BettyAnne Rogers, Pretreatment Coordinator & Laboratory Director Warwick Sewer Authority, Warwick, RI

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1 BettyAnne Rogers, Pretreatment Coordinator & Laboratory Director Warwick Sewer Authority, Warwick, RI

2 Warwick Sewer Authority Advanced Wastewater Treatment Facility 7.7 MGD (5 5.5 MGD) Outfall discharge to Pawtuxet River (along Cranston s & W. Warwick s WWTF) Rigorous RIPDES Permit discharge limits Biological Nutrient Removal/Actiflo TP Removal Very diverse commercial and industrial user base

3 Initial Contact The Phone Call Proclamation Ale Early 2017 Phone call from Proclamation Ale They ve outgrown their current facility in West Kingston, RI and they re looking to relocate to Warwick, RI (me.you ve got my attention) Reaching out to get information on water and sewer charges, building permits, etc. (me.concerned) Aggressively pursuing a lease agreement in the former Leviton Manufacturing facility (me..mildly alarmed) Their plan: to establish a 15,000 sq ft facility with more than 5x production capacity (me panicked) Proclamation Ale What s pretreatment? (me.terrified) Warwick Sewer Authority What do you use for pretreatment in your current facility? (me.anxious) Warwick Sewer Authority We need to meet

4 The WSA reached out to the WWTF receiving Proclamation Ale s process wastewater discharge We confirmed that Proclamation Ale is not permitted nor are they regulated in any way We also reached out to City of Warwick departments (planning, building) There were no records suggesting that Proclamation Ale had initiated the permitting process Additionally, the WSA reached out to several pretreatment professionals for insight regarding brewery wastewater Most had limited information, but reaffirmed our concerns regarding wastestream strength WSA hired ARCADIS to determine if increase in CBOD limit was technically justifiable We have significant CBOD loading that we can offer to those commercial users with elevated CBOD We researched brewery operations and brewery wastes on-line There was a ton of information on-line, we found one web-site that was particularly informative (brewerywastewater.com) We also did some cyber-stalking (like any good pretreatment professional would) They appeared to be genuinely passionate about and experienced in brewing beer They had an impressive following which substantiated their need/desire to grow

5 Purpose: Observe brewing operations and collect samples Numerous tanks to accommodate the various steps in the brewing process Hoses and pumps for transferring brewed liquids to different tanks and for discharging wastewater to the sewer system Floor/trench drains with access to the sewer system lining the front of the tanks for disposing of residual solids, beer and clean/sanitize-in-place (CIP/SIP) fluids Limited side-streaming of solids (Mash Tun) WSA collected samples of the residual wastewater from the Mash Tun and Fermenter for analysis

6 What s the big deal with brewery wastewater? Proclamation Ale - There isn t anything bad in the wastewater we put down the drain Pollutant - Parameter Fermenter Wastewater Results (mg/l) Mash Tun/Kettle Results (mg/l) WSA Daily Maximum Discharge Limits (mg/l) WSA Surcharge Limits (mg/l) ph s.u s.u s.u. Ammonia (NH 3 ) Total Phosphorus (TP) Nitrate (NO 3 ) Nitrite (NO 2 ) Total Suspended Solids (TSS) 1, Chemical Oxygen Demand (COD) 156,592 94,793 5,000* Biochemical Oxygen Demand (BOD) 93,000 56,000 1,000* Carbonaceous Biochemical Oxygen Demand (CBOD) 84,000 52,000 2, *Prior to April 1, 2015, the WSA had a daily maximum discharge limits for BOD & COD. The WSA now has a CBOD maximum allowable discharge limit.

7 Pretreatment 101 WSA reviewed results with Proclamation Ale, stressing the significant levels of pollutants in the samples compared to maximum allowable discharge limits What are local limits? Local limits are essential to protecting our treatment plant operations Local limits are enforceable Failure to meet limits requires administration of enforcement action which may include fines Strongly advised them to hire a QUALIFIED engineer ASAP to address pollutants of concern (POC)

8 Meeting with Engineer April 24, 2017 WSA confident they would not meet CBOD maximum discharge limit of 2,500 mg/l therefore mass loading (lbs/day) limit) WSA stressed side-streaming and solids removal (captive trenches, solids interceptor, settling tanks, other) removing excessive solids will reduce demand and nutrients (total phosphorus and nitrogen) concentrations as well WSA stressed automatic ph adjustment with continuous monitoring and alarm/shut off to provide compliant ph at all times Flow metering equipment will allow for high strength discharge to be metered slowly to WSA, thus preventing a slug of demand and/or other POC from entering the WSA s WWTF WSA stressed the importance of adequate storage capacity for wastewater to facilitate the slowly metered discharge and allow for continued production and additional wastewater generation Process wastewater connection must have internal monitoring points and an external manhole with separate process and sanitary lines for discreet observations and samplings Plumbing and floor plans (including all equipment specifications) must be submitted and approved by WSA prior to sign off on building permit

