Water Protection Program fact sheet
Division of Environmental Quality Director: Kyra Moore
PUB2829

The purpose of this publication is to provide information regarding options for wastewater generated during the manufacturing of beverages, such as beer, wine, distilled liquors, juices, etc. This publication is not intended to address specific design criteria, nor is it meant to answer all hypothetical scenarios. To help answer site-specific questions that may come up during the planning process, please contact the Missouri Department of Natural Resources, Water Protection Program for assistance.

Domestic versus Process Wastewater

Domestic Wastewater

As defined in Code of State Regulations 10 CSR 20-2.010(26), domestic wastewater is “wastewater (i.e., human sewage) originating primarily from the sanitary conveniences of residences, commercial buildings, factories, and institutions, including any water which may have infiltrated the sewers. Domestic wastewater excludes stormwater, animal waste, process waste, and other similar waste.” Excluding process waste applies to processed wastewaters from sources such as wineries, breweries, distilleries, meat processors, cheese processors, mortuaries, veterinary clinics, surgery suites, kennels, live fish bait operations, bio-fuel production facilities and any other commercial or industrial facilities that produce non-domestic waste.

Process Wastewater

As defined in 10 CSR 20-6.015(1)(B)10, process wastes are “The waste, wastewater, sludges, biosolids and residuals originating from sanitary conveniences, or generated during manufacturing or processing, or results from the production or use of any raw material, intermediate product, finished product, by-product, or waste product and includes discharges from land application fields that occur as a result of the land application process.” This includes, but is not limited to, wastewater generated from cleaning equipment, washing down manufacturing or processing areas and non-contact cooling water. It also includes wastewater that is similar in composition to domestic wastewater, but may have one or more of its constituents exceeding typical domestic effluent concentrations from a septic tank or other treatment component. This type of waste is the jurisdictional responsibility of the department, regardless of the amount produced per day.

To help understand the risk that process wastewater poses to the environment, consider the difference between domestic wastewater from a single family house and processed wastewater produced from a brewery. Typical effluent from a septic tank serving a single family home has a biological oxygen demand (BOD5) less than or equal to 170 milligrams per liter (mg/L), with the total suspended solids (TSS) being less than or equal to 60 mg/L. Process wastewater from a brewery has been reported to have BOD5 between 1,609 to 3,980 mg/L, with TSS ranging from 530 to 3,728 mg/L. Untreated or minimally treated process wastewater with high BOD5 or TSS can significantly deplete the dissolved oxygen concentration in the receiving waterbody, resulting in a negative impact to aquatic life.

Wastewater Systems

There are two general types of wastewater systems used in Missouri, . They can be classified as discharging and non-discharging systems.

Discharging Systems

Discharging systems are designed, constructed, operated and maintained to treat wastewater to reduce the concentration of pollutants before discharging the effluent to waters of the state, as defined in Missouri Revised Statutes, section 644.016(27), RSMo. Technologies installed and operated at these types of facilities must comply with the Missouri Clean Water Law and its implementing regulations and operate with a National Pollutant Discharge Elimination System permit issued by the department. Routine testing of the discharge is necessary to ensure the facility meets effluent limitations.

Facilities that propose to use discharging treatment technology for their wastewater should contact the department for specific information concerning antidegradation requirements and construction and operating permits.

Non-Discharging Systems

Non-discharging systems are designed, constructed, operated and maintained to prevent discharging to waters of the state. In order for facilities to be considered a non-discharging system, a facility must use a storage system with a capacity to hold the volume of wastewater generated. Non-discharging systems also must have an approved method for the final treatment of the wastewater before its storage system reaches maximum storage capacity. For example, the wastewater can be land applied (surface or subsurface) according to an operating permit issued by the department or it can be pumped and hauled to a permitted wastewater treatment facility.

Permits

Construction Permits

  • Construction permits are required before constructing all earthen lagoons (holding basins) receiving any amount of process wastewater.
  • Construction permits are not required before constructing non-discharging facilities that primarily handle processed wastewater and the wastewater will be either surface land applied, dispersed into the soil or pumped and hauled to a permitted facility. However, the collection and treatment systems must be designed by a Missouri registered professional engineer and be constructed according to design regulations, 10 CSR 20-8, and applicable guidance documents.

