what we heard - metro vancouver · wastewater system and are already working to minimize tss, the...

What We Heard Summary of stakeholder feedback on the Fermentation Operations Bylaw Proposed Requirements

December 3, 2014 - January 9, 2015

January 13, 2015

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Contents

1. Introduction ................................................................................................................... 2 1.1. Key Findings .......................................................................................................................3

2. Feedback on Proposed Bylaw Requirements ................................................................... 4 2.1. Solids Removal ...................................................................................................................4

Issue ...................................................................................................................................................... 4 Proposed requirement ......................................................................................................................... 5 Feedback on proposed requirement .................................................................................................... 5

2.2. pH Monitoring and Treatment ............................................................................................8 Issue ...................................................................................................................................................... 8 Proposed requirement ......................................................................................................................... 8 Feedback on proposed requirement .................................................................................................... 8

2.3. Monitoring Site ................................................................................................................ 10 Issue .................................................................................................................................................... 10 Proposed requirement ....................................................................................................................... 10 Feedback on proposed requirement .................................................................................................. 10

2.4. Record Keeping ................................................................................................................ 11 Issue .................................................................................................................................................... 11 Proposed bylaw requirement ............................................................................................................. 11 Feedback on proposed bylaw requirements ...................................................................................... 12

2.5. Regulatory Fees ................................................................................................................ 14 Issue .................................................................................................................................................... 14 Proposed bylaw requirement ............................................................................................................. 14 Regulatory Cost Recovery ................................................................................................................... 14 Treatment Cost Recovery ................................................................................................................... 15

3. Implementation ........................................................................................................... 16

Summary of Metro Vancouver’s Proposed Fermentation Operations Bylaw Stakeholder Engagement December 2014 – January 2015

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1. Introduction

In December 2014 Metro Vancouver conducted stakeholder engagement to present and gather feedback on a Proposed Fermentation Bylaw to limit the Total Suspended Solids (TSS) entering wastewater treatment plants. Engagement included a stakeholder meeting on December 3 at Creekside Community Recreation Centre in Vancouver, as well as an online survey that ran until January 9, 2015 on the project website. The following fermentation operations and related stakeholders were represented at the meeting or completed a survey: Stakeholder Meeting Richards Beull Sutton Coal Harbour Brewing BC Craft Brewers Guild Powell Street Brewer Bomber Brewing Steel Toad Moody Ales Cork It Winemakers Main Street Brewing O.T.R. Brewing Isabella Winery Steel and Oak Brewing Company Isabella Winery Brassneck Brewery 373245 BC Ltd. City of Vancouver Moody Ales Burnaby Brewing Callister Brewing Black Kettle Red Truck Brewery 33 Acres Brewing Four Winds Brewing Yellow Dog Brewing Postmark Brewing Off the Rail Brewing Company Artisan SakeMaker The Liberty Distiller Dogwood Brewing Parallel 49 Brewery

Online Survey Dogwood Brewing Long Table Distillery LTD Coal Harbour Brewing Co. Strange Fellows Brewing Granville Island Brewing Dageraad Brewing West Coast U Brew Black Kettle Brewing Storm brewing Isabella Winery ltd. 33 Acres Brewing Company Moody Ales Artisan SakeMaker Inc.


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Participants at the stakeholder meeting and those who completed the online survey were both asked to provide feedback on each of the bylaw’s proposed requirements. They were asked the following questions:

• What are your current practices, barriers and challenges related to the proposed bylaw requirements?

o Solids removal o pH monitoring and treatment o Monitoring site o Record keeping

• What resources could Metro Vancouver provide to assist with implementation?

This document summarizes responses to these questions and other feedback from both sources.

1.1. Key Findings While many stakeholders were generally supportive of the initiative to minimize TSS in the wastewater system and are already working to minimize TSS, the following key concerns about the bylaw and its implementation emerged from stakeholder engagement.

