Appendix K 

 

Reasonably Available Control Technology Analysis 

(RACT) for Wine Fermentation, Wine Storage Tanks, 

and Brandy Aging 
 

2007 Ozone Plan

This page intentionally blank.
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-1

Appendix K: Reasonably Available Control 

Technology (RACT) Analysis for Wine Fermentation, 

Wine Storage, and Brandy Aging

I. Executive Summary 

A. Summary of results 

B. Background 

 1. Reasonably Available Control Technology (RACT) 

 2. Wine fermentation, wine storage, and brandy aging 

C. Requirements for this analysis 

D. Approach - Top down Analysis. 

II. RACT Background 

A. Clean Air Act Requirements for RACT 

B. Cost Effectiveness Levels – What has EPA approved as RACT across the 

country 

C. Control technologies for wine fermentation and storage that are achieved 

in practice or technologically feasible 

III. Industry Background 

A. Winemaking process 

B. Winemaking industry 

IV. Cost Effectiveness and RACT Determination for Wine Fermentation 

A. Emission Control Technology For Control of Ethanol Emissions From Wine 

Fermentation Tanks 

1. Background 

2. Emissions Capture System 

3. Adsorption Vapor Recovery 

4. Thermal Oxidation 

 5. Catalytic Thermal Oxidation 

 6. Wet scrubbing (absorption) 

 7. Condensation, Refrigeration, and Cryogenic Systems 

8. Biological Oxidation 

9. Temperature Control of Fermentation 

 B. Cost Effectiveness for Red Wine Fermentation 

 1. Approach of Cost Effectiveness 

 2. Estimation approach and basis 

3. Cost effectiveness estimates 

 4. RACT selection for red wine fermentation 

 C. Cost Effectiveness for White Wine Fermentation 

 1 Estimation approach and basis 

2. Cost effectiveness estimates 

 3. RACT selection for red wine fermentation 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-2

V. Cost Effectiveness and RACT Determination for control of Ethanol 

Emissions from Wine Storage 

A. Emission Control Technology For Control of Emissions From Wine 

storage

1. Background 

2. Emissions Capture System 

3. Adsorption Vapor Recovery 

4. Thermal Oxidation 

 5. Catalytic Thermal Oxidation 

 6. Wet scrubbing (absorption) 

 7. Condensation, Refrigeration, and Cryogenic Systems 

VI. Cost Effectiveness and RACT Determination for Brandy Aging 

A. Emission Control Technology For Control of Ethanol Emissions From 

Brandy Aging 

 1. Background 

 2. Emissions Capture System

 3. Thermal Oxidation 

 4. Catalytic Thermal Oxidation 

 5. Adsorption Vapor Recovery 

 6. Wet scrubbing (absorption) 

 7. Condensation, Refrigeration, and Cryogenic Systems 

 8. Biological Oxidation 

 9. Modification of aging warehouse and/or aging operation 

B. Cost Effectiveness for Brandy aging 

 1. Approach for cost effectiveness 

 2. Estimating approach and basis 

 3. Cost effectiveness analysis for brandy aging operations 

 4. Cost effectiveness summary for brandy storage 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-3

I. EXECUTIVE SUMMARY 

A. Summary of results 

This report constitutes the technical and economic analysis conducted by the San 

Joaquin Valley Unified Air Pollution Control District (District) to determine the 

appropriate level of Reasonably Available Control Technology (RACT) for wine 

fermentation, wine storage tanks, and brandy aging operation. Based on the results of 

the analysis, the District believes that there is no feasible RACT-level control for wine 

fermentation, wine storage tanks, and brandy aging because of the following reasons: 

• Currently, there is no achieved in practice control technology to control VOC 

emissions from wine fermentation or brandy aging. 

• Technologically feasible control options to reduce VOC emissions from wine 

fermentation and wine storage tanks are not economically feasible. The 

estimated cost effectiveness is $32,000 to $48,000 per ton for red wine 

fermentation, $18,000 to $52,000 per ton for white wine fermentation, and 

$38,000 to $84,000 per ton for wine storage tanks. These cost effectiveness 

values exceed the threshold generally established by EPA for sources subject to 

existing Control Technique Guidance documents (CTGs)1

, which is about $4,400 

per ton of VOC ($2,000 per ton 1980 dollars adjusted to 2007 dollars)2. There is 

also concern that emissions control could contaminate the product or impact 

wine quality and consistency. 

• For brandy aging emissions control, the estimated cost effectiveness is about 

$1,000 per ton of VOC for catalytic oxidizer to $5,300 per ton for water scrubber. 

Although these values appear to be economically reasonable in comparison with 

the $4,400 per ton threshold generally established by EPA for sources subject to 

existing CTGs, the District believes that there is no feasible RACT-level control 

because the control technology has not yet been installed, operated and 

evaluated. A brandy facility operator was recently issued an Authority to 

Construct permit by the District. As such, control of brandy aging emissions 

could not be considered as achieved in practice at this time until after a few years 

when it can be determined that there would be no adverse impacts on aging 

operation and most importantly on the quality or consistency of the product. (See 

discussion in Section B.1 and Section VI of this report.) 

 

To determine RACT, the District researched control technologies that may have been 

achieved in practice, as well as controls that may be technologically feasible for wine 

fermentation, wine storage tanks, and brandy aging. Even though the cost 

effectiveness of controlling emissions from wine storage tanks has been determined to 

be economically infeasible, the District considered the use of pressure vacuum valves 

 

1

 May 18, 2006 Memorandum from William T. Harnett, Director of air Quality Policy Division, to Regional Air 

Division Directors. “RACT Qs & As – reasonably Available Control Technology (RACT): Questions and 

Answers”. On page 2, answer to question #6 stated that: “EPA has never issued a general cost of control for VOC, 

but costs of control in CTGs generally ranged around $2000/ton in 1980s dollars.” 

2

 Cost effectiveness value in 2007 dollars based on an 3% average inflation rate = $2000/ton x (1.03)27 yrs = 

$4,443/ton 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-4

and temperature control as achieved in practice BACT because they are in-place on 

virtually all wine storage tanks located in the District. Since there are no achieved in 

practice emission control technologies for wine fermentation or brandy aging and the 

fact that these source categories have never been controlled by other states in the 

nation or worldwide, the District evaluated control options that may be technologically 

feasible. The control technologies that were evaluated include thermal oxidation, 

catalytic thermal oxidation, regenerative thermal oxidizer, wet scrubbing (absorption), 

adsorption vapor recovery, and condensation, refrigeration, and cryogenic systems). 

These technologies are exhaust-type controls, which require the installation of ducting 

system to capture the emissions from the tanks and then sent to the control device for 

destruction or adsorption/absorption of VOC. Biological oxidation and temperature 

control of fermentation have been determined to be not technologically feasible. A 

detailed discussion of each control option is presented in Section IV of this report. 

B. Background 

1. Reasonably Available Control Technology (RACT) 

EPA defines RACT in the Strelow memorandum3

 as: “the lowest emission limitation that 

a particular source is capable of meeting by the application of control technology that is 

reasonably available, considering technological and economic feasibility.” Documents 

that are useful in establishing RACT include EPA’s Control Technique Guidance 

documents (CTGs), Alternative Control Technique guidelines (ACTs), Maximum 

Achievable Control Technology (MACT), National Emission Standards for Hazardous 

Air Pollutants (NESHAP), New Source Performance Standards (NSPS), EPA’s 

RACT/BACT/Lowest Achievable Emission Reduction (LAER) Clearinghouse, 

regulations adopted in other California air districts, other states in the nation or other 

countries. There are no CTG, ACT, MACT, NESHAP, NSPS, RACT, BACT, LAER or 

other federal documents that could be used to establish the appropriate RACT level for 

this source category. In fact District staff were unable to find any examples of any wine 

fermentation or branding aging emissions control currently being implemented either 

nationally or worldwide. District Rule 4694 (Wine fermentation and Storage Tanks) is 

the first regulation in the world requiring VOC control from wine fermentation and 

storage tanks. In the absence of achieved in practice control technology for wine 

fermentation or brandy aging, the District conducted a technical and economic analysis 

of all possible control options to determine RACT. The District believes that there is no 

feasible RACT-level control because none of the candidate controls are economically 

feasible. The unit cost for emissions reductions from wine fermentation and storage is 

very high compared to controls for other existing sources mandated-to-date by the 

District or other air quality agencies in California. It is important to mention that even 

though the unit cost of emissions reduction is very high for wine storage tanks, the 

District considers pressure vacuum (PV) valve as achieved-in-practice Best Available 

Control Technology since most storage tanks already have existing PV valves. 

 

3

 The Strelow RACT Memorandum, published in BNA Environmental Reporter, December 9, 1976, pages 1210-

1212. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-5

Recently, the District has issued an Authority to Construct permit for one brandy aging 

facility which has been proposed for purposes of generating Certified Emissions 

Reduction Credit (CERs) to offset the required wine fermentation emissions reduction 

required by Rule 4694 (Wine Fermentation and Storage Tanks). The proposed facility 

will modify an existing brandy aging warehouse to make it meet the EPA Test Method 

204 requirements for a Permanent Total Enclosure so that the ethanol emissions could 

be captured and destroyed using regenerative thermal oxidizer technology. However, 

the provisions of the permit requiring the operation of the capture and control system 

are provisional, based upon successful demonstration that the operation of the controls 

does not result in unacceptable impacts on brandy quality or consistency. Therefore, 

the District believes that, at this time, there is no feasible RACT-level control for brandy 

aging emissions until such time when the facility operator could successfully determine 

that the control would have no adverse impact on product quality or the aging process. 

2. Wine fermentation, wine storage, and brandy aging operation

Wine is an alcoholic beverage produced by fermentation of sugars in fruit juices, 

primarily grape juice. “Fermentation, the process which converts grape juice to wine, 

occurs via anaerobic breakdown of organic compounds, by action of microorganisms or 

their extracts, to products simpler than the starting substrate. With wine, breakdown of 

grape juice is caused by yeast. The yeast provides complicated enzymes that, in the 

presence of sugar, form alcohol, carbon dioxide, glycerin, and other products. The 

amount of time required to complete fermentation is a function of fermentation 

temperature, at 55 to 600

F, wines are fermented in 7 to 10 days, while at 75 to 800F, 

wines take 3 to 6 days to ferment.”4 In commercial wineries fermentation commonly 

occurs in fixed-roof steel tanks (fermenters) by inoculation of must with yeast. After 

fermentation, wine is transferred a number of times between storage tanks to perform 

various finishing operations such as “racking” (decantation for separation of sediment), 

filtration, malolactic fermentation (breakdown of malic acid to lactic acid and carbon 

dioxide). 

Brandy is prepared by distilling fermented grape juice and then aging the distilled 

product in wooden casks (usually oak) which colors it, mellows the palate, and adds 

additional aromas and flavors. The changes that occur during the aging process are the 

result of interactions between the aging brandy and the oak barrel, driven by the 

conditions of the surrounding atmosphere which may have both diurnal and seasonal 

variation. Both ethanol and water evaporate from the surface of the barrel during the 

aging process with the rate of evaporation (and the style of the brandy) depending upon 

both the porosity of the barrel and the atmospheric conditions of the storage among 

other factors. The average brandy aging period is about 2 to 3 years. A detailed 

discussion of brandy making and aging process is presented in Section VII. 

 

4

 California Air Resources Board (ARB) 8/06/03 Draft Technical Assessment Document “Strategies and Costs for 

Winery Ethanol emission Control”. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-6

C. Requirements for RACT Analysis 

The District adopted Rule 4694 (Wine Fermentation and Storage Tanks) on December 

15, 2005. The rule was submitted to the California Air Resources Board and was 

transmitted to the United States Environmental Protection Agency (EPA) on June 16, 

2006 for inclusion in the state implementation (SIP). On October 16, 2006, EPA Region 

IX provided written comments expressing similar concerns as those previously 

discussed by EPA correspondence to the District in October and December 2005, and 

March and June 2006. Basically, EPA required the District to demonstrate that Rule 

4694 meets RACT. EPA indicated that the analysis of RACT should systematically 

consider all possible controls for the sources and explain why rejected controls are 

technically or economically unreasonable to require. 

D. Approach - Top down Analysis. 

The District used a “top-down analysis” approach to determine the appropriate RACTlevel control for reducing emissions from wine fermentation, wine storage, and brandy 

aging operations. A top-down analysis consists of (1) identifying technologically 

feasible control technologies for the emission source category; (2) eliminating infeasible 

control technologies; (3) calculating and analyzing cost effectiveness of available control 

technologies; and (4) selecting RACT based on most cost effective control technology 

option. A detailed top-down analysis for this source category is presented in Section IV 

of this report. 

II. RACT BACKGROUND 

A. Clean Air Act Requirements to Implement RACT 

In the San Joaquin Valley Air Basin (SJVAB), monitored levels of ozone exceed 

National Ambient Air Quality Standards (NAAQS), which are set at levels that protect 

public health and welfare. Consequently, EPA has classified the SJVAB’s air quality as 

serious for its nonattainment designation for the federal eight-hour ozone NAAQS. 

Under the now revoked federal one-hour ozone standard, the SJVAB was classified as 

extreme nonattainment. As nonattainment area, Section 182(b)(2) and elsewhere in the 

Clean Air Act, the District is required to implement RACT for all NOx and VOC major 

sources within its jurisdiction. Wine fermentation and storage is a major VOC source, 

and as such RACT for this source category needs to be implemented. In addition, 

pursuant to the one-hour Ozone Attainment Demonstration Plan the District adopted 

Rule 4694 (Wine Fermentation and Storage Tanks) on December 15, 2006 to 

implement Best Available Retrofit Control Technology (BARCT). Upon submission of 

Rule 4694 to EPA for inclusion into the State Implementation Plan (SIP), EPA required 

the District to demonstrate that the rule implements RACT. To demonstrate RACT EPA 

stated that the analysis should systematically consider all possible control options and 

why rejected controls are technically and/or economically unreasonable to require. This 

report constitutes the District’s analysis of possible control options that may be 

technologically and economically feasible to determine the appropriate RACT 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-7

requirements. Based on the analysis, the District believes that there is no feasible 

RACT-level control for this source category due to reasons discussed above in Section 

I.A as well as the detailed analysis presented in Section IV. 

B. Cost Effectiveness Levels – What has EPA approved as RACT across the 

country? 

Based on EPA’s definition of RACT and the fact that there are no existing federal 

control requirements or technical guidance documents for controlling emissions from 

wine fermentation, wine storage, or brandy aging the District evaluated candidate 

control options that could be used to establish RACT requirements. In evaluating 

“economic feasibility” of requiring emission control, the District researched what EPA 

has historically considered as cost effective when adopting CTGs or other federal air 

emissions regulations. According to an EPA memorandum5

, the cost effectiveness for 

CTGs generally ranged around $2,000 per ton (1980 dollars), or $4,400/ton (adjusted to 

2007 dollars). The District is not aware of any other EPA guidance that specifically 

states a cost effectiveness level that is acceptable for RACT. In the absence of a 

specific EPA threshold, the District believes that it is reasonable to judge economic 

feasibility or infeasibility based on what the District has historically mandated for other 

source categories. The District believes that high unit cost of emissions reduction shown 

in Section IV is “economically infeasible” to mandate so there is no feasible RACT-level 

control for this source category. 

C. Control technologies for wine fermentation, wine storage tanks, and brandy 

aging that are achieved in practice or technologically feasible 

Wine fermentation and wine storage tanks 

After conducting research of technical documents relevant to wine fermentation 

emissions control, the District has determined that there are no technologies that have 

been achieved in practice or currently being used to control wine fermentation 

emissions. In the absence of achieved in practice control technologies, the District 

analyzed all possible options for VOC emissions control to determine their technological 

and economic feasibility. The control options that were analyzed are thermal oxidation, 

catalytic thermal oxidation, regenerative thermal oxidizer, wet scrubbing (absorption), 

adsorption vapor recovery, and condensation/refrigeration/ cryogenic systems. 

Biological oxidation and temperature control of fermentation are not technologically 

feasible as discussed in Section IV of this report. 

The District conducted separate analysis for red wine and white wine because of 

fermentation processing differences, duration of fermentation, and emission factors. 

The analysis considered all possible control options for VOC and their respective costs 

 

5

 May 18, 2006 Memorandum from William T. Harnett, Director of air Quality Policy Division, to Regional Air 

Division Directors. “RACT Qs & As – reasonably Available Control Technology (RACT): Questions and 

Answers”. On page 2, answer to question #6 stated that: “EPA has never issued a general cost of control for VOC, 

but costs of control in CTGs generally ranged around $2000/ton in 1980s dollars.” 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-8

as listed in the tables below. The annual costs are based on the assumption that 

controls are maximized and multiple tanks are ducted to a single control device. The 

unit cost is expected to be higher for single tank control compared to manifolding 

multiple tanks, and therefore single tank controls were not analyzed. Furthermore, the 

District does not believe that controlling only large tanks (fermenters) is a viable option 

because operators would likely shift their fermentation process to smaller uncontrolled 

tanks, thereby resulting to no achievable emissions reduction. 

The analysis demonstrated that all possible control options that may be technologically 

feasible to reduce VOC emissions from wine fermentation and wine storage tanks are 

not economically feasible. The cost effectiveness of controlling red wine fermentation is 

about $32,000 to $48,000 per ton of VOC reduced for a system that includes a Cleanin-place (CIP) process. Without a CIP, the red wine control cost is about $15,000 to 

$30,500 per ton VOC reduced. For white wine fermentation, the cost effectiveness is 

about $18,000 to $52,000 per ton of VOC reduced. Note that the $15,000 and $18,000 

per ton values are for carbon adsorption control, which is conservatively low because it 

does not include the cost to regenerate the spent carbon either onsite or offsite. Carbon 

adsorption control cost will be higher if carbon regeneration cost is included (ARB Draft 

Technical Assessment Document6

 estimated carbon adsorption cost effectiveness of 

$44.09 per pound, or $88,180 per ton). It is important to mention that a control system 

which includes a CIP would be required as part of standard fermentation operation 

process and to prevent possible cross-contamination of wine products due to the spread 

of microbes via ductwork, especially for multiple tanks that are manifolded together 

using a single capture and control device. The cost effectiveness of controlling 

emissions from wine storage tanks is about $38,000 to $84,000 per ton of VOC 

reduced. The estimated cost effectiveness of about $204,000/ton of VOC for pressure 

vacuum (PV) valves to control emissions from wine storage tanks is not economically 

feasible. The District, however, considers the use of PV valves as achieved in practice 

BACT because they already in-place on virtually all existing winery storage tanks within 

the District. 

The estimated cost effectiveness control options that may be technologically feasible for 

controlling VOC emissions from wine fermentation and wine storage emissions exceed 

the cost effectiveness threshold generally established by EPA for sources that are 

subject to CTGs as discussed below, and therefore can not be considered economically 

reasonable as RACT. As such, the District believes that there is no feasible RACT-level 

control for this source category. A detailed discussion of the cost analysis is presented 

in section IV of this report. 

It is important to mention that the costs of controlling emissions from wine fermentation 

and storage are significantly much higher compared to the costs of control for other 

existing sources mandated-to-date by the District or other air quality agencies in 

California. Furthermore, it exceeds the threshold generally established by EPA for 

Control Technique Guidance documents (CTGs), which is around $2,000 per ton (1980 

 

6

 California Air Resources Board (ARB) 8/06/03 Draft Technical Assessment Document “Strategies and Costs for 

Winery Ethanol emission Control”, Table B-4, page 115. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-9

dollars)7. Adjusted to 2007 dollars based on average annual inflation of 3%, the cost 

effectiveness of CTG8

 is about $4,400/ton. 

