SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

FINAL STAFF REPORT

Rule 4695 (Brandy Aging and Wine Aging Operations)

September 17, 2009

Prepared by: Peter Biscay, Air Quality Specialist

Reviewed by: Scott VanDyken, Air Quality Inspector Lori Sheridan, Air Quality Inspector Colette Kincaid, Senior Air Quality Specialist Dennis Roberts, Senior Air Quality Engineer Joe Nazareno, Senior Air Quality Engineer George Heinen, Supervising Air Quality Engineer Mike Oldershaw, Air Quality Compliance Manager Errol Villegas, Planning Manager Scott Nester, Director of Planning

I. SUMMARY

A. Reasons for Rule Development and Implementation

The California Air Resources Board (ARB) and United States Environmental Protection Agency (EPA) classified the San Joaquin Valley Air Basin (SJVAB) as a severe and

serious non-attainment area for the state and feder al ozone standards, respectively. In accordance with Federal Clean Air Act (CAA) require ments for non-attainment areas, the San Joaquin Valley Unified Air Pollution Contro l District (District) adopted the 2007 Ozone Plan to establish the strategy for attaining the federal eight-hour ozone standard. That plan is comprised of regulatory and incentive- based measures to reduce emissions of nitrogen oxides (NOx) and volatile organic compo unds (VOC), which are the precursors to ground-level ozone.

The 2007 Ozone Plan contains a commitment to develo p a control measure for VOC emissions from brandy aging and wine aging operatio ns. Emission controls have already been installed on most of the large brandy aging operations as an emission reduction measure to comply with the requirements o f Rule 4694 (Wine Fermentation and Storage Tanks), to which these emission reducti ons are credited. In addition to controlling VOC emissions from brandy aging operati ons, this control measure would require Reasonably Available Control Technology (RA CT) controls on wine aging operations at Major Sources.

As stated in the 2007 Ozone Plan possible cost effe ctive emission reductions could be achieved for brandy aging through adding emission c ontrol technologies. SuchSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 additional technologies are considered to be beyond RACT but are not yet achieved in practice for these operations. After a more extend ed operational period and a determination that there would be no adverse impact on either the aging operation or the quality or consistency of the product, the Dist rict may revisit this for Best Available Control Technology (BACT) for new or modified sourc es. The identified control technologies are considered to be applicable to the aging of wine as well as to brandy since the basic process of aging in wooden tanks or barrels in a warehouse is very similar. Major differences exist in the level of e missions, between the two operations and the impact of this difference on technology tra nsfer as examined by this project.

The adopted rule fulfills the District’s 2007 Ozone Plan commitment for control measure S-IND-14 (Aging of Brandy and Wine) in an effective , practicable, technologically feasible, and economically reasonable method, as de termined by the District’s Governing Board. This rule also satisfies SIP comm itments with the requirement of emission controls which help produce Reasonable Fur ther Progress (RFP) for the Attainment Demonstration; reduces emissions that ar e quantifiable, surplus, real, and enforceable; and satisfies the federal requirement to design a plan to achieve ozone

attainment.

B. Climate Change

The California Global Warming Solutions Act of 2006 (AB 32) created a comprehensive, multi-year program to reduce greenhouse gas (GHG) emissions in California, with the overall goal of restoring emissions to 1990 levels by the year 2020. In the coming years, ARB and the Legislature will be developing p olicies and programs to implement

AB32.

The District believes that the evidence and the rat ionale that climate change is occurring is compelling and convincing. In addition to the l ong-term consequences of climate change, the District is concerned with the potentia l ramifications of more moderate but imminent changes in weather patterns. The Valley d epends heavily on agriculture for its economy. Unanticipated and large fluctuations in these patterns could have a devastating effect on the Valley’s economy.

While there are many win-win strategies that can re duce both GHG and criteria/toxic pollutant emissions, when faced with situations tha t involve tradeoffs between the two, District staff believes that the more immediate pub lic health concerns that may arise from criteria or toxic pollutant emissions should t ake precedence.

C. Description of the Project

This rule codifies the requirement for Best Availab le Retrofit Control Technology (BARCT) and Reasonably Available Control Technology (RACT) VOC emission controls and management practices which have been employed b y wine fermentation operators under Rule 4694’s alternative emission reduction op tion. This rule specifies RACT forSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 major sources as the means to achieve the maximum a mount of VOC emission reductions by using control technologies that are r easonably available. Any VOC emissions reduction from the control of brandy agin g have already been accounted for by Rule 4694 and are not considered to be additive for SIP purposes.

This rule applies to all brandy aging and wine agin g facilities but exempts those facilities which have a Stationary Source Potential to Emit of less than 10 tons per year since they are not Major Sources. The federal Clean Air Act (CAA) requires all operations at Major Sources to have RACT, so controls for aging o perations at those facilities are included in the rule, regardless of the size of the aging operation, as long as it is conducted at a Major Source. Separate thresholds f or brandy aging and wine aging operations were determined based on operating chara cteristics, emissions, and a cost effectiveness analysis.

Existing brandy aging control systems have been ins talled and operating on four warehouses for almost two years, but, due to the br andy aging process length, this is not sufficient time to judge the impact of the cont rols on operations and product quality. Therefore, the compliance date has been set to allo w for time to reexamine rule requirements if operational or product quality issu es are deemed to be seriously

detrimental. District staff reviewed rules from ot her air districts in California, gathered

information from the Federal Alcohol and Tobacco Ta x and Trade Bureau, the Wine Institute, and from individual stakeholders to serv e as guidance and as information sources for rule development. District staff found that, at this time, there are no air districts in the nation that have regulations to co ntrol VOC emissions from brandy aging and wine aging operations.

The District staff understands that the nature of w hiskey aging operations differs from wine and brandy aging. Specifically, the ambient c onditions, such as storage temperature and humidity, as well as seasonal varia tions, are important factors in the whiskey aging process. All aging processes, depen ds upon the interaction of product in oak barrels, whiskey aging operations strive for a particular blend of temperature, humidity, and ventilation, leading to different typ es of warehouse. (Source: EPA, Final Report: Emission Factor Documentation for AP-42, Se ction 9.12.3, Distilled Spirits, p. 2-

7 (March 1997).) Therefore, whiskey aging is not co nsidered or included in this rule development process.

