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CARD Environmental Performance Report July 2009- December 2010

I. Introduction

1.1 Background

The Philippine Environmental Partnership Program (PEPP) is a program between the government, industry and civil society to promote improved environmental management and performance of industry. Since the beginning of the participation of the Center for Alcohol Research and Development Foundation (CARD) to the PEPP, participating distilleries have continuously implemented significant pollution control programs and demonstrated selfregulation geared towards full compliance to environmental regulations.

The purpose of the Environmental Performance Audit is to verify through a review the system's EMP implementation and effectiveness; to collect; and to evaluate objective evidence/s related to the EMP or EMS. This audit determines whether individual companys EMP is functioning as intended to produce desired outcomes; that documented practices and/or procedures are conducted; to identify those EMS elements that warrant efforts for continuous improvement; and to map a performance improvement pathway for the future.

Results of this and future audits will provide added value to our EMP system that will be viewed as an overall opportunity for enhancement. Since the audit is a snapshot in time, it cannot identify each and every area for improvement. However, the results of each of our audits do provide for an additional incremental step in the overall improvement of our EMPs.

1.2 Facilities Description

As of December, 2010 there is still a total of 11 participating distilleries in the Environmental Consent Agreement (ECONA) which was signed in December, 2003. following: These include the

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CARD Environmental Performance Report July 2009- December 2010

Absolut Distillers, Inc. (ADI)

ADI is a medium size alcohol distillery plant established in October, 1990. It is ADI

distillery complex occupies a total lot area of approximately nine hectares, sixty percent of which is dedicated to its wastewater treatment facility. Its major product is Ethyl Alcohol and liquefied Carbon Dioxide as a fermentation by-product. ADI has pioneered the Clean Development Mechanism (CDM) Project of the private manufacturing sector duly registered on October 2006 under the United Nations Framework Convention on Climate Change (UNFCC).

Alko Distillers, Inc. (ADI)

ADI was established in 1997 at Brgy. Baritao, Manaoag, Pangasinan in an estimated 1.2 hectare complex. The 10-year lease agreement with Hind Alcohol Company (HAC) expired last July 2010 and the management opted not to renew its contract.

Note: Not included in the audit scope.

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CARD Environmental Performance Report July 2009- December 2010

Asian Alcohol Corporation (AAC)

AAC plant was established in 1973 and is located at

Barangay Pulupandan,

Canjusa, Negros

Occidental, covering an area of approximately fifteen (15) hectares. The plant generates its own power and produces mainly hydrous ethyl alcohol with liquefied carbon dioxide as its by-product.

Not operating and was not included in the audit scope

Balayan Distillery, Inc (BDI)

BDI was established in 2001 and is located at Barangay Talisay, Calaca, Batangas covering an area of

approximately seven and a half (7.5) hectares. The

plant generates its own power mainly alcohol and produces ethyl

hydrous with

liquefied

carbon dioxide as its byproduct. The plant

features a small mooring facility at the shoreline along its private property for unloading of the materials.
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CARD Environmental Performance Report July 2009- December 2010

Central Azucarera de Tarlac (CAT) Distillery

The CAT Distillery is part of an` integrated manufacturing plant of the Jose Cojuangco & Sons Organization located in a fifty (50) hectare property inside the Luisita Agro-Industrial Complex in San Miguel, Tarlac City. Established in 1929, the

integrated facility produces both raw and refined sugar, and hydrous ethyl alcohol. Liquefied carbon dioxide and dried yeast are by-products of the Distillery.

Consolidated Distillers of the Far East, Inc. (CONDIS)

CONDIS started operations in 1990 and is located at

Barangay

Lumbangan,

Nasugbu, Batangas covering an area of approximately ten (10.0) hectares. The plant

generates its own power and produces mainly hydrous ethyl alcohol with liquefied carbon dioxide as its by-product.

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CARD Environmental Performance Report July 2009- December 2010

Distilleria Bago, Inc. (DBI) DBI was established in 1992 and is located at Km. 13.5, Brgy. Taloc, Bago City, Negros Occidental with an area of approximately 115 hectares. It then undertook a major expansion program that doubled its production capacity making it the largest of all the participating distilleries. The plant is an ISO 9001-2008 certified and produces hydrous ethyl alcohol and liquefied carbon dioxide.

Far East Alcohol Corporation (FEACO) FEACO was

incorporated in 1987 and is located in an approximately two (2) hectare property at Barrio Alauli, Apalit, Pampanga. The plant is ISO 9001-2000 certified and produces mainly hydrous ethyl alcohol.

