SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Health Risk Analysis for Rule 4694 December 15, 2005

E-1 Final Staff Report with Appendices

For Proposed Rule 4694

APPENDIX E

Health Risk Analysis For

RULE 4694 (Wine Fermentation and Storage Tanks)

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

Appendix E: Health Risk Analysis for Rule 4694 December 15, 2005

E-2 Final Staff Report with Appendices

For Proposed Rule 4694

Winery Modeling

For

Rule 4694

BY

San Joaquin Valley APCD

Kathi Crump and Leland Villalvazo
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Health Risk Analysis for Rule 4694 December 15, 2005

E-3 Final Staff Report with Appendices

For Proposed Rule 4694

Executive Summary

This document contains the health risk assessment (HRA) for E & J Gallo Winery –

Fresno, located at 6510 E Olive Fresno, California with 67,000,000 gallons/yr of wine 

fermentation (including both white & red wines) and E & J Gallo Winery – Livingston, 

located at 18000 West River Road Livingston, California with throughputs of 73,721,600 

gallons/yr (including both white & red wines).

The risk assessment was prepared to comply with the AB 2588, Air Toxic Hot Spots 

Information and Assessment Act of 1987. This HRA was conducted in accordance with 

the Office of Environmental Health Hazard Assessment (OEHHA) Health Risk 

Assessment Guidelines.

Emissions of toxic air contaminants from the facility have been identified and the 

resulting potential ambient air concentrations have been calculated. These 

concentrations have been used to arrive at conservative estimates of increase 

carcinogenic risk that might occur as a result of continuous exposure over a 70-year 

lifetime. In a similar fashion, concentrations of compounds with a non-carcinogenic 

adverse health effects were used to calculate the hazard indices (ratio of expected 

exposure to an acceptable exposure). A hazard index less than 1.0 is not considered to 

be a significant health risk. A hazard index greater than 1.0 is considered to be a 

significant risk and would result in the District consulting with the Office of 

Environmental Health Hazard Assessment (OEHHA) to determine the significance on a 

case-by-case basis. 

Carcinogenic risk was calculated at the site of the maximum offsite location. The 

resulting risk from the Livingston facility is 0.0894 in one million cancer cases, 0.0196 

for the chronic hazard index, and 0.0296 for the acute hazard index. The resulting risk 

from the Fresno facility is 0.0935 in one million cancer cases, 0.0208 for the chronic 

hazard index, and 0.0464 for the acute hazard index. 

Based on the results from the health risk assessment, it is not expected that any winery 

operating in the San Joaquin Valley would pose a significant risk. (A significant risk is 

considered to be a risk of 10 in one million cancer case or greater than or equal to one 

for either the acute or chronic hazard index.)

Results were similar for each analysis performed for eleven other wineries. 

Prioritization scores for all facilities are presented in Appendix 2.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Health Risk Analysis for Rule 4694 December 15, 2005

E-4 Final Staff Report with Appendices

For Proposed Rule 4694

SECTION 1

INTRODUCTION

This document presents the Health Risk Assessment for the emissions from E & J Gallo 

Winery – Fresno & Livingston for permitted tank throughput. This risk assessment was 

conducted in accordance with the AB2588 Health Risk Assessment Guidelines 

(OEHHA). This HRA includes: (1) an analysis of the dispersion of chemical emissions 

from the facility, (2) an assessment of human exposure to the chemicals, and (3) a 

quantitative estimation of individual health risks associated with those levels of 

exposure found in the OEHHA HRA Guidelines.

This HRA represents the results of an assessment that relied on emissions estimates, 

air dispersion modeling, and exposure scenarios. Conservative factors were selected to 

ensure that a health conservative approach was maintained throughout the process. 

The following portions of this section will describe the general approach used to 

development the Health Risk Assessment and the rationale for the modeling approach 

selected for these wineries.

1.1 Facility Description

E & J Gallo Winery – Fresno, located at 6510 E Olive Fresno, California and E & J Gallo 

Winery – Livingston, located at 18000 West River Road Livingston, California. E & J 

Gallo Winery is an independent winery with wine production, sales, and support 

operations located in Fresno and Livingston, California. 

The following device types were modeled in this HRA.

