SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix F: Alternative Emission Reductions for Rule 4694 December 15, 2005

F

- 1 Final Staff Report with Appendices

For Revised Proposed Rule 4694 

# APPENDIX F

Rule Consistency Analysis For

RULE 4694 (Wine Fermentation and Storage Tanks)

December 15, 2005SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix F: Rule Consistency Analysis for Rule 4694 Decem ber 15, 2005

F

- 2 Final Staff Report with Appendices

For Revised Proposed Rule 4694 RULE CONSISTENCY ANALYSIS FOR PROPOSED RULE 4694

I. REQUIREMENTS FOR RULE CONSISTENCY ANALYSIS

Pursuant to Section 40 727.2 of the California Health and Safety Code, prior to adopting

or amending a rule or regulation, the District is required to perform a written analysis

that identifies and compares the air pollution control elements of the rule with the

corresponding el ements of existing or proposed District and EPA regulations and

guidelines that apply to the source category. The rule elements that were analyzed are

emission limits, monitoring and testing, and recordkeeping and reporting requirements.

II. RULE CONSIST ENCY ANALYSIS RESULTS

A. SJVUAPCD Rules

Rule 4694 limits the emission of volatile organic compounds (VOC) from wine

fermentation tanks and tanks used for bulk storage of wine. No other District rules

existing or proposed, subject the source categories t o the same requirements of Rule

4694. Units subject to Rule 4694 could also be subject to other District rules including

Rule 2010 (Permits Required), Rule 2201 (New and Modified Stationary Source Review

Rule), and Rule 4102 (Nuisance).

B. Federal Rules and Regulations

1. Federal New Source Performance Standards (NSPS)

The federal NSPS were reviewed. No NSPS specific to wineries, or wine fermentation,

or bulk

- wine storage tanks were found. Subpart Kb

- Standards of Performance for

Volatile Organic Liqui d Storage Vessels (Including Petroleum Liquid Storage Vessels)

for Which Construction, Reconstruction, or Modification Commenced After July 23,

1984, was reviewed and determined to be not applicable to the tanks subject to Rule

4694. Specifically, Section 60.110b would exempt tanks storing bulk wine because the

combination of tank size and vapor pressure of stored bulk wine would meet the

exemption criteria.

2. Federal Control Technique Guidance Document (CTG), National Emissions

Standards for Hazardous A ir Pollutants (NESHAP), and Maximum Achievable

Performance Standards (MACT)

Ethanol is the primary air pollutant from wine fermentation. Wine also contains three

hazardous air pollutants: acetaldehyde, hydrogen sulfide, and methanol. No NESHAP

was found for ethanol, or the listed hazardous air pollutants. No CTG or MACT was

found for control of wine fermentation emissions, or emissions from bulk

- wine storage

tanks.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix F: Rule Consistency Analysis for Rule 4694 Decem ber 15, 2005

F

- 3 Final Staff Report with Appendices

For Revised Proposed Rule 4694 3. EPA Policy on Record Keeping

The recordkeeping requirements in Rule 4694 are consiste nt with EPA’s policy to keep

and maintain records for at least five years.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix F: Rule Consistency Analysis for Rule 4694 Decem ber 15, 2005

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- 4 Final Staff Report with Appendices

For Revised Proposed Rule 4694 This page intentionally blank