SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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 federal ozone standards, respectively. In 

accordance with Federal Clean Air Act (CAA) requirements for non-attainment areas, 

the San Joaquin Valley Unified Air Pollution Control 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 compounds (VOC), which are the 

precursors to ground-level ozone. 

The 2007 Ozone Plan contains a commitment to develop a control measure for VOC 

emissions from brandy aging and wine aging operations. Emission controls have 

already been installed on most of the large brandy aging operations as an emission 

reduction measure to comply with the requirements of Rule 4694 (Wine Fermentation 

and Storage Tanks), to which these emission reductions are credited. In addition to 

controlling VOC emissions from brandy aging operations, this control measure would 

require Reasonably Available Control Technology (RACT) controls on wine aging 

operations at Major Sources. 

As stated in the 2007 Ozone Plan possible cost effective emission reductions could be 

achieved for brandy aging through adding emission control technologies. Such 
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additional technologies are considered to be beyond RACT but are not yet achieved in 

practice for these operations. After a more extended 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 District may revisit this for Best Available 

Control Technology (BACT) for new or modified sources. 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 emissions, between the two operations 

and the impact of this difference on technology transfer 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 determined by the District’s 

Governing Board. This rule also satisfies SIP commitments with the requirement of 

emission controls which help produce Reasonable Further Progress (RFP) for the 

Attainment Demonstration; reduces emissions that are 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 policies and programs to implement 

AB32. 

The District believes that the evidence and the rationale that climate change is occurring 

is compelling and convincing. In addition to the long-term consequences of climate 

change, the District is concerned with the potential ramifications of more moderate but 

imminent changes in weather patterns. The Valley depends 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 reduce both GHG and criteria/toxic 

pollutant emissions, when faced with situations that involve tradeoffs between the two, 

District staff believes that the more immediate public health concerns that may arise 

from criteria or toxic pollutant emissions should take precedence. 

C. Description of the Project 

This rule codifies the requirement for Best Available Retrofit Control Technology 

(BARCT) and Reasonably Available Control Technology (RACT) VOC emission controls 

and management practices which have been employed by wine fermentation operators 

under Rule 4694’s alternative emission reduction option. This rule specifies RACT for 
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major sources as the means to achieve the maximum amount of VOC emission 

reductions by using control technologies that are reasonably available. Any VOC 

emissions reduction from the control of brandy aging 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 aging 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 operations 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 for brandy aging and wine aging 

operations were determined based on operating characteristics, emissions, and a cost 

effectiveness analysis. 

Existing brandy aging control systems have been installed and operating on four 

warehouses for almost two years, but, due to the brandy aging process length, this is 

not sufficient time to judge the impact of the controls on operations and product quality. 

Therefore, the compliance date has been set to allow for time to reexamine rule 

requirements if operational or product quality issues are deemed to be seriously 

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

information from the Federal Alcohol and Tobacco Tax and Trade Bureau, the Wine 

Institute, and from individual stakeholders to serve 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 control VOC emissions from brandy aging 

and wine aging operations. 

The District staff understands that the nature of whiskey aging operations differs from 

wine and brandy aging. Specifically, the ambient conditions, such as storage 

temperature and humidity, as well as seasonal variations, are important factors in the 

whiskey aging process. All aging processes, depends upon the interaction of product 

in oak barrels, whiskey aging operations strive for a particular blend of temperature, 

humidity, and ventilation, leading to different types of warehouse. (Source: EPA, Final 

Report: Emission Factor Documentation for AP-42, Section 9.12.3, Distilled Spirits, p. 2-

7 (March 1997).) Therefore, whiskey aging is not considered or included in this rule 

development process. 