Winery Fermentation Tanks

A review of AP-42 section 9.12.2 table 4-3, provided by Dan Barber, indicated that the 

primary toxic substance of concern from both a potency and risk standpoint is Hydrogen 

Sulfide and Acetaldehyde. Hydrogen Sulfide was emitted at a rate of 667.4 pounds per 

year (Fresno) and 727.96 pounds per year (Livingston). Acetaldehyde was emitted at a 

rate of 91.8 pounds per year (Fresno) and 102.04 pounds per year (Livingston). 

1.2 General Approach to Health Risk Assessment

A refined risk assessment, also called a comprehensive risk assessment as defined by 

the OEHHA HRA Guidelines, evaluates potential health risks to all individuals within the 

area of concern. To evaluate potential health risks to individuals, distinct exposure 

concentrations are determined for a network of receptors within an area around the 

facility. Risks at sensitive receptors (i.e., schools, day care centers and hospitals) were 

also evaluated. However, none were found to exceed a 1 in a million cancer risk or 1.0 

Hazard Indices. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Health Risk Analysis for Rule 4694 December 15, 2005

E-5 Final Staff Report with Appendices

For Proposed Rule 4694

1.3 Health Risk Assessment Approach

The USEPA model called ISCST3 was selected for the air dispersion model. Some key 

factors in the model setup included the use of Regulatory Default, Rural Dispersion 

(Fresno) or Urban Dispersion (Livingston) mode, and the treatment of fugitive emission 

as an area source. 

The Carcinogenic and Non-Carcinogenic risk values were derived by transferring the 

output of the lSCST3 dispersion modeling runs into a chemical analysis program. This 

program evaluates the effects of exposures to toxic substances under the influence of 

hourly meteorological data. The meteorological data used for this project has been 

approved by the District for modeling sources located in the Northern (Modesto Airport 

1999) and Central (Fresno Airport 1989) regions of the San Joaquin Valley.

An analysis of the results of the modeling runs conducted yielded predictions for the 

maximum exposed individual (MEI) at a hypothetical receptor. At this location, the 

maximum carcinogenic risk expressed in excess cancer cases per million exposed 

persons and the maximum hazard indices for both an acute and a chronic exposure 

expressed as a ratio to the Reference Exposure Levels (REL) are calculated and 

reported. The reported calculations were performed at the point of maximum exposure 

(MEI) in the belief that all other exposed persons will have risks that would not be any 

higher than those reported. It is important to remember that the MEl may not represent 

a specific person, but rather a predicted location at which a person might be exposed if 

he or she were to remain for an average person’s lifetime. This period is defined as 70 

years, 365 days a year, 24 hours per day. This average person’s lifetime is selected to 

be conservative in that it is a representation of the worst plausible exposure situation.

I.4 Comments Regarding the Modeling Approach used in performing the 

Health Risk Assessment

The District requires that certain options in the ISCST3 modeling program be selected 

unless a reasonable justification is approved before any modeling is performed. The 

required options include the regulatory default setting, the appropriate dispersion type ( 

i.e. urban or rural ), and the treatment of point and area sources. 

A chemical analysis program was used in conjunction with the ISCST3 modeling 

program to determine carcinogenic and non-carcinogenic risk values. The output file 

from the ISCST3 runs were inputted into ARB’s HARP. The HARP program requires 

that the air dispersion model (ISCST3) be run with a normalized emission rate for each 

source at 1 gram per second. The chemical analysis program will then take actual 

emission rates from each source and scale the estimated concentration at each 

receptor to reflect the concentration of estimated ground level concentrations of each 

toxic substance at each receptor modeled. The chemical analysis program then 

proceeds to perform the risk calculations based on OEHHA’s slop factor and REL 

factors to determine the total carcinogenic and non-carcinogenic risks at each receptor 

for all listed substances that have Slop Factors or REL. The final report from the HARP 

program is the estimated maximum Cancer Risk, non-carcinogenic Acute Hazard Index 

and non-carcinogenic Chronic Hazard Index at each receptor.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Health Risk Analysis for Rule 4694 December 15, 2005

E-6 Final Staff Report with Appendices

For Proposed Rule 4694

SECTION 2.0

HAZARD lDENTIFICATION

Hazard identification involves determining the potential health effects that may be 

associated with emitted pollutants. The OEHHA Guidelines are a compilation of both the 

chronic and acute potential health effects of numerous air contaminants. 