The following tables summarize the results of the District’s evaluation of technologically 

feasible control options. Section IV of this report presents detailed discussion of cost 

estimation methodology, sources of cost data, and assumptions/conditions used in 

estimating the capital investment cost, direct annual cost, and indirect annual cost, as 

well as annualized cost of feasible control options. 

Total Annualized for VOC Control of Red Wine Fermentation 

Includes Site Specific Costs, Clean–in-place (CIP), Maximum Vapor Rate Basis

 Thermal 

Oxidizer 

Catalytic 

Oxidizer 

Regenerative 

Thermal 

Oxidizer 

Refrigerated 

Condenser 

Water 

Scrubber 

Carbon 

Adsorption 

Total 

Annualized 

Cost ($) 

6,290,000 5,517,800 4,732,500 4,555,400 5,791,300 4,420,800 

Cost 

effectiveness 

($/ton VOC) 

48,300 41,300 36,400 35,300 44,900 32,300 

Total Annualized for VOC Control of Red Wine Fermentation 

Non-Site Specific Costs, No Clean–in-place (No CIP) Managed Vapor Rate Basis

 Thermal 

Oxidizer 

Catalytic 

Oxidizer 

Regenerative 

Thermal 

Oxidizer 

Refrigerated 

Condenser 

Water 

Scrubber 

Carbon 

Adsorption 

Total 

Annualized 

Cost ($) 

3,968,100 3,113,500 2,286,100 2,174,100 2,965,000 2,090,800 

Cost 

effectiveness 

($/ton VOC) 

30,500 23,300 16,700 16,900 23,000 15,300 

 

Total Annualized for VOC Control of White Wine Fermentation 

Non-Site Specific Costs, No Clean–in-place (No CIP), Managed Tank Flow

 Thermal 

Oxidizer 

Catalytic 

Oxidizer 

Regenerative 

Thermal 

Oxidizer 

Refrigerated 

Condenser 

Water 

Scrubber 

Carbon 

Adsorption 

Total Annualized 

Cost ($) 

3,098,900 2,244,300 1,416,900 1,304,900 1,412,400 1,221,500 

Cost effectiveness 

($/ton VOC) 

52,100 35,700 21,500 20,900 22,600 18,400 

 

7

 May 18, 2006 Memorandum from William T. Harnett, Director of air Quality Policy Division, to Regional Air 

Division Directors. “RACT Qs & As – reasonably Available Control Technology (RACT): Questions and 

Answers”. On page 2, answer to question #6 stated that: “EPA has never issued a general cost of control for VOC, 

but costs of control in CTGs generally ranged around $2000/ton in 1980s dollars.” 

8

Cost effectiveness value in 2007 dollars based on 3% average annual inflation rate = $2000/ton x (1.03)27 yrs = 

$4,443/ton 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-10

Storage Tank Emission Control Technology Analysis 

Wine storage tanks perform two functions in the winery: 

• Facilitation of post-fermentation processing operations such as racking, filtration, 

malolactic fermentation and bottling. In this role, the typical storage tank is filled and 

emptied several times per year and functions as a process vessel. 

• Storage of wine between processing operations up to the final operation of bottling. 

In this role, the objective is to avoid oxidation of the wine by both minimizing the 

wine temperature and the exposure of the wine to air. 

Emissions from storage tanks consist of both working losses and breathing losses. 

Working losses occur as a result of the displacement of the vapor space of the tank into 

the atmosphere due to tank filling operations. Working losses are primarily a function of 

tank throughput and the temperature and ethanol content of the wine. Breathing losses 

are the result of diurnal heating and cooling caused by the effect of atmospheric 

conditions on the contents of the tank. For a well-insulated tank, breathing losses will be 

negligible. 

The table below summarizes the result of the District’s evaluation of technologically 

feasible control options for storage tanks and their corresponding annualized costs as 

well as cost effectiveness. Section IV presents detailed discussion of cost estimation 

methodology, sources of cost data, and assumptions/conditions used in estimating the 

capital investment cost, direct annual cost, and indirect annual cost, as well as 

annualized cost of feasible control options. The analysis also indicated that PV valve 

and temperature control of storage tanks are not cost effective. However, since PV 

valves are currently being used on virtually all wine storage tanks within the District, 

they are considered as achieved in practice BACT and more stringent than RACT. 

Total Annualized for VOC Control of Wine Storage Tanks 

Non-Site Specific Costs, No Clean–in-place (No CIP)

 Thermal 

Oxidizer 

Catalytic 

Oxidizer 

Regenerative 

Thermal 

Oxidizer 

Refrigerated 

Condenser 

Water 

Scrubber 

Carbon 

Adsorption 

Total 

Annualized 

Cost ($) 

272,400 184,200 210,600 285,800 129,500 251,900 

Cost 

effectiveness 

($/ton VOC) 

75,700 51,200 58,500 83,800 38,000 70,000 

Brandy Aging 

The District is not aware of any brandy aging facility in the nation or worldwide that is 

currently controlling its ethanol emissions. In fact, the only known whiskey aging facility 

that was issued a Part 70 operating permit (Permit No. T 137-6928-00011 in December 

2002) by the Indiana Department of Environmental Management (IDEM) is Joseph E. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-11

Seagram & Sons, Inc. in Ripley County, Indiana. District staff reviewed the permit and 

found that there were no VOC control requirements specifically indicated for whiskey 

aging process. Therefore, the District believes that since IDEM (or EPA Region III which 

is the oversight agency for IDEM) did not require VOC control of the whiskey aging 

emissions, there is no feasible RACT-level control for similar distilled spirits like brandy. 

However on August 4, 2004, the Indiana Office of Environmental Adjudication [2004 

OEA 58 (03-A-J-3003)]9

 ordered the IDEM commissioner to rescind the permit for the 

Seagram facility. The District staff cannot find any facility in the nation that are 

mandated to control of brandy, whiskey or similar other distilled spirits. In the absence 

of achieved in practice control technologies, the District analyzed all possible control 

options for general VOC controls to determine their technological and economic 

feasibility. The control options that were analyzed are thermal oxidation, catalytic 

thermal oxidation, regenerative thermal oxidizer, wet scrubbing (absorption), adsorption 

vapor recovery, biological oxidation, and condensation/refrigeration/cryogenic systems. 

The estimated cost effectiveness analysis of controlling brandy aging emissions is about 

$1,000 to $5,300 per ton of VOC reduced as indicated below. 

Total Annualized for VOC Control of Brandy Aging 

 Thermal 

Oxidizer 

Catalytic 

Oxidizer 

Regenerative 

Thermal 

Oxidizer 

Refrigerated 

Condenser 

Water 

Scrubber 

Carbon 

Adsorption 

Biofilter 

Total 

Annualized 

Cost ($) 

569,700 351,400 410,320 410,700 1,723,400 454,500 781,100 

Cost 

effectiveness 

($/ton VOC) 

1,700 1,000 1,200 1,300 5,300 1,300 2,300 

III. Industry Background 

A. Winemaking process 

Wine production is predominantly a seasonal event, coinciding with the grape harvest 

season. Wine making involves three major steps: grapes are harvested, crushed, and 

then fermented. The wine fermentation step is typically a batch process. Within the 

San Joaquin Valley, about 97% of wine production occurs in the months of August 

through December. Fermentation is at its peak during September through October. 

About 74% of wine fermentation occurs within those months. During the peak of the 

grape harvest, wineries processing millions of gallons of wine annually will operate 24 

hours per day, seven days of the week. For a given fermenter, it is possible to run one 

fermentation batch after another throughout the harvest season. Between each batch, 

 

9

 2004 OEA 58 (03-A-J-3003) - Objection to the Issuance of Part 70 Operating Permit No. T-137-6928-0001 for 

Joseph Seagrams & Sons, Inc., Ripley County, Indiana. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-12

the fermenter is sterilized in accordance with U.S. Food and Drug Administration 

requirements and readied for a new fermentation batch. 

Seasonal throughput for a single fermenter varies from year to year and winery to 

winery. Assuming a fermentation season of 60 to 90 days, and a batch time of 5 days 

for red wine and 10 days for white wine, theoretical throughput for a single fermenter 

could be 12 to 18 batches for red wine and six to nine batches for white wine. 

According to the Wine Institute, this theoretical throughput is seldom achieved. The 

Wine Institute estimates that over 85% of wineries process 6 batches or less per tank, 

and 67% process 4 batches or less. According to a Wine Institute survey of nine large 

wineries operating in the District, the maximum number of batches for red and white 

wine was 18 and 8 batches respectively. 

Quantitative characterizations of fermentation emissions will vary from winery to winery 

and within a winery. Emissions produced during fermentation depend upon process 

parameters, such as sugar content of the must, degree of temperature control, and type 

of wine being produced. During the fermentation process, glucose and fructose in must 

undergo reaction by yeast activity and produce ethanol and carbon dioxide (CO2). The 

amount of ethanol emitted to the atmosphere depends on the fermentation temperature 

and duration, the sugar content of the must, and the volume of must. Because of their 

higher fermentation temperatures, shorter fermentation periods, and the presence of the 

cap, fermentation emissions per batch are higher for red wines than white wines. VOC 

concentrations and airflow rates for red wines reach higher peak values and vary more 

significantly than those encountered in white wine fermentation. 

B. Winemaking Industry 

Seventy percent of the State of California’s wine production occurs within the District. 

The majority of wine production in the District occurs at large wineries, with annual wine 

production capacities of tens of millions of gallons. In 2002, 18 wineries in the District 

had annual permitted production volumes ranging from 5 million to greater than 50 

million gallons. These 18 wineries accounted for 95% of the District’s emissions from 

wine fermentation. Of the 109 wineries operating in the SJVAB in 2002, 70% of the 

wineries had annual production volumes of less than 200,000 gallons, and 58% of the 

wineries had annual production volumes of less than 2,000 gallons. Ethanol constitutes 

the predominant VOC emissions from wine fermentation and storage tanks. 

Fermenters in use at large wineries in the District range in size from about 25,000 

gallons to 600,000 gallons. Most fermenters have manhole located on the roof of the 

tank that is open during fementation. Emissions are vented through the manhole 

without the aid of mechanical equipment (e.g., fans). Of the 4,533 total permitted wine 

tanks in the District, about 32% or 1,457 tanks are used exclusively for wine storage; 

about 10% or 448 tanks are used exclusively for wine fermentation; and 58% or 2,628 

tanks are used as both fermenters and storage tanks. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-13

IV. Cost Effectiveness and RACT Determination for Wine Fermentation 

A. Emission Control Technology For Control of Ethanol Emissions From 

Wine Fermentation Tanks 

1. Background 

Ethanol is the primary VOC produced during wine fermentation. Previous 

researchers10 have demonstrated that ethanol is released to the atmosphere 

primarily as a result of equilibrium between the gas phase and the liquid phase of 

the fermenting wine. The liquid phase is mostly water with the minor components 

consisting of sugars, and ethyl alcohol. The gas phase is mostly carbon dioxide with 

trace amounts of water and ethyl alcohol. The gas stream leaving a fermentation 

tank varies in ethyl alcohol concentration and flow rate depending on the 

fermentation temperature, the volume of fermenting juice in the tank, and how 

complete the conversion of sugar to ethyl alcohol has progressed. Higher 

fermentation temperature and greater liquid volumes in the tank cause a greater 

emission rate. Fermentation is a batch process, with typical frequencies at two to 

four batches per month over a three-month crush period. Both the flow rate of the 

vent stream and the uncontrolled emission rate of ethanol are highly variable over 

the time of fermentation. In addition, red wine fermentations occasionally become 

unstable resulting in a “foam-over” of the tank contents (similar to the results of 

shaking an open carbonated beverage). Foam-overs can forcefully discharge 

thousands of gallons of liquids from the fermentation tank into the air. To be 

considered technologically feasible, an emission control system must be able to 

operate reasonably under this batch operation scenario and be able to 

accommodate occasional foam-overs without contaminating co-connected tanks. 

Additionally, wine is a both a food grade product and a consumer product whose 

consumer acceptance is heavily influenced by style issues. Therefore, to be 

considered technologically feasible, an emission control system must 1) be 

designed to operate in accordance with the cleanliness and sanitation standards of 

the wine industry, the U.S. Food and Drug Administration, and with other 

requirements of state and local health authorities and 2) have no impact on the 

operation of the fermentation tank with respect to style, quality, or consistency of 

quality of the wine produced. 

The US EPA’s RACT/BACT/LAER Clearinghouse (RBLC) database contains casespecific information on the "Best Available" air pollution technologies that have been 

required to reduce the emission of air pollutants from stationary sources (e.g., 

power plants, steel mills, chemical plants, etc.). This information has been provided 

by State and local permitting agencies. The RBLC contains no examples of 

controlling wine fermentation emissions. Additional literature searches produced no 

examples of fermentation emission control being implemented worldwide. 

 

10 Modeling and Prediction of Evaporative Ethanol Loss During Wine Fermentations, Williams and Boulton, Am. J. 

Enol. Vitic., Vol 34, No. 4, 1983. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-14

The District has prepared a BACT guideline for Ethanol Fermentation Process 

Tanks (Guideline 4.12.4) for ethanol production from corn fermentation. Guideline 

4.12.4 establishes a 99.5% VOC emissions control efficiency using a fermentationwet scrubber vented to a CO2 recovery plant with a condenser and high-pressure 

scrubber; or equivalent. 

Differences between wine fermentation and ethanol for fuel production necessitates 

consideration of alternative control technologies. Of specific concern is treatment of 

the wastewater from the wet scrubber. During corn fermentation, waste water from 

the wet scrubber is conveyed back to a slurry tank and reused in the manufacturing 

process. Wine is a food product and for food safety reasons, the return of the 

waste water to the wine is not possible. As a control technology for wine 

fermentation, wet scrubbers would require alternative wastewater treatment or 

disposal methods. Guideline 4.12.4 identifies thermal oxidation with 98% VOC 

control as an alternative technology. Thermal oxidizers have been successfully 

used in different industrial settings operating in the District and are readily available. 

A review of established control technologies indicates that the following would be 

potentially applicable to the control of ethanol emissions from fermentation tanks: 

1. Oxidation (conversion of the VOC to CO2); 

2. Absorption (“scrubbers”, which transfer the VOC in air emissions to a liquid waste 

stream); 

3. Adsorption (often using activated carbon, which transfers the VOC in the air onto 

a solid substrate); 

4. Condensation (conversion of the VOC gases into liquids); and 

5. Biological control systems (e.g., bio-filters or bio-scrubbers) 

6. Temperature control of fermentation (refrigeration) to reduce the evaporative 

ethanol emissions. 

Review of the identified control technologies above indicates that options 1 through 

5 are all classified as capture and control systems and therefore all share a 

common requirement for a capture system. Since the capture system is common to 

these options, issues regarding the installation of such a system on fermentation 

tanks are also common and will thus be considered independent of the control 

technology selected. 

Each of the identified technologies, the common capture system and their potential 

application to wine fermentation is discussed in the following: 

2. Emissions Capture System 

The generic capture system consists primarily of a tank interface for connection of 

ductwork to the tank(s), ductwork running from the tank(s) to the control device 

including valving and instrumentation, and a separation device (knock out vessel) to 

prevent entrained liquids in the vent stream (such as might occur in a foam-over) 

from entering the control device and potentially damaging it. Most of the 

technological uncertainties and potential issues associated with the installation of 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-15

capture and control systems on fermentation tanks are associated with the 

operability of the ductwork (capture) system and the potential impact of the 

ductwork system on the fermentation tank operation. Essential fermentation-specific 

features of the ductwork system are: 

• The system must connect multiple tanks to a common control device. Reasons 

for this feature include: 

- The batch nature of the fermentation tank operation requires that multiple 

tanks be manifolded together to provide an averaging effect for reasonably 

continuous operation of a common control device. Due to the batch operation 

of each tank, the design capacity of a control device dedicated to a single tank 

would only be needed a few hours per week at the most and would operate a 

significant amount of time with zero or near-zero flow from the tanks. The 

result would be excessive operating cost for the control device and/or 

excessive turndown and cycling of the control device. 

 - Installation of a dedicated control device for each tank would be prohibitively 

expensive since the compact layout of essentially all wineries generally 

dictates that the control device be installed at some distance from the tank, 

requiring a significant dedicated run of ducting from each tank to the remote 

location of the control device. In particular, red wine fermentation tanks are 

installed in close proximity with the grape receiving, crushing, pressing and 

other material handling equipment due to the requirements to handle solid 

materials in these tanks and it is expected that essentially all such 

installations would require remote location of the control device due to lack of 

plot space in the vicinity of the fermentation tanks. Since large wineries have 

hundreds of tanks including 40-60 red wine fermenters, installation of a 

dedicated control device for each tank would be extremely inefficient from 

both a capital investment standpoint (excessive investment in ductwork and 

control devices) and would require excessive utilization of plot space for siting 

numerous control devices in the winery.

• The system must be capable of handling entrained liquids from the 

fermentation tanks and of preventing cross-contamination between tanks. A 

reasonable design will include features to avoid entry of entrained liquid from 

each tank into the common header that interconnects the tanks and will then 

continuously slope the main header from a high point, where the tank connects 

to the header, down to the knock out vessel located at the control device to 

ensure that liquids entering the header are not distributed to any of the 

connected tanks. A design approach for minimizing the entry of liquids from the 

tank to the main header has been proposed in the Eichleay study for the GalloLivingston Winery11 in which a motor operated isolation damper is installed in 

the branch duct from each tank to the main header. Closure of these valves 

would be actuated by a control system based on sensing a foam-over condition 

in the tank. In the event of a foam-over and a closure of the isolation damper, 

an individual tank vent system must also be provided to release the gases to 

 

11 Eichleay Engineers, Fermenter VOC Emissions Control Cost Estimate, 2005. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-16

the atmosphere to avoid over-pressure on the tank. The basic proposed design 

includes a frangible duct connection at the tank with an air gap which would 

allow large-scale venting of the tank with minimal entry of liquid into the ducting. 

A prototype of this duct connection design was demonstrated in 1990 in a 

program evaluating control of ethanol emissions from wine fermenters, 

conducted at the E. & J. Gallo Winery in Fresno, California 12. The design of 

the VOC capture system allowed fermentation emissions to vent naturally 

through a manway located at the top of the tank. The VOC capture system 

consisted of an emissions collection hood, located above the manway, 

connected by ductwork to a VOC control device. The collection hood was 

larger than the manway and was suspended above the opening, creating an air 

gap between the tank and the hood. The design included a fan with a flow-rate 

sufficient to pull emissions into the collection hood and force the emissions 

through the ductwork to the emissions control device. Based on results 

reported in the Gallo study, District staff considers it reasonable to expect 

similar emissions collection systems to have a capture efficiency of at least 

90%. 

• Requirements for sloping of the main header (typically a minimum of 1⁄4 inch per 

foot for efficient drainage) will set the elevation requirement of the main header 

at the most remote tank location. Minimum routing elevation of the headers 

within a plant is typically set at approximately 20 feet (and sometimes higher at 

major road locations) to avoid interference with operations and maintenance 

equipment access. These constraints can result in a high point elevation of 30 

to 40 feet for the main header in a typical plant. 

• The system must include provisions for cleaning and sterilization to meet the 

requirements for handling of food products. Fermentation systems must be 

cleaned and sterilized between each fermentation batch and this is typically 

accomplished by multiple washings with solutions of potassium hydroxide and 

chlorine dioxide. Since it would be impractical to disassemble the ductwork for 

cleaning between each batch, the ductwork design must incorporate a “cleanin-place” (CIP) system. Such a system has been proposed in the Eichleay 

study, consisting of a fixed spray header located inside the duct to apply the 

cleaning solutions to the inner wall of the duct plus ancillary systems to store 

and deliver the cleaning solutions to the spray system. In addition, cleanliness 

and corrosion-resistance considerations dictate that the ductwork be 

constructed of stainless steel. 