D. Rule Development Process 

As part of the rule development process, District staff conducted a series of public work 

shops on February 4, April 9, and June 17, 2009. At these meetings, District staff 

presented the objectives of the proposed rulemaking project and solicited comments 

and suggestions, which were then used to develop the rule and amend/augment the 

staff report. 
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Pursuant to state law, District staff was required to perform a socioeconomic impact 

analysis prior to the adoption, amendment, or repeal of a rule that has significant air 

quality benefits or that will strengthen emission limitations. As part of the District’s 

socioeconomic analysis process, District staff sought representatives from interested 

groups to participate as members of a Socioeconomic Focus Group. The Focus Group 

assisted District staff in determining the appropriate method for gathering information on 

regulatory compliance costs and business impacts resulting from compliance with the 

rule. The results of the socioeconomic analysis were compiled into a report that was 

presented along with the refined version of the proposed rule to the public and 

interested parties during the final workshop on June 17, 2009. The date for the public 

hearing to consider adoption of the proposed rule amendments was September 17, 

2009. 

II. DISCUSSION 

A. CURRENT REGULATIONS 

There are no existing rules in the nation that require 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 provides an exemption for tanks used 

in wine fermentation and storage of resulting products, by-products, and spirits. EPA 

considers VOC emissions from this source category to be significant and recommended 

further study and analysis. 

District Rule 4694 (Wine Fermentation and Storage Tanks) requires installation and 

operation of VOC emission control system to reduce emissions from wine fermentation 

and storage operations. As an alternative to controlling the emissions from wine 

fermentation and storage tanks, Rule 4694 allows operators to mitigate fermentation 

emissions by controlling alternative emission sources, such as reductions in surplus 

emissions from mobile sources, area sources, or other stationary sources. In lieu of 

installing VOC control devices on wine fermentation tanks to fulfill the Rule 4694 

requirements, operators voluntarily offered to control surplus emissions from brandy 

aging operations to obtain equivalent reductions which could then be creditable as 

Certified Emissions Reduction Credits (CER) under Rule 4694. 

To obtain the CER, operators of brandy aging facilities modified existing brandy aging 

warehouses to meet the requirements for a Permanent Total Enclosure as specified in 

EPA Test Method 204. This enabled ethanol emissions to be captured and destroyed 

using regenerative thermal oxidizer technology. Until the successful demonstration that 

the operation of the capture and control system will not result in unacceptable impacts 

on brandy quality, consistency, or volume loss, the conditions of the operating permits 

are provisional and subject to revisions. Operation of these controls has demonstrated 

that they are technologically feasible as VOC controls and are tentatively considered 
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applicable to both wine aging and brandy aging, pending final determination of the 

controls impacts on the brandy aging operations. 

B. SUMMARY OF PROPOSED RULE 

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

Ozone Plan. The draft rule would serve as a “backstop” measure to codify the control of 

VOC emissions from the aging of brandy which are currently being implemented by 

operators as an alternative compliance option in lieu of controlling the emissions from 

wine fermentation and storage in order to comply with Rule 4694 (Wine Fermentation 

and Storage). This proposed new Rule will require appropriate VOC control measures 

for wine aging operations which are currently uncontrolled. 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 operations, 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 with independent thresholds and 

application of control technologies. 

The major rule requirements include RACT, Additional RACT, and BARCT based on the 

throughput or emissions from the brandy aging or wine aging operations: 

• For a facility with a brandy or wine aging operation which has either an inventory 

or emissions less than Table 1 thresholds, operators must implement 

Reasonable Available Control Technologies (RACT) to include record keeping 

and work emission minimization practices. Such work practices include: prevent, 

minimize, and restrict the unnecessary occurrence of brandy or wine exposure to 

the atmosphere; prevent, minimize, and restrict the occurrence of leaks and 

spills; implement immediate clean up of leaks and spills by rinsing leaks or spills 

with water and washing the rinse into a proper drain; and implement immediate 

corrective actions to prevent a reoccurrence of a similar leak or spill. These are 

all reasonable practices currently being used by existing operations. 