The chemicals of concern emitted from the two E & J Gallo wineries are discussed 

briefly in Subsection 2.1. The non-carcinogenic health effects are discussed in 

Subsections 2.2 and 2.3 (chronic and acute, respectively). Carcinogenic health effects 

are discussed in Subsection 2.4. 

2.1 Chemicals of Concern

There are three chemicals emitted E & J Gallo wineries that have been assigned by the 

Office of Environmental Health Hazard Assessment as having a Reference Exposure 

Level (REL) or carcinogenic slop value. They are as follows:

Acetaldehyde, Hydrogen Sulfide, Methanol

2.2 Chronic Non-Carcinogenic Hazard

Chronic toxic effects are associated with long-term exposure to relatively low levels of a 

potentially hazardous substance. The chronic non-carcinogenic chemicals of concern 

from the E & J Gallo wineries were identified by comparing the chemicals listed in AP42 with those listed in OEHHA’s Guidelines. Acetaldehyde, Hydrogen Sulfide, and 

Methanol are the substances from AP-42 that was analyzed for chronic noncarcinogenic health effects.

2.3 Acute Non-Carcinogenic Hazard

Acute health effects are associated with a single exposure or repeated exposure over a 

short time period to relatively high concentrations of a chemical. The maximum hourly 

emission rates calculated from AP-42 were used to assess acute health hazards from 

those chemicals having acute toxic effects. The acute non-carcinogenic chemicals of 

concern from the E & J Gallo wineries were identified by comparing the chemicals listed 

in AP-42 with those listed in OEHHA’s Guidelines. Hydrogen Sulfide, and Methanol 

were identified as potentially posing an acute hazard.

2.4 Carcinogenic Hazard

Carcinogenic effects are generally associated with long-term exposure to relatively low 

levels of a hazardous substance. The carcinogenic chemical emitted from E & J Gallo 

wineries was Acetaldehyde. Comparing the chemicals listed in AP-42 with those listed 

in OEHHA’s Guidelines identified this substance. In accordance with the OEHHA’s 

Guidelines, the risks from this carcinogen was considered to be additive regardless of 

their mechanism of action on the likely target organ.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Health Risk Analysis for Rule 4694 December 15, 2005

E-7 Final Staff Report with Appendices

For Proposed Rule 4694

SECTION 3.0

DOSE-RESPONSE ASSESSMENT

Dose-response assessment is the process of characterizing the relationship between 

the dose of a chemical and the incidence of adverse health effects. From the 

quantitative dose-response relationship, values can be derived to estimate the likelihood 

of a specific adverse health effect as a function of exposure. Values used to assess 

health risks in this report include Acceptable Exposure Level (REL for non-carcinogens 

and the Slop Factor for carcinogens as compiled by OEHHA. These values are 

presented below. 

CAS # Compound _

75070 ACETALDEHYDE

ACUTE HAZARD

VALUES

CHRONIC HAZARD RESP

VALUES 1.11E-01

CARCINOGENIC AIR

2.70E-06

_________________________________________________________________________________________________________

_____

67561 METHANOL

ACUTE HAZARD CNS

VALUES 4.00E-05

CHRONIC HAZARD DEVEL

VALUES 3.00E-04

CARCINOGENIC 

_________________________________________________________________________________________________________

_____

7783064 HYDROGEN SULFIDE

ACUTE HAZARD CNS

VALUES 2.38E-02

CHRONIC HAZARD RESP

VALUES 1.00E-01

CARCINOGENIC 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Health Risk Analysis for Rule 4694 December 15, 2005

E-8 Final Staff Report with Appendices

For Proposed Rule 4694

SECTlON 4.0

EXPOSURE ASSESSMENT

Exposure assessment techniques measure the quantities or concentrations of 

risk agents received by individuals or populations. Exposure assessments 

typically estimate concentrations of a risk agent at a particular point of contact. 

Estimated chemical concentrations in the environmental media (e.g. air, soil, 

vegetables) and assumptions regarding probable human contact with these 

media are used to calculate an average daily human dose of the contaminants of 

concern. 