• The ductwork system must be supported independently of the fermentation 

tanks since the tanks are generally not designed to support any significant 

structural load. The ductwork presents a substantial load since it must be 

constructed with sufficient wall thickness to be self-supporting over spans of 

20+ feet and be durable enough for industrial plant operations as well as to 

support in-line components such as the motor operated valves, check valves 

 

12 Akton Associates, A Demonstration Program, Ethanol Emissions Control from Wine Fermentation Tanks 

Utilizing Carbon Adsorption Technology, 1990 
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Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-17

and other items. Internally it contains a spray header and wash nozzles and 

must be designed to run approximately 1/3 full of liquid due to the washing and 

sterilization operation. The potential load of the ductwork, combined with the 

elevation requirements for the ducting and the lack of structural support 

available from the tanks, dictates that substantial free standing steel structures 

be provided for support of the ductwork. Since the structures, along with their 

respective foundations, must be constructed in a highly congested area 

between storage tanks with little or non-existent crane access and must be 

constructed in a plant with on-going operations, it is reasonable to expect 

significantly higher costs per unit basis for steel and concrete structures erected 

under these conditions. Due to the congested nature of the plant environment 

and the limited window for construction due to plant operating requirements, 

construction approaches involving off-plot assembly of steel modules and 

setting of these modules with a helicopter were devised in the Eichleay study. 

Such installation would be conducted with craft labor on an overtime basis to 

accommodate a limited construction window and minimize costs for helicopter 

usage. 

3. Adsorption Vapor Recovery 

Adsorption vapor recovery is accomplished by passing the VOC-laden gas through 

beds containing adsorbents that have a high surface area to weight ratio. Typical 

adsorbents are activated carbon, zeolite, or organic polymers. As the gas stream 

passes through the bed, organic compounds adsorb weakly onto the adsorbent’s 

surface. Adsorption of the hydrocarbon molecules proceeds until the available 

surface area is filled or saturated with VOC molecules. The VOC molecules are 

retained until the regeneration step, or disposal of the spent adsorbent. 

Desorbing or removing captured VOCs regenerates the adsorbent. Decreasing the 

pressure, reducing the hydrocarbon concentration around the adsorbent or 

increasing the temperature of the bed can perform regeneration. A combination of 

these steps can also be used for regeneration. There are three basic types of 

adsorption systems available to recover or remove hydrocarbon vapors from an air 

stream. Two of these systems regenerate the adsorbent in-situ for reuse. The third 

system requires removal of the adsorbent to another site for regeneration. 

The two systems that provide in-situ regeneration are: Pressure Swing 

Regenerated Systems and Thermally Regenerated Systems (or a combination of 

the two methods). Since the net result of the combined adsorption and regeneration 

process only results in transfer of the ethanol from the fermentation vent stream to 

another liquid or gaseous stream, further treatment of the effluent of the 

regeneration process is required to either destroy or recover the ethanol (typically 

thermal oxidation of the stripping gas stream or water treatment in the case of 

steam stripping). 

The District considers adsorption vapor recovery (with appropriate handling of 

regeneration waste streams) as technologically feasible for application to wine 

fermentation. Based on California Air Resources Board (ARB) Suggested Control 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-18

Measure”13, a control efficiency of 95% is considered reasonable for adsorption 

systems which, when combined with an expected capture efficiency of 90%, yields 

an overall emission reduction of 86% for this technology. 

4. Thermal Oxidation (Incineration) 

A thermal oxidizer (TO) destroys VOCs by the process of combustion. A basic TO 

system consists of a combustion chamber, burner, stack, and combustion controls. 

All hydrocarbons are oxidized to carbon dioxide and water vapor by the proper mix 

of temperature, residence time and turbulence within the reactor chamber. 

Combustion of the contaminated gas stream occurs at high temperatures, normally 

650oC to 870oC (1,200oF to 1,600oF) when treating low concentration streams. 

Recent guarantees provided by TO vendors for destruction of ethanol in air in other 

proposed projects under review by the District have been based on a minimum 

combustor temperature of 1,500oF. 

TO systems can be divided into recuperative or regenerative systems, based on 

methods used to increase operating efficiencies by capturing heat from the 

combustion process. Recuperative TO systems increase fuel efficiency by use of a 

gas pre-heating section and a heat recovery section. Heat recovery can be as high 

as 70%. A regenerative system provides extremely high thermal-energy recovery; 

up to 95% of heat energy can be recovered. Regenerative TO systems use a 

ceramic heat-exchange bed to preheat process air to within 5% of the oxidation 

temperature. 

VOC conversion efficiencies range from 95% to 99.9% for TO systems. However, 

the combustion of supplemental fuel for the oxidation step (the amount depending 

upon the fuel value of the VOC and the level of heat recovery employed) produces 

NOx, an ozone precursor like VOC, thus offsetting some of the VOC emission 

reduction. The District considers thermal oxidation as technologically feasible for 

application to wine fermentation and that a control efficiency of 95% is reasonably 

achievable which, when combined with an expected capture efficiency of 90%, 

yields an overall emission reduction of 86% for this technology. 

5. Catalytic Thermal Oxidation 

A catalytic thermal oxidizer (CTO) is essentially a thermal oxidation unit with a 

catalyst module. These units are similar in design to recuperative units, except that 

VOCs are oxidized using precious metal or metal-oxide-based catalysts instead of 

high temperature. Operating at about half the temperature of thermal oxidizers, 

catalytic units have smaller footprints and may offer lower operating costs in certain 

circumstances. Since catalyst are employed, they are subject to catalyst poisoning 

or deactivation due to operating upset and may require periodic catalyst 

replacement which represents a substantial operating cost. 

Other industries have demonstrated typical VOC removal efficiencies of up to 98%. 

The District considers catalytic thermal oxidation as technologically feasible for 

 

13 Nelson Chan, et. al, A suggested Control Measure for Control of Ethanol Emissions From Winery Fermentation 

Tanks. October 7, 1986 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-19

application to wine fermentation and that a control efficiency of 95% is reasonably 

achievable which, when combined with an expected capture efficiency of 90%, 

yields an overall emission reduction of 86% for this technology. 

6. Wet Scrubbing (Absorption) 

The basic process involved in wet scrubbing is the contact of a polluted gas stream 

with a liquid solution. During operation, gas flows upward through a column 

containing packing or other mass transfer media. The scrubbing liquid is delivered 

to the top of the column and flows down (by gravity) through the porous mass 

transfer media, generating a substantial interfacial surface area between the gas 

and liquid phases in a counterflow arrangement which provides optimal mass 

transfer. Gaseous contaminants are absorbed into the liquid and the 

decontaminated gas stream flows out of the scrubber. 

Many scrubbing applications achieve emission reduction efficiencies of 99.9%. In a 

pilot study conducted by ARB in 1987, wet scrubbing demonstrated greater than 

90% reduction in ethanol emissions. The District considers wet scrubbing as 

technologically feasible for application to wine fermentation and that a control 

efficiency of 90% is reasonably achievable which, when combined with an expected 

capture efficiency of 90%, yields an overall emission reduction of 81% for this 

technology. 

7. Condensation, Refrigeration, and Cryogenic Systems 

Condensation, refrigeration, and cryogenic systems remove organic vapor by 

condensing the target gases on cold surfaces. These cold conditions can be 

created by passing cold water through an indirect heat exchanger, by spraying cold 

liquid into an open chamber with the gas stream, by using a refrigerant to create 

very cold coils, or by injecting cryogenic gases such as liquid nitrogen into the gas 

stream. The concentration of VOCs is reduced to the level equivalent to the vapor 

pressures of the compounds at the operating temperature. Removal efficiencies 

attainable with this approach depend strongly on the outlet gas temperature. For 

cold-water-based condensation systems, the outlet gas temperature is usually in 

the 40 to 50°F range, and the VOC removal efficiencies can be in the 90% to 99% 

range depending on the vapor pressures of the specific compounds. For refrigerant 

and cryogenic systems, the removal efficiencies can be considerably above 99% 

due to the extremely low vapor pressures of essentially all VOC compounds at the 

very low operating temperatures of -70°F to less than -200°F. Water vapor content 

in the gas stream may place a lower limit on the outlet gas temperature due to 

potential ice formation. 

The application of refrigerated condenser to the control of ethanol emissions from a 

fermentation tank was examined by the wine industry(x). The results of that study 

indicated that a 90 % ethanol recovery could be achieved at an outlet gas 

temperature of -12 0

F. However, it was noted that ice formation could be a problem 

at this temperature and that special equipment designs would be required for 

reasonable operation. In addition, the ethanol is recovered in aqueous solution and 

must be further process for recovery of the ethanol. The District considers 

refrigerated condensation as technologically feasible for application to wine 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-20

fermentation and that a control efficiency of 90% is reasonably achievable which, 

when combined with an expected capture efficiency of 90%, yields an overall 

emission reduction of 81% for this technology. 

8. Biological Oxidation 

Biological oxidation systems are a relatively new means of air pollution control. 

VOCs can be removed by forcing them to absorb into an aqueous liquid or moist 

media inoculated with microorganisms that consume the dissolved and/or adsorbed 

organic compounds. The control systems usually consist of an irrigated packed 

bed that hosts the microorganisms (biofilters). A presaturator is often placed ahead 

of the biological system to increase the gas stream relative humidity to more than 

95%. The gas stream temperatures are maintained at less than approximately 

105°F to avoid harming the organisms and to prevent excessive moisture loss from 

the media. 

Biological oxidation systems are used primarily for very low concentration VOCladen gas streams. The VOC inlet concentrations are often less than 500 ppmv 

and sometimes less than 100 ppmv. The overall VOC destruction efficiencies are 

often above 95%. The District does not consider biological oxidation to be 

technologically feasible for application to wine fermentation based on the following: 

• Emissions from the tanks only occur approximately 12 weeks per year. The 

short and potentially intermittent nature of the emissions would not be 

appropriate to maintaining a healthy bed of microorganisms in the filter. 

• Wine is a food-grade product and requires stringent sterilization practices from 

the standpoint of eliminating contamination and preserving product quality. The 

introduction of a system containing microorganisms is not considered feasible 

within the sterilization practices normally employed. The microorganisms could 

potentially be a health risk due to potential contamination of the wine. 

9. Temperature Control of Fermentation 

Ethanol losses from fermentation increase with increasing temperature. Therefore, 

lowering fermentation temperatures could result in lower ethanol emissions. 

However, there is a lack of empirical data supporting accurate characterization of 

the resulting emission reduction or establishment of the appropriate fermentation 

temperature limits. Actual emission reductions would be determined by complex 

interactions including factors such as non-isothermal fermentation, presence of the 

pomace cap in red wine fermentation, and starting and ending Brix levels. The 

ARB Technical Assessment Document (TAD) presents a hypothetical 15 percent 

and 30 percent reduction in ethanol emissions from red wine and white wine 

fermentations respectively. The authors note, however, that emission reductions of 

that magnitude would probably be achieved in only a few isolated cases. Because 

of the lack of empirical data and the uncertainty of achievable emissions reductions, 

and due to potential issues concerning the impact of fermentation temperature 

control on the style of wine produced, the District does not consider temperature 

control to be a viable VOC control option at this time. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-21

B. Cost Effectiveness for Red Wine Fermentation 

1. Approach for Cost Effectiveness 

Because of processing differences, red wine fermentation has an emission factor 

about 2.5 times greater than white wine fermentation. Red wine has an emissions 

factor of 6.2 lb VOC/1,000 gallons, and white wine has an emissions factor of 2.5 

lb/1000 gallons of fermented must. In addition, red wine fermentation batches are 

completed in 3 to 5 days versus 10 to 14 days for white wine fermentation. 

Therefore, a red wine fermentation tank of a given size will potentially operate at 

significantly higher throughput and produce significantly higher emissions per unit of 

throughput relative to a white wine fermentation tank of the same size. As a result 

of these fundamental differences in emission rate, cost effectiveness for red wine 

will be considered separately from that for white wine. 

The following emission control technologies have been determined to be 

technologically feasible for control of VOC emissions from wine fermentation tanks: 

• Oxidation (86% control) 

• Refrigerated Condenser (81% control) 

• Wet Scrubber (81% control) 

• Carbon Adsorption (86% control) 

Since “oxidation” includes recuperative and regenerative thermal oxidizers plus 

catalytic oxidizers, the cost effectiveness of the following cases will be examined for 

the determination of RACT for red wine fermentation: 

Case 1 Thermal oxidation with 0% heat recovery (low capital/high operating cost) 

Case 2 Catalytic oxidation with 50% heat recovery (mid range capital/mid range 

operating cost) 

Case 3 Regenerative thermal oxidation with 95% heat recovery (high capital/low 

operating cost) 

Case 4 Refrigerated Condenser 

Case 5 Water scrubber 

Case 6 Carbon adsorption 

The approach of the cost effectiveness analysis will be to first determine which, if 

any, of the above cases potentially qualifies as RACT based on having a potential 

cost effectiveness below the assumed EPA threshold of $4,400/ton of VOC. All 

cases which are shown to have a cost effectiveness higher than $4,400/ton will be 

discarded. Cases which fall below the threshold will then be further examined and 

compared with respect to relative cost effectiveness, technical risk, reasonableness, 

and socio-economic impact to determine which, if any, qualify as RACT for red wine 

fermentation. 

To establish a comparative physical scope of each of the above cases, the District’s 

approach is based on applying the six different control technologies to the actual red 

wine fermentation tanks at the E & J Gallo Winery at Livingston, California, rather 

than a hypothetical red wine fermentation installation. The rationale for this is based 

on the following: 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-22

• The Gallo facility at Livingston is sufficiently representative of typical red wine 

fermentation facilities located at major source wineries to allow it to serve as a 

general model for the physical scope requirements of such facilities. 

• The availability of plot space for installation of ductwork and control devices is a 

significant cost factor for all major red wine fermentation facilities. Basing the cost 

effectiveness analysis on an actual representative facility ensures that these 

factors are considered in the analysis. 

• The Eichleay study details the potential application of VOC controls to this facility 

and addresses many of the technical issues and site specific factors. This study 

developed two separate estimates, one for the fermentation control system 

installation (main estimate) and a second “utilities” estimate to cover the clean-inplace system, the expansion of the plant electric utility and the instrument air 

system. District staff has reviewed the estimating methodology employed in the 

Eichleay estimates and found that the estimating approach is fundamentally 

sound and follows accepted practice in the engineering and construction 

industry, applying reasonable unit rates and costs for materials and labor for 

development of direct costs. This information is available to use as a basis for 

this cost effectiveness analysis. 

• Parametric studies to examine the impact of tank throughput on cost 

effectiveness, based on the Livingston capital cost model, will be generally 

applicable to other sites since the capital cost for ductwork and a control device 

are more a function of total connected tank capacity rather than the number of 

tanks connected to the control device. Given a total connected tank capacity, 

changes in annual throughput are strictly an operational phenomena based on 

the average number of tank turns per season for the collection of tanks. For a 

given total connected tank capacity, a collection of smaller tanks (50,000 gallon 

capacity for a major source winery) is expected to be somewhat more expensive 

than a system consisting of fewer, larger tanks due to costs associated with 

increased complexity in the ductwork and supporting structure as well as the 

increased instrumentation count and associated electrical requirements. Since 

the Livingston facility primarily consists of red fermentation tanks of 100,000 

gallon or larger capacity, a parametric study of throughput will be slightly 

optimistic when considering only 50,000 gallon tanks. 

2. Estimating Approach and Basis 

Estimates of Total Capital Investment (TCI), annual costs, potential emission 

reductions, and the resulting cost effectiveness were prepared for each of the control 

technology cases above. The general approach and basis of the estimates is as 

follows: 

• EPA’s cost model for VOC incineration systems, as presented in the EPA Control 

Cost Manual, Section 3.2, Tables 2.8 and 2.9, was used for all cases with the 

exception of the refrigerated condenser (case 4) estimate which used Section 

3.1, Table 2.3 for Total Capital Investment (note that the EPA cost model was 

adjusted to a California location by taking sales tax at 8% rather than 3%). 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-23

• All estimates are based on the general facilities design prepared by Eichleay for 

the Gallo winery at Livingston, CA. Using this basis, the impact of substituting 

different control technologies will be examined. It is assumed that the basic 

scope of ductwork and supports, tank modifications, ancillary systems and site 

specific costs will be common to all technologies. 

• The feasibility of application of VOC controls to multiple fermentation tanks has 

not been demonstrated and significant uncertainties exist with respect to the 

actual design requirements. The general facilities design as prepared by Eichleay 

contains significant scope with respect to site specific factors. In addition, the 

Eichleay study based the capacity of the control device and ductwork on a peak 

vapor generation rate occurring simultaneously from all tanks connected to a 

control device. The District’s analysis of this design basis indicates that the 

probability of such a simultaneous occurrence is potentially small and that, by 

management of the timing of fermentation batches in the collection of tanks, the 

ductwork and control device could conceivable be sized at a capacity of less than 

70% of the simultaneous peak rate without significantly affecting the potential 

production rate of the connected tanks. To examine the sensitivity of the results 

to these factors, the District will consider two potential capital investment 

scenarios with respect to each control technology case: 

1. Site specific with CIP, Simultaneous Peak Vapor Rate – includes complete 

facility design with CIP as prepared by Eichleay for Gallo Modesto with the 

ductwork and control device designed for a simultaneous peak vapor 

generation rate from all tanks connected to the control device. 

2. Non-site specific without CIP, Managed Fermentation Tanks – reflects a 

hypothetical and optimistic case wherein costs for all site specific factors and 

CIP are negligible and assumes that tank management procedures can be 

implemented to maintain the combined vapor generation rate from all tanks at 

less than 70% of the peak simultaneous generation rate. 

• This facility consists of 60 red wine fermentation tanks with a combined nominal 

capacity of 6,850,000 gallons. In the general facilities design as prepared by 

Eichleay the tanks are grouped into four separate groups of tanks, each group 

separately manifolded together and ducted to a separate dedicated control 

device. The tank groupings are designated as: 

VOC-1 Seventeen (17) 100,000 gallon tanks 

VOC-2 Twelve (12) 200,000 gallon tanks 

VOC-3 Ten (10) 100,000 gallon tanks and seven (7) 50,000 gallon tanks 

VOC-4 Fourteen (14) 100,000 gallon tanks 

• Base control device capacity (per the Eichleay study) is based on a peak vapor 

rate of 9.75 scfm/1000 gallons of wine fermenting (85 0

F fermentation 

temperature) and assumes all fermenters connected to the control device are 

simultaneously operating at maximum vapor generation rate. Per the study, an 

additional 23.6 % flow capacity must be added to the control device to account 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-24

for the combustion air which must be added. On this basis, the four control 

devices have been determined to require the following capacities: 

VOC Device 

Capacity of Device and 

Ductwork per Eichleay 

Study 

Capacity of Control 

Device with Tank 

Management (70%) 

VOC-1 16,000 12,480 

VOC-2 22,000 17,160 

VOC-3 13,000 10,140 

VOC-4 13,000 10,140 

• Purchased equipment costs for the knock out vessels and the ductwork have 

been extracted from the main Eichleay estimate. A purchased material cost of 

$148,000 for the knock out vessels was taken from page 15 of Eichleay’s main 

estimate. Sizing criteria is presented in the Eichleay study and the pricing was 

developed based on Eichleay’s in-house estimating data for this type of 

equipment derived from purchasing experience on previous projects. A material 

cost of $1,105,000 for the ductwork has been extracted from pages 16 through 

23 of the main Eichleay estimate. Estimated ductwork quantities are based on 

Eichleay plan drawing SK-30913-001 and the process flow diagram presented in 

Eichleay drawing SK-30892-003. Unit costs for fabricated stainless steel 

ductwork are based on a budgetary quotation obtained by Eichleay from Viron 

International, a ductwork spool fabricator. 