• Cost of compliance is a major concern. The proposed Bylaw could result in a higher cost some operators more than others. Regulatory fees and costs of compliance risk being inequitable depending on the following factors:

o Size of the operation: Investment in new equipment, staff, and payment flat rate administrative fees are disproportionately large for small operators with minimal impacts to the waste water system. In some instances, the expense of monitoring, record keeping, and regulation (to both the operators and Metro Vancouver) exceed treatment recovery costs.

o Production processes: Some operators do not use products or processes that result in many of the waste solids or liquids regulated by the bylaw, but will still be obliged to comply due to general classifications.

o Age of operation: The cost of retrofitting existing operations to comply with the new standards will be significantly more than establishing new operations that comply. This is particularly the case where new equipment required for compliance demands additional space in already small facilities.

• There is a lack of supporting services in the region. Many operators cited the difficulty of finding companies or other parties (e.g. farmers) to take their organic waste products. This is particularly the case with yeast, which requires more expensive equipment, efficient storage and transport.


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• Ensuring equitability. Generally there was acceptance of regulatory requirements but desire to ensure regulations are applied equitability across sectors (e.g. restaurants, fermentation operations etc.) and that thresholds and requirements are based on and reflective of local conditions within Metro Vancouver.

• Desire for Metro Vancouver support in complying with regulation requirements. Operators would like technical and educational support for how to best achieve compliance in a cost effective way. This could include providing best practices from other regional districts and municipalities, individual site assessments and recommendations, educational materials, providing knowledgeable point-of-contact person for questions.

The remaining sections of this document provide more detail on feedback from stakeholders on each of the proposed bylaw requirements as well as implementation.

2. Feedback on Proposed Bylaw Requirements

2.1. Solids Removal Issue Fermentation operations generate high concentrations of suspended solids (spent grains, fruit and yeast) in the production of beer, wine or spirits. Inspections of some of these facilities have indicated that a significant amount of solids are being discharged to sewer. High concentrations of suspended solids may reduce available wastewater treatment plant capacity and contribute to odours and corrosion within the collection system.

Suspended solids from fermentation operations typically come from: • the mash tun • mash tun washing • the brewing kettle • brewing kettle washing • backflushing mash tun strainers or filters or trub filters • wastewater residue containing yeast Potential methods to remove the solids could include, but are not limited to: • a strainer or filter with a sieve size no greater than 1000 microns • solids settling in a separate vessel and discharging the decant water • for yeast-containing effluent, the use of a filter with a sieve size no greater than 10 microns Operators should also be aware that starting in 2015, organic material, including the removed suspended solids, will be banned from regional and municipal solid waste facilities, to encourage alternate uses.


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

Feedback on proposed requirement Proposed bylaw requirement: solids removal Q: WHAT ARE YOUR CURRENT PRACTICES FOR REMOVING SUSPENDED SOLIDS? Types of solids

• Distilleries - yeast is the main suspended solid • Breweries - grain is the main type of suspended solid

Screening

• Most new operations capture their solids • Solids (yeast, hops, grains) go through large screen, then Trade Waste Interceptor (TWI);

greens separated for collection • Some breweries use a TWI for screening but it is not clear if they are sized appropriately • Red Truck (brewery) uses Diatomaceous Earth (DE) collection and disposal; direct pick-up

system to farmers • One brewery runs all kettle and mash tun rinse water through a pre-strainer before allowing

to enter a floor drain, where they enter a solid water interceptor built into the floor • Four Winds (brewery) uses strain out vs. slurry and sends direct to farmer • Drain screens/filters in place in many operations, but at different points in the process • One brewery uses a holding tank with buffer to drain and filter solids • Dry hopping (adding hops after boiling within fermentation vessels) is increasingly common

which creates more semi-dissolved and dissolved solids • Remove solids by draining from the bottom of the vessel when dry hopping • Effluent from washing is strained to 1mm • One operator uses tightly knitted cloth bags to capture all solids

Uses for organics

• Most, if not all, solids are captured and recycled into food products • Spent grain/solids sent to Enterra (fish farm food), farmers (animal feed), or are used for

food and beverage products for human consumption • Solids from mash tun into barrel

Storage

• Yeast storage tanks helpful for managing waste stream • Organic waste is stored in the alley

Disposal

• After screening of waste streams (as listed in question), some operators send to garbage, compost, or dispose with spent grains


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• Grain bags for specialty grains and hops go to recycling; the only thing flushed is the yeast slurry and it is mixed with water before discharge.

