Proposed Fermentation Operations Bylaw … Fermentation Operations Bylaw Stakeholder Meeting #2 ......

Proposed Fermentation Operations BylawStakeholder Meeting #2

Creekside Community Recreation Centre

Jeff Gogol

Environmental Regulatory Planner

May 14, 2015

11308296

Meeting Objectives

• Provide fermentation operators with a summary of what we have heard to date

• Provide fermentation operators with an update on the proposed bylaw

• Provide fermentation operators with an opportunity to ask questions and provide comment on the updated requirements

Meeting Agenda

9:00 – 9:10 am Registration

9:10 – 9:20 am Welcome & agenda review

9:20 – 9:40 am Presentation: What we’ve heard from stakeholders Revised proposed bylaw requirements

9:40 – 10:10 am Q&A

10:10 –10:45 am Table discussions

10:45 – 10:55 am Report back

10:55 – 11:00 am Wrap-up & next steps

Proposed Bylaw for Fermentation Operations

Bylaw purpose:

Reduce and prevent spent grains, fruit and yeast from fermentation operations from going down the drain

Proposed Bylaw for Fermentation Operations

Applies to:

• any business using yeast to produce alcoholic beverages, and

• discharging up to 300m3 (300,000 l) of wastewater into the sewer within 30 days

Includes:

• brew pubs, cottage breweries, micro-breweries, vint-on-premises, wineries, distilleries and u-brews.

Ensuring waste from fermentation operations is managed responsibly

• Spent grains, fruit and yeast are entering and stressing the sewer system

• Fermentation operations to remove solids from wastewater

• Monitor the pH of cleaning and sterilization water

• Metro Vancouver supporting these operations to find practical and cost-effective solutions for managing this waste

Supporting fermentation operations to comply with the bylaw

• MV designing a bylaw that is easy to understand and reflects the unique conditions of these operations

• Set of standards these operations need to meet

• Multiple ways of achieving the standards, depending on the businesses’ unique situation


• Bylaw Implementation Guide

• Metro Vancouver website: www.metrovancouver.org

• Metro Vancouver or City of Vancouver Regulatory Officer


• Working closely with stakeholder groups throughout bylaw development

• Ensuring requirements are fair, practical and achievable while safeguarding the treatment system

Engaging with stakeholders throughout bylaw development

• Met face-to-face with and toured a range of different types and sizes of fermentation operations around the region

• Gave us insight into the different business perspectives and situations

Engaging with stakeholders throughout bylaw development

December 2014 – January 2015:

• Stakeholder workshop with 30 brewers, distillers, vintners from across the region to present the proposed requirements and listen to their feedback

• Online survey: 13 respondents

Outcomes of bylaw development consultations

Revised the initial requirements

• Simplified

• Streamlined

• Added time for operators to monitor and adjust practices

Proposed Requirements

Requirement 1: Remove solids

Requirement 2: Install a monitoring point

Requirement 3: Monitor and treat wastewater pH

Requirement 4: Keep records

Requirement 5: Pay Regulatory Fees

Requirement 6: Pay Treatment Fees

Requirement 7: Authorized discharge of off-spec product

Regulatory Authority

• Metro Vancouver regulates all fermentation operations across the region

• City of Vancouver regulates on Metro Vancouver’s behalf within the city


When coarse solids like spent grains and fruit, and fine solids suspended in water, like yeast, enter the sewer it stresses the system and costs money to maintain and repair.

This requirement will ensure both coarse and suspended solids are removed from wastewater.


Initial Requirement

The proposed bylaw would use the existing 600 mg/L limit for Total Suspended Solids (TSS) set out in the current Metro Vancouver Sewer Use Bylaw.

Updated Requirement

a) The discharge of coarse spent grains or fruit pulp to the sewer will be prohibited on the date the bylaw is enacted

b) The maximum concentration of Total Suspended Solids (TSS) shall not exceed 1,200 mg/L

c) All operations must comply with this limit no later than 12 months after bylaw is enacted


Rationale for Changes

• Initial requirement did not specifically address the need to remove coarse solids

• Increasing maximum TSS limit since operations employing best practices for this sector usually have TSS concentrations between 600 to 800 mg/L

• 1,200 mg/L limit is achievable using best practices and/or adequate wastewater treatment


To ensure operators and regulatory staff have accurate knowledge of wastewater quality, they must be able to access wastewater for sampling purposes.

Wastewater monitoring point must be located downstream of all treatment.


Initial Requirement

A proper monitoring point required to confirm compliance with the proposed requirements of this bylaw and Sewer Use Bylaw.

Updated Requirement

• Install a suitable monitoring point accessible during operating hours

• Six months after bylaw adoption bylaw

• Downstream of all process waste

Example of suitable monitoring point



Allow operators additional time to install a monitoring point if one is not already in place.


Cleaning and sterilizing activities for fermentation operations can impact the pH levels of wastewater which can damage pipes and can cause chemical imbalances that may be dangerous for workers in the sewer.

This requirement will ensure wastewater is tested regularly and adjusted to meet appropriate pH levels.