International Pharmaceuticals, Inc. (IPI) Distillery

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CARD Environmental Performance Report July 2009- December 2010

IPI Distillery was established in 1993 and is located at Barangay Purisima, Manapla, Negros Occidental. The plant produces mainly hydrous ethyl alcohol. It ceased

operation in August 2009.

Kooll Company, Inc. (KCI)

KCI started operation in 1969 and is located at Barangay Bubog, Talisay City, Negros Occidental covering an area of approximately four (4)

hectares. The plant produces mainly hydrous ethyl alcohol with dried yeast as its byproduct.

Leyte Agri Corporation (LAC)

In 2001, LAC bought the existing plant from AA Aqua Agri Corporation located at Barrio Ipil, Ormoc, Leyte covering an area seven The of (7) plant

approximately hectares.

produces mainly hydrous and anhydrous ethyl alcohol with liquefied carbon dioxide as its by-product. It is the first bio-ethanol plant in the Philippines which started its operation in April 2008.

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CARD Environmental Performance Report July 2009- December 2010

All these distilleries are active members of CARD Foundation from the beginning of the ECONA to the present. The updated contact details of the distilleries are shown in Table 1.

Table 1. Participating Members

Company Absolut Distillers, Inc (ADI) Barangay Malaruhatan Lian, Batangas Alko Distillers, Inc. (ADI) Bo. Baritao, Manaoag, Pangasinan Asian Alcohol Corporation (AAC) 11 Alijis Road, Bacolod City

Contact Person Gerardo T. Tee Jaime Giovanni H. Tan

Contact Details 043-215-2439 gerrytee@yahoo.com www.jagitan@yahoo.com.ph

Engr. Philip T. Baligod

075-529-011 kis@mozcom.com
NOTE: No operations

Henry L. Tan Susan C. Benitez

034-434-7001 susan.benitez@asianalcohol.com.ph scbenitez@yahoo.com


NOTE: No operations

Balayan Distillery Inc. (BDI) Km. 118 Barangay Talisay Calaca, Batangas

Redmond L. Lee Abigail S. Macalalad

02-635-9888 043-223-7426 balayan_distillery@yahoo.com gabby_macalalad@yahoo.com

Central Azucarera de Tarlac (CAT) Barangay Central, Tarlac City

Fernando C. Cojuangco Fernando B. Urbanozo Romeo B. Ecraela

045-491-1086 r_ecraela@yahoo.com

Consolidated Distillers of the Far East Inc. (CONDIS) Lumbangan, Nasugbu, Batangas

Felizardo T. Sapno Luzviminda A. Angeles

02-867-8873 to 75 043-931-3827 luzangeles2000@yahoo.com

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CARD Environmental Performance Report July 2009- December 2010

Distileria Bago, Inc. (DBI) Km. 13.5 Brgy. Taloc, Bago City, Negros Occidental

Cesar B. Gimena Alfredo P. Aquino Kerwin L. Lopez

034-444-2965 klopez@smg.sanmiguel.com.ph

Company Far East Alcohol Corp. (FEACO) Brgy. Alauli, San Vicente, Apalit, Pampanga

Contact Person Antonio S. Co Rodolfo B. Calagui Juanito C. Manalang

Contact Details 045-302-5904 rcalagui@feac.com.ph


jmanalang@yahoo.com

Kooll Company Inc. (KOOLL) Brgy. Bubog, Talisay City , Negros Occidental Leyte Agri Corp. (LAC) Brgy. Ipil, Ormoc City, Leyte

Juanito Y. Gamboa Benjamin A. Masiglat

034-495-2718 034-495-1994 koollcompany@yahoo.com

Ruben A. Villanueva Maria Perpetua T. Honrado

02-848-0224 ravill@broline.com mthonrado@taocommodity.com.ph

2.0 AUDIT OBJECTIVES

The 2010 CARD Foundation Performance Audit focused on site inspection and table validation. The objective of the internal audit was to assess implementation and compliance of set Environmental Management Plans (EMPs) based on Environmental Management System (EMS).

2.1 AUDIT SCOPE AND METHODOLOGY

2.1.1 Audit Scope

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CARD Environmental Performance Report July 2009- December 2010

The scope of this Performance Audit encompassed the entire wastewater value chain (pre-treatment, collection and treatment, storage and transportation and end use / disposition), as it applies to each companys individual operations, with special attention to practices and management activities that directly support wastewater treatment-related operations, processes and activities.