Compliance

• Some solids go into the drain (e.g. clay, yeast) • Breweries within CoV (based on recent sampling) have complied with Total Suspended

Solids (TSS) requirement Q: WHAT ARE THE BARRIERS OR CHALLENGES TO IMPLEMENT THIS REQUIREMENT? General

• Minimal for new breweries • Cost of implementing can be damaging to tight margins in operating capital • Does not apply to all operators: one distiller uses the traditional British methodology that

incorporates a pre-distilled neutral grain spirit base and as a result does not produce many of the waste solids covered under proposed bylaw

Disposal/collection • Consistent demand for organics/spent grains (e.g. farmers inconsistent and seasonality) • One brewery physically can’t fit Enterra bins in place • More breweries trucking to Enterra may overwhelm the system • Small cost with Enterra vs. free with farmers • For smaller operations solids volume not large enough to make money selling to farmers • Cost of removal of co-products and processing for storage/transport an issue (e.g., for yeast

slurry, a $150k centrifuge) • Hard to find someone to remove live yeast

Screening/equipment

• Addressing higher level of filtration (e.g. TWI expensive) • Situations differ; finding a well-designed piece of equipment for particular brewhouse a

challenge • Compliance will require more than a TWI • Retrofitting would require space and money • All brewing equipment outlets are very near to the floor which leaves no drop to install any

filtering or settling prior to going into the drain • Adding a pump would be a significant cost and may not be feasible as outflow is not steady

enough to pump continuously; any pump capable of handling solids may be damaged from running dry.

• Decanting may be easier and lower cost than new filters • May create flood risk – changing filter size without other changes • Standard interceptor design may not be sufficient, but were approved by City inspectors • Hard to find someone to take DE cleaning kettle to remove hops • Screening requires extra water and series of sieves • Filtering/killing yeast effluent impractical: 10 micron filter is very slow; cost of pumps,

storage vessels, re-plumbing for steam process.


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• High cost of space (especially in CoV) for installing equipment (e.g., large holding tanks) – not just capital but rental

• Spillage inevitable: impossible to pass all floor wash water through a 10-micron sieve Storage

• Hop and yeast - storage capacity and redundancy for collection • Space, nuisances (e.g. rodents), permission to leave in alleys, odour, pick-up times, building

construction (e.g., below ground exit would require a ramp for removal to street storage) Process

• Requirements focus on “end of pipe” (i.e. monitoring contaminants at the last stage of the process before the materials are disposed in sewer) and not upfront to encourage and/or account for waste reduction at the source

• Climbing into vessels physically and removing brewery solids from vessels would be against WorkSafe "Confined Spaces" requirements

• Some distilleries do not do their own fermentation; they receive 195 proof Neutral Grain Spirits, and therefore do not have or employ an of the following items or operations in distillation: o the mash tun o mash tun washing o the brewing kettle o brewing kettle washing o backflushing mash tun strainers or filters or trub filters o wastewater residue containing yeast

Questions

• What do we do with lees? • How do we dispose of filter stocks?

