SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 17, 2009 

B-1 Final Staff Report with Appendices 

for Rule 4695

APPENDIX B 

EMISSION REDUCTION ANALYSIS 

FOR RULE 4695 

September 17, 2009 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 17, 2009 

B-2 Final Staff Report with Appendices 

for Rule 4695 

This page intentionally left blank. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 17, 2009 

B-3 Final Staff Report with Appendices 

for Rule 4695 

APPENDIX B 

Emission Reduction Analysis 

I. SUMMARY 

This appendix details the estimated volatile organic compounds (VOC) emission 

reductions for the controls proposed in the proposed Rule 4695 (Brandy Aging and Wine 

Aging). 

The 2007 Ozone Plan estimates a 2012 brandy and wine VOC emission baseline of 2.30 

tons per day. This baseline accounts for a total of 4.5 tons per day of reductions from 

facilities that are part of alternative compliance options for Rule 4694 (Wine Fermentation 

and Storage Tanks). Those reductions are SIP creditable to previous 1-Hour Ozone Plan 

commitments) for the Brandy and Wine Aging (S-IND-14) control measure. Approximately 

98 percent of the brandy aging emissions in the San Joaquin Valley (four facilities) are 

already controlled in accordance with the requirements of this rule. 

Implementation of this rule is expected to require emission controls on one additional 

brandy aging facility, resulting in an annual emission reduction of 0.12 tons per day 

attributable to this rule for brandy aging. The wine aging RACT emission controls are 

considered to be currently achieved in practice at the affected facilities so no additional 

emission reductions would accrue from those requirements. 

II. BACKGROUND 

District staff is proposing to implement VOC control requirements for Major Sources, 

i.e., facilities with a Stationary Source Potential to Emit of 10 tons per year or more, 

which conduct brandy aging and wine aging operations. The particular level of control 

required for the aging operation depends on the level of emissions from the operations, 

not from the total emissions from the Stationary Source. 

III. EMISSION REDUCTION ANALYSIS 

Reductions from Brandy Aging 

Based on the District’s survey, there is currently only one larger brandy aging operation 

in the District which does not have BARCT VOC emission controls pursuant to this rule. 

Based on information provided by that facility, the District has determined that this 

operation currently has Uncontrolled Aging Emissions (UAE) of 47.3 tons per year or 

0.13 tons per day. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 17, 2009 

B-4 Final Staff Report with Appendices 

for Rule 4695 

The following equation was used to calculate the facility’s UAE. 

UAE = TAAI * AEF 

Where: 

UAE = Uncontrolled Aging Emissions, in pounds of ethanol per year. 

TAAI = Total Annual Aging Inventory, in gallons of brandy per year. 

AEF = Aging Emission Factor, in pounds of ethanol per gallon of brandy. 

Brandy AEF = 3 proof gallons loss/50 gallon barrel x 0.5 gallons ethanol/ proof 

gallons x 6.616 lb ethanol/gallon. 

The brandy AEF uses the 3 proof gallons loss/50 gallon barrel as the default value. This 

value is after warehouse refrigeration and is accepted by the industry and is used by the 

District in the permitting process. 

Reductions from Wine Aging

Per the District’s survey there are a number of uncontrolled wine aging operations in the 

District. The survey includes both barrel aging operations and large wooden storage 

tanks located at wineries. The basis and assumptions for estimating emissions from 

these sources are as follows: 

Annual emissions from wine aging (tons per year) = (L x I x P x D) ÷ 2,000 lb/ton 

Where 

L = Percentage wine loss per year (assumed to be 3%, as discussed in the 

Staff Report) 

I = Average annual wine aging inventory, in gallons (2007 year data) 

P = Average ethanol content of the aged wine: 

(For wines with <14% Alcohol by Volume (ABV), P = 14%; 

 For wines with >14% ABV, P = 19%) 

D = Density of pure ethanol 6.6 in lb/gallon 

Table 1, below, shows the results of applying the above formula to the various wine 

aging operations in the Valley. As explained elsewhere in the Staff Report, all facilities 

are expected to be in compliance with the RACT and Additional RACT requirements of 

this rule so no additional emission reductions will result from those requirements. Also, 

the addition of BARCT level controls was deemed to be too costly so no additional 

BARCT controls will be required and no additional emission reductions will be 

generated from wine aging operations. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 17, 2009 

B-5 Final Staff Report with Appendices 

for Rule 4695 

Table 1 – Fugitive VOC Emissions from Wine Aging for 2007. 

Facility 

No. 

Gallons 

Stored 

<14% ABV 

Gallons 

Stored 

>14% ABV 

Total 

Gallons 

Emissions 

<14% tpy 

Emissions 

>14% tpy 

Emissions 

Facility tpy 

*1 1,770,000 0 1,770,000 11.45 0 11.45

2 0 198,900 198,900 0 3.75 3.75

3 0 193,000 193,000 0 3.65 3.65

4 104,460 46,860 151,320 1.45 0.9 2.35

5 113,687 18,916 132,603 1.6 0.35 1.95

6 20,000 60,000 80,000 0.3 1.15 1.45

7 46,728 23,364 70,092 0.65 0.45 1.1

8 13,629 45,002 58,631 0.2 0.85 1.05

9 1,475 45,525 47,000 0 0.85 0.85

10 0 14,800 14,800 0 0.3 0.3

11 8,500 6,200 14,700 0.1 0.1 0.2

12 1,379 8,917 10,296 0 0.15 0.15

13 6,000 4,000 10,000 0.1 0.1 0.2

14 6,608 767 7,375 0.1 0 0.1

15 3,120 0 3,120 0.05 0 0.05

16 1,500 1,500 3,000 0.02 0.03 0.05

17 0 2,459 2,459 0 0.05 0.05

18 710 270 980 0 0 0

19 120 600 720 0 0 0

20 320 320 640 0 0 0

21 0 250 250 0 0 0

22 180 0 180 0 0 0

Totals 2,098,416 671,650 2770066 16.02 12.68 28.70

* Using stakeholder evaporative loss rate of 1.4% by volume, all others use 3% by volume. 

Reductions from Brandy Aging

Summarizing the expected and calculated emission reduction from BARCT: 

A. Emission Reductions = current emissions x implementation control efficiency. 

B. Implementation Control Efficiency (90%) = 92% PTE criteria x 98% control 

efficiency 

Therefore, 

Emission Reduction from Brandy Aging = 47.3 tons/year x 90% 

= 42.6 tons per year 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 17, 2009 

B-6 Final Staff Report with Appendices 

for Rule 4695 

Emission Reduction from Wine Aging will be zero because all facilities are already 

complying with RACT or and Additional RACT level control requirements. Therefore, as 

seen in Table 2, emission reductions associated with Rule 4695 will be 0.12 tons per 

day. 

Table 2 Emission Reductions for Rule 4695 

Emission Reductions 

Operation 

Tons per Year Tons per Day 

Brandy Aging 42.6 0.12 

Wine Aging 0 0 

Total 42.6 0.12