Specifically, the scope of this audit included: Validation of compliance with the regulated aspects (all applicable requirements). Review of documentation or proof of compliance showing that EMPs have been properly implemented and maintained. Audit of performance of the wastewater treatment plant. The audits were performed onsite at the plant facilities. Verification of pertinent transactions to assess functionality of set EMPs. Examination of outcomes being achieved by the company through the use of their set EMPs.

2.1.2 Audit Methodology

The audit was performed by assessing key processes or activities related to the companys program for conformance with the regulated and unregulated aspects of the set EMPs. Using sampling techniques, the auditors interviewed key persons, observed practices in place and reviewed pertinent documents and records. Plant representatives were interviewed to validate set programs.

Note: No audit was conducted for 2010. Audit Schedule for 2011
Date : February 9 Time: 9:00 AM-5PM Location: Federal Activity/Agenda: Consolidation of 2010 PEPP report. Preparation of Audit Plan
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CARD Environmental Performance Report July 2009- December 2010

March 8

6:20-7:20 AM 7:20AM-11:00AM 12:00NN-5:30PM

BCD to MNL MNL to Batangas BDI Batangas ADI Batangas CONDIS Batangas BTGS to Tarlac CAT Tarlac FEACO Apalit Apalit to Tarlac CAT Conference room CAT to Manila

PCOs from Bacolod to Manila All PCOs from Manila to Batangas Plant Audit Plant Audit Plant Audit All PCOs from Batangas to Tarlac City Plant Audit Plant Audit Overnight at Tarlac Consolidation of Luzon Audit results. PCOs from Tarlac to Manila PCOs from Manila to Bacolod

March 9

8:00AM-12:00NN 1:00PM-5:00PM 5:00PM-11:00PM

March 10

8:00AM-11AM 1:00PM-5:00PM 5:00PM-6:00PM

March 11

8:00AM-4:00 PM 4:00PM-8PM

March 12 April 25

8:40 AM 9:00 AM-10:25AM 7:00 AM 8:00AM 10:00AM-12:00NN 1:00PM-5:00PM 8:30AM-10:30AM BAC to CBU MNL to CBU CBU to Ormoc LAC Ormoc Ormoc to CBU Consolidation of reports 6:00PM-7:00PM CBU to BCD DBI Bago City Kooll Talisay City AAC office

PCOs from Bacolod to Cebu PCOs from MNL to Cebu PCOs from Cebu to Ormoc Via Ferry Plant Audit PCO from Ormoc to Cebu Via Ferry

April 26

1:00PM-5:00PM

PCO from Cebu to Bacolod Plant Audit Plant Audit Consolidation of Visayas Audit results. PCOs from Bacolod to Manila

April 27

8:00 AM-11:00NN 2:00PM-5:00PM

April 28 April 29

8:00AM-4:00PM 10:40 AM

2.2 AUDIT TEAM The Center for Alcohol Research and Development Foundation selected the individuals listed in Table 2 to serve as members of the Environmental Performance Audit Team. All team members have received internal EMS auditor training, and were deemed competent to have

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the level of expertise necessary to conduct the audit. These individuals were chosen based on their knowledge of the organization and/or their ability to gather objective evidence.

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CARD Environmental Performance Report July 2009- December 2010

Table 2. Composition of the Audit Team

Role Lead Auditor Auditor Auditor Auditor Auditor Auditor Auditor Adviser Adviser

Name (Firm) Kerwin L. Lopez, DBI Abigail S. Macalalad, BDI Romeo B. Ecraela, CAT Jaime Giovanni H. Tan, ADI Rodolfo B. Calagui, FEACO Luzviminda A. Angeles, CONDIS Melinda E. Bartolome, TDI Susan C. Benitez, AAC Ma. Perpetua T. Honrado, LAC

3.0 ENVIRONMENTAL PERFORMANCE

3.1 Regulated Aspects 3.1.1 Environmental Impact System (PD 1586)

All distilleries have existing Environmental Compliance Certificates (ECCs) covering the different areas of operation of their plants. A number of distilleries were in operation before the enactment and effectivity of this Presidential Decree e.g. CAT and KOOL but all succeeding projects and expansions have secured ECCs. Examples of these projects are capacity expansions, storage facilities, fertilization program and system upgrading. Some plants have not implemented any expansion programs since the start of their operation.
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CARD Environmental Performance Report July 2009- December 2010