Suggestions • Demonstrate/showcase site-specific solutions • MV or CoV “Walk-throughs” of operations addressing these requirements • Grandfather older breweries that predate current standards • Provide/communicate programs for dealing with solids


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2.2. pH Monitoring and Treatment Issue Variable pH, as a result of caustic and acid cleaners, and acidic waste beer or wine, is also of concern. Caustics and acids are corrosives that may cause damage to sewer collection and treatment works and shorten the lifespan of sewer infrastructure, and pose a risk to sewer workers. The Sewer Use Bylaw stipulates pH between 5.5 and 10.5 prior to discharging the wastewater to sanitary sewer. Proposed requirement Metro Vancouver is proposing that liquid waste from cleaning and sterilizing activities be tested for pH and adjusted to meet the Sewer Use Bylaw requirement prior to discharge to sewer. Feedback on proposed requirement Proposed bylaw requirement: Monitor and treat pH to Sewer Use Bylaw permitted amount Q: WHAT ARE YOUR CURRENT PRACTICES, IF ANY, FOR MONITORING pH? Current Practices in monitoring pH

• Little to no monitoring of pH • Use of litmus paper test

Current Practices in adjusting pH

• Chemicals, cleaning solutions neutralized before discharge • pH of cleaning solutions and wastewater already fall below stipulated levels • Acidic chemicals are discharged shortly after basic chemicals and residence time in the trade

waste interceptor should allow for proper mixing and neutralization before discharge • Some breweries neutralize spent caustic with acid before draining • Some pre-mixing of acidic and basic solutions, but not currently measured • Dilution with sufficient water to bring into pH compliance • Currently, no treatment prior to discharge • Use of acid and caustic cleaning cycles expected to neutralize wastewater sufficiently • Compliance with the Sewer Use Bylaw pH requirements is not an issue for smaller breweries

Q: DO YOU ADJUST THE pH OF THE WASTEWATER PRIOR TO DISCHARGING TO SEWER? IF YES, HOW OFTEN?*

Answer Number of Responses Yes 2 No 12

*DATA SHOWN HERE IS FROM ONLINE SURVEY ONLY


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Q: WHAT ARE THE BARRIERS OR CHALLENGES TO IMPLEMENT THIS REQUIREMENT?

• Some operators have no need to monitor pH (‘discharge’ is only water) • Wide range within the Sewer Use Bylaw for pH levels • Easy to monitor tasks (tank) • Wastewater is harder • Cost and space requirements of additional monitoring equipment or modifying existing

equipment (e.g. tanks, pumps, pH remediation sump) • Frequency of sampling (i.e. small breweries don’t brew every day) • Difficult to adjust pH at the end of the process • Time intensive • Cost, scope, scale and Biochemical Oxygen Demand (BOD) monitoring • Unclear on monitoring expectations and methods – sampling tools, frequency, location

(tank, final collection, sump) who administers etc. • If sampling occurs at the tank, there would still be wash-down of H2O • Frequency and logging methodology challenge • Broad spectrum of pH - how to deal with changing characteristics • Standards for measuring pH • Implementation of system • Infrastructure required • Ease of measurement (specialized labour, access challenges) • Validity: Samples can always be collected at a time that we know we are in compliance • So small that it’s hard for us to get a proper sample reading

Questions

• Can monitoring costs come from elsewhere in system (e.g. taxes)? • What type of equipment is involved (e.g. for sampling)? • What happens to bad batches? • Do we sample from the interceptor? • Who does the monitoring and when? (note: certain times would have increased cost) • How do we learn more about pH monitoring and treatment – is there a kit? • Will there be standardized monitoring times? • What are different monitoring sites in use (e.g. where already in place) • If pH is not a problem, why is this one of the proposed requirements? • Why monitor pH by taking random samples at the TWI outlet? There can be low and high

events that swing the pH wildly and this should not matter much. Is it not most important to take a totalized sample that reflects the buffering capacity of a much larger discharge than just one TWIs worth of liquid?

• We have no need for it so why are you forcing us to join the others?


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Suggestions • Inform people of the requirements for a sampling location • Provide this information to new breweries, in design stages and just opening • Provide a period of education and support before penalties start; good practices will

remove the challenges.