D. Rule Development Process

As part of the rule development process, District s taff conducted a series of public work shops on February 4, April 9, and June 17, 2009. A t these meetings, District staff presented the objectives of the proposed rulemaking project and solicited comments and suggestions, which were then used to develop th e rule and amend/augment the staff report.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 Pursuant to state law, District staff was required to perform a socioeconomic impact analysis prior to the adoption, amendment, or repea l of a rule that has significant air quality benefits or that will strengthen emission l imitations. As part of the District’s socioeconomic analysis process, District staff soug ht representatives from interested groups to participate as members of a Socioeconomic Focus Group. The Focus Group assisted District staff in determining the appropri ate method for gathering information on regulatory compliance costs and business impacts re sulting from compliance with the rule. The results of the socioeconomic analysis we re compiled into a report that was presented along with the refined version of the pro posed rule to the public and interested parties during the final workshop on Jun e 17, 2009. The date for the public hearing to consider adoption of the proposed rule a mendments was September 17,

2009.

II. DISCUSSION

A. CURRENT REGULATIONS

There are no existing rules in the nation that requ ire controlling VOC emissions from brandy aging and wine aging operations. Rule 4623 (Storage of Organic Liquids) limits VOC emissions from the storage of organic liquids. Although not identified as a rule deficiency, EPA expressed concern that the rule pro vides an exemption for tanks used in wine fermentation and storage of resulting produ cts, by-products, and spirits. EPA considers VOC emissions from this source category t o be significant and recommended further study and analysis.

District Rule 4694 (Wine Fermentation and Storage T anks) requires installation and operation of VOC emission control system to reduce emissions from wine fermentation and storage operations. As an alternative to contr olling the emissions from wine fermentation and storage tanks, Rule 4694 allows op erators to mitigate fermentation emissions by controlling alternative emission sourc es, such as reductions in surplus emissions from mobile sources, area sources, or oth er stationary sources. In lieu of installing VOC control devices on wine fermentation tanks to fulfill the Rule 4694 requirements, operators voluntarily offered to cont rol surplus emissions from brandy aging operations to obtain equivalent reductions wh ich could then be creditable as Certified Emissions Reduction Credits (CER) under R ule 4694.

To obtain the CER, operators of brandy aging facili ties modified existing brandy aging warehouses to meet the requirements for a Permanent Total Enclosure as specified in

EPA Test Method 204. This enabled ethanol emission s to be captured and destroyed using regenerative thermal oxidizer technology. Un til the successful demonstration that the operation of the capture and control system wil l not result in unacceptable impacts on brandy quality, consistency, or volume loss, the conditions of the operating permits are provisional and subject to revisions. Operatio n of these controls has demonstrated that they are technologically feasible as VOC contr ols and are tentatively consideredSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 applicable to both wine aging and brandy aging, pen ding final determination of the controls impacts on the brandy aging operations.

B. SUMMARY OF PROPOSED RULE

Proposed new Rule 4695 would implement a VOC contro l measure (S-IND-14) in the

Ozone Plan. The draft rule would serve as a “backs top” measure to codify the control of VOC emissions from the aging of brandy which are cu rrently being implemented by operators as an alternative compliance option in li eu of controlling the emissions from wine fermentation and storage in order to comply wi th Rule 4694 (Wine Fermentation and Storage). This proposed new Rule will require a ppropriate VOC control measures for wine aging operations which are currently uncon trolled. The rule applies to wine aging and brandy aging operations at Major Sources, which have a Potential To Emit of at least 10 tons VOC per year. If the facility is a Major Source, the rule requirements apply to that facility’s brandy and wine aging oper ations, regardless of aging operation’s size, container size, or container material type. The rule requires the brandy aging and wine aging operations to be assessed separately wit h independent thresholds and application of control technologies.

The major rule requirements include RACT, Additiona l RACT, and BARCT based on the throughput or emissions from the brandy aging or wi ne aging operations:

• For a facility with a brandy or wine aging operati on which has either an inventory or emissions less than Table 1 thresholds, operator s must implement Reasonable Available Control Technologies (RACT) to include record keeping and work emission minimization practices. Such wor k practices include: prevent, minimize, and restrict the unnecessary occurrence o f brandy or wine exposure to the atmosphere; prevent, minimize, and restrict the occurrence of leaks and spills; implement immediate clean up of leaks and s pills by rinsing leaks or spills with water and washing the rinse into a proper drai n; and implement immediate corrective actions to prevent a reoccurrence of a s imilar leak or spill. These are all reasonable practices currently being used by ex isting operations.

• For a facility with a brandy aging operation that equal or exceed both the applicable inventory and the emissions thresholds l isted in Table 1, the operator shall implement brandy RACT by implementing record keeping and work emission minimization practices in addition to BARC T emission capture and control by use of a Permanent Total Enclosure (PTE) that is vented to a control

device.

o This emission control implementation is more strin gent and has a total control efficiency of 90 percent through the use of the Permanent Total Enclosure (EPA Method 204) to encapsulate the emiss ions in the building (92% control efficiency) which are then vented to a Thermal Oxidizer (TO) that burns off the VOC emissions (98% control effic iency).SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 o BARCT does not require refrigeration, but large wa rehouses usually practice refrigeration to minimize ethanol evaporat ive loss.

o The rule requires warehouses to continuously meet the criteria for Normal Operation except for periods when the non-Personnel access doors are opened for personnel and equipment access as requir ed for operational

or maintenance functions and/or when the VOC contro l device is

shutdown for scheduled routine maintenance. Cumulat ive duration for all such periods are not exceed eight (8) percent of t he total operating hours or 701 hours per year, whichever is less. This dur ation includes periods of downtime as required to perform scheduled routin e maintenance, which are not to exceed three (3) percent of the to tal hours of operations or 240 hours per year, whichever is less.

o The rule also provides for an alternative control measure which may be approved by the APCO, provided it is demonstrated t hat brandy emissions will not exceed 0.3 proof gallons per 50 gallons. This would be equivalent to a warehouse with a system capable of a 90% combined capture and control efficiency.

