Dealing with waste

[j1334]

Hi all,

My distillery has been up and running for awhile. One problem I've encountered is how to deal with the waste (heads & tails). We've done a few recovery runs, however we're running out of space to store the ever increasing stock pile. It's not much (about 50 wine gallons), but in our tiny distillery that takes up a lot of room.

What are the TTB regulations regarding disposal of waste alcohol. Can it be diluted down to 10% and sent down the drain (one thing I've heard) or do I need to send it off to waste disposal? Forms to fill out, etc.

Any experiences would be helpful.

Best,

J

[TetonDistillery]

Buy an alcohol furnace. Burn them.

We have a alcohol furnace to heat the tasting room and we have one at home.

If you need to burn more, get your friends to buy furnaces also.

[middleofnowhere]

Why are you not running the tails in your next run?

[j1334]

Thanks guys. Wondering more what the TTB regulation is. Can't really find anything on their site regarding disposal of spirits (just wine & beer).

@TetonVodka … That would be cool. However, probably not practical for us.

@middleofnowhere … We do rerun them, but it's getting to be a space issue as we every run we generate more and more. Our distillery is only 600 square feet and we store in 5 gallon glass carboys, it's already pretty tight.

[middleofnowhere]

That is small! Do you have a website, I wanna see this setup. Have you considered getting a 55 gallon SS drum for storage? Food grade ones are rather cheap, would take up less floor space, are stackable, and wouldn't break as easily.

[Rickdiculous]

There has to be a better answer to this question. Some of the people on this site are distilling too much ethanol to simply be giving it away as window cleaner in the winter. How about some of the bigger producers weigh in on this.

Hazmat disposal?

Diluted down the drain?

storing in a 55 gallon ss drum only passes the problem on down the road.

I'm curious about this as well. I do like the ethanol stoves. Pretty cool possibility.

[Dehner Distillery]

it is organic.

thin it down and dump it. make as "destroyed" or "losses"

take care

[Dehner Distillery]

it would be no worse than a bad batch of beer from a micro brew.

take care

[dhdunbar]

You account for the production of the heads and tails in your production records. If you put the tails back into the next run, you make a record of that. You can destroy the heads. It is a destruction. You can destroy it on or off premises, but different rules apply:

Sec. 19.459 Voluntary destruction.

(a) General. A proprietor may voluntarily destroy spirits, denatured spirits, articles, or wines on bonded premises as provided in this section. There is no tax liability on spirits, denatured spirits,articles, or wines destroyed in accordance with this section.

( Wine notice. A proprietor may destroy wine held on bonded premises only after the proprietor has filed a notice of intent to destroy with the appropriate TTB officer stating the kind and quantity of wine to be destroyed and the date and manner in which the wine is to be destroyed. The wine may be destroyed after the filing of the notice.

© Gauging. A proprietor must gauge all spirits, denatured spirits, articles, or wines to be destroyed. The proprietor may establish the gauge of spirits in bottles on the basis of legible case markings and label information in accordance with Sec. 19.286. The proprietor must individually count bottles in partial cases.

(d) Destruction off bonded premises. If a proprietor intends to remove spirits, denatured spirits, articles, or wines from bonded premises in order to destroy them at a location off bonded premises, the proprietor must file a consent of surety to cover the removal. When the destruction takes place off plant premises, the proprietor must comply with applicable Federal, State, and local environmental laws and regulations.

(e) Record of destruction. The proprietor must record the destruction of spirits, denatured spirits, articles, or wines as provided in Sec. 19.617.

Just make sure you do it properly. Read and understand 19.617:

Sec. 19.617 Destruction records.

Each time that a proprietor voluntarily destroys spirits, denatured spirits, articles, or wines, the proprietor must prepare a record of the destruction that sets forth:

(a) The identification of the spirits, denatured spirits, articles, or wines, including kind, quantity, elements of gauge, name and permit number of the producer, warehouseman or processor, and identity and type

of container;

( The date, time, place and manner of the destruction;

© A statement that the spirits had, or had not, previously been withdrawn and returned to bond; and

(d) The name and title of any representative of the proprietor who accomplished or supervised the destruction.

That is pretty much it. For some reason I'm now sleepy.

[dhdunbar]

By the way, if anyone can explain why I seem to smile so often, I'd like to know. Would I be less happy if I used Explorer rather than Chrome? It seems when I quote the regs, smiles appear. I don't find them that entertaining, but I get paid to read them.

[Rickdiculous]

Let me rephrase my question?

How are you destroying your heads and tails?

Do you have a hazmat person pick them up and destroy them?

Are you watering them down and putting them down the drain?

Or is this simply one of those dirty little secrets no one wants to talk about?

My property sits on top of my drinking water, which is also consumed by and bathed it by my wife and kids. Simply putting this down my septic diluted or not doesn't sound like a good idea to me. Would you drink a diluted version of your heads?

So what are you actually doing with them in large quantities? I can read a regulation but that doesn't give anyone the "how to" I believe they and myself are looking for.

[HedgeBird]

My property sits on top of my drinking water, which is also consumed by and bathed it by my wife and kids. Simply putting this down my septic diluted or not doesn't sound like a good idea to me. Would you drink a diluted version of your heads?

No, I would not drink diluted heads but then again I would also not want to drink diluted sewer water.

If you have concerns about your septic water getting into your drinking water you should probably worry more about the shit you flush down the toilet than the diluted heads.

[HedgeBird]

By the way, if anyone can explain why I seem to smile so often, I'd like to know. Would I be less happy if I used Explorer rather than Chrome? It seems when I quote the regs, smiles appear. I don't find them that entertaining, but I get paid to read them.