The ECCs of each distillery is shown in Table 4

Table 4. List of Environmental Compliance Certificates Issued to Distilleries

Company

Environmental Compliance Certificate # (ECC) 8703-003-114

Project

ADI

Alcohol Distillery

AAC

0601-0326-084-120 0697-1118-567-120A 0605-0411-185-120 0607-1227-442-120

Barrel Farm Expansion Project Molasses Storage Tanks Storage Terminal Expansion Project

BDI

ECC 0005-161-114

Alcohol Distillery

CAT

Not Covered

Condis

ECC-263-BA-120-94 ECC 4A-2002-041-120 ECC 4A-2004-0194-3529 ECC-4A-2005-0458-3131

Distillery Expansion Re-distillation Plant Fertilization Program Modernization/ Upgrading of Distillery Columns Modification and upgrading of the redistillation plant

ECC-4A-2007-0189-3131

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CARD Environmental Performance Report July 2009- December 2010

Company

Environmental Compliance Certificate # (ECC) ECC 1 9204-026-114CD ECC 2 0697-1111-497-120 ECC 3 0601-0716-200-120

Project

DBI

Alcohol Distillery Expansion Project Molasses Tanks and Submarine Pipeline Cassava Composting Plant 69 KV Transmission Line

ECC 4 0602-0923-317-120 ECC 5 0603-0707-251-120

Feaco

ECC 03-PA 1007-220043-120A

Fertilization Program

Kooll

0600-0621-127-120 0698-1012-210-120A

CO2 Recovery Plant Molasses Tank

LAC

08-070604-0044

Alcohol Distillery

3.1.2 Clean Air Act (RA 8749) Distilleries operate boilers to generate its needed steam and power in processing, hence, each distillery has one or more smokestacks and is considered a point source. Facilities for air pollution control include water scrubbers, flares, gas recovery systems dust/particulate collectors and all the distilleries so far are adequately equipped as manifested by their valid permits to operate from the DENR-EMB. Details of which are shown in Table 5.

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CARD Environmental Performance Report July 2009- December 2010

Table 5. List of Permit to Operate (Air) Issued to the Distilleries

Company ADI BDI CAT Condis DBI Feaco Kooll LAC

Permit to Operate (POA) 2010-POA-0410-002 2010-POA-0410-504

Validity August 26, 2011 August 13, 2010

2010-POA-0410-005 10-POA-G-0645-123 TPOA-90J-03PA-047 09-POA-H-0645-038 09-POA-E-0837-0261

August 22, 2010 September 15, 2011 October 30, 2010 August 15, 2010 February 28, 2010

3.1.3 Clean Water Act (RA 9275) Distilleries discharging wastewater either to a receiving body or to farmlands as fertilizer must secure a Discharge Permit. Herewith is the breakdown of how the 10 distilleries discharge their effluent. BDI and KOOLL through barging to the dumping site designated by the Coast Guard. CAT holds a permit to discharge its effluent to Class D (OEI) RBW, Bojo Creek.
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CARD Environmental Performance Report July 2009- December 2010

DBI was given permit to discharge through the Guimaras Strait via submarine outfall.

ADI, CONDIS, FEACO and LAC were permitted to discharge their waste to farmlands as fertilizer by the fertilizer and pesticide authority.

Most of the plants have undergone various enhancement projects for the wastewater treatment plant and have been continuously implementing programs geared towards the reduction of pollution load. Among these are the continuous enzyme treatment to reduce TSS concentration and application of inoculants for further slops digestion. For this period under review, AAC was under TLO issued by the Pollution Adjudication Board. All other distilleries have no notice of violation for non-compliance to water standards. All measures for pollution prevention were religiously carried out as

manifested in the EMP report. Table 6 shows the details of the permits to discharge of the distilleries while Table 6 shows the FPA permits of the four distilleries.

