UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA’s Rulemaking for the California State Implementation Plan

regarding

San Joaquin Valley Unified Air Pollution Control District (SJVUAPC D)

SJVUAPCD Rule 4694 Wine Fermentation and Storage Tanks

Prepared by: Lily Wong

April 1 2 , 201 22 TABLE OF CONTENTS

1. Rule Identification

2. Background

a. San Joaquin Valley Nonattainment Status

b. Clean Air Act and Reasonably Available Control Technology

c. Wine r y Emissions in SJVAB

d. Brief S ummary of O riginal ly Submitted R ule 4694

e. SJV UAPCD ’s RACT A nalysis

- W ine F ermentation

- W ine S torage
f. EPA’s Review of SJV’s RACT Analysis

- Wine Storage

- Wine Fermentation

g. Why did SJV UAPCD Amend Their Submittal of Rule 4694?

h. Effect of Interplay between Rule 4694 and Rule 4695

- RACT

- No Double Counting of Emission Reductions

3. Rule Summary

4. EPA Review Criteria

a. Enforceability

b. SIP Revisions

c. Stringency

5. EPA Evaluation

a. Enforceability

b. SIP Revisions

c. Stringency

6. EPA Action

7. Recommendations

8. References3

1. RULE IDENTIFICATION

Agency: San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD)

Current SIP Approved Rule: None

Submittal Subject to this TSD: Rule 4694 Wine Fermentation and Storage Tanks Adopted: December 15, 2005

Submitted: November 18, 2011 1

Completeness Determination: December 22 , 20 11

2. BACKGROUND

a. San Joaquin Valley Nonattainment Statu s SJVUAPCD has primary responsibility for regulating air pol lution in the San Joaquin Valley

Air Basin (SJVAB)

. The SJVAB is designated nonattainment for the 1

- hour ozone

standard

, 2 the 1997 8

- hour ozone standard, both the 1997 24

- hour and annual PM 2.5 standards, and the 2006 24

- hour PM 2.5 standard. For the 1

- hour ozone standard and the 8

- hour ozone standard , the area is classified as extreme

. EPA re

- designated the SJV AB to
attainment for the PM 10 standard ( 73 FR 66759

, November 12, 2008)

.

b. Clean Air Act and Reasonably Available Control Technology Section 182 of the Clean Air Act (CAA) requires areas that are classified as moderate or above for ozone nonattainment to implement reasonably available control technology (RACT) for major stationar y sources of volatile organic compounds ( VOCs ) or nitrogen

oxides ( NO

x ) and for sources covered by a Control Technique s Guideline s documents (CTG s ). In areas classified as extreme, m ajor stationary sources are defined as sources that

emit or have the pote ntial to emit 10 tons/ year of VOC or NO

x . While EPA has not issued a CTG for wine fermentation and storage tanks , these winery sources are major stationary

sources of VOC emissions. T herefore

, SJVUAPCD must demonstrate that RACT has been applied to winery emissions from fermentation and storage

.

1 Rule 4694 was originally submitted to EPA on June 16, 2006, and this Technical Support Document (TSD) will refer to that version of the rule as the “originally submitted Rule 4694.” On August 18, 2011, the SJVUAPCD adopted Resolution No. 11

- 08

- 20 in whic h the Governing Board approved “... an amendment to its earlier SIP submittal of Rule 4694 (Wine Fermentation and Storage Tanks), as set forth in the strike

- out version of the Rule, attached hereto and incorporated herein by this reference.” The Resolution also stated that the strike

- out text represents SJVUAPCD’s withdrawal of those provisions for consideration by EPA for SIP approval. This revised SIP submittal of Rule 4694 was submitted to EPA from California Air Resources Board (CARB) on November 18,

20 11 will be referred to in this TSD as the “amended submittal of Rule 4694.”