Typing the following creates the sunglass wearing emoticon smiley... (i guess folks think the capital B sorta of looks like sunglasses)

So every sub-section B creates one.. You could try using the <> code thingy to paste in the regs instead of just pasting them right into the reply box.

full list of emoticons:

http://jwtalk.net/forums/index.php?app=forums&module=extras&section=legends

[Rickdiculous]

I'm sorry hedgebird you seem to lack a basic understanding of chemistry to think my shit is more toxic then compounds like methanol and acetyl acetate. Also, a septic system is design to deal with the shit as you so nicely put it. It is not designed for the waste output of distillation. So unless you care to answer the actual question don't insult me. I live in a rural area on a lake where this is a major concern, not a joke.

[jo-el-eo]

Hey Rick,

As you know, most folks redistill their tails. A few folks redistill their heads, but that's dodgy territory depending on how it's done. (I thought they were just doing it wrong, but there are some complex distillation schemes used in Scotland that redistill heads). Most folks claim they're reusing the heads for cleaning, solvent etc - but as we've interrogated a bit my impression is that most goes down the drain at most places, likely diluted in pot lees or water. On one hand it's a natural product of fermentation, but on the other hand it's very concentrated. I wouldn't want to dump it on a septic either. Burning it isn't a bad idea, if you can do so safely. We've been looking around for places that could use it locally for cleaning/solvent - but not much luck so far.

Joel

[jo-el-eo]

Oh yeah - one other thing. Until you're in processing or storage, the TTB doesn't require you to file anything about destruction. Losses are expected as part of distilling, so they don't expect everything to add up perfectly in the production account.

[HedgeBird]

Rickdiculous - I am not insulting you. You expressed concerns about heads traveling from your septic to your well water. As I view heads as less dangerous then septic water I made the point that If you are worried about cross contamination the sewage would be the bigger issue.

Having heads disposed off-site by a third party is not really an option for most of us because as dhdunbar pointed out, you or your representative must "supervise" the actual destruction. That basically leaves three options.

- Find some practical way to use it up

- Dump it down the drain

- Burn it

I think most people on this board agree that it is safe to dispose of heads by diluting and dumping down the drain:

Methanol - Methanol is readily biodegradable in both aerobic (oxygen present) and anaerobic (oxygen absent) environments. Methanol will not persist in the environment. The half-life for methanol in groundwater is just one to seven days, while many common gasoline components have half-lives in the hundreds of days (such as benzene at 10–730 days). Since methanol is miscible with water and biodegradable, it is unlikely to accumulate in groundwater, surface water, air or soil.. In some wastewater treatment plants, a small amount of methanol is added to wastewater to provide a carbon food source for the denitrifying bacteria, which convert nitrates to nitrogen to reduce the nitrification of sensitive aquifers.

Ethyl acetate- Ethyl acetate is used primarily as a solvent and diluent, being favored because of its low cost, low toxicity, and agreeable odor. Coffee beans and tea leaves are decaffeinated with this solvent. Ethyl acetate is present in confectionery, perfumes, and fruits. Given that the chemical is naturally present in many organisms, there is little risk of toxicity.

If you can't find a practical way to re-use this on site, and do not feel comfortable disposing of it in your septic system it would seem to me that destruction by fire may be the last remaining option.

This topic has also been discuses numerous times on this forum. You may want to give the following threads a read:

http://adiforums.com/index.php?showtopic=5112&hl=heads

http://adiforums.com/index.php?showtopic=4879&hl=heads#entry27246

http://adiforums.com/index.php?showtopic=49&hl=+dispose%20+heads

http://adiforums.com/index.php?showtopic=1839&hl=%2Bdispose+%2Bheads

http://adiforums.com/index.php?showtopic=906&hl=%2Bdispose+%2Bheads

[TetonDistillery]

Buy an ethanol furnace. Have your friends and neighbors get one also.

Supply them all with free fuel (heads) for the winter. Problem solved.

Here is the wall mounted type. Seriously, this is a great solution. Your friends and neighbors will love you for how much money you save them in the winter because of the free fuel.

They will even take it off your hands during the summer to store up for the next winter.

If you get an industrial alcohol license, you can even sell the heads.

[Rickdiculous]

Thank you, and I appreciate your well written answer, truly. I will check those posts and I have already found a good third party to give them to if necessary. I apologize for over reacting to your first response.

Rick

[TetonDistillery]

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[schnit]

Are those ethanol furnaces vented? Reason I ask is that my state strictly forbids "ventless" natural gas/propane heaters (and I'm guessing ethanol falls into that category as well).

[TetonDistillery]

You will have to do your own research on that. We have never had an issue in Idaho, Colorado or the state of Washington. They are very common around those states.

[bdkolstad]

Rad!

[OldSpye]

For what it's worth, the stuff works pretty good as lamp oil, too.

[dhdunbar]

Oh yeah - one other thing. Until you're in processing or storage, the TTB doesn't require you to file anything about destruction. Losses are expected as part of distilling, so they don't expect everything to add up perfectly in the production account.

TTB certainly expects losses, and this sounds like the advice that some TTB employees might give orally, but the regulations do require reporting of spirits destroyed in the production account before a production gauge is made. The provision is fairly well hidden in the requirement that you keep production records:

Sec. 19.585 (a) (2) A proprietor must maintain daily records of spirits lost or destroyed prior to the production gauge;

The general rule is that you must account for "every drop," to borrow a phrase from TTB's Expo presentation, of the spirits that come off the still. Is it something they enforce? I think some TTB employees may and some may not. But the requirement is there and I try to make people aware of what is required. What they do with the information is up to them.