Operating Permit Exemptions

Beverage manufacturing facilities that qualify for a non-discharging exemption fall under one of the categories listed below:

  • Facilities whose only emissions go to a publicly owned treatment works are exempt from the requirement to obtain an operating permit.
  • Facilities that are compliant with the Missouri Water Quality Standards, 10 CSR 20-7.031, generate less than 3,000 gallons per year (gpy) and surface land apply the processed wastewater are exempt from the requirement to obtain an operating permit.
  • 10 CSR 20-6.015(3)(B)12 states “An operating permit is not required for process waste holding structures from which the contents are hauled to a permitted treatment or disposal facility, if the owner has a written contract with the hauler and approval from the receiving facility.” If the owner is unable or cannot provide the appropriate documentation demonstrating their facility is exempt, then they must obtain a site-specific pump and haul operating permit for processed wastewater. An operating permit may also be required if the department determines that the operating practices are not adequate to ensure no discharge occurs.

Operating Permits

Facilities not covered by an exemption are required to obtain one of the following operating permits:

  1. General Permit MOG-822 – Land Application of Food Processing Wastewater

    • This general permit authorizes up to 10,000 gallons per day (gpd) for surface land application and up to 1,000 gpd for subsurface soil dispersal of processed wastewater. This general permit also authorizes surface and subsurface treatment and disposal of up to 500 gpd of domestic wastewater when combined with industrial process wastewater.
  2. Site-Specific Permit

    • These permits are tailored to the individual site characteristics and the surrounding environment in order to ensure adequate protection of public health and the environment.
    • When surface land application of process waste will be greater than 10,000 gpd, or the subsurface dispersal will occur at a rate greater than 1,000 gpd, then a site-specific permit is required.
    • This permit is also required if the operations would not meet all applicability statements in the general permit, including setback distances.

Please note that although some processed wastewater facilities may be exempt from operating permits, they remain the jurisdiction of the department throughout their lifespan. 10 CSR 20-6.015(2)(B) allows the department to require permits for facilities that would otherwise be exempt, where necessary to protect public health and the environment.

Questions to Consider

The following are some basic questions that should help you get started when determining the method of wastewater treatment:

Question: What is the estimated gpy of processed wastewater that may be generated?
Answer: The department recommends contacting similar beverage manufacturing facilities to assist you in estimating the amount of processed wastewater that you could generate. The estimate should include wastewater from cleaning, spillage, etc.

Question: What is the maximum gpd of domestic wastewater that may be generated?
Answer: The department recommends using Table 2A – Quantities of Domestic Sewage Flows, found in 19 CSR 20-3.060, when calculating the maximum daily flows of domestic wastewater.

Question: Is there sufficient suitable area available for surface land application or subsurface soil dispersal of the wastewater?
Answer: A professional soil scientist who is familiar with surface land application or subsurface soil dispersal of wastewater will be able to assist you when determining a suitable soil treatment area.

Question: Will the domestic and non-domestic wastewater be combined?
Answer: If yes, the wastewater treatment system will be the department’s jurisdictional responsibility, regardless of the amount of domestic wastewater produced per day. If no, you should contact the department for assistance with respect to jurisdiction when using two separate wastewater treatment systems, i.e., one for the domestic wastewater and the other for processed waste.

Question: Will your source of water supply meet all applicable setback distances from the wastewater treatment system including the soil treatment area?
Answer: If no and you are unable to relocate the soil treatment area, a site-specific permit will be required. You should contact the department’s Public Drinking Water Branch for assistance.

Question: Is there any type of housing being planned as part of the facility, including but not limited to hotel, motel, recreational camping sites or cabins?
Answer: If so, you should contact the department for assistance with respect to any applicable regulations.

Question: How much land may be disturbed during construction activities for the entire facility?
Answer: If greater than one acre of land is disturbed, you should contact the department for assistance with respect to any applicable regulations.

The department recommends that you contact the Missouri Department of Health and Senior Services’ Manufactured Food Program regarding any regulations they may have concerning beverage manufacturing facilities. The Manufactured Food Program can be contacted at 573-751-6095 or 800-628-9891.

Summary

This publication is intended to provide information concerning wastewater treatment options to help you determine a sustainable method of treatment for wastewater generated during the manufacturing of beverages. It is not intended to address specific design criteria.

During your planning phase, please contact the department for assistance to ensure your method of wastewater treatment is not only sustainable but is protective of public health and the environment.


Nothing in this document may be used to implement any enforcement action or levy any penalty unless promulgated by rule under chapter 536 or authorized by statute.


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