• For a facility with a brandy aging operation that equal or exceed both the 

applicable inventory and the emissions thresholds listed in Table 1, the operator 

shall implement brandy RACT by implementing record keeping and work 

emission minimization practices in addition to BARCT 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 stringent and has a total 

control efficiency of 90 percent through the use of the Permanent Total 

Enclosure (EPA Method 204) to encapsulate the emissions in the building 

(92% control efficiency) which are then vented to a Thermal Oxidizer (TO) 

that burns off the VOC emissions (98% control efficiency). 
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o BARCT does not require refrigeration, but large warehouses usually 

practice refrigeration to minimize ethanol evaporative 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 required for operational 

or maintenance functions and/or when the VOC control device is 

shutdown for scheduled routine maintenance. Cumulative duration for all 

such periods are not exceed eight (8) percent of the total operating hours 

or 701 hours per year, whichever is less. This duration includes periods 

of downtime as required to perform scheduled routine maintenance, 

which are not to exceed three (3) percent of the total 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 that 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 equals or exceed both the 

applicable inventory and the emissions thresholds listed in Table 1, the operator 

shall implement RACT record keeping and work emission 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 smaller operations and is not as 

stringent as BARCT for this class and category of source. Additional RACT 

specifies maintaining a nominal warehouse daily temperature, averaged over a 

calendar year, not to exceed 70 degrees Fahrenheit. 

o As explained later in this report, research into the affects of humidity and 

temperature has shown that controlling these factors can reduce 

evaporation and therefore control VOC emissions. The 70 degree 

temperature threshold was set high enough to allow for variations in 

aging practices and equipment limitations while still 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 operation 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 refrigeration. 

o Two additional RACT control alternatives to the temperature 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 equation and an Aging 

Emission Factor (AEF) of 0.02783, which is based on the District default 
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3% evaporative loss rate, as explained below. This option is considered 

to produce equivalent reductions to the temperature option. 

o The second control alternative is to age wine in non-porous tanks. These 

tanks must be equipped with operable pressure-vacuum relief valves and 

the temperature of the aging wine must be maintained at or below 75 

degrees Fahrenheit. This alternative is already achieved in practice on 

tanks which are used for wine storage and must comply with Rule 4694 

(Wine Fermentation and Storage) requirements. 

Table 1 below summarizes the thresholds and applicable 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 annual brandy evaporative loss rate 

of 3 proof gallons per barrel per year, and an average annual wine evaporative loss rate 

of 3% by volume per barrel per year, and a cost effectiveness of approximately $25,000 

per ton for both. Using these emission factors, wine has an ethanol level of nearly onesixth that of brandy and a proportionally lower emission rate. Because of the 

differences in emission rates, wine aging controls have much higher cost effectiveness 

values compared to a similarly-sized brandy aging warehouse. Cost effectiveness 

details are provided in Appendix C. 

The rule allows facilities the opportunity to calculate and use their own Uncontrolled 

Aging Emissions (UAE) in relation to this rule’s thresholds. To determine a specific 

operation’s Uncontrolled Aging Emissions (UAE) use the following formula: 
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UAE = TAAI * AEF 

Where: 

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

GMI = Gallons in Monthly Inventory, in gallons per 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 per 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 per barrel per year. This is 

explained in great detail below. Using the above loss rates allows for the aging emission 

factors to be calculated as follows: 

Brandy Default AEF = 3 proof gallons loss/50 gallon 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 Barbara Air 

Pollution Control District’s ‘Wine Production Emission 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 operators to calculate the brandy and 

wine AEF using such a site-specific loss rate in place of the District’s default values. 

This allowance is to reflect the effects of individual 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 aging emissions do not exceed 0.3% by 

volume. This fugitive emission value is equivalent the fugitive emissions released by a 
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PTE and RTO that have a combined destruction efficiency of 90%. The basis for this 

allowance is as follows: 

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

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

• The PTE is vented to a VOC control device that destroys 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 destruction efficiency 

• If 90% of the evaporative loss is captured and destroyed, then 10% of the 

ethanol (or 0.3% of the total wine) would be emitted 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 than 0.3% of the total wine is 

equivalent to a PTE and VOC control having a 90% capture and control 

efficiency. 