• Ductwork sizing for the Eichleay study was based on admission of the 

combustion air for the RTO at the connection to the tank. This basis added 

23.6% to the flow capacity of the ductwork. For those control technologies not 

based on combustion, this duct capacity will not be needed. Ductwork capacity 

could hypothetically be reduced by 1.0/1.236 = 81%. Since capacity is a function 

of the square of the duct diameter, the net effect is a reduction in average duct 

diameter of (81%)1/2 = 90%. Using a capacity exponent from Table 1.9, Section 

2, Chapter 1 of the EPA Control Cost Manual for plate 304 stainless steel duct, 

cost for ductwork materials, extracted from the Eichleay study is $1,105,000 x 

(0.90)1.23 = $970,000. 

• For consideration of the “managed fermentation tank” operation with total vapor 

flow at 70% of the Eichleay case, the following adjustments will be made to the 

costs for the knock out vessels and the ductwork: 

Knock out vessels: The cost extracted from the Eichleay study will be adjusted to 

a 70% capacity factor using a capacity exponent of 0.6. Therefore, at 70% 

capacity, cost for the knock out vessels is $148,000 x (0.70)0.6 = $120,000. 

Ductwork: The most optimistic case for the ductwork is to assume that not only 

can a 70% capacity reduction in fermenter flow be achieved but also that the 

combustion air for incinerator operation can be admitted at the control device and 

not at the tank (per the basis of the Eichleay study). Ductwork capacity could 

hypothetically be reduced by 0.70/1.236 = 57%. Since capacity is a function of 

the square of the duct diameter, the net effect is a reduction in average duct 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-25

diameter of (57%)1/2 = 75%. Using a capacity exponent from Table 1.9, Section 

2, Chapter 1 of the EPA Control Cost Manual for plate 304 stainless steel duct, 

cost for ductwork materials, extracted from the Eichleay study is $1,105,000 x 

(0.75)1.23 = $776,000. 

• Direct costs taken from the Eichleay study will be used for estimation of site 

specific and other costs not covered by the equipment factors in the EPA VOC 

incineration cost model. These costs include site preparation, structural steel 

pipeway for ductwork support with helicopter setting of steel structures, clean-inplace (CIP) system, expansion of the plant electric utility, modification of 

fermentation tanks for duct connections, and the instrumentation system for 

control of tank foam-overs. 

• Site preparation costs to develop a plot area for the VOC control equipment have 

been extracted from page 4 of the main Eichleay estimate. Costs include 

subcontract pricing for demolition of an existing road, installation and compaction 

of fill, and new area and road pavement. These costs total $1,254,000 and are 

based on budgetary subcontract pricing obtained by Eichleay. 

• Total direct cost for structural steel (labor + materials + subcontracts) has been 

extracted from the total presented on page 8 of the Eichleay estimate 

($2,532,000). Steel design and quantities in this estimate are based on Eichleay 

plan drawing SK-30913-001 and the steel structure sections presented in 

Eichleay drawing SK-S12. Pricing is based on quotation obtained by Eichleay 

from a structural steel fabricator in Bakersfield, CA. 

• Pricing for use of a helicopter to set steel structures and ductwork was taken 

from page 24 of the main Eichleay estimate. Pricing was obtained by Eichleay 

from a helicopter firm based out of the Fresno Airport. 

• The Eichleay utility estimate developed a total direct cost of $4,700,000 for both 

the CIP system and the expansion of the plant electric utility. A direct cost for the 

electric utility expansion of $314,000 (including prorated craft overtime) was 

extracted from page 8 of the utilities estimate. The balance of the total direct cost 

($4,386,000) is taken as the cost for the CIP system (this figure includes a small 

amount for expansion of the plant instrument air system also). To determine the 

TCI for both items, the TCI of the utilities estimate ($8,880,000) was prorated to 

each item based on respective direct costs. 

• The direct costs (materials, labor, and subcontracts) to modify the fermentation 

tanks for installation of new nozzles required for connection of ductwork includes 

costs for build and teardown of scaffolding in each tank, demolition of existing 

insulation, machine cutting of each tank, fabrication and installation of new 

nozzles, and post-weld passivation of the tank. These costs are taken from 

pages 15 and 16 of the main estimate and total $487,000. 

• The direct cost for an instrumentation system for control of tank foam-overs was 

taken from page 13 of the main Eichleay estimate and totals $572,000 for 

capacitance probes, actuated butterfly valves and switches. Design basis for the 

system is presented in Eichleay drawing SK-30892-007. Unit material costs are 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-26

based on budgetary vendor’s pricing obtained by Eichleay. Unit labor factors and 

costs are based on Eichleay’s in-house estimating data. 

• The EPA model cost factor for foundations and supports is normally taken at 8% 

of purchased equipment cost which in this case includes only the control device, 

the knock out vessel and the ductwork. It thus does not factor in the costs of 

foundations for the substantial steel structures required for this project. 

Therefore, the direct cost for installation of foundations was taken from the 

Eichleay study and substituted for the EPA factor in this account. Concrete 

foundation design consists of drilled concrete piers for supporting of pipeway 

structures and conventional mat foundations for support of the control devices. 

Drilled concrete piers require a minimal footprint relative to conventional footers 

and for this reason are the standard approach for support under new steel 

columns when they are being installed in congested areas in existing industrial 

facilities. Direct costs (material + labor + subcontract) for concrete foundations 

have been extracted from page 4 of the estimate (excavations allowances for 

control device foundations totaling $21,800 and the total from page 5 ($444,950)) 

which covers drilling, rebar fabrication and setting, forming, pouring and finishing 

of the drilled piers and mat foundations. Estimated quantities are based on 

Eichleay plan drawing SK-30913-001 and the steel structure sections presented 

in Eichleay drawing SK-S12. The unit costs are based on Eichleay’s historical 

experience with subcontract pricing for these items. 

• Annual natural gas usage of 67,412 therms was estimated for the Gallo 

Livingston design by Eichleay (Appendix G of the Eichleay study) based on a 12 

week season and 95% thermally efficient RTO’s operating 50% of the time with 

an ethanol concentration of 6,034 ppmv for 50% of the time and in hot standby 

the other 50% with allowance for startups. Energy cost was established at 

$0.61/therm based on current operations at Livingston. Annual natural gas cost 

so determined is $110,500 per year. This natural gas usage and cost basis will 

be used as the basis for the cost effectiveness calculations, factored as required 

for the thermal efficiency basis of the proposed control unit. 

• Power consumption for the Gallo facility is estimated by Eichleay at 586 kWh with 

an annual cost of $141,800 (Appendix G of the Eichleay study). Since essentially 

all this power is consumed by the induced draft fans at the VOC control unit, this 

power basis will be assumed to be the same for the induced draft fans 

associated with all control technologies, factored down as required for control 

units not requiring combustion air. 

• Total Capital Investment has been annualized based on a 10 year equipment life 

and a 10% opportunity cost for capital (CRF = 0.163). 

• Calculation of potential emissions is based upon the red wine emission factor of 

6.2 lb-ethanol per 1000 gallons of must and upon the proposed average number 

of turns for the total red fermentation tankage capacity at Livingston. The 

average number of tank turns is converted to a tankage throughput based on a 

typical fermentation working capacity of 75% of the nominal tank capacity. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-27

• Calculated VOC emission reductions will be debited for collateral NOx production 

from firing of natural gas where applicable based on 1 lb NOX = 1 lb VOC. NOx 

production is based on 0.1 lb-NOx/MMBtu per AP-42. 

• Historical information provided by the industry indicates that, on average, red 

wine fermenters operate with 3 to 5 turns per season. For reference, actual 

production figures for Livingston for 2004 indicate that the total red fermenter 

capacity was turned 3.6 times. To screen the potential control cases for cost 

effectiveness within the RACT threshold, an average annual throughput of 10 

tank turns was assumed for the Livingston facility, almost three times the 

historical throughput and double the average turnover for 50,000 gallon tanks as 

reported by the industry. 

3. Cost Effectiveness Estimates 

Table 1 presents the development of Total Capital Investment (TCI) for all control 

cases based on the general facilities design prepared by Eichleay and Table 2 

presents the associated annual costs, emission reductions, and cost effectiveness 

for each collection and control case. Table 3 presents TCI for the non-site specific 

“managed tank operation” without CIP as described previously and Table 4 presents 

the associated annual costs, emission reductions, and cost effectiveness for each 

control case under this scenario. Discussion of each results are as follows: 

Case 1: Collection and Control with a Thermal Oxidizer

The thermal oxidizer pricing for this case was taken from the EPA Control Cost 

Manual, Section 3.2, Figure 2.4, based on the control device capacities from the 

Eichleay study and with a 0% energy recovery. As such, it represents a minimum 

capital investment/maximum operating cost scenario for use of a oxidizer. The price 

from Figure 2.4 (1999 dollars) was adjusted to 2006 dollars based on average 

annual inflation of 3%. 

Annual fuel cost for this case was calculated based on the Eichleay estimate of 

annual fuel consumption for RTO’s with 95% energy recovery. Since this case 

includes no heat recovery, the Eichleay estimate was divided by 0.05 (factor of 20) 

to make it reflect this case. 

With 10 tank turns and an expected collection and control efficiency of 86%, cost 

effectiveness of this control option ranges from $30,500 per ton for the most 

optimistic case (Table 4) up to $48,300 per ton for the general facilities design 

presented by Eichleay (Table 2). 

Case 2: Collection and Control with a Catalytic Oxidizer

The thermal oxidizer pricing for this case was taken from the EPA Control Cost 

Manual, Section 3.2, Figure 2.6, based on the control device capacities from the 

Eichleay study and with a 50% energy recovery. As such, it represents a mid range 

capital investment/mid range operating cost scenario for use of a oxidizer. The price 

from Figure 2.6 (1999 dollars) was adjusted to 2006 dollars based on average 

annual inflation of 3%. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-28

Annual fuel cost for this case was calculated based on the Eichleay estimate of 

annual fuel consumption for RTO’s with 95% energy recovery. Since this case 

includes no heat recovery, the Eichleay estimate was multiplied by 0.5/0.05 = 10 to 

make it reflect this case. 

With 10 tank turns and an expected collection and control efficiency of 86%, cost 

effectiveness of this control option ranges from $23,300 per ton for the most 

optimistic case (Table 4) up to $41,300 per ton for the general facilities design 

presented by Eichleay (Table 2). 

Case 3: Collection and Control with a Regenerative Thermal Oxidizer

The thermal oxidizer pricing for this case was taken from the Eichleay study which 

was based on budget quotation obtained by Eichleay during the study. This pricing 

appears to be consistent with EPA Control Cost Manual, Section 3.2, Figure 2.5, 

based on the control device capacities from the Eichleay study. As such, it 

represents a high capital investment/low operating cost scenario for use of a 

oxidizer. 

Annual fuel cost for this case was that calculated by the Eichleay study for of annual 

fuel consumption for RTO’s with 95% energy recovery. 

With 10 tank turns and an expected collection and control efficiency of 86%, cost 

effectiveness of this control option ranges from $16,700 per ton for the most 

optimistic case (Table 4) up to $34,600 per ton for the general facilities design 

presented by Eichleay (Table 2). 

Case 4: Collection and Control with a Refrigerated Condenser

The refrigerated condenser pricing for this case was taken from the EPA Control 

Cost Manual, Section 3.1, Chapter 2, Figure 2.5, based on the control device 

capacities from the Eichleay study, adjusted downward by 23.6% since no 

combustion air would be required for this case. The price from Figure 2.5 (1990 

dollars) was adjusted to 2006 dollars based on average annual inflation of 3%. 

Electric power cost for I.D. fan operation was factored down from the thermal 

oxidizer case by dividing by 1.236 to account for no need for combustion air with this 

technology. 

No electric power cost was allowed for operation of the refrigeration and for handling 

of the aqueous ethanol solution. Since these costs would be substantial, the 

calculated cost effectiveness is optimistically low. 

With 10 tank turns and an expected collection and control efficiency of 81%, cost 

effectiveness of this control option ranges from $16,900 per ton for the most 

optimistic case (Table 4) up to $34,600 per ton for the general facilities design 

presented by Eichleay (Table 2). 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-29

Case 5: Collection and Control with a Water Scrubber

The water scrubber pricing for this case was extrapolated from two budgetary 

quotations obtained in a study by STI14, based on the control device capacities from 

the Eichleay study, adjusted downward by 23.6% since no combustion air would be 

required for this case. The price from STI (2003 dollars) was adjusted to 2007 

dollars based on average annual inflation of 3%. 

Water disposal costs for this case were also taken from the STI study based on a 

12-week operating season. Using the STI assumptions, water disposal requirements 

were taken to be 6 gallons per minute for each 5,000 cfm of flow with a disposal cost 

of $0.25/gallon. 

Electric power cost for I.D. fan operation was factored down from the thermal 

oxidizer case by dividing by 1.236 to account for no need for combustion air with this 

technology. 

With 10 tank turns and an expected collection and control efficiency of 81%, cost 

effectiveness of this control option ranges from $23,000 per ton for the most 

optimistic case (Table 4) up to $44,200 per ton for the general facilities design 

presented by Eichleay (Table 2). 

Case 6: Collection and Control with Carbon Adsorption

Pricing for the carbon adsorption systems was interpolated from pricing obtained by 

the wine industry for carbon adsorption systems and presented in the TAD (page 

77). Sizing was based on the control device capacities from the Eichleay study, 

adjusted downward by 23.6% since no combustion air would be required for this 

case. The price from page 77 (1991 dollars) was adjusted to 2007 dollars based on 

average annual inflation of 3%. 

No utility costs were allowed for operation of the carbon regeneration system or for 

handling water or vapor streams containing the captured ethanol. Since these costs 

would be substantial, the calculated cost effectiveness is optimistically low. 

With 10 tank turns an expected collection and control efficiency of 81%, cost 

effectiveness of this control option ranges from $15,300 per ton for the most 

optimistic case (Table 4) up to $31,700 per ton for the general facilities design 

presented by Eichleay (Table 2). 

4. RACT Selection for Red Wine Fermentation 

The six cases examined under the most optimistic capital investment scenario 

yielded a lowest evaluated cost effectiveness of $15,300 per ton for carbon 

adsorption control technology. For reasons already discussed, this evaluated cost 

effectiveness is artificially low. Other factors making this evaluated cost optimistically 

low include: 

• Only direct costs for structural steel installation, tank modifications, the foam over 

control system and helicopter-based construction were included with no indirect 

costs. These costs could be 50-100% higher when indirect costs are applied. 

 14 Sonoma Technology, Inc., Control Technology Evaluation: Wineries – Fermentation Processes, 2003. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-30

• The EPA cost model only applies factors for engineering, construction and field 

expense, contractor fees and contingency to the purchased equipment costs 

rather than the total direct cost. Since other direct costs such as foundations and 

supports, electrical and piping all have a substantial indirect cost, these costs are 

ignored in this evaluation. Standard practice in the engineering and construction 

industry for a factored estimate of this type is to apply indirect cost factors to the 

total direct cost. 

• EPA cost model factors for engineering, construction and field expenses and 

contingency are low relative to typical experience and practice in the engineering 

and construction industry for industrial construction of this type. Engineering 

costs and construction and field expense are each more typically 10-20%, of total 

direct cost. Industry practice would consider an estimate of this type to have an 

accuracy of no better than + 25%. Based on this, industry practice is to set 

contingency at 15-20% of total direct cost as a minimum. 

• EPA cost model factors for operating and maintenance labor, at 1⁄2 hour per shift, 

are significantly lower than would be required for a system of this type. Both the 

District and industry expect that a minimum of a full time operating person would 

be required to manage the four VOC control systems during the crush season. 

There would also be additional operational impacts on the fermentation tank 

operation to perform CIP operations on ductwork and ensure proper operation 

with the control devices. Preventative maintenance outside of the crush season 

would include CIP of the main headers, opening and inspecting all equipment 

and performing normal maintenance, repairs and check out for all four VOC 

systems. Such maintenance alone could be expected to require 3-4 weeks for a 

crew of four maintenance personnel, far exceeding the maintenance cost 

included with this study. 

The above analysis indicates that there are currently no technologically feasible 

VOC control technologies which offer a cost effectiveness that is less than EPA’s 

assumed RACT threshold of $4,400/ton of VOC. Therefore, the District believes that 

there is no feasible RACT-level control for red wine fermentation. 
San Joaquin Valley Unified Air Pollution Control District 

Appendix K: RACT Analysis for W

Storage T

Appendix K-31EPA Cost Model Table 1 Total Capital Investment for VOC Control of Red Wine Fermentation 

Site specific Costs, CIP, Maximum Vapor Rate Basis 

Control Device

Case 1 

Thermal Ox 

Site Specific, w/CIP

Case 2 

Catalytic Oxidizer 

Site Specific, w/CIP 

Case 3 

RTO 

Site Specific, 

w/CIP 

Case 4 

Refrigerated 

Condenser 

Site Specific, 

w/CIP 

 Water Scrub 

Site Specific, w/CIP 

Ca

Sit

Direct Costs Purchased Equipment Costs 

Control Device $507,000 $1,349,000 $1,877,000 $1,800,000 $287,000 

Knock Out Vessels $148,000 $148,000 $148,000 $148,000 $148,000 

Ductwork $1,105,000 $1,105,000 $1,105,000 $970,000 $970,000 

Subtotal Equipment (A) $1,760,000 $2,602,000 $3,130,000 $2,918,000 $1,405,000 Instrumentation (0.10 x A) $176,000 $260,000 $313,000 $292,000 $141,000 Sales Tax (0.08 x A) $141,000 $208,000 $250,000 $233,000 $112,000 Freight (0.05 x A) $88,000 $130,000 $157,000 $146,000 $70,000 Purchased Equipment Cost (PEC) $2,165,000 $3,200,000 $3,850,000 $3,589,000 $1,728,000 Direct Installation CostsFoundations and Supports (Eichleay Study) $467,000 $467,000 $467,000 $467,000 $467,000 Handling & Erection $303,000 $448,000 $539,000 $502,000 $242,000 Electrical $87,000 $128,000 $154,000 $144,000 $69,000 Piping $43,000 $64,000 $77,000 $72,000 $35,000 Site Prep & MiscellaneousStructural Steel Pipeway $2,532,000 $2,532,000 $2,532,000 $2,532,000 $2,532,000 Site Prep $1,254,000 $1,254,000 $1,254,000 $1,254,000 $1,254,000 CIP System $8,294,000 $8,294,000 $8,294,000 $8,294,000 $8,294,000 Electrical Utility $594,000 $594,000 $594,000 $594,000 $594,000 Tank Modifications $487,000 $487,000 $487,000 $487,000 $487,000 Foam Over Control System $572,000 $572,000 $572,000 $572,000 $572,000 Helicopter Use $977,000 $977,000 $977,000 $977,000 $977,000 Total Direct Costs $17,775,000 $19,017,000 $19,797,000 $19,484,000 $17,251,000 Indirect CostsEngineering $217,000 $320,000 $385,000 $359,000 $173,000 Construction & Field Expenses $108,000 $160,000 $193,000 $179,000 $86,000 Contractor Fees $217,000 $320,000 $385,000 $359,000 $173,000 Start Up $43,000 $64,000 $77,000 $72,000 $35,000 Performance Test $22,000 $32,000 $39,000 $36,000 $17,000 Contingencies $65,000 $96,000 $116,000 $108,000 $52,000 Total Indirect Costs $672,000 $992,000 $1,195,000 $1,113,000 $536,000 Total Capital Investment $18,447,000 $20,009,000 $20,992,000 $20,597,000 $17,787,000 
San Joaquin Valley Unified Air Pollution Control District 