• For a facility with a wine aging operation which e quals or exceed both the applicable inventory and the emissions thresholds l isted in Table 1, the operator shall implement RACT record keeping and work emissi on minimization practices

in addition to Additional RACT. Additional RACT is RACT for larger sources based on the observed emission reduction techniques commonly used by such operations. Additional RACT is not applied to smal ler operations and is not as stringent as BARCT for this class and category of s ource. Additional RACT specifies maintaining a nominal warehouse daily tem perature, averaged over a calendar year, not to exceed 70 degrees Fahrenheit.

o As explained later in this report, research into t he affects of humidity and temperature has shown that controlling these factor s can reduce evaporation and therefore control VOC emissions. T he 70 degree temperature threshold was set high enough to allow for variations in aging practices and equipment limitations while sti ll being low enough to produce meaningful reductions.

o The applicability threshold of 590,000 gallons is based on a 10,000 barrel inventory of 59 gallons per barrel. Such an operat ion would have an Uncontrolled Aging Emission (UAE) of 16,000 pounds per year and was selected as a natural breakpoint between the large wine aging operations that implement refrigeration or temperature control and the small wine aging operations that do not implement refrigeratio n.

o Two additional RACT control alternatives to the te mperature option are provided in the rule. The first alternative would allow a control that reduces the VOC Uncontrolled Annual Emissions by 50 %. This factor will be calculated by using the UAE calculation equ ation and an Aging Emission Factor (AEF) of 0.02783, which is based on the District defaultSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 3% evaporative loss rate, as explained below. Thi s option is considered to produce equivalent reductions to the temperature option.

o The second control alternative is to age wine in n on-porous tanks. These tanks must be equipped with operable pressure-vacuu m relief valves and the temperature of the aging wine must be maintaine d at or below 75 degrees Fahrenheit. This alternative is already ach ieved in practice on tanks which are used for wine storage and must comp ly with Rule 4694 (Wine Fermentation and Storage) requirements.

Table 1 below summarizes the thresholds and applica ble requirements for the various sizes of operations, as discussed above.

Table 1.

Product Type Total Annual

Aging Inventory (gallons per year) Uncontrolled Aging

Emissions (lbs/yr) Requirement Control Technology

Level

< 40,000 < 8,000 Records & Work

Practices RACT

Brandy

> 40,000 > 8,000 Records & Work

Practices & PTE

vented to a

control device RACT and

BARCT

< 590,000 <16,000 Records & Work

Practices RACT

Wine

> 590,000 > 16,000 Records & Work

Practices & Temperature

control RACT and

Additional

RACT

The difference between brandy aging and wine aging thresholds are due to the District calculating emission factors based on an average an nual brandy evaporative loss rate of 3 proof gallons per barrel per year, and an aver age annual wine evaporative loss rate of 3% by volume per barrel per year, and a cost eff ectiveness of approximately $25,000 per ton for both. Using these emission factors, wi ne has an ethanol level of nearly onesixth that of brandy and a proportionally lower emi ssion rate. Because of the differences in emission rates, wine aging controls have much higher cost effectiveness values compared to a similarly-sized brandy aging w arehouse. Cost effectiveness details are provided in Appendix C.

The rule allows facilities the opportunity to calcu late and use their own Uncontrolled Aging Emissions (UAE) in relation to this rule’s th resholds. To determine a specific operation’s Uncontrolled Aging Emissions (UAE) use the following formula:SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 UAE = TAAI * AEF

Where: UAE = Uncontrolled Aging Emissions, in pounds of e thanol per year. TAAI = Total Annual Aging Inventory, in gallons per year. AEF = Aging Emission Factor, in pounds of ethanol per gallon.

Total Annual Aging Inventory is an average of a cal endar year inventory derived from the Tobacco Tax and Trade Bureau (TTB) Form 5110.11 for brandy and Form 5120.17 (replaced Form 702) for wine. The calculation is as follows:

TAAI = ∑ GMI ÷ 12 months/year.

TAAI = Total Annual Aging Inventory, in gallons pe r year. GMI = Gallons in Monthly Inventory, in gallons pe r year.

The District’s default Aging Emission Factors (AEF) are: brandy 0.1986 lb ethanol per 50 gallon barrel and wine 0.02783 lb ethanol loss p er gallon wine. These values are based on the District default values of evaporative loss of 3 proof gallons per barrel per year. This loss rate is based on the average loss rate for all permitted facilities in the District, except one facility that is not industry representative. The wine default value is based on an evaporative loss rate of 3% by volume p er barrel per year. This is explained in great detail below. Using the above lo ss rates allows for the aging emission

factors to be calculated as follows:

Brandy Default AEF = 3 proof gallons loss/50 gallo n barrel x 0.5 gallon ethanol/ proof gallon x 6.616 lb ethanol/gallon. = 0.1986 pounds of ethanol/gallon of brandy aged

Wine Default AEF = 0.03 gallons loss/gallon wine x 8.14 lb wine/gallon wine x 0.114 lb ethanol/lb wine (simplified from Santa Bar bara Air

Pollution Control District’s ‘Wine Production Emiss ion Factors). = 0.02783 pounds of ethanol/gallon of wine aged

Wine aging operators have indicated that their site -specific loss rate may be significantly lower than the assumed 3% rate. The rule allows op erators to calculate the brandy and wine AEF using such a site-specific loss rate in pl ace of the District’s default values.

This allowance is to reflect the effects of individ ual practices that may be employed to reduce evaporative losses.

Additionally, the rule provides for two alternative emission controls for tanks that are not

housed in a PTE and vented to a VOC control device. First, the rule allows use of such tanks if the operator can demonstrate that the agin g emissions do not exceed 0.3% by volume. This fugitive emission value is equivalent the fugitive emissions released by aSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 PTE and RTO that have a combined destruction effici ency of 90%. The basis for this

allowance is as follows:

• Wine barrels have a District default evaporative l oss rate of 3%.