Secondly, the rule allows operators to use non-wooden 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 eliminates evaporation and emissions 

from the aging operations by maintaining the tank contents 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 temperature variability. Tank 

contents are maintained at or below 75o

F. Volumetric loss rates for these tank controls 

are expected to be 0.3% or less, which would be equivalent 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 technique. 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 from 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 that aptly demonstrates for the 

purposes of this rule the scientific relationship of decrease temperature and proportional 

decrease of monthly ethanol evaporation from barrel aging wine as shown below in 

Diagram 1. 
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Diagram1. Linear regression of temperature and ethanol 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 controls regularly put into practice 

other than temperature control, as currently achieved 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 increase 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 Joaquin Valley has great diurnal and 

seasonal temperature variations. Diurnal variations from night to day average 30 

degrees, with extreme diurnal variations of up to 64 degrees Fahrenheit. The seasonal 

winter to summer monthly variations average 60 degrees, 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 temperatures below a certain point, generally 

around 60 degrees Fahrenheit. The exact aging temperature 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 refrigeration equipment limitations. 

Another seasonal operational factor involved in an aging warehouse’s daily temperature 

fluctuations is fermentation. Fermentations produce 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 excess carbon dioxide gas thus 

contributing to daily variations in a controlled warehouse’s daily temperature. 

Consequently, because of the above detailed diurnal and seasonal temperature 
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fluctuations the warehouse nominal daily temperature 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 also implement capture and control of 

VOC emissions by using a PTE vented to a control device. 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 operations in the District are using a 

warehouse that is a PTE venting to a Regenerative Thermal Oxidizer (RTO). Out of 

several control devices at stakeholder disposal, the brandy aging industry has 

universally selected the use of a Regenerative Thermal Oxidizer (RTO) due to its low 

annual maintenance costs for this control application. 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 alternative compliance option in lieu of 

controlling the emissions from wine fermentation and 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 reductions 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 01 0 

Total 42.6 0.12 

1 Current wine aging facilities meet RACT control requirements. 

In determining a reasonable level at which to require BARCT, staff used a $25,000 per 

ton cost effectiveness cut point. This level is similar to that which has been historically 

used in other VOC control rule determinations. This 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 the District (except one facility that is not 
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industry representative). The subsequently calculated brandy aging emission factor is 

0.1986 pounds ethanol per gallon annually. 

District research developed an evaporative loss rate 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 range, the 3% value is the appropriate 

value to use for the District’s evaporative loss rate, which takes into account weighted 

inventories and evaporative loss rates. The wine evaporative loss rate of 3% by volume 

per barrel per year and the wine aging emission factor of 0.02783 pounds ethanol per 

gallon are based on the results of District research outlined in the following: 

• According to Tobacco and Tax Trade Bureau (TTB) data 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 includes losses due to spillage, 

leakage, soakage, evaporation, include aging, and other 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 rates can be no less than 0.16% 

by volume per year. This sets the low end of the evaporative 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 volume, 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 facility. These smaller facilities average 

approximately 800 – 1,000 barrels in aging inventory. District staff understands 

that these smaller facilities do not utilize climate controls for their aging barrels 

and that these barrels are aged in existing operational buildings (fermentation, 

storage tank, filtering, and/or bottling rooms/buildings). From the District survey 

these smaller facilities make up 37% of the annual wine aging inventory gallons. 

• District research has also shown wine aging warehouses that are in mild climates 

(or warehouses that are operated with climate controls of approximately 60 

degrees Fahrenheit and 75 percent humidity, according to stakeholder 

information) are expected to have loss rates of no greater than 3% by volume, 

based on the factor developed by the publicly-vetted Santa Barbara Air Pollution 

Control District permit development process. Santa Barbara has a mild climate 

with average temperature of 61 degrees Fahrenheit and 50% humidity. 

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

the TTB whereby losses due to spillage, leakage, soakage, evaporation, 

including wine aging, and other losses normally occurring from racking and 

filtering, of up to 3% loss by volume, are not taxed. It is assumed that this 

allowance is recognition that the 3% loss is what would normally occur from a 

reasonably well-managed wine production operation. Since the other 97% is 
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taxed, operators would have an incentive to minimize emissions or they would 

end up being taxed on lost product. 