Appendix K: RACT Analysis for W

Storage T

Appendix K-32EPA Cost Model Table 2 Annual Costs for VOC Control of Red Wine Fermentation 

Includes Site Specific Cost, CIP, Maximum Vapor Rate

Control Device Case 1 Thermal Ox Case 2 Catalytic Ox Case 3 RTO Case 4 Refrigerated Cond. Case 5 Water Scrubber 

Ca

Total Capital Investment $18,447,000 $20,009,000 $20,992,000 $20,597,000 $17,787,000 Direct Annual Costs Labor & Materials Operating Labor (0.5 hr/shift-unit @ $12.95/hour) $1,632 $1,632 $1,632 $1,632 $1,632 Supervisor (15% of operator cost) $245 $245 $245 $245 $245  Operating Materials (15% of total 

maintenance cost) $490 $490 $490 $28,360 $490 

Maintenance Labor (0.5 hr/shift-unit@ $12.95/hour) $1,632 $1,632 $1,632 $1,632 $1,632 Maintenance Materials (100% of maintenance labor) $1,632 $1,632 $1,632 $1,632 $1,632 

Utilities 

Natural Gas $2,210,000 $1,105,000 $110,500 $0 $0 Electricity $141,800 $141,800 $141,800 $114,700 $114,700 Water Disposal $0 $0 $0 $0 $1,879,000 

Total Direct Annual Cost $2,357,400 $1,252,400 $257,900 $148,200 $1,999,300 Indirect Annual Costs 

Overhead (60% of labor & Mat'ls) $3,400 $3,400 $3,400 $20,100 $3,400 Administrative Charges (2% of TCI) $368,900 $400,200 $419,800 $411,900 $355,700 Property Taxes (2% TCI) $368,900 $400,200 $419,800 $411,900 $355,700 Insurance (1% TCI) $184,500 $200,100 $209,900 $206,000 $177,900 Capital Recovery (CRF = 0.163) $3,006,900 $3,261,500 $3,421,700 $3,357,300 $2,899,300 

Total Indirect Annual Cost $3,932,600 $4,265,400 $4,474,600 $4,407,200 $3,792,000 Total Annualized Cost $6,290,000 $5,517,800 $4,732,500 $4,555,400 $5,791,300 Emission Reductions  Annual Average Tank Tunover 10 10 10 10 10  Collection & Control Efficiency 86% 86% 86% 81% 81%  Annual Emission Reduction (tons) 130.22 133.60 136.63 129.00 129.00 Cost Effectiveness $/ton $48,300 $41,300 $34,600 $35,300 $44,900 
San Joaquin Valley Unified Air Pollution Control District 

Appendix K: RACT Analysis for W

Storage T

Appendix K-33EPA Cost Model Table 3 Total Capital Investment for VOC Control of Red Wine Fermentation 

Non-Site specific Cost, No CIP, Managed Vapor Rate Basis 

Control Device

Case 1 

Thermal Ox 

Non-Site Specific, 

No CIP

Case 2 

Catalytic Oxidizer 

Non-Site Specific, 

No CIP

Case 3 

RTO 

Non-Site Specific, 

No CIP

Case 4 

Refrigerated 

Condenser 

Non-Site Specific, 

No CIP

Case 5 

Water Scrub 

Non-Site 

Specific, 

No CIP

Direct Costs Purchased Equipment Costs 

Control Device $456,000 $1,089,000 $1,511,000 $1,464,000 $253,000 

Knock Out Vessels $120,000 $120,000 $120,000 $120,000 $120,000 

Ductwork $776,000 $776,000 $776,000 $776,000 $776,000 

Subtotal Equipment (A) $1,352,000 $1,985,000 $2,407,000 $2,360,000 $1,149,000 Instrumentation (0.10 x A) $135,000 $199,000 $241,000 $236,000 $115,000 Sales Tax (0.08 x A) $108,000 $159,000 $193,000 $189,000 $92,000 Freight (0.05 x A) $68,000 $99,000 $120,000 $118,000 $57,000 Purchased Equipment Cost (PEC) $1,663,000 $2,442,000 $2,961,000 $2,903,000 $1,413,000 Direct Installation CostsFoundations and Supports (Eichleay Study) $467,000 $467,000 $467,000 $467,000 $467,000 Handling & Erection $233,000 $342,000 $415,000 $406,000 $198,000 Electrical $67,000 $98,000 $118,000 $116,000 $57,000 Piping $33,000 $49,000 $59,000 $58,000 $28,000 Site Prep & MiscellaneousStructural Steel Pipeway $2,532,000 $2,532,000 $2,532,000 $2,532,000 $2,532,000 Site Prep $0 $0 $0 $0 $0 CIP System $0 $0 $0 $0 $0 Electrical Utility $0 $0 $0 $0 $0 Tank Modifications $487,000 $487,000 $487,000 $487,000 $487,000 Foam Over Control System $572,000 $572,000 $572,000 $572,000 $572,000 Helicopter Use $977,000 $977,000 $977,000 $977,000 $977,000 Total Direct Costs $7,031,000 $7,966,000 $8,588,000 $8,518,000 $6,731,000 Indirect CostsEngineering $166,000 $244,000 $296,000 $290,000 $141,000 Construction & Field Expenses $83,000 $122,000 $148,000 $145,000 $71,000 Contractor Fees $166,000 $244,000 $296,000 $290,000 $141,000 Start Up $33,000 $49,000 $59,000 $58,000 $28,000 Performance Test $17,000 $24,000 $30,000 $29,000 $14,000 Contingencies $50,000 $73,000 $89,000 $87,000 $42,000 Total Indirect Costs $515,000 $756,000 $918,000 $899,000 $437,000 Total Capital Investment $7,546,000 $8,722,000 $9,506,000 $9,417,000 $7,168,000 
San Joaquin Valley Unified Air Pollution Control District 

Appendix K: RACT Analysis for W

Storage T

Appendix K-34EPA Cost Model Table 4 Annual Costs for VOC Control of Red Wine fermentation 

Non-Site Specific Cost, No CIP, Managed Vapor Rate Basis 

Control Device Case 1 Thermal Ox Case 2 Catalytic Oxidizer Case 3 RTO Case 4 Refrigerated Condenser Case 5 Water Scrubber Total Capital Investment $7,546,000 $8,722,000 $9,506,000 $9,417,000 $7,168,000 Direct Annual Costs Labor & Materials 

Operating Labor (0.5 hr/shift-unit @ $12.95/hour) $1,632 $1,632 $1,632 $1,632 $1,632 

 Supervisor (15% of operator cost) $245 $245 $245 $245 $245 

Operating Materials (15% of total maintenance cost) $490 $490 $490 $28,360 $490 Maintenance Labor (0.5 hr/shiftunit@ $12.95/hour) $1,632 $1,632 $1,632 $1,632 $1,632 Maintenance Materials (100% of maintenance labor) $1,632 $1,632 $1,632 $1,632 $1,632 

Utilities  Natural Gas $2,210,000 $1,105,000 $110,500 $0 $0  Electricity $141,800 $141,800 $141,800 $114,700 $114,700  Water Disposal $0 $0 $0 $0 $1,315,000 Total Direct Annual Cost $2,357,400 $1,252,400 $257,900 $148,200 $1,435,300 Indirect Annual Costs 

Overhead (60% of labor & Mat'ls) $3,400 $3,400 $3,400 $20,100 $3,400 

 Administrative Charges (2% of TCI) $150,900 $174,400 $190,100 $188,300 $143,400  Property Taxes (2% TCI) $150,900 $174,400 $190,100 $188,300 $143,400  Insurance (1% TCI) $75,500 $87,200 $95,100 $94,200 $71,700  Capital Recovery (CRF = 0.163) $1,230,000 $1,421,700 $1,549,500 $1,535,000 $1,168,400 Total Indirect Annual Cost $1,610,700 $1,861,100 $2,028,200 $2,025,900 $1,530,300 Total Annualized Cost $3,968,100 $3,113,500 $2,286,100 $2,174,100 $2,965,600 Emission Reductions  Annual Average Tank Tunover 10 10 10 10 10  Collection & Control Efficiency 86% 86% 86% 81% 81%  Annual Emission Reduction (tons) 130.22 133.60 136.63 129.00 129.00 Cost Effectiveness $/ton $30,500 $23,300 $16,700 $16,900 $23,000 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-35

C. Cost Effectiveness for White Wine Fermentation 

1. Estimating Approach and Basis for White Wine 

Differences between red and white fermentation with respect to sizing and installation of a 

VOC control device and to the potential emission reductions which can be achieved are 

as follows: 

• White wine fermentation produces only 2.5 lb of ethanol emission per 1000 gallons 

fermented versus 6.2 lb per 1000 gallons for red wine. 

• White wines are fermented at maximum temperatures of 60 o

F versus 85 oF for red 

wine. 

• Due to the lower temperature and reaction rate for white wine fermentation, vapor flow 

from a white wine fermenter is substantially reduced relative to a red wine fermenter. 

• Due to the much slower fermentation rates for white wine, these tanks are only turned 

an average of two times per season versus an average of four turns for red wine 

fermentation. 

• Due to lower reaction rates, foam over is not a significant problem for white wine 

fermenters. 

However, as with red wine fermenters, white wine fermenters require a ductwork system 

for capture and collection of the ethanol emissions and a system for cleaning and 

sterilization (CIP system). As with red fermenters, they are typically installed in close 

proximity, lacking plot space for installation of control devices and are not designed to 

provide structural support for ductwork. 

Based on the above a simplified approach, based on the estimates of capital investment 

and operating cost already developed for red wine, will be employed to examine the 

potential cost effectiveness of VOC control for white wine fermentation: 

• A review of fermentation modeling results presented by Williams and Boulton, showing 

ethanol concentration and emission rate from fermentation operations at 60 and 85 o

F, 

it is estimated that the peak vapor flow rate for fermentation at 60 o

F is approximately 

58% of that for fermentation at 85 o

F. Based on this, it will be optimistically assumed 

that a white wine emission control system can be sized for 50% of the size of a red 

wine control system, given equivalent fermentation tank volume to be controlled. To 

model this scenario using the capital and operating costs which have been prepared 

for red wine, the control system scope and sizing for the red wine case will be utilized 

to reflect white wine fermentation but the connected hypothetical white wine 

fermentation tankage capacity will be assumed to be twice that of the tankage volume 

in the red wine case. Therefore the four VOC control systems previously identified for 

control of red wine emissions at Gallo-Modesto will be assumed to be connected to 

white wine fermentation tankage of 2 x 6,850,000 = 13,700,000 gallons (nominal 

capacity). 

• It will be optimistically assumed that the collection system ductwork is sufficiently 

reduced in size such that the steel support structures are not required and that the 

ductwork can be supported from the tanks or routed on existing steel supports. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-36

Therefore, costs for steel structures and the use of a helicopter for construction will not 

be included. 

• Since white wine does not experience the foaming problems of red wine, it will be 

assumed that foam over control instrumentation is not required. 

• As was assumed in the most optimistic case for red wine, it will be assumed that site 

specific costs and costs for the CIP system are negligible. 

• It will be assumed that water disposal costs for the water scrubber case are 

proportional to the emission reductions. The value estimated for red wine will be 

factored down on this basis. 

• All other costs, as estimated for the six technology cases for red wine, will be assumed 

to be the same for white wine. 

• To provide the most optimistic evaluation of cost effectiveness, it will be assumed that 

the white wine tankage is operated at six turnovers per season, three times the 

industry average throughput for white wine fermentation tanks. 

2. Cost Effectiveness Estimates for White Wine Fermentation 

Tables 5 and 6 present a “most optimistic” case for control of white wine, based on using 

the six technologically feasible control device technologies previously identified. Note that 

these estimates of capital investment and operating costs are the same as presented in 

Tables 3 and 4 except that costs for structural steel, the foam control system, and 

helicopter based construction have been deleted. The emission reductions are based on a 

tankage capacity twice that used for red wine, six tank turns per season, and 2.5 lbethanol/1000 gallons. 

As shown, “most-optimistic” cost effectiveness estimates range from $18,400 to $52,100 

per ton. 

3. RACT Selection for White Wine Fermentation

The six cases examined under the most optimistic capital investment scenario yielded a 

lowest evaluated cost effectiveness of $18,400 per ton for carbon adsorption control 

technology. Due to the simplifying assumptions and other factors as discussed for red 

wine, the District’s opinion is that these results significantly understate the true cost 

effectiveness for control of ethanol emissions from white wine fermentation. The above 

analysis indicates that there are currently no technologically feasible VOC control 

technologies which offer a cost effectiveness that is less than EPA’s assumed RACT 

threshold of $4,400/ton of VOC. Therefore, the District believes that there is no feasible 

RACT-level control for white wine fermentation. 
San Joaquin Valley Unified Air Pollution Control District 

Appendix K: RACT Analysis for Wi

Storage T

Appendix K-37 EPA Cost Model Table 5 Total Capital Investment (TCI) for VOC Control of White Wine Fermentation 

Non-Site Specific, No CIP, Managed Tank Vapor Flow 

Control Device

Case 1 

Thermal Ox 

Non-Site Specific, 

no CIP

Case 2 

Catalytic Oxidizer 

Non-Site Specific, no 

CIP

Case 3 

RTO 

Non-Site Specific, 

no CIP

Case 4 

Refrigerated 

Condenser 

Non-Site Specific, no 

CIP

Case 5 

Water Scrub 

Non-Site 

Specific, no CIP

Direct Costs Purchased Equipment Costs 

Control Device $456,000 $1,089,000 $1,511,000 $1,464,000 $253,000 

Knock Out Vessels $120,000 $120,000 $120,000 $120,000 $120,000 

Ductwork $776,000 $776,000 $776,000 $776,000 $776,000 

Subtotal Equipment (A) $1,352,000 $1,985,000 $2,407,000 $2,360,000 $1,149,000 Instrumentation (0.10 x A) $135,000 $199,000 $241,000 $236,000 $115,000 Sales Tax (0.08 x A) $108,000 $159,000 $193,000 $189,000 $92,000 Freight (0.05 x A) $68,000 $99,000 $120,000 $118,000 $57,000 Purchased Equipment Cost (PEC) $1,663,000 $2,442,000 $2,961,000 $2,903,000 $1,413,000 Direct Installation CostsFoundations and Supports (Eichleay Study) $467,000 $467,000 $467,000 $467,000 $467,000 Handling & Erection $233,000 $342,000 $415,000 $406,000 $198,000 Electrical $67,000 $98,000 $118,000 $116,000 $57,000 Piping $33,000 $49,000 $59,000 $58,000 $28,000 Site Prep & MiscellaneousStructural Steel Pipeway $0 $0 $0 $0 $0 Site Prep $0 $0 $0 $0 $0 CIP System $0 $0 $0 $0 $0 Electrical Utility $0 $0 $0 $0 $0 Tank Modifications $487,000 $487,000 $487,000 $487,000 $487,000 Foam Over Control System $0 $0 $0 $0 $0 Helicopter Use $0 $0 $0 $0 $0 Total Direct Costs $2,950,000 $3,885,000 $4,507,000 $4,437,000 $2,650,000 Indirect CostsEngineering $166,000 $244,000 $296,000 $290,000 $141,000 Construction & Field Expenses $83,000 $122,000 $148,000 $145,000 $71,000 Contractor Fees $166,000 $244,000 $296,000 $290,000 $141,000 Start Up $33,000 $49,000 $59,000 $58,000 $28,000 Performance Test $17,000 $24,000 $30,000 $29,000 $14,000 Contingencies $50,000 $73,000 $89,000 $87,000 $42,000 Total Indirect Costs $515,000 $756,000 $918,000 $899,000 $437,000 Total Capital Investment $3,465,000 $4,641,000 $5,425,000 $5,336,000 $3,087,000 
San Joaquin Valley Unified Air Pollution Control District 

Appendix K: RACT Analysis for Wi

Storage T

Appendix K-38 EPA Cost Model Table 6 Annual Costs for VOC Control of White Wine Fermentation 

Non-Site Specific, No CIP, Managed Tank Vapor Flow 

Control Device 

Case 1 

Thermal Ox 

Non-Site Specific, 

no CIP 

Case 2 

Catalytic Oxidizer 

Non-Site Specific, no 

CIP 

Case 3 

RTO 

Non-Site Specific, 

no CIP 

Case 4 

Refrigerated 

Condenser 

Non-Site Specific, no 

CIP 

Case 5 

Water Scrubber

Non-Site 

Specific, no CIP

Total Capital Investment $3,465,000 $4,641,000 $5,425,000 $5,336,000 $3,087,000 Direct Annual Costs Labor & Materials 

Operating Labor (0.5 hr/shift-unit @ $12.95/hour) $1,632 $1,632 $1,632 $1,632 $1,632 

 Supervisor (15% of operator cost) $245 $245 $245 $245 $245 

Operating Materials (15% of total maintenance cost) $490 $490 $490 $28,360 $490 Maintenance Labor (0.5 hr/shiftunit@ $12.95/hour) $1,632 $1,632 $1,632 $1,632 $1,632 Maintenance Materials (100% of maintenance labor) $1,632 $1,632 $1,632 $1,632 $1,632 

Utilities 

Natural Gas $2,210,000 $1,105,000 $110,500 $0 $0 

 Electricity $141,800 $141,800 $141,800 $114,700 $114,700  Water Disposal $0 $0 $0 $0 $631,200 Total Direct Annual Cost $2,357,400 $1,252,400 $257,900 $148,200 $751,500 Indirect Annual Costs  Overhead (60% of labor & Mat'ls) $3,400 $3,400 $3,400 $20,100 $3,400  Administrative Charges (2% of TCI) $69,300 $92,800 $108,500 $106,700 $61,700  Property Taxes (2% TCI) $69,300 $92,800 $108,500 $106,700 $61,700  Insurance (1% TCI) $34,700 $46,400 $54,300 $53,400 $30,900  Capital Recovery (CRF = 0.163) $564,800 $756,500 $884,300 $869,800 $503,200 Total Indirect Annual Cost $741,500 $991,900 $1,159,000 $1,156,700 $660,900 Total Annualized Cost $3,098,900 $2,244,300 $1,416,900 $1,304,900 $1,412,400 Emission Reductions  Annual Average Tank Tunover 6 6 6 6 6  Collection & Control Efficiency 86% 86% 86% 81% 81%  Annual Emission Reduction (tons) 59.53 62.90 65.94 62.42 62.42 Cost Effectiveness $/ton $52,100 $35,700 $21,500 $20,900 $22,600 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-39 

V. Cost effectiveness and RACT Determination for Control of Ethanol Emissions 

from Wine Storage 

A. Emission Control Technology for Control of Emissions from Wine Storage 

1. Background 

Wine storage tanks perform two functions in the winery: 

• Facilitation of post-fermentation processing operations such as racking, filtration, 

malolactic fermentation and bottling. In this role, the typical storage tank is filled and 

emptied several times per year and functions as a process vessel. 

• Storage of wine between processing operations up to the final operation of bottling. 

In this role, the objective is to avoid oxidation of the wine by both minimizing the wine 

temperature and the exposure of the wine to air. 

Emissions from storage tanks consist of both working losses and breathing losses. The 

former losses occur as a result of the displacement of the vapor space of the tank into the 

atmosphere as a result of tank filling operations and is primarily a function of tank 

throughput and the temperature and ethanol content of the wine. Breathing losses are the 

result of diurnal heating and cooling caused by the effect of atmospheric conditions on the 

contents of the tank. For a well-insulated tank, breathing losses will be negligible. 