• The PTE captures 92% of this 3% evaporative loss.

• The PTE is vented to a VOC control device that des troys 98% of the emissions captured by the PTE.

• Total capture and control of the system is

0.92 x 0.98 = 0.90 capture and control destruct ion efficiency

• If 90% of the evaporative loss is captured and des troyed, then 10% of the ethanol (or 0.3% of the total wine) would be emitte d to the atmosphere.

0.03 x (1 - 0.90) = 0.003 or 0.3% of the total wine

• Therefore, a system with VOC emissions of less tha n 0.3% of the total wine is equivalent to a PTE and VOC control having a 90% ca pture and control efficiency.

Secondly, the rule allows operators to use non-wood en tanks if they are equipped with pressure vacuum relief (PVR) valves and temperature controls. The combination of the PVR valves and temperature control reduces or elimi nates evaporation and emissions from the aging operations by maintaining the tank c ontents in a static state. The PVR valves stay closed during aging since refrigerating the tank contents prevents them from evaporating and expanding and contracting due to te mperature variability. Tank

contents are maintained at or below 75 o F. Volumetric loss rates for these tank controls are expected to be 0.3% or less, which would be equ ivalent to the other two control options.

District research has found that temperature can be used as a primary, singular, and

direct wine ethanol emission reduction/control tech nique. Based on an initial study’s data (Blazer, R. M., Wine Evaporation from Barrels, Practical Winery and Vineyard Jan/Feb 20-22 (1991)), District staff ran a linear regression that showed a proportional relationship between temperature and ethanol loss f rom wine aging in barrels. Further research concluded that ethanol loss is independent of humidity. The Blazer data may have limited use but it is an appropriate example t hat aptly demonstrates for the purposes of this rule the scientific relationship o f decrease temperature and proportional decrease of monthly ethanol evaporation from barrel aging wine as shown below in Diagram 1.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 Diagram1. Linear regression of temperature and eth anol loss per barrel.



## Temperature and Monthly
Ethanol Loss per Barrel

y = 4.353x - 209.58

R 2 = 0.9759



### 0 50 100 150 200 250

50 60 70 80 90 100

Temperature ( o 

### F)Ethanol Loss(mL)

Because there are no other wine aging emission cont rols regularly put into practice other than temperature control, as currently achiev ed in practice for larger brandy aging and wine aging operations, and because temperature control is not only used to substantially reduce evaporative loss but to increa se product quality; temperature control is to be considered a Reasonably Available Control Technology (RACT) practice. Because this practice will not generate additional reductions from current practices, no further emission reductions for RACT will be credited to this rule.

The use of a controlled nominal daily temperature, averaged over a calendar year, is considered RACT for two reasons. First, the San Jo aquin Valley has great diurnal and seasonal temperature variations. Diurnal variation s from night to day average 30 degrees, with extreme diurnal variations of up to 6 4 degrees Fahrenheit. The seasonal winter to summer monthly variations average 60 degr ees, with extreme variations of up to 98 degrees Fahrenheit, based on a summer high of 115 degrees to winter low of 18 degrees. Second, the existing larger brandy aging and wine aging operations already employ refrigeration to maintain summer temperature s below a certain point, generally around 60 degrees Fahrenheit. The exact aging temp erature can vary by 10 degrees Fahrenheit at certain times of the year, depending on the outside temperature, related operations occurring in the warehouse, and the refr igeration equipment limitations.

Another seasonal operational factor involved in an aging warehouse’s daily temperature fluctuations is fermentation. Fermentations produc e large amounts of carbon dioxide gas. During the fall months of wine fermentation, doors nearest a fermentation section of the aging warehouse may be opened to exit the ex cess carbon dioxide gas thus contributing to daily variations in a controlled wa rehouse’s daily temperature. Consequently, because of the above detailed diurnal and seasonal temperatureSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 fluctuations the warehouse nominal daily temperatur e must be averaged over the course of a calendar year.

All wine aging and brandy aging operations at Major Sources must implement RACT as detailed earlier. Larger brandy operations must al so implement capture and control of VOC emissions by using a PTE vented to a control de vice. This system is much more costly than the RACT requirements and is therefore considered a BARCT. As detailed in Appendix C, the high cost effectiveness of this BARCT requirement limits its application to the largest brandy aging operations which would otherwise have the highest emissions of VOC.

Currently, four of five largest brandy aging operat ions in the District are using a warehouse that is a PTE venting to a Regenerative T hermal Oxidizer (RTO). Out of several control devices at stakeholder disposal, th e brandy aging industry has universally selected the use of a Regenerative Ther mal Oxidizer (RTO) due to its low annual maintenance costs for this control applicati on. Because of the current installation and operation of the RTOs, it has been demonstrated that RTOs are practical and effective controls for high levels of VOC emissions. The RTOs that are currently in operation were installed as an alterna tive compliance option in lieu of controlling the emissions from wine fermentation an d storage for Rule 4694 (Wine Fermentation and Storage).

As explained in Appendix B, the expected reductions are summarized in Table 2 below. These emission reductions only include the reductio ns which will be realized from the one, uncontrolled brandy aging warehouse and do not include those reductions that are creditable to the Rule 4694. The compliance date for achieving this reduction is January 1, 2012.

Table 2: Emission Reductions for Rule 4695

Operation Tons per Year Tons per Day Brandy Aging 42.6 0.12 Wine Aging 0 1 0

Total 42.6 0.12

1 Current wine aging facilities meet RACT control req uirements

.

In determining a reasonable level at which to requi re BARCT, staff used a $25,000 per ton cost effectiveness cut point. This level is si milar to that which has been historically

used in other VOC control rule determinations. Thi s value will not generally cause a significant socioeconomic impact and yet will still affect a reasonable level of emission

control.