Table 6. List of Discharge Permits

Company ADI BDI CAT Condis DBI Feaco

Discharge Permit (DP) 2010-DP-BA-0398 2010-DP-BA03-064 DP-10L-03TA-1056 2010-DP-BA-03-096 10-DPW-G-0645-123 DP-09J-03PA-031

Validity August 31, 2011 September 11, 2011 December 30, 2011

July 15, 2011 October 13, 2010

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CARD Environmental Performance Report July 2009- December 2010

Kooll LAC

09-DPW-H-0645-038 10-DP-C-0837-0206

August 15, 2010 February 28, 2011

3.1.4 Hazardous Wastes Management (RA 6969)

Disposal of any hazardous wastes in any form are regulated under the Republic Act No. 6969. Alcohol plants do not generate hazardous wastes but they are required to obtain hazardous wastes generators IDs because some of the facilities used such as transformers, generators and trucks generate hazardous wastes such as PCB and used oil respectively. However, the operations make use of sulfuric acid, which is a regulated substance and so there is a need for all distilleries to secure permit from PDEA to make use of the substance.

Table 7. Fertilizer and Pesticides Authority Permits

Company ADI

FPA Control # Manufacturing - # 129 Warehousing W-126 Product Registration 1 1LF-1103 Abono

Condis

Manufacturing - # 252 Warehousing - W-249 Product Registration 1 1LF-2000

Feaco

Manufacturing - # 096

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CARD Environmental Performance Report July 2009- December 2010

Warehousing W-047 (L3) Warehousing W-046 (L2) Warehousing W-045 (L1) License-121 Control No :01-04L-2009 License-125 Control No :01-04L-2010 Product Registrations 1 1LF-1148 Product Registrations 1 1LF-1149 Product Registrations 1 1LF-1150 LAC Experimental Use Permit F-337

Older distilleries have facilities that still contain Polychlorinated bi-phenyls (PCB) such as AAC and LAC. These companies likewise registered their PCB containing facilities in the same manner as the asbestos under the Chemical Control Order Registry.

Refer to Table 8 for the list of Hazardous Wastes Generators IDs of the distilleries.

Table 8. Hazardous Wastes Generators IDs of the Distilleries

Company ADI AAC BDI CAT

Hazardous Wastes Generators ID # 04-10-0130 06-45-0020 04-10-0134 03-69-0001

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CARD Environmental Performance Report July 2009- December 2010

Condis DBI Feaco Kooll LAC

04-10-0017 06-45-0029 03-54-0087 06-45-0054 08-37-0008

Table 9. PDEA License of the Distilleries

Company ADI

PDEA License No. P3-01447001-R011 P6-01447001-R014

BDI

P3-129R258-042309-050710 P6-350R107-042309-050710

CAT

P3-1224R020-011409-011910 P6-229R008-011409-011910

Condis

P3-934R260-042409-042510 P6-388R108-042409-042510

DBI Feaco

P3-913R238-041609-033110 P3-995R770-60707-61410 P6-221R771-60607-61410

Kooll LAC

P3-1590-080709-080710 P3-204R257-042309-042610 P6-235R106-042309-042610


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CARD Environmental Performance Report July 2009- December 2010

3.1.5 Department Administrative Order 26

Directly ensuring their compliance to environmental regulations are the Pollution Control Officers (PCOs) of the distilleries. The list of updated PCOs together with their accreditation numbers is shown in Table 10. Table 10. List of Pollution Control Officers

Company ACI ALKO AAC BDI CAT Condis DBI Feaco IPI Kooll LAC

PCO Gerry Tee Jaime Giovanni H. Tan Engr. Philip Baligod Susan Benitez (PCO III) Joerey B. Ison Abigail Macalalad Romeo B. Ecraela Luzviminda A. Angeles Kerwin L. Lopez Rodolfo S. Calagui Wilma Dignos Benjamin Masiglat Andres Aquino II Yolanda Juanillo Nofe M. Cabintoy Cynthia G. Leonidas Dalla D. Atok

Accreditation # Accredited, 1988 2006-205 Accredited, 1998 2000-3131-0645-278 04-0645-3131-407 2004-1051 01J-03TA-018-2001 2007-2170 05-0645-3131-508 02C-03PA-056 99-3131-0645-262 05-0645-3134-498 05-0645-3134-499 06-067 06-068 06-069 06-070

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CARD Environmental Performance Report July 2009- December 2010