• Published research has also shown that measured wine evaporative loss rates 

which were measured under environmentally controlled conditions in wine aging 

warehouses and caves - demonstrate a wine aging evaporative loss range from 

0.3% to 1.4% by volume. This measured wine evaporative 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 temperature spread was 

selected from the data set to reproduce the wine evaporative 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 requirements 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 inventory, 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. These 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 per ton. Because there are no wine 

aging warehouses of that size in the Valley, and because 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 installation 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 heat, originally from open flames, 

to wine. This wine is boiled at a temperature between the boiling point of alcohol (ethyl 

alcohol) and the boiling point of water. This heating a liquid to separate components 

with different boiling points is called heat distillation. The low-boiling point liquids 

distilled from wine include almost all of the alcohol, a small amount of water, and many 

of the wine's organic compounds. It is these chemicals that give brandy its taste and 

aroma. The resulting vapors are collected and cooled. 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. 
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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 bottled at a minimum of 80° proof. In 

the United States, "proof" denotes the ethyl alcohol 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 proof 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 fermentation of sugars in fruit juices, 

primarily grape juice. This fermentation process is an anaerobic breakdown of organic 

compounds by microscopic yeast organisms which provide complicated enzymes that, 

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

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

where at 55 to 600

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

take 3 to 6 days to ferment. In commercial wineries 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, wine is transferred a number of times 

between storage tanks to perform various finishing operations such as racking or 

decantation for separation of sediment, and filtration. 

In California, table wines can be made from either a single grape variety or made from a 

combination of many grape varieties. These table wines have an alcohol content that 

ranges from 7 to 14 percent by volume (14° to 28° proof). Some of these table wines 

are subsequently aged in oak barrels or casks, to improve 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 of 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 process 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 turned, and when stored horizontally, 

facilitates racking or the transfer of the liquid to another barrel. 
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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) which develop into a multitude of 

sweet woody aromas, which will add flavor to whatever liquid is stored inside the barrel. 

For wines, this ‘toast’ level can be adjusted according 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 mellows 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 makes it possible to immediately detect 

any leaks, or mere traces of moisture caused by unusually 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 nearly three inches shorter and over one 

inch broader at the bilge. Wine barrels are purchased new or used and are made of 

oak from America, France, or Eastern Europe. Larger 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 used to ferment or age the wine. 

D. Fugitive Emission Driving Force: Diffusion

Wood is a solid, porous, and permeable material. Porosity 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 cell 
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wall. Permeability is a measure of the ease by which fluids are transported through a 

porous solid under the influence of some driving force, such as chemical potential. 

There are several types of chemical potential driving 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 structure. These pathways consist of 

cavities in vessel cells, fibers, ray cells, pit chambers, intercellular spaces, and 

transitory cell wall passageways. 

Diffusion will redistribute moisture and vapor between the interior and exterior barrel 

surfaces, until the moisture or vapor level is uniform throughout the wood and the 

surrounding air, and a zero chemical potential gradient is reached at equilibrium. 

Diffusion’s constant driving force to reach equilibrium, forces a wine’s 7 to 14%, or a 

brandy’s 40% alcohol from the porous barrel into the 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 known today as fugitive emissions. 

IV. Fugitive Emission Control Techniques 

A. 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 could be considered to be 100%. However, since 

brandy aging and wine aging operations are a continuous 24 hour/day operation 

throughout the year, it would be difficult and expensive 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 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. 

Although neither of the terms “Fan Inlet Pressure Control Point” and “Maximum 

Allowable Negative Gauge Pressure” appear in EPA Method 204, the industry has 

previously indicated that there are technical difficulties with continuous monitoring and 

directly controlling a differential pressure of 0.013 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 the induced draft fan, typically located 

on the inlet ductwork near the fan inlet plenum. Due to pressure losses in the ductwork, 

the vacuum at this point is considerably higher than that in the warehouse (on the order 

of 2 “WC) which is more easily measured and controlled. The facility is required to 
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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 combustion to destroy VOCs. 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 

(1,200o

F to 1,600oF) when treating low concentration streams. Recent source tests at 

existing facilities utilizing TO control have demonstrated a 98% destruction efficiency at 

a combustor temperature of 1400o Fahrenheit. 

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 produces NOx, an ozone precursor 

like VOC, thus offsetting some of the VOC emission reduction. The District considers 

thermal oxidation as technologically feasible for the application to brandy aging and 

wine aging. 