2.3. Monitoring Site Issue Regulation and enforcement need a way to confirm compliance with required pH balance. Proposed requirement A proper monitoring site is required to confirm compliance with the proposed requirements of this sector-specific bylaw as well as the Sewer Use Bylaw. The monitoring site would provide access to the process wastewater prior to mixing with the fermentation operation’s domestic waste. Metro Vancouver is proposing that a suitable monitoring site would be a sampling point downstream of all process waste that is representative of the final discharge of sanitary sewage. Feedback on proposed requirement Proposed bylaw requirement: Provide a monitoring site Q: WHAT ARE THE BARRIERS OR CHALLENGES TO IMPLEMENT THIS REQUIREMENT? General comments

• Only production material goes through TWI • Not much monitoring occurring currently • Received survey on size of monitoring site but no follow-up communication • Occasionally need to dump product that is not bottled • CoV already requires a sample point as a condition of permit, sampling tee is therefore not

an issue for breweries in the CoV

Barriers/Challenges • No barrier: Any operator with a TWI already in place should be able to take samples • Cost (of retrofitting, production shutdowns, etc.) • Accessibility - may need to dig up interceptor • More feasible for new operations (costly for old breweries to add one) • Clarity - City of Vancouver vs. MV requirements may become complicated for businesses • Consistency for monitoring, clear standards, level playing field • Inspectors need to be consistent • Implementation - site specific differences, labour requirements, retro-fitting • Accounting for a site with mixed businesses (e.g. offices, restaurant, brewery)


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• Accounting for difference between small batch vs. continuous operations • Ensuring/having the right infrastructure • Cost for additional equipment • Scope/scale • Businesses need access to information pre-design of their systems • Accounting for product dumps that are not bottled - already lost income and then have to

discharge, but need to lower pH and dilution is not the solution, so what should we do? • Calibrating equipment – requires weekly adjustments, time consuming • Access (one operator has a monitoring site that is accessed by city staff, but it is difficult to

access and releases foul odours) • Knowledge of proper monitoring proper procedures and location

Questions

• If operations get pH and other metrics in place, does the brewery still pay? (I.e. is there incentive to stay below bylaw minimum?)

• Can SOPS be accepted instead of installing a sample point? • Are there minimum thresholds for triggering regulations? • What happens when non-compliant?

Suggestions • Brewers Guild purchases monitoring and sampling equipment for sharing amongst guild

members • Existing breweries should be given extended time to reach compliance due to additional

cost of retrofit

2.4. Record Keeping Issue In order to monitor and track adherence to the proposed bylaw requirements, regulation and enforcement requires records of compliance to review. Proposed bylaw requirement The following processes would require record keeping for compliance with the proposed bylaw:

• Method of removing solids • hL of product being produced • Treatment of kettle wastewater and kettle wash water • Methods of solids removal • Method of treatment to remove yeast residue • Method of pH measurement • Dates and results of pH testing

Metro Vancouver is proposing that the following activities be recorded and kept at the facility for a minimum two-year period.


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Q: RECORDS CURRENTLY KEPT BY FERMENTATION OPERATIONS.*

*DATA SHOWN HERE IS FROM ONLINE SURVEY ONLY Feedback on proposed bylaw requirements

Proposed bylaw requirement: record keeping for periodic inspection on waste management practices and activities (method of removing solids, hL of product being produced, treatment of kettle wastewater and kettle wash water, methods of solids removal, method of treatment to remove yeast residue, method of pH measurement, dates and results of pH testing)

Q: WHAT ARE THE BARRIERS OR CHALLENGES TO IMPLEMENT THIS REQUIREMENT? Current Practices

• Distilleries and wineries keep extensive records • Beer lost is recorded • Some currently keep records for Canada Revenue Agency • Some breweries (outside of CoV) keep record of pH but not of production • hL beer is tracked in CoV as it is a permit requirement for all breweries • Material consumption tracked • Qualitative knowledge on day-to-day operations • pH records probably manageable for all as long as method of recoding is easy • Cleanout records kept – no other kinds of records kept listed on the feedback form • Water usage - paying for in and out • For permitted fermentation operations flow data is required • Cost for waste treatment - 80% of flow not going out, needs average that reflects this