The brandy evaporative loss rate of 3 proof gallons per barrel per year is based on the average loss rate for all permitted facilities in t he District (except one facility that is notSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 industry representative). The subsequently calculat ed brandy aging emission factor is 0.1986 pounds ethanol per gallon annually.

District research developed an evaporative loss rat e scale showing that the annual wine aging evaporative loss rate for various operations in the District may range from 0.16% to 10% by volume. It was found that within that ran ge, the 3% value is the appropriate value to use for the District’s evaporative loss ra te, which takes into account weighted inventories and evaporative loss rates. The wine e vaporative loss rate of 3% by volume per barrel per year and the wine aging emission fac tor of 0.02783 pounds ethanol per gallon are based on the results of District researc h outlined in the following:

• According to Tobacco and Tax Trade Bureau (TTB) da ta for the years 2004, 2005, and 2006; and Wine Institute wine production values for those same years, wine loss during production is only 0.16%. This in cludes losses due to spillage, leakage, soakage, evaporation, include aging, and o ther losses normally occurring from racking and filtering. However, the overwhelming majority of this wine production is not aged. Therefore, for those wines that go through this production process and are then aged, the loss rate s can be no less than 0.16% by volume per year. This sets the low end of the ev aporative loss scale to 0.16%.

• District research has also shown that non-climate controlled wine aging warehouses in hot climates may lose up to 10% by vo lume, thereby setting the high end of the evaporative loss rate scale at 10%. From District surveys there are 22 wine aging facilities in District operation. Of those facilities, 21 facilities are less then one-tenth the size of the largest facilit y. These smaller facilities average approximately 800 – 1,000 barrels in aging inventor y. District staff understands

that these smaller facilities do not utilize climat e controls for their aging barrels and that these barrels are aged in existing operati onal buildings (fermentation, storage tank, filtering, and/or bottling rooms/buil dings). From the District survey these smaller facilities make up 37% of the annual wine aging inventory gallons.

• District research has also shown wine aging wareho uses that are in mild climates (or warehouses that are operated with climate contr ols of approximately 60 degrees Fahrenheit and 75 percent humidity, accordi ng to stakeholder information) are expected to have loss rates of no greater than 3% by volume, based on the factor developed by the publicly-vette d Santa Barbara Air Pollution Control District permit development process. Santa Barbara has a mild climate with average temperature of 61 degrees Fahrenheit a nd 50% humidity.

• The likelihood that losses of no greater than 3% i s also supported by data from

the TTB whereby losses due to spillage, leakage, soakag e, evaporation, including wine aging, and other losses normally occ urring from racking and filtering, of up to 3% loss by volume, are not taxe d. It is assumed that this allowance is recognition that the 3% loss is what w ould normally occur from a reasonably well-managed wine production operation. Since the other 97% isSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 taxed, operators would have an incentive to minimiz e emissions or they would end up being taxed on lost product.

• Published research has also shown that measured wi ne evaporative loss rates which were measured under environmentally controlle d conditions in wine aging warehouses and caves - demonstrate a wine aging eva porative loss range from 0.3% to 1.4% by volume. This measured wine evapora tive loss rate range was based on the spread of relative humidity from 60 to 75% and temperature 59 to 95 degrees Fahrenheit. This relative humidity and t emperature spread was selected from the data set to reproduce the wine ev aporative loss rates submitted by stakeholders of 0.29% to 1.4%.

The rule includes an allowance for operators to use site-specific loss rates in determining the applicability of the rule requireme nts to their aging operations. Stakeholders have requested that the site-specific loss factors also be used in calculating the emissions inventory for this source category. While the District is always open to improving the accuracy of the emissions inv entory, such a determination is beyond scope of his project and will be pursued as a separate issue.

District Staff welcomed input from stakeholders who submitted similar but a facility specific wine evaporative loss rate (1.4%), cost of control total capital and annual investment data, and a resulting cost effectiveness analysis. Staff Report Appendices B, C, and D incorporated stakeholder results. Thes e analyses resulted in a second wine cost effectiveness value of $76,695 per ton. The District subsequently adjusted up the above wine aging threshold limit to 30 tons (60 ,000 pounds) per year with a subsequent cost effectiveness of value of $26,700 p er ton. Because there are no wine aging warehouses of that size in the Valley, and be cause the District’s permitting process would prevent the establishment of one that large, the scenario of a wine aging operation large enough that would require the insta llation of a BARCT PTE and VOC control was dropped from the rule.

III. BACKGROUND

A. Brandy and Brandy Aging

The name brandy comes from the Dutch word brandewijn, meaning "burnt wine." The name is apt as most brandies are made by applying h eat, originally from open flames, to wine. This wine is boiled at a temperature betwe en the boiling point of alcohol (ethyl alcohol) and the boiling point of water. This heati ng a liquid to separate components with different boiling points is called heat distil lation. The low-boiling point liquids

distilled from wine include almost all of the alcoh ol, a small amount of water, and many of the wine's organic compounds. It is these chemic als that give brandy its taste and aroma. The resulting vapors are collected and coole d. To drive out more of the water, always saving the alcohol, the distillation process can be repeated several times more depending on the alcohol content desired.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 In California, these brandies are generally made of wine produced from many varieties of grapes but principally use Thompson Seedless and Chardonnay. Brandy is produced with an ethyl alcohol of less than 190° proof and b ottled at a minimum of 80° proof. In the United States, "proof" denotes the ethyl alcoho l content of a liquid at 15.6°C (60°F), stated in units of twice the percent ethyl alcohol by volume. For governmental reporting purposes, ethanol is reported in volume units of pr oof gallons, which is one liquid gallon of proof spirits which are 50% ethanol, by volume, at 60 degrees Fahrenheit.

B. Wine and Wine Aging

Wine is an alcoholic beverage produced by the ferme ntation of sugars in fruit juices, primarily grape juice. This fermentation process i s an anaerobic breakdown of organic compounds by microscopic yeast organisms which prov ide complicated enzymes that, in the presence of sugar, form alcohol, carbon diox ide, glycerin, and other products.

