe created modern brewing and preserved the tradition during tumultuous events such as the fall of the Holy Roman Empire, the French Revolution, and two world wars. Even the founding fathers of America, George Washington, Thomas Jefferson, and Benjamin Franklin, had their own recipes for beer. Today, beer is still loved by many and is the third most consumed beverage worldwide, behind water and tea.

In the United States, much of the beer that is consumed comes from craft breweries. The craft beer industry has been the centerpiece for much of the economic revitalization in many small towns and cities across the United States. Craft breweries have experienced success due to their ability to push boundaries and cater to and adapt to changing local tastes. With all of the success that the industry has been having, it is sometimes easy to overlook the fact that brewing is a process that may trigger environmental permitting and compliance.

The number one environmental consideration that craft brewers need to be aware of is wastewater requirements. The process of brewing beer creates wastewater that is high in organic compounds. Because of the high concentration of organics, many publicly owned treatment works (POTWs) may impose a surcharge on a brewery due to the high cost of treating their wastewater. Most POTWs are designed to treat sewage and sanitary wastewater not industrial wastewaters like that from brewing. Depending on the breweries distance to a local POTW, an on-site treatment system that acts as a septic system may need to be installed. Additionally, some POTWs may have pre-treatment requirements, to reduce contaminants, which may cause a brewery of the need to install holding tanks and/or pre-treatments systems.

In addition to wastewater, storm water discharge should be evaluated at the brewery to determine compliance. If a brewery is expanding and disturbing a specific amount of land, a storm water permit for construction may need to be obtained. This permit helps control sediment and contamination runoff from a construction site due to a rain or snow event. If a brewery is storing materials, byproducts, and /or waste outside an industrial storm water permit may need to be issued to control storm water discharge at the facility. If there is no outside storage, your brewery may be able to obtain a No Exposure Certification in lieu of a storm water permit.

Once wastewater and storm water issues are evaluated, breweries must evaluate air and solid waste issues. An air permit is required for any air pollution source unless that source is considered exempt. A source of air pollution is anything that emits dust, fumes, mist, smoke, vapors, or odors. In the brewing process, a source may be grain handling equipment. However, depending on the operation size there may be additional sources such as fermenting equipment or backup generators. Solid wastes such as spent grains, yeasts, and diatomaceous earth may be produced during the brewing process. Understanding the solid wastes produced and characterizing the waste is vital to compliant operations. Certain solid wastes may be considered hazardous (fluorescent light bulbs, caustic cleaners, batteries, etc.) and may need special disposal. Other wastes may be able to have beneficial reuse such as spent grains being used for animal feed or a fuel source for power generation.

While this is by no means an exhaustive list of environmental considerations for craft breweries it is a starting point. If you are in the early stages of opening a craft brewery or brewpub it is important to not overlook if your operations will trigger environmental regulations. This will allow ample time to plan how the brewery will comply with the environmental regulations. If you are currently operating a craft brewery, it is important to get a handle on your operations compliance or non-compliance with environmental regulations. This will help with mitigating and eliminating potential environmental, health, and safety risks. If you are not sure where to begin, August Mack has experience with large breweries as well as craft breweries and can be a valuable resource to assist in determining what environmental regulations may apply to your operations.


Shawn Woll is the Business Development Representative for August Mack Environmental, Inc. in the Lancaster, Pennsylvania office. He has industry experience in geologic field services, sustainability, and, design and installation of renewable energy systems. Shawn heads the business development in the Pennsylvania office focusing on compliance, transaction, and eCAP clients. Shawn earned a Bachelor’s of Science degree in Geoscience from The Pennsylvania State University. Shawn can be reached at 717.399.9587 ext. 227 or via email at swoll@augustmack.com


Upcoming Webinars
Michigan Webinar Series: Non-Scope Considerations in Real Estate Transactions
Going the Distance - Implementing Continuing Obligations at Contaminated Properties
What Are My Compliance Requirements for a Reciprocating Internal Combustion Engine (RICE)?
Upcoming Events
August Mack Continuing Legal Education Event in Illinois
2019 Conference on Environmental Liabilities, Risk Assessment, and Remediation

August Mack Blog Augsut Mack LinkedIn August Mack TwitterAugust Mack Google PlusAugust Mack YouTube Channel

© August Mack Environmental, Inc.