Emission rates of toxic compounds from each source at the facility were 

calculated from AP-42 section 9.12.2 table 4-3, provided by Dan Barber. The 

annual averages and maximum hourly emission rates found in Appendix 1 were 

used for calculating annual average and maximum hourly ambient air 

concentrations of the contaminants. The District approved Industrial Source 

Complex-Short Term (lSCST3) modeling program was used to predict 

ground-level concentrations. Below are the source parameters used during the 

ISCST3 modeling runs. 

E & J Gallo - Fresno

• Source Parameters

o Ht = 10m

o Area = 250m X 375m

• Modeled as Urban

• Fresno 1989 Met data

• 5388 Receptors

E & J Gallo - Livingston

• Source Parameters

o Ht = 10m

o Area = 267m X 550m

• Modeled as Rural

• Modesto 1999 Met data

• 3044 Receptors

The lSCST3 dispersion model was used to provide ambient air concentrations 

(i.e., concentration per unit emission rate) at the site of maximum impact and at 

other various receptor sites. ARB’s/ OEHHA’s approved HARP program was 

used to calculate the inhalation exposures of specific facility-emitted air toxics at 

each receptor site. This model provides both the risk value at the site of 

maximum impact and the maximally exposed receptor. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Health Risk Analysis for Rule 4694 December 15, 2005

E-9 Final Staff Report with Appendices

For Proposed Rule 4694

Appendix 1

Emission Factors

And

Emissions Summary
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Health Risk Analysis for Rule 4694 December 15, 2005

E-10 Final Staff Report with Appendices

For Proposed Rule 4694

Emission Factors

Red Wine

Pollutant Name Emission Factor

Acetaldehyde 0.0027 lb/1000gal

Hydrogen Sulfide 0.0017 lb/1000gal

Methanol 0.0036 lb/1000gal

White Wine

Pollutant Name Emission Factor

Acetaldehyde 0.00072 lb/1000gal

Hydrogen Sulfide 0.014 lb/1000gal

Methanol 0.00064 lb/1000gal

Emissions Data

E & J Gallo - Fresno

Red Wine

Pollutant Name Lb/HR Lb/Yr

Acetaldehyde 6.78 E-3 59.4

Hydrogen Sulfide 4.27 E-3 37.4

Methanol 6.28 E-3 55.0

White Wine

Pollutant Name Lb/HR Lb/Yr

Acetaldehyde 3.70 E-3 32.4

Hydrogen Sulfide 7.19 E-2 630.0

Methanol 3.28 E-3 28.8

E & J Gallo - Livingston

Red Wine

Pollutant Name Lb/HR Lb/Yr

Acetaldehyde 7.62 E-3 66.76

Hydrogen Sulfide 4.80 E-3 42.03

Methanol 7.06 E-3 61.82

White Wine

Pollutant Name Lb/HR Lb/Yr

Acetaldehyde 4.03 E-3 35.28

Hydrogen Sulfide 7.83 E-2 685.93

Methanol 3.58 E-3 31.36
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Health Risk Analysis for Rule 4694 December 15, 2005

E-11 Final Staff Report with Appendices

For Proposed Rule 4694

Appendix 2

Prioritization Scores

For 13 Winery Facilities

N-266 7,600,000 14,500,000 22,100,000 1.42E-01 4.31E-01 8.82E-01

N-956 7,000,000 5,500,000 12,500,000 1.05E-01 1.97E-01 3.63E-01

N-1237 24,726,000 48,995,600 73,721,600 4.69E-01 1.45E+00 2.97E+00

N-1665 24,200,000 26,900,000 51,100,000 3.89E-01 8.81E-01 1.71E+00

N-2321 7,300,000 10,000,000 17,300,000 1.24E-01 3.14E-01 6.23E-01

N-3386* 0 0 0 0.00E+00 0.00E+00 0.00E+00

N-4939 7,100,000 7,900,000 15,000,000 1.14E-01 2.59E-01 5.01E-01

* Data has been requested from the facility

Adjustment Factors Cancer Chronic Acute

White 3.31E-09 2.55E-08 5.72E-08

Red 1.24E-08 8.07E-09 6.93E-09
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix E: Health Risk Analysis for Rule 4694 December 15, 2005

E-12 Final Staff Report with Appendices

For Proposed Rule 4694

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