3.2 Unregulated Aspects and Implementation of OTPs 4.2.1 Reduction in Slops Generation

The production of alcohol entails the production of slops and other liquid wastes. Distilleries produce huge volume of slops which has a strong pollution load. Most of the slops produced is being confined in temporary, lagoons or digesters as a means of avoiding water pollution. Reduction in slops generation has been one of the major waste minimization activities being continuously implemented, monitored and evaluated in distilleries. The programs being implemented in line with slops reduction include process upgrading and modernization and the use of better yeasts. Some plants have been utilizing enzyme to increase the efficiency of sugar conversion to ethanol. Others have recently deployed enhanced batch culture and continuous fermentation with Yeast Recycling System. 4.2.2 Renewable Energy from Wastewater Treatment In abeyance to the governments stringent regulations on the qualities of industrial effluents, distilleries have developed and enhanced their wastewater treatment plant facilities using the best available technology. Most of the distilleries have been using anaerobic digester technology to turn wastewater into energy. Anaerobic Digestion improves wastewater treatment efficiency while providing value added by products such as energy in the process. These companies have invested more than Php 150 million over the past years to implement this process, which combines the treatment of wastewater with the generation of energy to minimize the plant's reliance on fossil fuels. The heart of the treatment facility is an anaerobic digester, where micro-organisms naturally degrade waste materials, producing biogas (methane) in the process. Biogas is then collected and stored before
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being utilized as boiler fuel to produce steam, which is used in the distillery for alcohol production. This wastewater treatment process has produced significant quantities of renewable energy. Plants have derived more than 40% of its energy requirements from naturally created biogas. The distilleries have put in a lot of money for their cogeneration facility, producing electricity from biogas, enhancing the site's energy efficiency and its reduced reliance on fossil fuels.

4.2.3 Utilization of Treated Slops/ Sludge as Fertilizer

Slops is usually considered as wastes but it has all the essential elements required for the growth of plants, therefore it has an agronomic value. The use of slops for agricultural purposes is continuously being practiced by the distilleries since it ensures a sustainable environment by improving the soil pH, increasing the soils nutrient content and improving the soils physical properties. A study carried out by the distilleries has proven the use of slops as fertilizer on sugar cane and other crops. Researchers have also studied its application for other crops such as corn, papaya, vegetables, mango and ornamentals. At present, there are four distilleries with on-going fertilization programs, namely, ADI, CONDIS, FEACO, and LAC. After passing slops thru a series of treatment, digested slops is subsequently withdrawn and delivered thru tank trucks and sprayed as soil conditioner and fertilizer. Its utilization for agricultural purposes is an economical and feasible alternative. Distilleries undertaking agricultural application of slops have secured the corresponding permits from FPA and ensure that their product is safely transported and uniformly applied in the field. Regular monitoring of groundwater, surface water and soil is being conducted in the areas applied with distillery effluent. The records of soil and groundwater quality data are properly maintained and copies of the collected data
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are submitted to EMB as part of their compliance requirements. Site evaluation of the area prior to fertilization is likewise conducted. 100 percent utilization of slops for fertilization results in the absence of wastewater discharges such as in the case of ADI, CONDIS and FEACO.

4.2.4 Reduction of Washings The distilleries resource conservation program have significantly reduced the used of fresh water in the washing activities within the plant. Volume reduction ranged from 2 to 50 percent.

These reductions were achieved through the following measures:

the 50 percent reduction was achieved by simply using the wash water twice;

decreasing the frequency of washing from 10 times to 6 times; substituting washing with dry cleaning where possible; and use of spent CO2 scrubber water instead of fresh water. use of RC bottoms product in cleaning fermentation vessels instead of fresh water

collection of reject water from the reverse osmosis for re-use recover water from the CO2 and air blower for re-use re-used of yeast separator flushing water to other processes

The decreased fresh water consumption further led to energy conservation since there was a significant decrease in the operation of water pumps.

4.2.5 Reduction/ Recycling of Solid Wastes


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CARD Environmental Performance Report July 2009- December 2010

The most common solid wastes from the distilleries are used containers that come in the form of plastic and metal drums, carbouys, and sacks. All these are recyclable and as such are collected and either sold to scrap buyers or donated to the local community as part of their outreach programs. Some companies are implementing a supplier return policy to eliminate accumulation of carbouys in the plant.

Sludge from the wastewater treatment process are stored and disposed of as follows:

Dried, collected and stored in 25 K bags; Dewatered and disposed of through the landfill; Used as organic fertilizer for fruit trees (mangoes); and Used as part of feeds for aqua cultures.

4.2.6 Prevention of Accidental Releases

There were no accidental releases, both in the transport of treated slops for fertilization and in the barging of slops to designated discharge points during the period in review. Distilleries having fertilization and barging activities have continuously

implemented protocols drafted for conducting these activities and trained personnel directly involved in the transport and barging of treated slops.

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