After fermentation, wine is transferred a number of times between storage tanks to 

perform various finishing operations such as “racking” (decantation for separation of 

sediment), filtration, malolactic fermentation (breakdown of malic acid to lactic acid and 

carbon dioxide), and bottling operations. Since the bottling process is a year-round 

operation, each batch of wine will have a definite residence time in storage, before 

bottling, which includes the time spent in performing the various post-fermentation 

finishing processes. The post-fermentation operations result in “working losses” from the 

storage tanks since they require draining and filling the tanks several times. Storage 

before bottling generates “breathing losses” from the tanks. 

The District has prepared a BACT guideline for wine storage tanks (Guideline 4.12.8). 

Guideline 4.12.8 establishes the installation of insulation and a pressure/vacuum valve set 

within 10% of the maximum allowable working pressure of the tank, “gas tight” tank 

operation and maintenance of a continuous storage temperature not exceeding 75 o

F 

within 60 days of completion of fermentation as “achieved in practice”. The following 

capture and control options are also identified as technologically feasible: 

• Refrigeration of wine or equivalent 

• Capture of VOCs and thermal or catalytic oxidation or equivalent 

• Capture of VOCs and carbon adsorption or equivalent 

• Capture of VOCs and absorption or equivalent (water scrubber) 

• Capture of VOCs and condensation or equivalent (refrigerated condenser) 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-40 

The US EPA’s RACT/BACT/LAER contains no examples of controlling wine storage tank 

emissions. Additional literature searches produced no examples of wine storage tank 

emission control being implemented worldwide. 

2. Pressure/Vacuum Valves on Wine Storage Tanks w/ “Gas Tight” Operation 

VOCs (ethanol) are emitted from the storage tanks as a result of both working losses 

(which occur when the liquid level in the tank changes) and breathing losses (expansion 

and contraction effects due to temperature variations). The proposed pressure/vacuum 

valve limits these emissions by requiring the maximum amount of variation in tank 

pressure before allowing the tank to vent to the atmosphere or allowing air admission to 

the tank. These valves are in common use in this application in the industry for purposes 

of minimizing contact of the wine with oxygen to preserve product quality. 

3. Storage Tank Insulation 

Application of insulation to a storage tank isolates the contents from the impact of diurnal 

heating and cooling cycles due to sunlight and atmospheric conditions and minimizes the 

resulting breathing losses from the tank. Insulation is commonly applied to wine storage 

tanks in conjunction with refrigeration of the tank to maintain the wine contents below 40 

o

F during storage to preserve wine quality. As mentioned previously, breathing losses are 

considered negligible for a well insulated tank. 

 4. Refrigerated Storage (Temperature Control) 

As mentioned, refrigeration is commonly employed in conjunction with tank insulation for 

purposes of preserving product quality during long term storage. Maintaining the wine at a 

reduced temperature lowers the volatility of the ethanol and thus reduces the emissions 

from working losses and essentially eliminates breathing losses. Since the majority of the 

storage tank emissions result from working losses associated with wine transfer 

operations rather than with tank breathing losses, the most effective utilization of 

refrigeration requires that the fermented must be cooled immediately after fermentation, 

prior to transfer operations such as racking and clarification. 

4. Capture and Control 

The balance of the identified technologically feasible controls consist of capture and 

control technologies and have been previously discussed in this document under wine 

fermentation. The general discussion previously presented is applicable to wine storage 

as well. However, application of each of the technologies to wine storage is based on 

maintaining the tank in a “gas tight” condition, connected to the control device via ducting, 

and therefore the District considers that the capture efficiency associated with each 

technology is 100%. Therefore, based on the previous discussion, the capture and control 

systems are considered to have the following overall emission control efficiencies: 

Capture of VOCs and thermal or catalytic oxidation: 95% control 

Capture of VOCs and carbon adsorption: 95% control 

Capture of VOCs and water scrubber: 90% control 

Capture of VOCs and refrigerated condenser: 90% control 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-41 

B. Cost Effectiveness Analysis

1. Approach for Cost Effectiveness 

The following cases will be examined for cost effectiveness for control of wine storage 

tank emissions:: 

Case 1 Pressure/Vacuum Valve with “Gas Tight” Tank Operation 

Case 2 Storage Tank Insulation 

Case 3 Storage Tank Refrigeration (with Insulation) 

Case 4 Thermal oxidation with 0% heat recovery (low capital/high operating cost) 

Case 5 Catalytic oxidation with 50% heat recovery (mid range capital/mid range 

operating cost) 

Case 6 Regenerative thermal oxidation with 95% heat recovery (high capital/low 

operating cost) 

Case 7 Refrigerated Condenser 

Case 8 Water scrubber 

Case 9 Carbon adsorption 

The approach of the cost effectiveness analysis will be to first determine which, if any, of 

the above cases potentially qualifies as RACT based on having a potential cost 

effectiveness below the EPA’s assumed RACT threshold of $4,400/ton of VOC. All cases 

which are shown to have a cost effectiveness higher than $4,400/ton will be discarded. 

Cases which fall below the threshold will then be further examined and compared with 

respect to relative cost effectiveness, technical risk, reasonableness, and socio-economic 

impact to determine which, if any, qualify as RACT for wine storage tanks. 

To establish a comparative physical scope of each of the above cases, the District’s 

approach is based on applying the nine different control technologies to a hypothetical 

650,000 gallon storage tank (43’ diameter x 60 feet tall) located in Fresno, CA. For 

options controlling multiple tanks, a hypothetical assembly of eight (8) 650,000 gallon 

capacity tanks aligned in two groups of 4 on either side of a common pipeway. The 

rationale for this is based on the following: 

• A 650,000 gallon tank is representative of the largest storage tanks currently in use in 

the San Joaquin Valley. Due to economy of scale, it can be assumed that applying 

controls to this size of tank will provide the most optimistic cost effectiveness and that 

all smaller tanks, equipped with the same controls, will be less cost effective. 

• Fresno is centrally located in the valley and provides a reasonable basis for average 

atmospheric conditions. 

• An assemblage of eight tanks grouped along a pipeway is a reasonably common yet 

generic arrangement for wine storage tanks and provides significant total storage 

capacity for economy of scale with respect to controls. Cost effectiveness based on 

this configuration should provide an optimistic assessment of cost effectiveness 

relative to the average storage tank installation in the San Joaquin Valley. Larger 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-42 

assemblages of tanks of this size could result in significant increases in collection 

manifold sizes and elevations due to combining flows from large numbers of tanks and 

to the sloping requirements for installation of free-draining ductwork. 

2. Estimating Approach and Basis 

The approach for cost effectiveness determination will be based on the following 

elements: 

• Cases 1-3 are process modifications rather than installation of emission controls. A 

simplified cost effectiveness for these cases was calculated based on only a direct 

cost of certain major components of the scope to demonstrate that the proposed 

process modification exceeds the cost effectiveness threshold for RACT. 

• EPA’s cost model for VOC incineration systems, as presented in the EPA Control Cost 

Manual, Section 3.2, Tables 2.8 and 2.9, was used for all capture and control cases 

with the exception of the refrigerated condenser (case 7) estimate which used Section 

3.1, Table 2.3 for Total Capital Investment (note also that the EPA cost model was 

adjusted to a California location by taking sales tax at 8% rather than 3%). 

• All estimates are based on the model 650,000 gallon capacity storage tank (43’ dia. x 

60’ tall). 

• All capture and control cases (cases 4-9) are assumed to be manifolded together to a 

common control device based on a tank battery of eight (8) 650,000 gallon tanks. 

• Potential uncontrolled emissions from each model storage tank have been determined 

to be 947 lb-ethanol/year based on simulation of a 650,000 gallon uninsulated tank 

containing wine with 13.9 % ethanol and which experiences 6 turnovers per season15. 

Tank simulation was performed using the TANKS 4.0 program, setting the 

pressure/vacuum valve setting to zero to simulate tank operation without a valve. 

• Control device capacity for cases 4-9 is 1450 scfm based air displacement from the 

tanks during filling operations and upon an assumed pumping capability to fill a 

storage tank in a single 8-hour shift. It is assumed that all eight tanks can possibly fill 

at the same time. 

• Each capture and control case is assumed to have the same requirements for the 

collection system consisting of ducting which connects all eight tanks to a common 

manifold which, in turn, connects to a knock out vessel located just upstream of the 

control device. The minimum scope of the collection system was determined to be: 

- Tank modifications to add a new vent nozzle on each tank 

- Installation of 60 feet of 6’ dia. stainless steel ducting from each tank to the central 

manifold (total of 480 linear feet) 

- Installation of a 10” dia. stainless steel central manifold ducting (250 linear feet) 

- Installation of a knock out pot upstream of the control device 

 

15 Average storage tank turnovers of six per year is based on conversation with Bob Calvin of Constellation Wine and is 

corroborated by Authority to Construct applications received to date by the District for new wine storage tanks. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-43 

• It was optimistically assumed that the cost of structural supports and of the clean-inplace (CIP) system for cleaning and sterilization of the ductwork would be negligible. 

• Purchased costs for ducting were taken from the EPA Control Cost Manual, Section 2, 

Chapter 1 and corrected to last quarter 2006 by assuming average 3% annual 

inflation. An allowance of $5,000 was used for the knock out vessel and an allowance 

of $2000 per tank was used for the tank modifications to add a vent nozzle. 

• Potential site specific costs such as site preparation, electric utility expansion and 

natural gas utility expansion were optimistically ignored. 

• Total Capital Investment was annualized based on a 10 year equipment life and a 10% 

opportunity cost for capital (CRF = 0.163). 

• Electric power costs were considered only for the induced draft fan required to deliver 

the 1450 cfm combined vent from the tanks through the control device and to the vent 

stack (assumed to be the same for all cases). Power costs for refrigeration and for 

regeneration of activated carbon were optimistically ignored. 

• Pricing for natural gas and electricity were applied at $0.61/therm and $0.12/kwh 

based on the Eichleay study for fermentation control for Gallo’s Modesto winery. 

3. Cost Effectiveness Analysis for Wine Storage Tanks 

Case 1 - Pressure/Vacuum Valve 

The 650,000 gallon storage tank model (TANKS 4.0) was revised to include a 

pressure/vacuum valve using default pressure and vacuum settings of 0.03 psig per 

TANKS 4.0. The resulting simulation indicated that breathing losses from a single tank 

were reduced from 387 lb/year to 373 lb/year for a net reduction in breathing loss of 14 

lb/year with an ethanol content of 53.7 wt%. This yields a negligible emission reduction of 

only 8 lb/yr, or 0.004 tons/year. Working losses were not affected as would be expected. 

Assuming a de minimus investment cost of $5000 to install a flanged nozzle on the 

stainless steel storage tank and to purchase and install a pressure/vacuum valve and 

associated stainless steel piping yields an annualized investment of 0.163 x $5000 = 

$815/year. Cost effectiveness of the pressure/vacuum valve will thus be on the order of 

$815/0.004 = $204,000/ton. 

Case 2 - Storage Tank Insulation 

To evaluate the potential effectiveness of insulation in controlling ethanol emissions from 

wine storage tanks, it was optimistically assumed that the tank insulation value is high 

enough to effectively eliminate the impact of changing ambient conditions, such that the 

tank contents stays at a uniform annual average temperature throughout the year. The net 

result of this assumption is that breathing losses from the tank are negligible. It is also 

assumed that the tank is equipped with a pressure/vacuum valve since this is a common 

practice in the industry for quality control reasons. With a pressure vacuum valve in place, 

the elimination of all breathing losses would potentially result in a reduction in tank losses 

of 373 lb/year, equivalent to 200 lb-ethanol/year (0.10 tons/year). 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-44 

The cost to insulate a new 43’ dia. x 60 ft tall, 650,000 gallon tank during initial 

construction is estimated at $131,900 based on an installed insulation cost16 of $16.21per 

square foot. Note that insulation costs for insulating existing storage tanks would be 

considerably higher since an existing tank may require structural modifications to support 

the weight of the insulation and would require scaffolding of the tank to perform the 

installation (scaffolding is used for general construction of a new tank and the scaffolding 

cost would therefore is not be directly attributable to the installation of insulation in the 

case of new tank construction). Annualized direct cost of insulation on a new tank is thus 

0.163 x $132,000 = $21,500/year. Cost effectiveness of insulation, based only on the 

initial investment for insulation is determined to be $21,500/(0.10 tons/year) = 

$215,000/ton. 

Case 3 - Refrigerated Storage

Based on simulations with TANKS 4.0, maintaining a controlled 40 oF storage temperature 

on wine with 13.9% ethanol in a 650,000 gallon tank reduces ethanol emissions by 758 

lb/year (0.38 tons per year) relative to an uninsulated and unrefrigerated tank, equipped 

with a pressure/vacuum valve at a Fresno, CA location. 

To evaluate the potential cost effectiveness of 40 o

F refrigerated storage in controlling 

ethanol emissions from wine storage tanks, capital investment requirements are based on 

applying insulation to a 650,000 gallon tank plus installation of purchased refrigeration 

capacity of 21 tons17. Using the estimate of insulation cost developed above and adding 

the bare purchase price of a 21 ton refrigeration unit (based on EPA Control Cost Manual, 

Section 3.1, Figure 2.5, the investment (2006) for a 650,000 gallon tank would be: 

Insulation (not including tank mods or scaffolding) = $132,000 

Purchase price for 21 ton refrigeration (no installation cost included) = $112,000

Total Cost = $244,000 

Optimistically ignoring both the installation costs for the refrigeration and the annual cost 

associated with operations and maintenance, annualized direct cost of refrigeration plus 

insulation on a new tank is thus 0.163 x $244,000 = $39,700/year and the cost 

effectiveness would be estimated at $39,700/0.38 = $105,000/ton. 

Collection and Control Cases:

Table 7 presents the development of Total Capital Investment for all cases and Table 8 

presents the annual costs, emission reductions, and cost effectiveness for each collection 

and control case. Discussion of each case follows: 

Case 4 - Collection and Control with a Thermal Oxidizer

Capital investment for this case as well as all remaining capture and control cases is 

presented in 7. Annual costs, emission reductions and calculated cost effectiveness are 

presented in Table 8. The selected thermal oxidizer for this case was priced from the EPA 

 

16 Information provided by T. Vitali of O’Neal Beverages (2006) for 3” thick spay-on urethane foam insulation on the tank 

walls and 9” thick urethane foam on the roof, based on actual insulation costs for new 190,000 gallon tanks at the O’Neal 

Winery in Parlier. 

17 0.032 tons per 1000 gallons of insulated storage capacity based on estimated capacity requirements supplied by Tom 

Vitiali at O’Neal Beverages. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-45 

Control Cost Manual, Section 3.2, Figure 2.4, based on a 1,450 scfm unit with 0% energy 

recovery. As such, it represents a minimum capital investment scenario for use of a thermal 

oxidizer. The price from Figure 2.4 (1990 dollars) was adjusted to 2006 dollars based on 

average annual inflation of 3%. 

The emission reduction for this case is: 

8 tanks x 947 lb-ethanol/tank x 1 ton/2000 lb x 95% = 3.60 tons-ethanol/year. 

Annual fuel cost for this case was calculated based on heating the 1,450 scfm to 1,500 o

F 

with no heat recovery but allowing a 50% reduction from the theoretical fuel consumption 

based on using a variable frequency drive on the ID fan, allowing turn down of the unit. 

With an expected collection and control efficiency of 95%, cost effectiveness of this 

control option is optimistically estimated at $75,700 per ton. 

Case 5 - Collection and Control with a Catalytic Oxidizer

The catalytic oxidizer for this case was priced from the EPA Control Cost Manual, Section 

3.2, Figure 2.6, based on a 1,450 scfm unit with 50% energy recovery. As such, it 

represents a mid range capital investment scenario for use of oxidizer technology. The 

price from Figure 2.4 (1990 dollars) was adjusted to 2006 dollars based on average 

annual inflation of 3%. 

The emission reduction for this case is: 

8 tanks x 947 lb-ethanol/tank x 1 ton/2000 lb x 95% = 3.60 tons-ethanol/year. 

Annual fuel cost for this case was calculated based on heating the 1,450 scfm to 600 oF 

with a 50% reduction for heat recovery and another 50% reduction for turndown capability 

based on using a variable frequency drive on the ID fan. With an expected collection and 

control efficiency of 95%, cost effectiveness of this control option is optimistically 

estimated at $51,200 per ton. 

Case 6 - Collection and Control with a Regenerative Thermal Oxidizer (RTO)

The regenerative thermal oxidizer for this case was priced based on vendor quotations 

from the STI wine fermentation study for RTO’s with capacities of 500 scfm and 5000 

scfm. These prices were interpolated to determine the price of a 1,450 scfm unit. RTO’s 

typically have an energy efficiency of approximately 95% and, as such, this case 

represents a maximum capital investment scenario for use of a thermal oxidizer. The price 

derived from the STI data (2003 dollars) was adjusted to 2006 dollars based on average 

annual inflation of 3%. 

The emission reduction for this case is: 

8 tanks x 947 lb-ethanol/tank x 1 ton/2000 lb x 95% = 3.60 tons-ethanol/year. 

Annual fuel cost for this case was calculated based on heating the 1,450 scfm to 1,500 0

F 

with 95% heat recovery. With an expected collection and control efficiency of 95%, cost 

effectiveness of this control option is optimistically estimated at $58,500 per ton. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-46 

Case 7 - Collection and Control with a Refrigerated Condenser

It was assumed that the refrigerated condenser would operate at a condensing 

temperature of –12 o

F and achieve a 90% collection and control based on the TAD. The 

refrigerated condenser duty for this case was determined to be 9.6 tons of refrigeration 

and was priced based on the EPA Control Cost Manual, Section 3.1, Figure 2.5, based on 

a –20 o

F refrigerant condensing temperature. The price from Figure 2.5 (1990 dollars) was 

adjusted to 2006 dollars based on average annual inflation of 3%. 

The emission reduction for this case is: 

8 tanks x 947 lb-ethanol/tank x 1 ton/2000 lb x 90% = 3.41 tons-ethanol/year. 

Electric power costs for operation of the refrigeration were ignored in the analysis. 

With an expected collection and control efficiency of 90% per the TAD, cost effectiveness 

of this control option is optimistically estimated at $83,800 per ton. 

Case 8 - Collection and Control with a Water Scrubber

The selected water scrubber for this case was priced based on vendor quotations 

obtained from the STI study for scrubbers with capacities of 500 scfm and 5000 scfm. 

These prices were interpolated to determine the price of a 1,450 scfm unit. The price 

derived from the STI data (2003 dollars) was adjusted to 2006 dollars based on average 

annual inflation of 3%. 

The emission reduction for this case is: 

8 tanks x 947 lb-ethanol/tank x 1 ton/2000 lb x 90% = 3.41 tons-ethanol/year. 

Costs for disposal of ethanol-laden water from operation of the scrubber were not 

included in the analysis. 

With an assumed collection and control efficiency of 95%, cost effectiveness of this 

control option is optimistically estimated at $38,000 per ton. 

Case 9 - Collection and Control with Carbon Adsorption

The selected water scrubber for this case was priced based on pricing presented in the 

TAD for activated carbon adsorption systems including carbon canisters, blower, and 

regeneration system. Prices from the TAD were interpolated to determine the price of a 

1,450 scfm unit. The price derived from the TAD (1991 dollars) was adjusted to 2006 

dollars based on average annual inflation of 3%. 

The emission reduction for this case is: 

8 tanks x 947 lb-ethanol/tank x 1 ton/2000 lb x 95% = 3.60 tons-ethanol/year 

Utility costs for operation of the carbon regeneration system were not included in the 

analysis. With an expected collection and control efficiency of 95%, cost effectiveness of 

this control option is optimistically estimated at $70,000 per ton. 

4. RACT Selection for Wine Storage Tanks 

The nine cases examined under an optimistic capital investment scenario yielded 

evaluated cost effectiveness ranging from $38,000 per ton for water scrubber control 

technology to $75,700 per ton a thermal oxidizer without heat recovery. For reasons 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-47 

already discussed, these evaluated cost effectiveness are artificially low. Factors making 

these evaluated costs optimistically low include: 

• It was assumed that the cost of engineered structures to support the ductwork would 

be negligible. 

