SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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

F-1 Final Staff Report with Appendices 

For Revised Proposed Rule 4694

APPENDIX F

Rule Consistency Analysis For 

RULE 4694 (Wine Fermentation and Storage Tanks)

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

Appendix F: Rule Consistency Analysis for Rule 4694 December 15, 2005

F-2 Final Staff Report with Appendices 

For Revised Proposed Rule 4694

RULE CONSISTENCY ANALYSIS FOR PROPOSED RULE 4694

I. REQUIREMENTS FOR RULE CONSISTENCY ANALYSIS

Pursuant to Section 40727.2 of the California Health and Safety Code, prior to adopting 

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

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

corresponding elements of existing or proposed District and EPA regulations and 

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

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

II. RULE CONSISTENCY ANALYSIS RESULTS

A. SJVUAPCD Rules

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

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

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

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

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

Rule), and Rule 4102 (Nuisance).

B. Federal Rules and Regulations

1. Federal New Source Performance Standards (NSPS)

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

or bulk-wine storage tanks were found. Subpart Kb-Standards of Performance for 

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

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

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

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

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

exemption criteria.

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

Standards for Hazardous Air Pollutants (NESHAP), and Maximum Achievable 

Performance Standards (MACT)

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

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

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

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

tanks.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix F: Rule Consistency Analysis for Rule 4694 December 15, 2005

F-3 Final Staff Report with Appendices 

For Revised Proposed Rule 4694

3. EPA Policy on Record Keeping

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

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

Appendix F: Rule Consistency Analysis for Rule 4694 December 15, 2005

F-4 Final Staff Report with Appendices 

For Revised Proposed Rule 4694

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