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Anheuser-Busch Companies

Letter from Water Docket Re: Supplemental Info to XL Proposal


August 11, 1995

Regulatory Reinvention Pilot Projects,
Water Docket
Mail Code 4101
401 M Street, S.W.
Washington, DC 20460

Re: Supplemental Information to July 27, 1995 Project XL Proposal

Dear Sir/Madame:

It is our understanding that there is some confusion as to exactly what the expanded bubble encompasses and how it works. This is in response to the request that a supplement be submitted to clarify this area.

The expanded bubble concept (see attached diagram) is both multi-media in that it includes both air and water/wastewater and cross-media since it would involve trading across different media.

Presently, the only regulatory limits imposed on Anheuser-Busch for air emissions are through air permits for brewery operations. Similarly, the only regulatory limits imposed on Anheuser-Busch for wastewater emissions are by its NPDES permit for land application. As indicated in Appendices B and C of the Project XL proposal, less than one-half of the total air emissions impact of the brewery in the community actually comes from brewery emissions. Likewise, the major impact of the brewery on wastewater discharges to receiving streams is from effluent from the city's wastewater treatment plant, not Anheuser-Busch's land application operation.

The concept for the expanded bubble is to establish acceptable baseline emissions for all media (only air and water for pilot project) that account for total impact of the brewery in the community, not just emissions from brewery permitted sites.

The Nox data contained in Appendix B of the Project XL proposal will be used to illustrate the bubble concept from an air standpoint. The data in the following table were used to generate the graph in Appendix B.


NOx Air Emissions - lb/yr
At Brewery

(A-B Permitted) At JEA

1) From steam/power generation at brewery 196,000

2) From electricity purchased by brewery from JEA 166,000

3) From electricity purchased by Jacksonville water plant 6,000 for water provided to brewery

4) From electricity purchased by Jacksonville wastewater 353,000 plant to treat brewery wastewater

________ ________

TOTAL 196,000 + 525,000 = 721,000

% NOx Emissions from brewery = 27%

The baseline emission for NOx would be established as follows:

NOx Emission - lb

1) From brewery boilers/cogeneration V

2) KWH elec. purchased by brewery from JEA x W JEA emissions factor (lb NOx/KWH)

3) KWH elec. purchased by Jacksonville water plant X to treat A-B water x JEA emission factor

4) KWH elec. purchased by Jacksonville wastewater plant Y to treat A-B wastewater x JEA emission factor

5) KWH elec. purchased by A-B land application Z operation x JEA emission factor _______________


Similar baseline emissions would be established for all air and wastewater parameters.

Once the baseline emissions are established, these will be used as the basis for determining future compliance. The low NOx burner example contained in the Project XL proposal demonstrates how this expanded bubble concept allows industry to make the best business decision (accomplishing NOx reduction through pollution prevention/resource conservation), while achieving significantly improved community NOx reductions compared to the installation of low NOx burners - a win for industry and a win for the environment.

Also, once the community baseline emissions are established for all media, this will provide a basis for trading across media. By considering all media in decision making, it will help prevent making decisions that may improve one specific media, but at a net negative impact on overall community multi-media emissions.

It is hoped the above helps to clarify the expanded bubble concept. We look forward to the opportunity to be chosen as one of the Project XL pilots.



J.W. Sugar
Sr. Director
Corporate Environmental Affairs

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