The amount of time required to complete a fermentat ion is a function of temperature,

where at 55 to 60 0 F, wines are fermented in 7 to 10 days, and at 75 t o 80 0 F, wines will take 3 to 6 days to ferment. In commercial winerie s fermentation of the grape juice or must (grape juice plus berry skins) commonly occurs in fixed-roof steel fermentation tanks inoculated with yeast. After fermentation, w ine is transferred a number of times between storage tanks to perform various finishing operations such as racking or decantation for separation of sediment, and filtrat ion.

In California, table wines can be made from either a single grape variety or made from a combination of many grape varieties. These table w ines have an alcohol content that ranges from 7 to 14 percent by volume (14° to 28° p roof). Some of these table wines are subsequently aged in oak barrels or casks, to i mprove the quality. The changes that occur during the aging process are the result of interactions between the aging wine and the oak barrel, driven by the conditions o f the surrounding atmosphere which may have both diurnal and seasonal variation. Both the ethanol and water evaporate from the surface of the barrel during the aging pro cess with the rate of evaporation depending upon both the porosity of the barrel and the atmospheric conditions of the storage room among other factors.

C. Fugitive Emission Source: The Barrel

Modern barrels (Diagram 2) are made of oak staves ( Diagram 3) shaped into bulging cylinders that are bound by steel hoops and capped with flat circular heads at both ends The belly, or bilge, allows them to be rolled and t urned, and when stored horizontally, facilitates racking or the transfer of the liquid t o another barrel.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 Diagram 2. Wood barrel components. Diagram 3. Stave components.

The inside of the barrel is then subjected to fire, known as ‘toasting’ that caramelizes some of the woody substances (generally sugars) whi ch develop into a multitude of sweet woody aromas, which will add flavor to whatev er liquid is stored inside the barrel. For wines, this ‘toast’ level can be adjusted accor ding to the customers' requests: light, medium or heavy toast. For Bourbon, the ‘toasting’ is heavy (or charred) that leaves a heavy charcoal layer on the inside that greatly mel lows the liquid contents.

Once finished, a test of impermeability is made by pouring a small amount of hot water under pressure into the barrel. This procedure make s it possible to immediately detect any leaks, or mere traces of moisture caused by unu sually porous areas or a manufacturing defect.

California brandy makers buy used American Bourbon barrels to age their brandy. These barrels generally hold 53 gallons are made of American oak. Barrels used for wine are fashioned in two principal configurations: the 59-gallon French Bordeaux and the 60-gallon French Burgundy. The latter is nearl y three inches shorter and over one inch broader at the bilge. Wine barrels are purcha sed new or used and are made of oak from America, France, or Eastern Europe. Large r barrels of 79 to 185 gallons are called puncheons and offer a lower wood surface-to- wine ratio imparting less oak and vanilla characteristics to the wine. Large upright tanks generally fixed in place and

constructed of wood are called casks and can be use d to ferment or age the wine.

D. Fugitive Emission Driving Force: Diffusion

Wood is a solid, porous, and permeable material. Po rosity is the volume fraction of void space in a solid. The porosity is reported to be 1. 2 to 4.6% of dry volume of wood cellSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 wall. Permeability is a measure of the ease by whi ch fluids are transported through a porous solid under the influence of some driving fo rce, such as chemical potential. There are several types of chemical potential drivi ng forces, but in this instance, it is

diffusion. The diffusive movement of moisture and vapor through the wood is by several types of passageways and variations in wood structu re. These pathways consist of cavities in vessel cells, fibers, ray cells, pit ch ambers, intercellular spaces, and transitory cell wall passageways.

Diffusion will redistribute moisture and vapor betw een the interior and exterior barrel surfaces, until the moisture or vapor level is unif orm throughout the wood and the surrounding air, and a zero chemical potential grad ient is reached at equilibrium.

Diffusion’s constant driving force to reach equilib rium, forces a wine’s 7 to 14%, or a brandy’s 40% alcohol from the porous barrel into th e housing room where, at least for brandy, there is a constant state of disequilibrium . This diffusion of alcohol and water

over time causes a decrease in volume of the barrel ’s liquid contents. This loss is historically known as “the angels share” but is kno wn today as fugitive emissions.

IV. Fugitive Emission Control Techniques

A. Emissions Capture System

The brandy storage warehouse functions as an enclos ure from which the ethanol emissions can be captured. The capture efficiency is primarily a function of the configuration of this structure. Since such a stru cture can be sealed and ventilated to a control device such that it qualifies as a Total En closure pursuant to U.S. EPA Method 204, the theoretical capture efficiency could be co nsidered to be 100%. However, since brandy aging and wine aging operations are a contin uous 24 hour/day operation throughout the year, it would be difficult and expe nsive to continuously maintain the

warehouse in a Total Enclosure status due to the on -going requirements to transport the product into and out of the warehouse and the requi rements for maintenance during which the warehouse must be opened or the control d evice 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.

Although neither of the terms “Fan Inlet Pressure C ontrol Point” and “Maximum Allowable Negative Gauge Pressure” appear in EPA Me thod 204, the industry has previously indicated that there are technical diffi culties with continuous monitoring and directly controlling a differential pressure of 0.0 13 mm Hg and has requested use of a surrogate for monitoring and for controlling of the induced draft fan. The selected surrogate is the pressure control instrument for th e induced draft fan, typically located on the inlet ductwork near the fan inlet plenum. D ue to pressure losses in the ductwork, the vacuum at this point is considerably higher tha n that in the warehouse (on the order of 2 “WC) which is more easily measured and control led. The facility is required toSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 establish, control, and periodically demonstrate a control set pressure at this point which ensures that the PTE requirement of 0.013 mm Hg is met.

