SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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, 2009SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 DI STRICT

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 organi c compounds (VOC) emission reductions for the controls proposed in the propose d Rule 4695 (Brandy Aging and Wine Aging).

The 2007 Ozone Plan estimates a 2012 brandy and win e VOC emission baseline of 2.30 tons per day. This baseline accounts for a total o f 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 credi table to previous 1-Hour Ozone Plan commitments) for the Brandy and Wine Aging (S-IND-1 4) control measure. Approximately 98 percent of the brandy aging emissions in the San Joaquin Valley (four facilities) are already controlled in accordance with the requireme nts of this rule.

Implementation of this rule is expected to require emission controls on one additional brandy aging facility, resulting in an annual emiss ion reduction of 0.12 tons per day attributable to this rule for brandy aging. The win e 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 require ments.

II. BACKGROUND

District staff is proposing to implement VOC contro l 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 operation s. The particular level of control required for the aging operation depends on the lev el of emissions from the operations, not from the total emissions from the Stationary So urce.

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 emiss ion controls pursuant to this rule. Based on information provided by that facility, the District has determined that this operation currently has Uncontrolled Aging Emission s (UAE) of 47.3 tons per year or 0.13 tons per day.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 fa cility’s UAE.

UAE = TAAI * AEF

Where: UAE = Uncontrolled Aging Emissions, in pounds of e thanol 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 gal lon barrel as the default value. This value is after warehouse refrigeration and is accep ted 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 unc ontrolled wine aging operations in the District. The survey includes both barrel aging op erations and large wooden storage tanks located at wineries. The basis and assumptio ns 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 gallo ns (2007 year data) P = Average ethanol content of the aged wine: (For wines with <14% Alcohol by Volume (ABV), P = 1 4%; 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 a bove formula to the various wine aging operations in the Valley. As explained else where 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 e mission reductions will be generated from wine aging operations.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 fo r 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% b y volume, all others use 3% by volume.

Reductions from Brandy Aging

Summarizing the expected and calculated emission re duction from BARCT:

A. Emission Reductions = current emissions x im plementation 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 yearSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 bec ause all facilities are already complying with RACT or and Additional RACT level co ntrol requirements. Therefore, as
seen in Table 2, emission reductions associated wit h 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