• It was assumed that the cost of the CIP system was negligible. 

• Cases 1 through 3 based the capital investment on only the purchase cost of the 

equipment or the direct cost of a major element. Other significant direct cost and all 

the indirect costs were ignored. 

• Site specific costs for site preparation, electricity or fuel gas supply were ignored. 

• Utility costs for refrigeration, carbon regeneration, water disposal, and waste stream 

handling were ignored. 

• The EPA cost model only applies factors for engineering, construction and field 

expense, contractor fees and contingency to the purchased equipment costs rather 

than the total direct cost. Since other direct costs such as foundations and supports, 

electrical and piping all have a substantial indirect cost, these costs are ignored in this 

evaluation. Standard practice in the engineering and construction industry for a 

factored estimate of this type is to apply indirect cost factors to the total direct cost. 

• EPA cost model factors for engineering, construction and field expenses and 

contingency are low relative to typical experience and practice in the engineering and 

construction industry for industrial construction of this type. Engineering costs and 

construction and field expense are each more typically 10-20%, of total direct cost. 

Industry practice would consider an estimate of this type to have an accuracy of no 

better than + 25%. Based on this, industry practice is to set contingency at 15-20% of 

total direct cost as a minimum. 

The above analysis indicates that there are currently no feasible VOC control 

technologies which offer a cost effectiveness less than EPA’s assumed threshold of 

$4,400 per ton. Therefore, there is no feasible RACT-level control exist for wine storage 

tanks. 
San Joaquin Valley Unified Air Pollution Control District 

Appendix K: RACT Analysis for W

Storage T

Appendix K-48 EPA Cost Model Table 7 Total Capital Investment for VOC Control on Wine Storage Tanks 

Non-Site Specific, No CIP (Cases 4 through 9) 

Control Device

Case 4 

Thermal Ox 

Assume CIP Cost 

Negligible

Case 5 

Catalytic Ox. 

Assume CIP Cost 

Negligible

Case 6 

RTO 

Assume CIP Cost 

Negligible

Case 7 

Refrigerated 

Condenser 

Assume CIP Cost 

Negligible

Case 8 

Water Scrubber

Assume CIP 

Cost Negligible

Direct Costs Purchased Equipment Costs 

Control Device $55,000 $77,300 $140,400 $260,500 $30,300 

Knock Out Vessels $5,000 $5,000 $5,000 $5,000 $5,000 

Ductwork $88,400 $88,400 $88,400 $88,400 $88,400 

Subtotal Equipment $148,400 $170,700 $233,800 $353,900 $123,700 Instrumentation $14,800 $17,100 $23,400 $35,400 $12,400 Sales Tax $11,900 $13,700 $18,700 $28,300 $9,900 Freight $7,400 $8,500 $11,700 $17,700 $6,200 Purchased Equipment Cost (PEC) $182,500 $210,000 $287,600 $435,300 $152,200 Direct Installation CostsFoundations and Supports $14,600 $16,800 $23,000 $34,800 $12,200 Handling & Erection $25,600 $29,400 $40,300 $60,900 $21,300 Electrical $7,300 $8,400 $11,500 $17,400 $6,100 Piping $3,700 $4,200 $5,800 $8,700 $3,000 Site Prep & MiscellaneousSite Prep $0 $0 $0 $0 $0 CIP System $0 $0 $0 $0 $0 Electrical Utility $0 $0 $0 $0 $0 Tank Modifications $16,000 $16,000 $16,000 $16,000 $16,000 Total Direct Costs $249,700 $284,800 $384,200 $573,100 $210,800 Indirect CostsEngineering $18,300 $21,000 $28,800 $43,500 $15,200 Construction & Field Expenses $9,100 $10,500 $14,400 $21,800 $7,600 Contractor Fees $18,300 $21,000 $28,800 $43,500 $15,200 Start Up $3,700 $4,200 $5,800 $8,700 $3,000 Performance Test $1,800 $2,100 $2,900 $4,400 $1,500 Contingencies $5,500 $6,300 $8,600 $13,100 $4,600 Total Indirect Costs $56,700 $65,100 $89,300 $135,000 $47,100 Total Capital Investment $488,900 $559,900 $761,100 $1,143,400 $410,100 
San Joaquin Valley Unified Air Pollution Control District 

Appendix K: RACT Analysis for W

Storage T

Appendix K-49 EPA Cost Model Table 8 Annual Costs for VOC Control on Wine Storage Tanks 

Non-Site Specific, No CIP (Cases 4 through 9) 

Control Device Case 4 Thermal Ox Case 5 Catalytic Ox. Case 6 RTO Case 7 Refrigerated Condenser Case 8 Water Scrubber Total Capital Investment $488,900 $559,900 $761,100 $1,143,400 $410,100 Direct Annual Costs Labor & Materials  Operating Labor (0.5 hr/shift-unit @  $12.95/hour) $7,100 $7,100 $7,100 $7,100 $7,100  Supervisor (15% of operator cost) $1,100 $1,100 $1,100 $1,100 $1,100  Operating Materials (15% of total  maintenance cost) $2,100 $2,100 $2,100 $2,100 $2,100  Maintenance Labor (0.5 hr/shift-unit@  $12.95/hour) $7,100 $7,100 $7,100 $7,100 $7,100  Maintenance Materials (100% of  maintenance labor) $7,100 $7,100 $7,100 $7,100 $7,100 Total Labor & Materials $24,500 $24,500 $24,500 $24,500 $24,500 Utilities  Natural Gas $126,000 $22,700 $6,300 $0 $0  Electricity $3,000 $3,000 $3,000 $3,000 $3,000  Water Disposal $0 $0 $0 $0 $0 Total Direct Annual Cost $153,500 $50,200 $33,800 $27,500 $27,500 Indirect Annual Costs  Overhead (60% of labor & Mat'ls) $14,700 $14,700 $14,700 $14,700 $14,700  Administrative Charges (2% of TCI) $9,800 $11,200 $15,200 $22,900 $8,200  Property Taxes (2% TCI) $9,800 $11,200 $15,200 $22,900 $8,200  Insurance (1% TCI) $4,900 $5,600 $7,600 $11,400 $4,100  Capital Recovery (CRF = 0.163) $79,700 $91,300 $124,100 $186,400 $66,800 Total Indirect Annual Cost $118,900 $134,000 $176,800 $258,300 $102,000 Total Annualized Cost $272,400 $184,200 $210,600 $285,800 $129,500 Emission Reductions 3.60 3.60 3.60 3.41 3.41 Cost Effectiveness $/ton $75,700 $51,200 $58,500 $83,800 $38,000 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-50 

VI. Cost Effectiveness and RACT Determination for Brandy Aging 

 A. Emission Control Technology For Control of Ethanol Emissions From Brandy 

Aging 

1. Background 

Brandy is prepared by distilling fermented grape juice and then aging the distilled product 

in wooden casks (usually oak) which colors it, mellows the palate, and adds additional 

aromas and flavors. The changes which occur during the aging process are the result of 

interactions between the aging brandy and the oak barrel, driven by the conditions of the 

surrounding atmosphere which may have both diurnal and seasonal variation. Both 

ethanol and water evaporate from the surface of the barrel during the aging process with 

the rate of evaporation (and the style of the brandy) depending upon both the porosity of 

the barrel and the atmospheric conditions of the storage among other factors. 

In the typical aging operation, the freshly distilled brandy is transferred to tankage where 

the proof is adjusted to approximately 100-120 proof by addition of water and then 

transferred to a gauging tank which is equipped with instrumentation to accurately 

determine the volume of the contents. The brandy is then transferred by batch into “lots” of 

oak barrels. The amount of brandy transferred into a “lot” of barrels is determined based on 

the difference between the starting and the ending volume of brandy in the gauging tank. 

The volume so determined is then corrected for temperature and proof content, using 

methods specified by the Alcohol and Tobacco Tax and Trade Bureau (TTB), U.S. 

Department of Treasury, to determine the number of proof-gallons transferred into the “lot” 

of barrels (a proof-gallon is one gallon of 100 proof brandy at 60 o

F). The “lot” of barrels is 

then placed into a warehouse for an average aging period of 2-3 years. 

After completion of the required aging period, the barrels are removed from the 

warehouse by “lot” and dumped into a gauging tank to determine the residual volume and 

proof in the “lot” of barrels. The result is corrected for temperature and proof to yield the 

number of residual proof-gallons in the “lot”. The difference between the proof-gallons 

filled and the residual proof-gallons is the loss to the atmosphere and is reported as 

proof-gallons lost per barrel-year. The filling and dumping of barrels to and from storage 

is rigidly controlled, metered, and reported for tax purposes, using the methods specified 

by the TTB. Depending upon aging practices, warehouse construction and site specific 

conditions, annual brandy losses may vary between 1.5 and 4.5 proof gallons per barrel, 

equivalent to a range of approximately 5 to 15 lb-ethanol/year-barrel. 

The US EPA’s RACT/BACT/LAER Clearinghouse (RBLC) database contains casespecific information on the "Best Available" air pollution technologies that have been 

required to reduce the emission of air pollutants from stationary sources (e.g., power 

plants, steel mills, chemical plants, etc.). This information has been provided by State 

and local permitting agencies. The RBLC contains no examples of controlling brandy 

aging emissions. Additional literature searches produced no examples of brandy aging 

emission control being implemented worldwide. 

The District has issued an Authority to Construct permit for one brandy aging facility 

which has been proposed for purposes of generating Certified Emission Reductions 

(CER’s) to offset required wine fermentation emission reductions required pursuant to the 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-51 

District’s Rule 4694, Wine Fermentation and Storage Tanks. The proposed facility will 

modify an existing brandy storage warehouse to capture ethanol emissions and destroy 

them using regenerative thermal oxidizer technology. However, the provisions of the 

permit requiring operation of the capture and control system are provisional, based upon 

successful demonstration that operation of the controls does not result in unacceptable 

impacts on brandy quality or consistency. 

A review of the emission mechanism for brandy aging and of the established VOC control 

technologies indicates that the following would be potentially applicable to the control of 

ethanol emissions from brandy aging operations: 

1. Oxidation (conversion of the VOC to CO2); 

2. Absorption (“scrubbers”, which transfer the VOC in air emissions to a liquid waste 

stream); 

3. Adsorption (often using activated carbon, which transfers the VOC in the air onto a 

solid substrate); 

4. Condensation (conversion of the VOC gases into liquids); and 

7. Biological control systems (e.g., bio-filters or bio-scrubbers) 

8. Modification of the aging warehouse and/or the aging operation to reduce the 

evaporative ethanol emissions. 

Review of the identified control technologies above indicates that options 1 through 5 are 

all classified as capture and control systems and therefore all share a common 

requirement for a capture system. Since the capture system is common to these options, 

issues regarding the installation of such a system on a brandy aging operation are also 

common and will thus be considered independent of the control technology selected. 

Each of the identified technologies, the common capture system and their potential 

application to brandy aging is discussed in the following: 

2. Emissions Capture System 

The brandy storage warehouse functions as an enclosure from which the ethanol 

emissions can be captured. The capture efficiency is primarily a function of the 

configuration of this structure. Since such a structure can be sealed and ventilated to a 

control device such that it qualifies as a “Total Enclosure” pursuant to U.S. EPA Method 

204, the theoretical capture efficiency would be considered to be 100%. However, since 

the brandy storage operation (and its emissions) is a continuous 24 hour/day operation 

throughout the year, it would be difficult and expensive to continuously maintain the 

warehouse in “Total Enclosure” status due to on-going requirements to transport product 

into and out of the warehouse and to requirements for maintenance during which the 

warehouse must be opened or the control device must be shut down. During such 

periods, uncontrolled emissions are delivered to the atmosphere in the absence of 

expensive air lock systems and/or redundant control devices. 

Based upon information supplied by industry, the District has determined that warehouse 

enclosures can potentially achieve a capture efficiency of 90% based on a warehouse 

designed to EPA Method 204 criteria for a “Total Enclosure” and appropriate allowances 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-52 

for time periods during which the enclosure does not qualify under Method 204 due to 

operational and maintenance issues. 

3. Thermal Oxidation (Incineration) 

A thermal oxidizer (TO) destroys VOCs by the process of combustion. A basic TO 

system consists of a combustion chamber, burner, stack, and combustion controls. All 

hydrocarbons are oxidized to carbon dioxide and water vapor by the proper mix of 

temperature, residence time and turbulence within the reactor chamber. Combustion of 

the contaminated gas stream occurs at high temperatures, normally 650o

C to 870oC 

(1,200o

F to 1,600oF) when treating low concentration streams. Recent guarantees 

provided by TO vendors for destruction of ethanol in air in other proposed projects under 

review by the District have been based on a minimum combustor temperature of 1,500o

F. 

TO systems can be divided into recuperative or regenerative systems, based on methods 

used to increase operating efficiencies by capturing heat from the combustion process. 

Recuperative TO systems increase fuel efficiency by use of a gas pre-heating section 

and a heat recovery section. Heat recovery can be as high as 70%. A regenerative 

system provides extremely high thermal-energy recovery; up to 95% of heat energy can 

be recovered. Regenerative TO systems use a ceramic heat-exchange bed to preheat 

process air to within 5% of the oxidation temperature. 

VOC conversion efficiencies range from 95% to 99.9% for TO systems. However, the 

combustion of supplemental fuel for the oxidation step (the amount depending upon the 

fuel value of the VOC and the level of heat recovery employed) produces NOx, an ozone 

precursor like VOC, thus offsetting some of the VOC emission reduction. The District 

considers thermal oxidation as technologically feasible for application to brandy storage 

and that a control efficiency of 95% is reasonably achievable which, when combined with 

an expected capture efficiency of 90%, yields an overall emission reduction of 86% for 

this technology. 

4. Catalytic Thermal Oxidation 

A catalytic thermal oxidizer (CTO) is essentially a thermal oxidation unit with a catalyst 

module. These units are similar in design to recuperative units, except that VOCs are 

oxidized using precious metal or metal-oxide-based catalysts instead of high 

temperature. Operating at about half the temperature of thermal oxidizers, catalytic units 

have smaller footprints and may offer lower operating costs in certain circumstances. 

Since catalyst are employed, they are subject to catalyst poisoning or deactivation due to 

operating upset and may require periodic catalyst replacement which represents a 

substantial operating cost. 

Other industries have demonstrated typical VOC removal efficiencies of up to 98%. The 

District considers catalytic thermal oxidation as technologically feasible for application to 

brandy storage and that a control efficiency of 95% is reasonably achievable which, when 

combined with an expected capture efficiency of 90%, yields an overall emission 

reduction of 86% for this technology. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-53 

 5. Adsorption Vapor Recovery 

Adsorption vapor recovery is accomplished by passing the VOC-laden gas through beds 

containing adsorbents that have a high surface area to weight ratio. Typical adsorbents 

are activated carbon, zeolite, or organic polymers. As the gas stream passes through the 

bed, organic compounds adsorb weakly onto the adsorbent’s surface. Adsorption of the 

hydrocarbon molecules proceeds until the available surface area is filled or saturated 

with VOC molecules. The VOC molecules are retained until the regeneration step, or 

disposal of the spent adsorbent. 

Desorbing or removing captured VOCs regenerates the adsorbent. Decreasing the 

pressure, reducing the hydrocarbon concentration around the adsorbent or increasing the 

temperature of the bed can perform regeneration. A combination of these steps can also 

be used for regeneration. There are three basic types of adsorption systems available to 

recover or remove hydrocarbon vapors from an air stream. Two of these systems 

regenerate the adsorbent in-situ for reuse. The third system requires removal of the 

adsorbent to another site for regeneration. 

The two systems that provide in-situ regeneration are: Pressure Swing Regenerated 

Systems and Thermally Regenerated Systems (or a combination of the two methods). 

Since the net result of the combined adsorption and regeneration process only results in 

transfer of the ethanol from the fermentation vent stream to another liquid or gaseous 

stream, further treatment of the effluent of the regeneration process is required to either 

destroy or recover the ethanol (typically thermal oxidation of the stripping gas stream or 

water treatment in the case of steam stripping). 

The District considers adsorption vapor recovery (with appropriate handling of 

regeneration waste streams) as technologically feasible for application to brandy aging. 

Based on a draft technical assessment document (TAD) prepared by ARB18, a control 

efficiency of 95% is considered reasonable for adsorption systems when controlling 

ethanol emissions from wine fermentation, a more demanding application due to the 

presence of large amounts of CO2. This efficiency, when combined with an expected 

capture efficiency of 90%, yields an overall emission reduction of 86% for this 

technology. 

6. Wet Scrubbing (Absorption) 

The basic process involved in wet scrubbing is the contact of a polluted gas stream with 

a liquid solution. During operation, gas flows upward through a column containing 

packing or other mass transfer media. The scrubbing liquid is delivered to the top of the 

column and flows down (by gravity) through the porous mass transfer media, generating 

a substantial interfacial surface area between the gas and liquid phases in a counterflow 

arrangement which provides optimal mass transfer. Gaseous contaminants are 

absorbed into the liquid and the decontaminated gas stream flows out of the scrubber. 

 

18 Strategies and Costs for Winery Ethanol Emission Control – Technical Assessment Document (Draft),August 6, 2003, p. 

34. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-54 

Many scrubbing applications achieve emission reduction efficiencies of 99.9%. In a pilot 

study19 conducted by ARB in 1987, wet scrubbing demonstrated greater than 90% 

reduction in ethanol emissions when operated for control of ethanol emissions from wine 

fermentation tanks.. The District considers wet scrubbing as technologically feasible for 

application to wine fermentation and that a control efficiency of 90% is reasonably 

achievable which, when combined with an expected capture efficiency of 90%, yields an 

overall emission reduction of 81% for this technology. 

7. Condensation, Refrigeration, and Cryogenic Systems 

Condensation, refrigeration, and cryogenic systems remove organic vapor by condensing 

the target gases on cold surfaces. These cold conditions can be created by passing cold 

water through an indirect heat exchanger, by spraying cold liquid into an open chamber 

with the gas stream, by using a refrigerant to create very cold coils, or by injecting 

cryogenic gases such as liquid nitrogen into the gas stream. The concentration of VOCs 

is reduced to the level equivalent to the vapor pressures of the compounds at the 

operating temperature. Removal efficiencies attainable with this approach depend 

strongly on the outlet gas temperature. For cold-water-based condensation systems, the 

outlet gas temperature is usually in the 40 to 50°F range, and the VOC removal 

efficiencies can be in the 90% to 99% range depending on the vapor pressures of the 

specific compounds. For refrigerant and cryogenic systems, the removal efficiencies can 

be considerably above 99% due to the extremely low vapor pressures of essentially all 

VOC compounds at the very low operating temperatures of -70°F to less than -200°F. 

Water vapor content in the gas stream may place a lower limit on the outlet gas 

temperature due to potential ice formation. 

The application of refrigerated condenser to the control of ethanol emissions from a 

fermentation tank was examined by ARB20. The results of that study indicated that a 90 

% ethanol recovery could be achieved at an outlet gas temperature of -12 0

F when 

controlling ethanol emissions from wine fermentation tanks. However, it was noted that 

ice formation could be a problem at this temperature and that special equipment designs 

would be required for reasonable operation. In addition, the ethanol is recovered in 

aqueous solution and must be further process for recovery of the ethanol. The District 

considers refrigerated condensation as technologically feasible for application to brandy 

aging and that a control efficiency of 90% is reasonably achievable which, when 

combined with an expected capture efficiency of 90%, yields an overall emission 

reduction of 81% for this technology. 