B. Control Technologies and Devices (Exhaust-type)

1. Thermal Oxidation (Incineration)

Thermal oxidizers (TO) use the process of combustio n to destroy VOCs. A basic TO system consists of a combustion chamber, burner, st ack, and combustion controls. All hydrocarbons are oxidized to carbon dioxide and wat er vapor by the proper mix of temperature, residence time and turbulence within t he reactor chamber. Combustion of the contaminated gas stream occurs at high temperat ures, normally 650 o C to 870 o C (1,200 o F to 1,600 o F) when treating low concentration streams. Recent source tests at existing facilities utilizing TO control have demon strated a 98% destruction efficiency at a combustor temperature of 1400 o Fahrenheit.

TO systems can be divided into recuperative or rege nerative systems, based on methods used to increase operating efficiencies by capturing heat from the combustion process. Recuperative TO systems increase fuel eff iciency 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 syste ms use a ceramic heat-exchange bed to preheat process air to within 5% of the oxid ation temperature.

VOC conversion efficiencies range from 95% to 99.9% for TO systems. However, the combustion of supplemental fuel for the oxidation p roduces NOx, an ozone precursor like VOC, thus offsetting some of the VOC emission reduction. The District considers thermal oxidation as technologically feasible for t he application to brandy aging and wine aging.

Stakeholders have implemented thermal oxidation con trols for their brandy storage warehouses and are currently adjusting the function al operations of this system to minimize any detrimental quality and evaporative ef fects. This control technology is currently operating on six permit units in the San Joaquin Valley.

2. 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 recup erative units, except that VOCs are oxidized at lower temperatures using precious metal or metal-oxide-based catalysts. Operating at about half the temperature of thermal oxidizers, catalytic units have smaller physical footprints and may offer lower operating c osts in certain circumstances. Since catalysts are employed, these systems are subject t o catalyst poisoning or deactivation due to operating upset and may require periodic cat alyst replacement, which represents a substantial operating cost.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 Other industries have demonstrated typical VOC remo val efficiencies of up to 98%. The District considers catalytic thermal oxidation as t echnologically feasible for application to brandy aging and wine aging and that a control effi ciency of 98% is reasonably

achievable.

3. Adsorption Vapor Recovery

Adsorption vapor recovery is accomplished by passin g the VOC-laden gas through beds containing adsorbents that have a high surface area to weight ratio. Typical adsorbents are activated carbon, zeolite, or organi c polymers. As the gas stream passes through the bed, organic compounds adsorb we akly onto the adsorbent’s surface. Adsorption of the hydrocarbon molecules p roceeds until the available surface

area is filled or saturated with VOC molecules. Th e VOC molecules are retained until the regeneration step, or disposal of the spent ads orbent.

Desorbing or removing captured VOCs regenerates the adsorbent. Decreasing the pressure, reducing the hydrocarbon concentration ar ound 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 bas ic types of adsorption systems available to recover or remove hydrocarbon vapors f rom 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 a re: Pressure Swing Regenerated Systems and Thermally Regenerated Systems (or a com bination of the two methods). Since the net result of the combined adsorption and regeneration process only results in

transfer of the ethanol from the vent stream to ano ther liquid or gaseous stream, further treatment of the effluent of the regeneration proce ss 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 (w ith appropriate handling of regeneration waste streams) as technologically feas ible for application to brandy aging and wine aging. Based on a draft technical assessm ent document (TAD) prepared by the ARB, a control efficiency of 95% is considered reasonable for adsorption systems when controlling ethanol emissions (from wine ferme ntation), a more demanding application due to the presence of large amounts of CO2.

4. 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 upw ard 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 poro us mass transfer media, generating

a substantial interfacial surface area between the gas and liquid phases in a counterSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 flow arrangement which provides optimal mass trans fer. Gaseous contaminants are absorbed into the liquid and the decontaminated gas stream flows out of the scrubber.

Many scrubbing applications achieve emission reduct ion efficiencies of 99.9%. In a pilot study conducted by the ARB in 1987, wet scrub bing demonstrated greater than 90% reduction in ethanol emissions when operated fo r control of ethanol emissions (from wine fermentation tanks). The District consid ers wet scrubbing as technologically feasible for application to brandy aging and wine a ging and that a control efficiency of 90% is reasonably achievable.

5. Condensation, Refrigeration, and Cryogenic Syste ms

Condensation, refrigeration, and cryogenic systems remove organic vapor by condensing the target gases on cold surfaces. Thes e cold conditions can be created by passing cold water through an indirect heat exchang er, by spraying cold liquid into an open chamber with the gas stream, by using a refrig erant to create very cold coils, or by injecting cryogenic gases such as liquid nitrogen i nto the gas stream. The concentration of VOCs is reduced to the level equiv alent to the vapor pressures of the compounds at the operating temperature. Removal eff iciencies attainable with this approach depend strongly on the outlet gas temperat ure. 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 ref rigerant 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 v ery low operating temperatures of - 70°F to less than -200°F. Water vapor content in th e gas stream may place a lower limit on the outlet gas temperature due to potential ice formation.

The application of refrigerated condenser to the co ntrol of ethanol emissions (from a fermentation tank) was examined by ARB. 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. However, it was note d that ice formation could be a problem at this temperature and that special equipm ent designs would be required for reasonable operation. In addition, the ethanol is r ecovered in aqueous solution and must be further process for recovery of the ethanol . The District considers refrigerated condensation as technologically feasible for applic ation to brandy aging and wine aging and that a control efficiency of 90% is reasonably achievable.

6. Biological Oxidation

VOCs can be removed by forcing them to absorb into an aqueous liquid or moist media inoculated with microorganisms that consume the dis solved 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 streamSAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 temperatures are maintained at less than approximat ely 105°F to avoid harming the organisms and to prevent excessive moisture loss fr om the media.

Biological oxidation systems are most often used fo r very low concentration VOC-laden gas streams for odor control. The VOC inlet concen trations are often less than 500 ppmv and sometimes less than 100 ppmv and achieve c ontrol efficiencies exceeding 95%. However, biofilters have been demonstrated in industrial applications achieving 90% control efficiency when controlling higher etha nol inlet concentrations (up to 3 g/1000 m 3 ). The District considers biological oxidation to b e technologically feasible for application to brandy aging and wine aging and that a control efficiency of 90% is reasonably achievable.