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Method ofremoving

solids fromthe mash tunand mash tunwash water

How manyhectolitres

(hl) ofproduct isproduced

Method oftreatment of

kettlewastewaterand kettle

wash water

Method (s) ofsolids

removal fromwastewatergenerated

Method oftreatment toremove yeast

residue

Method of pHmeasurement

and pHadjustment

forwastewater

Dates andresults of pH

testing

COUNT OF RECORDS KEPT BY BREWERY/DISTILLERY OPERATORS


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Barriers/Challenges • Frequency of record keeping/labour • Making record keeping part of routine operations • Water consumption should be easier, other parameters may be more challenging • Planning for changes and additional regulations • Distinguishing between water volumes for lounge vs. tasting room • Not clear on the frequency requirement for sampling • Space requirements and source of contamination • Not clear who to contact with further questions • Requirements to report method seem reasonable (as set out in feedback form) • Applicability: e.g., UBrew not regulated by volume • Cost of additional staff • Does not make sense for very small operators or operators with little waste

Questions

• Will there be water conservation measures that affect breweries? • How much data/level of detail required? • Some restaurants clean/monitor grease traps and empty solids - is this an opportunity for

fermentation operations? • What are other cities/regions doing? • Can distilleries and wineries (who already keep extensive records) not be required to

complete an additional form with repetitive information? • Should brewers be required to report dumped batches?

Suggestions

• Create clear standards that are easy understand and record • Avoid redundant requirements - consider regional, provincial, federal standardized form • Provide education and support • Create good templates for record keeping


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2.5. Regulatory Fees Issue There is a cost to Metro Vancouver for regulating this sector with the proposed bylaw requirements. Metro Vancouver would like to recover this cost, which is consistent with current practices of recovering regulatory costs. There is a need to encourage operations to remain compliant with bylaw requirements. Proposed bylaw requirement Metro Vancouver is proposing a two-tier fee structure to recover regulatory and treatment costs. Regulatory Cost Recovery To recover the costs to regulate this sector, an annual administration fee of $200 is being proposed. This fee is designed to recover the inspection, sampling and analysis costs and is consistent with other sector-specific regulations that Metro Vancouver administers. Q: DO YOU SUPPORT AN ANNUAL ADMINISTRATION FEE ALIGNED WITH OTHER REGULATIONS?*

• Yes. The process seems fair. • No. The process does not appear fair.

Answer Number of Responses Yes 6 No 8 *DATA SHOWN HERE IS FROM ONLINE SURVEY ONLY Q: (IF ‘NO’) PLEASE SPECIFY WHAT METHOD SHOULD BE USED: General Comments

• We do not fall into the category you are imposing this fee for. • Given the amount of discharge of small producers (smaller than some restaurants), fee

seems unfairly high • Small producers (nano-breweries) should not be forced to pay the same flat fee as large

producers (e.g., Molson) • We will incur extra costs to comply with the regulations and do not think it is fair that we

are asked to subsidize the administration of these new regulations • We're already paying WAY more than this for our waste discharge permit. We'd love to get

bumped down to $200 a year • Cost should be taken out of taxes already being paid • $200 fee seems reasonable • TSS/BOD – difficult to monitor


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Questions • Operators are already forced to pay for testing and submission to lab – what would the fee

be for? • Does the $200 fee apply if an operation is not fermenting and bringing in material from

elsewhere? • How is the fee distributed among other industries? (E.g. the fee does not currently apply to

restaurants regulated by the same bylaw). Suggestions

• For small operators the regulatory cost recovery of $200 is as large or larger (up to 4x) than treatment cost recovery (based on formula provided); Admin. Fee should be scaled according to operations size

Treatment Cost Recovery 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.