9 Building Permit Approval Following our 4/24/17 meeting with the Engineer 5/11/17 - Engineer provided general proposal for treatment and discharge No plans, no specs 5/25/17 - WSA provides comprehensive review/comments detailing exactly what the Engineer needs to provide us in order to receive our approval for building permit 6/16/17 -Engineer calls and asks What exactly do I need to get an approved building permit? 6/20/17 Required plans/specs arrive 6/20/17 WSA signs off on building permit (me.see 5/25/17) 6/16/17 - Proclamation owner calls and asks, What s the hold-up on our building permit? (me.refer to previous bullet) Extended Plan: Proclamation will continue to brew at West Kingston location until they obtain their Certificate of Occupancy SERIOUSLY should I be worried?

10 Several changes to plumbing are required to separate sanitary and process wastestreams Sampling/observation manhole is installed Painters, carpenters, plumbers are full throttle with beautifying the interior and exterior facility, as well as, installing the huge vessels used in the brewing operation However, not much has been done on the pretreatment end

11 10/20/17 Call to Engineer to discuss installation of ph adjustment and monitoring equipment, flow monitoring equipment, as well as, mixers for discharge Multiple deviations from the approved plan were identified during this conversation Engineer told by WSA that the approved plan must be adhered to, any/all changes would require WSA approval prior to implementation Engineer must coordinate inspection with WSA in order to obtain our approval for their certificate of occupancy (CO)

12 WSA has not heard back from Engineer.. 11/14/17 Phone call to Proclamation owner to determine their status and anticipated opening date Soft opening scheduled for 11/29/17! They have already discharged some rinse water that included caustic and acid to prep the tanks for brewing! They have begun brewing! WSA reminded them that they do not have a discharge permit, nor do they have their CO yet! Cease and desist from further discharge! WSA heads out to inspect the facility and we find..

13 WSA inspection on 11/14/17 identifies multiple unaddressed deficiencies that were previously discussed with Engineer No automated ph adjust system manually adjusting No continuous flow monitoring equipment planning to gauge volume based on level in tank and adjust the ball valves to achieve permit required flow rate. No mixers planning to mix by recirculating with pumps Discharge tank is loaded with solids Side-streaming limited to mash/tun, not addressing solids from fermenters! Solids interceptor undersized! WSA provides wastewater discharge permit with log sheet that must be completed each day Each batch discharge will be logged and sampled Engineer put on notice! Deficiencies must be addressed immediately!

14 SOME POSITIVES TO NOTE Manual ph Adjust Lesson 101 courtesy WSA Proclamation Ale now side-streaming from fermenters farmer will take the trub for land application! Discharge log sheet provided by WSA is being completed each day and providing useful information on volumes of waste being generated Data demonstrate that about half of the batches failed to meet TSS limit of 1,000 mg/l, however better house-keeping and side-streaming has kept average down around 1,600 mg/l ph and flow rates have been compliant excluding one day (period of 5 months) All CBOD concentrations have been well within mass limit (< 1,200 lbs/day) provided to Proclamation Ale (average 225 lbs/day, range lbs/day) New Engineer is hired to re-design pretreatment system. New Engineer has worked on various pretreatment projects within the City of Warwick, wellrespected! All long-lead items associated with the re-design (excluding chart recorder) are in and system will be completed by end of May/early June. Pollutant Parameter Carbonaceous Biochemical Oxygen Demand (CBOD) Total Suspended Solids (TSS) WSA Daily Maximum Effluent Discharge Limit (mg/l) Surcharge Limit (mg/l) < 1200 lbs/day 250 1, ph s.u. - Flow limited to the hours of 8:00 AM to 8:00 PM < 250 gallons/hour < 3,000 gallons/day -

15 Know the engineer, make sure they are qualified to work in the brewery arena Be prepared for the deer in the headlights look when you mention Pretreatment Be prepared for possible push-back Demand is a concern, but manageable if you have reserve loading, I guarantee your local limit is not going to be met ph is easily managed with continuous monitoring and automated adjustment, but be aware that the ph can easily drop 2 units within 2-3 hours TSS is a huge concern, emphasize side-streaming and other ways to remove it prior to it entering storage/ph adjustment tank(s) Other POC may require you to derive new local limits, Total P and N Be prepared for other brewers to follow the move to your City or Town Brand new grain silo purchased by Proclamation Ale $$$$