C. Emission Reductions

The 2007 Ozone Plan estimates a 2012 brandy aging a nd wine aging VOC emission baseline of 2.30 tons per day. This value has been adjusted to account for 4.5 tons per day of reductions from facilities that are part of alternative compliance options in Rule 4694 (Wine Fermentation and Storage Tanks). These emissions are SIP creditable to previous 1-Hour Ozone Plan commitments for the Bran dy and Wine Aging (S-IND-14) control measure. Approximately 98 percent of the br andy aging emissions in the San Joaquin Valley (four facilities) are already contro lled in accordance with the requirements of this rule. Implementation of this rule is expected to require emission controls on one additional brandy aging facility, r esulting in an annual emission reduction of 0.12 tons per day attributable to this rule for brandy aging. The wine aging emission reductions are currently achieved in pract ice and are considered RACT and

are not creditable to this rule.

As previously stated in this Draft Staff Report, th e District sought as much reduction of VOC emissions from brandy aging and wine aging as e xpeditiously as practicable, technologically feasible, and economically reasonab le, as determined by the District’s Governing Board. The VOC emissions reduction analys is is presented in Appendix B of the Final Draft Staff Report and also includes stak eholder submitted data.

V. COST EFFECTIVENESS ANALYSIS

Pursuant to CH&SC section 40920.6(a), a cost effect iveness analysis is required for rules that implement RACT. The purpose of the cost effec tiveness analysis is to evaluate the

economic reasonableness of the rule or rule amendme nts. The analysis also serves as a guideline for developing the control requirements o f the rule. District staff has conducted a cost effectiveness analysis for Rule 4695. The cos t effectiveness analysis is presented in Appendix C of the Final Draft Staff Report.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 VI. SOCIOECONOMIC ANALYSIS

Pursuant to CH&SC 40728.5, “whenever a district int ends to propose the adoption, amendment, or repeal of a rule or regulation that w ill significantly affect air quality or emissions limitations, that agency shall, to the ex tent data are available; perform an assessment of the socioeconomic impacts of the adop tion, amendment, or repeal of the rule or regulation.” The socioeconomic impact of Ru le 4695 is presented in Appendix D of the Final Draft Staff Report.

VII. RULE CONSISTENCY ANALYSIS

Pursuant to the state Health and Safety Code, Secti on 40272.2, District staff has prepared a rule consistency analysis of Rule 4695. The Rule Consistency Analysis is presented in Appendix E of the Final Draft Staff Report.

VIII. ENVIRONMENTAL IMPACTS

Pursuant to the California Environmental Quality Ac t (CEQA), District staff investigated the possible environmental impacts of the proposed Rule 4695. Based on the Initial Study District staff concluded that the proposed rule wil l not have any significant adverse effects on the environment. Staff recommends filing a Negat ive Declaration under the provisions of the Public Resource Code 15061 (b) (3) to be pre sented to the Governing Board Chair for signature.

IX. REFERENCES

1. AP-42, Chapter 9.12.2, ‘Wines and Brandy’, http://www.epa.gov/ttn/chief/ap42/ch09/final/c9s12- 2.pdf 2. Blazer, R.M. Wine Evaporation from Barrels, Prac tical Winery and Vineyard, January/February, 20-22, (1991). 3. Botany 410: http://www.botany.hawaii.edu/faculty/webb/bot410/41 0Labs/LabsHTML99/Xylem/Labxyphlo99.html 4. California Air Resources Board (ARB) 8/06/03 Dra ft Technical Assessment Document “Strategies and Costs for Winery Ethanol e mission Control”. 5. Cinnabar Vineyards and Winery | Wine Barrels and Puncheons: http://www.cinnabarwine.com/news0223-02b.html 6. Cooperage – The Making of a Wine Barrel: Crafty Owl Primitives * Tom &

Deirdre Crawl: http://www.crafty-owl.com/cooperage.htm 7. Goldman, M., Engineering and Compliance Division Manager, Santa Barbara County Air Pollution Control District, Personal Com munication, August, 22, 2008. 8. Google Images: http://images.google.com/images?q=picture+of+wood+s eive+tubes&rls=com.mic

rosoft:en-us&ie=UTF-8&oe=UTF8&um=1&sa=X&oi=image_result_group&resnum=1&ct=title

.SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

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for Rule 4695 9. How Products Are Made, Volume 7, http://www.madehow.com/Volume7/Brandy.html

10. How Wine Barrels Are Made: http://www.mastergardenproducts.com/barrelsmade.htm

. 11. Devinny, et.al, Biofiltration for Air Pollution Control, CRC Press, Boca Raton,

1999. 12. Kelvin Cooperage | Wine Barrels: http://www.kelvincooperage.com/winebarrels.htm 13. Kentucky Barrels LLC: http://www.kentuckybarrels.com/barrels.html 14. Nelson Chan, et.al., A Suggested Control Measur e for Control of Ethanol Emissions From Winery Fermentation Tanks. October 7, 1986. 15. San Joaquin Valley Unified Air Pollution Contro l District, Daniel T. Barber, Ph.D., Air Quality Specialist, ‘Final Staff Report: Rule 4694 (Wine Fermentation and Storage Tanks)’, December 15, 2005. 16. San Joaquin Valley Unified Air Pollution Contro l District, ‘2007 Ozone Plan’,

2007. 17. Santa Barbara county Air Pollution Control Dist rict: http://www.sbcapcd.org/eng/winery/winery.htm

. 18. Strategies and Costs for Winery Ethanol Emissio n Control – Technical Assessment Document (Draft), August 6, 2003. 19. The Beverage Tasting Group, ‘Brandy Facts’, http://www.tastings.com/spirits/ brandy.html 20. United States Government, ‘Code of Federal Regu lations, Amended Clean Air Act’, February 24, 2004. 21. Willey, G., Supervising Engineer, Engineering D epartment, San Luis Obispo Air Pollution Control District, Personal Communication, August, 21, 2008. 22. World Cooperage: http://www.worldcooperage.com/pages/product_barresl _trad,html

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