Q: DO YOU HAVE ANY COMMENTS ON THIS METHOD OF COST RECOVERY Comments

• This seems very high and doesn't offer incentive to improve practices beyond the "industry standard"

• The sample equation in the feedback form seems to be for a much larger brewery than most so they potential cost is higher than would be for most of the smaller breweries impacted by this bylaw

• Fees and taxes are much more disproportionately burdensome to small operators • Multi-tier taxation and costs in Vancouver already makes operating here very expensive,

particularly for small operators • All the craft breweries, distilleries and U-brew/U-vints in the Metro Vancouver jurisdiction

combined are unlikely to match that discharged by Molson on Burrard St. or Rogers sugar refinery, which we were told by authorities has no solids separation practices in place. The most fair place to start would be to require the largest producers (which also have the largest reserves of cash for installing the necessary equipment as a retrofit) to separate out their solids to remove the bulk of the burden from the systems and then start to look at smaller producers if this is not enough relief on the system.

• The cost should come out of the liquor taxes that are already paid to the government • Measurement of Biological Oxygen Demand and Total Suspended Solids are based upon

samples we would have to take from our trade waste...most practical. Depending on the amount of solids in the trade waste vessel, these samples could give inconsistent values that would be used to calculate a treatment recovery cost.

• Automated sampling would probably give the most accuracy but would be expensive to install, maintain and may/may not give accurate results as these are sensitive pieces of equipment that could get damaged in the brewery through brewery operations.


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• Waste Water flow-meters are known to not always give consistent, accurate measurements and could affect the calculation of treatment cost recovery.

Questions • So will it be a fair implementation? Are you charging other sectors also? What about

restaurants, night clubs, dry cleaners? Or for that matter anybody that flushes waste?

Suggestions • Cost recovery should be scaled to size of operations • Charging on total load makes more sense than charging on per L TSS and BOD which could

cause breweries to increase water usage to bring down these levels • A fee system that is based on volume, TSS and BOD is the fairest way to recover whatever

additional burden may be placed on the utility by fermentation operations. • Small microbreweries should simply pay a flat fee to Metro Vancouver to compensate for

the small amount of TSS and BOD.

3. Implementation

Q: MOVING FORWARD, WHAT TYPES OF RESOURCES WOULD HELP YOUR OPERATION IN IMPLEMENTING THIS BYLAW?

General • Consider a phase-in/fluid period in the beginning • Consider grandfather clause for monitoring site/pH • MV monitor to see what pH is and apply fee instead • Make rules clear and easily accessible in one location • Target smaller and bigger breweries differently • Provide standard sizing for the interceptor • Assistance with processing or collection of spent grains, hops and yeast • Different standards for different size operations/older operations • Set up peer audit • Have a minimum operating threshold before regulations are triggered • Provide portable equipment (e.g. sampling tee) • A company to remove spent yeast from small breweries in an affordable and simple way.

Fees/Taxation • Tax credit for the purchase and installation of any additional filtering or settling equipment

deemed necessary by the utility (especially for existing operations and small producers) • Tax incentive programs or grants to encourage upgrading waste water systems. • Base fees on MV sampling • No fees


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Education • Provide case studies of similar sized operators from other jurisdictions (e.g. bylaws, permits,

requirements) • Consultation and information sharing • Consultation with city waste water engineers to provide practical knowledge on how to

improve waste water treatment • Provide information to breweries opening up (preferably in the design stage) • Provide overview of process • Site-specific education and requirements – (e.g. different monitoring sites in use) • Joint with LCBC – 1st process that fermentation operators go through • Provide simple guide to assist in the implementation of the bylaw • Sharing resources/SOPS for breweries with “bad” practices

Information • More info on what the city wants • Be accessible • One-window” information system • Designate a person/advisor to liaise with • Hotline for questions • Link to municipality re: plumbing requirements • Be clear whether to call MV or CoV • Align regulations with MoV municipalities • Companies who use brewery waste • Information about different types of equipment and procedures that are used in other

markets by small to medium sized fermentation operations for reducing TSS, BOD, and pH treatment.

• Provide an example of the monitoring point schedule e.g., how frequently should measurements be taken?

Site Visits • Site visits to review system (i.e. is a sump needed), walk-through, assessment, assistance • MV sampling crew could identify it the configuration works

what we heard - metro vancouver · wastewater system and are already working to minimize tss, the...

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