Initial Requirement

• Wastewater from cleaning and sterilizing activities be tested for pH and adjusted to meet the Sewer Use Bylaw range for pH (between 5.5 and 10.5)


Updated Requirement

• Each operation required to monitor and record the pH from the monitoring point a minimum of once per day during cleaning and sterilizing

• pH level should be measured immediately onsite using a pH meter

• pH monitoring to begin once monitoring point installed, to determine whether wastewater complies with Sewer Use Bylaw range of 5.5 and 10.5


Updated requirement continued:

• Nine months after bylaw enactment, all operations submit pH Characterization Report showing daily pH results

• If Characterization Report shows wastewater with pH outside the 5.5 and 10.5 range, must submit a Compliance Plan to Metro Vancouver by 12 months after bylaw enactment

• Compliance Plan details procedures operator will undertake to fall within the pH range

• Wastewater pH levels must be in compliance 18 months after the adoption of the bylaw



Proposed changes are to allow operators the time to monitor the pH of their wastewater and determine the treatment methods that best suit their operations.


Records are required so regulatory staff can confirm operators are complying with the bylaw when they inspect the facility.

Records can also assist operators understand wastewater quality over time.


Initial Requirement

The following processes would require record keeping to comply with the proposed bylaw:

• Method of removing solids

• Hectolitres (hl) of product being produced

• Treatment of kettle wastewater and kettle washwater

• Method of treatment to remove yeast residue

• Method of pH measurement

• Dates and results of pH testing

Metro Vancouver is proposing that the records be kept at the facility and available for inspection for a minimum two-year period.


Updated Requirement

Operators to keep the following records: • Hectolitres (hl) of product being produced per calendar

month • Dates, times and results of pH testing

Operators begin recording monthly hl of product as soon as bylaw enacted.

Record keeping of daily pH testing must begin no later than 6 months after bylaw enactment.

Records to be kept at the facility and available for inspection for a minimum two-year period.



Metro Vancouver has streamlined the reporting requirements.


Initial Requirement

• To recover the costs to regulate fermentation operations under this bylaw, an annual administration fee of $200 is being proposed.

• Regulatory fees will be invoiced within the first 6 months after the enactment of bylaw and annually thereafter.

Updated Requirement

• No revisions


Rationale

This fee is designed to recover the costs of inspection, sampling and analysis costs and is consistent with the direction Metro Vancouver is going with other sector-specific bylaws.


Initial Requirement

• Cost recovery for treatment will be based on estimates of the discharge volume and quality derived from the amount of product produced and industry discharge quality standards. The same method would be used for distilleries and wineries based on their production data and industry standards.


Updated Requirement

• All fermentation operations required to pay annual amount for treatment fees based on annual production of product.

• Treatment fees will be invoiced within the first 6 months of each calendar year beginning in 2016.

• Metro Vancouver will determine the appropriate fee category based on BC Liquor Distribution Branch records or operator’s records

Proposed Metro Vancouver Treatment Fees

Note: Municipal Sanitary Sewer Fees are not included in these fees

Proposed Metro Vancouver Treatment Fees



• Fee structure has been simplified

• Charges are required to recover costs of treating wastewater from fermentation operations

• Fermentation operations are unique in their higher concentration of suspended solids despite onsite treatment

• Any fermentation operation of any size pays treatment fees, either through a bylaw or a permit

• The significantly lower volume of wastewater produced annually by distilleries is reflected in the proposed fee


Initial Requirement

None

Updated Requirement

Prior to the discharge of off-spec product to sewer, operator must contact Metro Vancouver / City of Vancouver to authorize the discharge to sewer



Off-spec product (bad batches) very high in Biochemical Oxygen Demand (BOD) which can negatively impact the region’s wastewater treatment plants.

Regulatory staff will determine whether the discharge is appropriate and if there are specific requirements for discharging.

Proposed Implementation Timeline

Metro Vancouver enacts the bylaw

• Discharge of coarse solids prohibited

• Record hl/month

• Obtain permission to discharge off-spec product

• Treatment fees will be invoiced within the first 6 months of each calendar year beginning 2016


1 – 6 months after bylaw enactment

• Suitable monitoring point must be installed no later than 6 months

• Regulatory fee will be invoiced within first 6 months



• Monitor wastewater pH at least once per day

• At 9 months, all operators submit pH Characterization Report to MV

• Record hl/month and daily pH testing dates, times and results



• Max. concentration of TSS must not exceed 1,200 mg/l by 12 months after bylaw enacted

• If pH is out of compliance, operator submits Compliance Plan by 12 months


12- 18 months after bylaw enactment

• Wastewater pH must be in compliance by 18 months after bylaw enacted

Table Discussions

Is there anything else that Metro Vancouver should consider before finalizing and implementing the bylaw?

Next Steps

• Summarize the input we receive today and circulate to workshop participants

• Consider your feedback in finalizing the proposed requirements

• Draft the Bylaw Implementation Guide

• Draft the Fermentation Operations Bylaw

When Metro Vancouver Board adopts bylaw:

• Communicate bylaw enactment to fermentation operators and distribute the Implementation Guide

Proposed Fermentation Operations Bylaw … Fermentation Operations Bylaw Stakeholder Meeting #2 ......

Documents

Transcript of Proposed Fermentation Operations Bylaw … Fermentation Operations Bylaw Stakeholder Meeting #2 ......