8. Biological Oxidation 

VOCs can be removed by forcing them to absorb into an aqueous liquid or moist media 

inoculated with microorganisms that consume the dissolved and/or adsorbed organic 

compounds. The control systems usually consist of an irrigated packed bed that hosts 

the microorganisms (biofilters). A presaturator is often placed ahead of the biological 

system to increase the gas stream relative humidity to more than 95%. The gas stream 

 

19 Nelson Chan, et. al, A suggested Control Measure for Control of Ethanol Emissions From Winery Fermentation Tanks. 

October 7, 1986 

20 Strategies and Costs for Winery Ethanol Emission Control – Technical Assessment Document (Draft),August 6, 2003, p. 

31. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-55 

temperatures are maintained at less than approximately 105°F to avoid harming the 

organisms and to prevent excessive moisture loss from the media. 

Biological oxidation systems are most often used for very low concentration VOC-laden 

gas streams for odor control. The VOC inlet concentrations are often less than 500 ppmv 

and sometimes less than 100 ppmv and achieve control efficiencies exceeding 95%. 

However, biofilters have been demonstrated21 in industrial applications achieving 90% 

control efficiency when controlling higher ethanol inlet concentrations (up to 3 g/1000 

m3

). The District considers biological oxidation to be technologically feasible for 

application to brandy aging and that a control efficiency of 90% is reasonably achievable 

which, when combined with an expected capture efficiency of 90%, yields an overall 

emission reduction of 81% for this technology. 

 9. Modification of the aging warehouse and/or the aging operation to reduce 

evaporative ethanol emissions 

Emission reduction could theoretically be achieved by a combination of atmospheric 

control in the storage warehouse and by barrel management practices. This is evidenced 

by a potential 300% variation in emission factors between different brandy aging 

operations in the San Joaquin Valley. However, warehouse and barrel management are 

the primary variables which are manipulated by the aging operation to produce specific 

style characteristics in each product. Since brandy is a consumer product whose 

consumer acceptance is heavily influenced by style issues, manipulation of these 

variables for the purpose of emission control would result in fundamentally changing the 

final product of the process, potentially leading to loss of both market share and 

competitive edge. Therefore, the District does not consider this approach as a 

technologically feasible approach and it will not be considered further. 

C. Cost Effectiveness for Brandy Aging 

1. Approach for Cost Effectiveness 

The following emission control technologies have been determined to be technologically 

feasible for control of VOC emissions from brandy aging operations: 

• Oxidation (86% control) 

• Refrigerated Condenser (81% control) 

• Wet Scrubber (81% control) 

• Carbon Adsorption (86% control) 

• Biofiltration 

Since “oxidation” includes recuperative and regenerative thermal oxidizers plus catalytic 

oxidizers, the cost effectiveness of the following cases will be examined for the 

determination of RACT for brandy aging: 

Case 1 Thermal oxidation with 0% heat recovery (low capital/high operating cost) 

Case 2 Catalytic oxidation with 50% heat recovery (mid range capital/mid range 

operating cost) 

 

21 J.S.Devinny, et.al.,Biofiltration for Air Pollution Control,CRC Press, Boca Raton, 1999, p. 235. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-56 

Case 3 Regenerative thermal oxidation with 95% heat recovery (high capital/low 

operating cost) 

Case 4 Refrigerated Condenser 

Case 5 Water scrubber 

Case 6 Carbon adsorption 

Case 6 Biofiltration 

The approach of the cost effectiveness analysis will be to first determine which, if any, of 

the above cases potentially qualifies as RACT based on having a potential cost 

effectiveness below EPA’s assumed RACT threshold of $4,400/ton of VOC. Cases which 

are shown to have a cost effectiveness higher than $4,400/ton will be discarded. Cases 

which fall below the threshold will be considered potential candidates for RACT and will 

then be further examined and compared with respect to relative cost effectiveness, 

technical risk, reasonableness, and socio-economic impact to determine which, if any, 

actually qualify as RACT for brandy aging. 

2. Estimating Approach and Basis 

The approach for cost effectiveness determination will be based on the following 

elements: 

• EPA’s cost model for VOC incineration systems, as presented in the EPA Control Cost 

Manual, Section 3.2, Tables 2.8 and 2.9, was used for all capture and control cases 

with the exception of the refrigerated condenser (case 7) estimate which used Section 

3.1, Table 2.3 for Total Capital Investment (note also that the EPA cost model was 

adjusted to a California location by taking sales tax at 8% rather than 3%). 

• All estimates are based on a warehouse ventilation rate of 10,000 scfm based on 

industry estimates of the required ventilation rate for a large brandy storage 

warehouse in the San Joaquin Valley with a storage capacity of 161,500 barrels. The 

ethanol emission factor will be assumed to be the minimum within the typical range 

(1.5 proof gallons loss per barrel-year) to determine the maximum value of cost 

effectiveness (least cost effective) for this warehouse configuration (consideration of 

higher emission factors will result in lower values – more cost effective). 

• Potential uncontrolled emissions are 401 tons-VOC/year for an annual brandy loss of 

1.5 proof gallons per barrel based on a storage capacity of 161,000 barrels and a 

factor of 3.31 lb-ethanol/proof gallon. 

• Each case is assumed to have the same requirements for collection ducting from the 

warehouse to the control device which is based on a warehouse of approximately 

156,000 square feet, consistent with a ventilation rate of 10,000 scfm. The ducting is 

estimated to consist of 1,290 linear feet of collection ductwork within the warehouse 

with an average diameter of 12 inches plus 450 linear feet of main header ducting with 

a diameter of 25 inches. 

• Purchased costs for ducting were taken from the EPA Control Cost Manual, Section 2, 

Chapter 1 and corrected to 1st quarter 2007 by assuming average 3% annual inflation. 

• Each case is assumed to have the same requirements for warehouse modifications 

for compliance with EPA Method 204. Allowances of $30,000 and $10,000 were 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-57 

placed in the estimate for installation of automated doors and miscellaneous building 

modifications respectively. 

• Potential site specific costs such as site preparation, electric utility expansion and 

natural gas utility expansion were optimistically ignored. 

• Power consumption by the induced draft fan is common to all cases and is based on 

an induced draft fan rated at 10,000 scfm, 10 inches water column static pressure 

differential, and a fan efficiency of 65%. 

• Total Capital Investment was annualized based on a 10 year equipment life and a 10% 

opportunity cost for capital (CRF = 0.163). 

• Pricing for natural gas and electricity were applied at $0.61/therm and $0.12/kwh 

based on current prices reported by Gallo for these items at their Livingston winery. 

3. Cost Effectiveness Analysis for Brandy Aging Operations 

Case 1 - Collection and Control with a Thermal Oxidizer

Capital investment for this case as well as all other capture and control cases is presented 

in Table 9. Annual costs, emission reductions and calculated cost effectiveness are 

presented in Table 10. The thermal oxidizer for this case was priced from the EPA Control 

Cost Manual, Section 3.2, Figure 2.4, based on a 10,000 scfm unit with 0% energy 

recovery. As such, it represents a minimum capital investment scenario for use of a 

thermal oxidizer. The price from Figure 2.4 (1990 dollars) was adjusted to 2007 dollars 

based on average annual inflation of 3%. 

Annual fuel costs are based on an industry estimate of 3.2 billion Btu/year (32,000 

therms/yr) for a facility of this size with 95% heat recovery (approximately 50% of 

theoretical fuel consumption when not allowing for heating value of ethanol). This was 

divided by 0.05 to convert it to an expected fuel consumption of 640,000 therms/year for 

this zero heat recovery case. 

With an expected collection and control efficiency of 86%, cost effectiveness of this 

control option is estimated at $1,700 per ton. 

Case 2 - Collection and Control with a Catalytic Oxidizer

The catalytic oxidizer for this case was priced from the EPA Control Cost Manual, Section 

3.2, Figure 2.6, based on a 10,000 scfm unit with 50% energy recovery. As such, it 

represents a mid range capital investment scenario for use of oxidizer technology. The 

price from Figure 2.4 (1990 dollars) was adjusted to 2007 dollars based on average 

annual inflation of 3%. 

Annual fuel cost for this case was calculated based on applying a 50% heat recovery 

factor to the zero heat recovery case of 640,000 therms. 

No allowance was applied for potential catalyst replacements during the 10 year 

equipment life. 

With an expected collection and control efficiency of 86%, cost effectiveness of this 

control option is estimated at $1,000 per ton. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-58 

Case 3 - Collection and Control with a Regenerative Thermal Oxidizer (RTO)

The RTO for this case was priced from the EPA Control Cost Manual, Section 3.2, Figure 

2.5, based on a 10,000 scfm unit with 95% energy recovery. As such, it represents a high 

range capital investment scenario for use of oxidizer technology. The price from Figure 

2.5 (1999 dollars) was adjusted to 2007 dollars based on average annual inflation of 3%. 

The industry estimate of 3.2 billion Btu/year (32,000 therms/yr) for a facility of this size 

with 95% heat recovery (approximately 50% of theoretical fuel consumption when not 

allowing for heating value of ethanol) was used for annual fuel cost. 

With an expected collection and control efficiency of 86%, cost effectiveness of this 

control option is estimated at $1,200 per ton. 

Case 4 - Collection and Control with a Refrigerated Condenser

It was assumed that the refrigerated condenser would operate at a condensing 

temperature of –12 o

F and achieve a 90% collection and control based on the TAD. The 

refrigerated condenser duty for this case was determined to be 78.6 tons of refrigeration 

and was priced based on the EPA Control Cost Manual, Section 3.1, Figure 2.5, based on 

a –20 oF refrigerant condensing temperature. The price from Figure 2.5 (1990 dollars) was 

adjusted to 2007 dollars based on average annual inflation of 3%. 

Electric power costs for operation of the refrigeration were estimated at 1.54 kw/ton. 

With an expected collection and control efficiency of 90%, cost effectiveness of this 

control option is estimated at $1,300 per ton. 

Case 5 - Collection and Control with a Water Scrubber

The water scrubber for this case was priced based on vendor quotations obtained from a 

study of the application of the application of water scrubbers to the control of ethanol 

emissions from wine fermentation tanks by Sonoma Technology, Incorporated (STI)22. 

The STI study presented prices for scrubber with capacities of 500 scfm and 5000 scfm. 

These prices were extrapolated with a consistent exponent factor to determine the price of 

a 10,000 scfm unit. The price derived from the STI data (2003 dollars) was adjusted to 

2007 dollars based on average annual inflation of 3%. 

Water disposal costs for this case were also taken from the STI study. Using the STI 

assumptions, water disposal requirements were taken to be 6 gallons per minute for each 

5,000 cfm of flow with a disposal cost of $0.25/gallon. 

With an expected collection and control efficiency of 81%, cost effectiveness of this 

control option is estimated at $5,300 per ton. 

Case 6 - Collection and Control with Carbon Adsorption

The carbon adsorption system for this case was priced based on pricing presented in the 

Technical Assessment Document (TAD)23 for activated carbon adsorption systems 

including carbon canisters, blower, and regeneration system. Prices from the TAD were 

 

22 Control Technology Evaluation: Wineries – Fermentation Processes, Sonoma Technologies, Inc., October 21, 2003. 

23 Strategies and Costs for Winery Ethanol Emission Control – Technical Assessment Document (Draft),August 6, 2003, p. 

77. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-59 

interpolated to determine the price of a 10,000 scfm unit. The price derived from the TAD 

(1991 dollars) was adjusted to 2007 dollars based on average annual inflation of 3%. 

Utility costs for operation of the carbon regeneration system were also included in the 

analysis based on the TAD. Per unit values derived from that document, combined costs 

for steam and cooling water used for regeneration were determined to be $99.63/tonethanol. 

Water disposal cost resulting from carbon regeneration were calculated at $175 per ton of 

ethanol emission reduction based on unit values derived from the TAD and the water 

disposal cost of $0.25 per gallon from the TAD. 

With an expected collection and control efficiency of 86%, cost effectiveness of this 

control option is optimistically estimated at $1,300 per ton. 

Case 7 - Collection and Control with Biofiltration

The biofilter size for this case was determined to be 315 cubic meters based on the size 

of another 10,000 scfm unit presented by Devinney24. Per Devinney, biofilter reactor costs 

range from $1,000 to $3,500 per cubic meter25. An average cost of $2,250 per cubic 

meter (1997 cost) was used and was adjusted to 2007 dollars based on average annual 

inflation of 3%. 

Potential water injection costs for humidification of the biofilter were ignored. 

With an expected collection and control efficiency of 81%, cost effectiveness of this 

control option is estimated at $2,300 per ton. 

4. Cost Effectiveness Summary for Brandy Storage 

The seven cases examined yielded evaluated cost effectiveness values ranging from 

$1,000 per ton for catalytic oxidizer control technology to $5,300 per ton for a water 

scrubber. All cases evaluated lie below the EPA’s assumed RACT threshold of $4,400/ton 

with the exception of the water scrubber technology which is only marginally above the 

threshold, primarily due to the costs associated with water disposal. Although these 

values appear to be economically reasonable in comparison with the $4,400 per ton 

threshold generally established by EPA for sources subject to existing CTGs, the District 

believes that there is no feasible RACT-level control because the control technology has 

not yet been installed, operated and evaluated. As stated above, the brandy facility 

operator was recently issued an Authority to Construct permit by the District. As such, 

control of brandy aging emissions could not be considered as achieved in practice at this 

time until after a few years when it can be determined that there would be no adverse 

impacts on aging operation and most importantly on the quality or consistency of the 

product. 

Factors which might increase the evaluated cost effectiveness (less cost effective) are: 

• Site specific costs for site preparation, electricity or fuel gas supply were ignored. 

 

24 Devinney, et.al., p. 236. 

25 Devinney, et.al., p. 175. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

 Appendix K: RACT Analysis for Wine Fermentation, Wine 

Storage Tanks, and Brandy Aging 

2007 Ozone Plan

Appendix K-60 

• The EPA cost model only applies factors for engineering, construction and field 

expense, contractor fees and contingency to the purchased equipment costs rather 

than the total direct cost. Since other direct costs such as foundations and supports, 

electrical and piping all have a substantial indirect cost, these costs are ignored in this 

evaluation. Standard practice in the engineering and construction industry for a 

factored estimate of this type is to apply indirect cost factors to the total direct cost. 

• EPA cost model factors for engineering, construction and field expenses and 

contingency are low relative to typical experience and practice in the engineering and 

construction industry for industrial construction of this type. Engineering costs and 

construction and field expense are each more typically 10-20%, of total direct cost. 

Industry practice would consider an estimate of this type to have an accuracy of no 

better than + 25%. Based on this, industry practice is to set contingency at 15-20% of 

total direct cost as a minimum. 

Factors which might decrease the evaluated cost effectiveness (more cost effective) are: 

• The evaluation is based on the lower range of emission factors for ethanol loss. Use of 

an average emission factor would make all options more cost effective. 

• The capital cost is based on the larger end of the expected range of warehouse 

storage capacities. Use of a more average size facility (smaller facility) with more 

average emission factors (higher emission factors) would make all cases more cost 

effective. 
San Joaquin Valley Unified Air Pollution Control District 

Appendix K: RACT Analysis for W

Storage T

Appendix K-61 EPA Cost Model Table 9 Total Capital Investment for VOC Control on Brandy Storage Operations Control Device 

Case 1 

Thermal Ox 

Case 2 

Catalytic Ox. 

Case 3 

RTO 

Case 4 

Refrigerated 

Condenser 

Case 5 

Water Scrubber 

Carbo

Direct Costs Purchased Equipment Costs 

Control Device $114,100 $261,400 $425,900 $267,800 $65,900 

Knock Out Vessels $0 $0 $0 $0 $0 

Ductwork $46,900 $46,900 $46,900 $46,900 $46,900 

Subtotal Equipment $161,000 $308,300 $472,800 $314,700 $112,800 Instrumentation $16,100 $30,800 $47,300 $31,500 $11,300 Sales Tax $12,900 $24,700 $37,800 $25,200 $9,000 Freight $8,100 $15,400 $23,600 $15,700 $5,600 Purchased Equipment Cost (PEC) $198,100 $379,200 $581,500 $387,100 $138,700 Direct Installation CostsFoundations and Supports $15,800 $30,300 $46,500 $31,000 $11,100 Handling & Erection $27,700 $53,100 $81,400 $54,200 $19,400 Electrical $7,900 $15,200 $23,300 $15,500 $5,500 Piping $4,000 $7,600 $11,600 $7,700 $2,800 Site Prep & MiscellaneousAutomated Doors (2) $30,000 $30,000 $30,000 $30,000 $30,000 Warehouse Modifications $10,000 $10,000 $10,000 $10,000 $10,000 Total Direct Costs $293,500 $525,400 $784,300 $535,500 $217,500 Indirect CostsEngineering $19,800 $37,900 $58,200 $38,700 $13,900 Construction & Field Expenses $9,900 $19,000 $29,100 $19,400 $6,900 Contractor Fees $19,800 $37,900 $58,200 $38,700 $13,900 Start Up $4,000 $7,600 $11,600 $7,700 $2,800 Performance Test $2,000 $3,800 $5,800 $3,900 $1,400 Contingencies $5,900 $11,400 $17,400 $11,600 $4,200 Total Indirect Costs $61,400 $117,600 $180,300 $120,000 $43,100 Total Capital Investment $553,000 $1,022,200 $1,546,100 $1,042,600 $399,300 
San Joaquin Valley Unified Air Pollution Control District 

Appendix K: RACT Analysis for W

Storage T

Appendix K-62 EPA Cost Model Table 10 Annual Costs for VOC Control on Brandy Storage OperationsControl Device Case 1 Thermal Ox Case 2 Catalytic Ox. Case 3 RTO Case 4 Refrigerated Condenser Case 5 Water Scrubber 

Carbo

Total Capital Investment $553,000 $1,022,200 $1,546,100 $1,042,600 $399,300 Direct Annual Costs Labor & Materials 

Operating Labor (0.5 hr/shiftunit @ $12.95/hour) $7,100 $7,100 $7,100 $7,100 $7,100 Supervisor (15% of operator cost) $1,100 $1,100 $1,100 $1,100 $1,100 Operating Materials (15% of total maintenance cost) $2,100 $2,100 $2,100 $2,100 $2,100 Maintenance Labor (0.5 hr/shift-unit@ $12.95/hour) $7,100 $7,100 $7,100 $7,100 $7,100 Maintenance Materials (100% of maintenance labor) $7,100 $7,100 $7,100 $7,100 $7,100 

 Total Labor & Materials $24,500 $24,500 $24,500 $24,500 $24,500 Utilities  Natural Gas $390,400 $72,300 $19,520 $0 $0  Electricity $22,300 $22,300 $22,300 $149,400 $22,300  Carbon Regeneration $0 $0 $0 $0 $0 

Water Disposal $0 $0 $0 $0 $1,576,800 

Total Direct Annual Cost $437,200 $119,100 $66,320 $173,900 $1,623,600 Indirect Annual Costs 

Overhead (60% of labor & Mat'ls) $14,700 $14,700 $14,700 $14,700 $14,700 Administrative Charges (2% of TCI) $11,100 $20,400 $30,900 $20,900 $8,000 Property Taxes (2% TCI) $11,100 $20,400 $30,900 $20,900 $8,000 

 Insurance (1% TCI) $5,500 $10,200 $15,500 $10,400 $4,000 

Capital Recovery (CRF = 0.163) $90,100 $166,600 $252,000 $169,900 $65,100 

Total Indirect Annual Cost $132,500 $232,300 $344,000 $236,800 $99,800 Total Annualized Cost $569,700 $351,400 $410,320 $410,700 $1,723,400  Emission Reductions 344.79 344.79 344.79 324.75 324.75 Cost Effectiveness $/ton $1,700 $1,000 $1,200 $1,300 $5,300