Stakeholders have implemented thermal oxidation controls for their brandy storage 

warehouses and are currently adjusting the functional operations of this system to 

minimize any detrimental quality and evaporative effects. 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 recuperative 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 costs in certain circumstances. Since 

catalysts are employed, these systems are subject to catalyst poisoning or deactivation 

due to operating upset and may require periodic catalyst replacement, which represents 

a substantial operating cost. 
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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 aging and wine aging and that a control efficiency of 98% is reasonably 

achievable. 

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 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 

and wine aging. Based on a draft technical assessment document (TAD) prepared by 

the ARB, 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. 

 

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 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 counter 
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flow 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 the 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 brandy aging and wine aging and that a control efficiency of 

90% is reasonably achievable. 

 

5. 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 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 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 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 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 
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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 demonstrated 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 wine aging and that a control efficiency of 90% is 

reasonably achievable. 

C. Emission Reductions 

The 2007 Ozone Plan estimates a 2012 brandy aging and 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 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 

emission reductions are currently achieved in practice and are considered RACT and 

are not creditable to this rule. 

As previously stated in this Draft Staff Report, the District sought as much reduction of 

VOC emissions from brandy aging and wine aging as expeditiously as practicable, 

technologically feasible, and economically reasonable, as determined by the District’s 

Governing Board. The VOC emissions reduction analysis is presented in Appendix B of 

the Final Draft Staff Report and also includes stakeholder submitted data. 

V. COST EFFECTIVENESS ANALYSIS 

Pursuant to CH&SC section 40920.6(a), a cost effectiveness analysis is required for rules 

that implement RACT. The purpose of the cost effectiveness analysis is to evaluate the 

economic reasonableness of the rule or rule amendments. The analysis also serves as a 

guideline for developing the control requirements of the rule. District staff has conducted a 

cost effectiveness analysis for Rule 4695. The cost effectiveness analysis is presented 

in Appendix C of the Final Draft Staff Report. 
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VI. SOCIOECONOMIC ANALYSIS 

Pursuant to CH&SC 40728.5, “whenever a district intends to propose the adoption, 

amendment, or repeal of a rule or regulation that will significantly affect air quality or 

emissions limitations, that agency shall, to the extent data are available; perform an 

assessment of the socioeconomic impacts of the adoption, amendment, or repeal of the 

rule or regulation.” The socioeconomic impact of Rule 4695 is presented in Appendix D 

of the Final Draft Staff Report. 

VII. RULE CONSISTENCY ANALYSIS 

Pursuant to the state Health and Safety Code, Section 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 Act (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 will not have any significant adverse effects 

on the environment. Staff recommends filing a Negative Declaration under the provisions 

of the Public Resource Code 15061 (b) (3) to be presented 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, Practical Winery and Vineyard, 

January/February, 20-22, (1991). 

3. Botany 410: 

http://www.botany.hawaii.edu/faculty/webb/bot410/410Labs/LabsHTML99/Xylem/Labxyphlo99.html

4. California Air Resources Board (ARB) 8/06/03 Draft Technical Assessment 

Document “Strategies and Costs for Winery Ethanol emission 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 Communication, August, 22, 2008. 

8. Google Images: 

http://images.google.com/images?q=picture+of+wood+seive+tubes&rls=com.mic

rosoft:en-us&ie=UTF-8&oe=UTF8&um=1&sa=X&oi=image_result_group&resnum=1&ct=title. 
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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 Measure for Control of Ethanol 

Emissions From Winery Fermentation Tanks. October 7, 1986. 

15. San Joaquin Valley Unified Air Pollution Control 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 Control District, ‘2007 Ozone Plan’, 

2007. 

17. Santa Barbara county Air Pollution Control District: 

http://www.sbcapcd.org/eng/winery/winery.htm. 

18. Strategies and Costs for Winery Ethanol Emission 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 Regulations, Amended Clean Air 

Act’, February 24, 2004. 

21. Willey, G., Supervising Engineer, Engineering Department, San Luis Obispo Air 

Pollution Control District, Personal Communication, August, 21, 2008. 

22. World Cooperage: 

http://www.worldcooperage.com/pages/product_barresl_trad,html.