2 Although the 1

- hr ozone standard was revoked effective June 2005, RACT control obligations remain under CAA

Section 182 even after revocation of the 1

- hour ozone standard. S ee 40 CFR 51.905(a)(1)(i), 51.900(f)(1).4

EPA defines RACT as the “lowest emissions limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility.” ( 44 FR 53761

, September 17, 1979 ). A RACT analysis should, therefore, take into account technological a nd economic impacts of controls. As economic factors may vary within a state and between different states, a control technology or emissions limitation approved as RACT in one location does not necessarily

define RACT for another location.

c. Winery Emissions in SJVAB Wine is an alcoholic beverage produced by fermentation of sugars in fruit juices, primarily grape juice. The grape juice is inoculated with yeast and the fermentation process converts sugars to ethanol (a VOC) and carbon dioxide. Wine fermentation is seasonal and a batch process which correspond s to the grape harvest. Wine making is further categorized as red or white wine. Because of processing differences, red wine has a higher emission factor, emitting roughly 2.5 times more VOC than white wine.

After fermentation

, wine is transferred a number of times between storage tanks to perform various polish ing operations such as “racking” (decantation for separation of sediment), filtration, malolactic fermentation (breakdown of malic acid to lactic acid and carbon dioxide), and bottling operations. The VOC emissions during wine storage are categorized

as “ working losses” which occurs during transferring of wine from tank to tank, and “breathing losses” which occur during storage prior to bottling.

According to the S taff R eport for Rule 4 6 94, 3 approximately 70% of California’s wine production occurs within the SJVAB , and t he majority of wine production i n SJVAB occurs at large wineries with tens of millions of gallons of annual production capacity

. The Staff Report stated that SJVUAPCD’s 2003 PM 10 Plan estimates that ethanol emissions in the

SJVAB fr om wine fermentation, bulk

- wine storage, and barrel aging of wine and brandy averaged 7.0 tons per day (tpd) in 1999. 4 The 2004 1

- hour Ozone Plan estimated baseline

ethanol emissions from wine fermentation and bulk

- wine storage w ould be 2.1 tons per day

i n 2010

. In 2002, 18 wineries in the SJVUAPCD had annual permitted production volumes ranging from 5 million to greater than 50 million gallons. These 18 wineries accounted for

95% of the SJVAB ’s emissions from wine fermentation. Of the 109 wineries operat ing in the SJVAB in 2002, 70% of the wineries had annual production volumes of less than 200,000 gallons, and 58% of the wineries had annual production volumes of less than 2,000 gallons.

d. B rief Summary Of Original ly Submitted Rule 4694

3 Although SJVUAPCD submitted Rule 4694 twice (June 16, 2006 and November 18, 2011), SJVUAPCD only submitted one staff report for Rule 4694. The staff report is entitled, “SJVUAPCD Final Staff Report Rule 4694 (Win e Fermentation and Storage Tanks),” and dated December 15, 2005. Hereinafter, this document will be referred to as the “Staff Report.”

4 The referenced estimates of ethanol emissions were from three activities at wineries, and original ly submitted Rule

46 94 only addressed emissions from two activities

– w ine fermentation and bulk storage . Emissions from the third activity were addressed in SJVUAPCD’s September 17, 2009 adoption of Rule 4695 “Brandy Aging and Wine Aging Operations.” Rule 4695 defined agin g as keeping in a “... non

- temporary or transient manner, brandy or wine in containers with the objective of acquiring desirable characteristics from contact with wood.”5

Although EPA is not acting on the original version of Rule 4694 submitted on June 16, 2006,
EPA’s evaluation of amended Rule 4694 takes into account SJVUAPCD’s analyses with
respect to the original version of Rule 4694. Therefore the original ly submitted R ule 4694 adopted D ecember 15, 2005 is summarized below in order to provide the context for SJVUAPCD’s analyses.

Original ly submitted R ule 4694 applies to wineries that ferment wine o r store wine in bulk containers, and a s torage t ank is defined as any container having an internal volume greater

than 250 gallons that is used to hold wine

.

For the fermentation ope rations, original ly submitted Rule 4694 requires the winery to

achieve 35% reduction in annual fermentation emissions , compared against a baseline

defined in the rule . The source may comply with this requirement by: 1) capturing and controlling emissions from the fermentation tanks, 2) obtaining equivalent emission reductions from other mobile, area, or stationary sources (called “Certif ied Emission Reductions” or CERs) , or 3) paying a fee to SJVUAPCD

, which will thereafter obtain

emission reductions (called “ District Obtained Emissions Reductions” or DOERs)

. Original ly submitted Rule 4694 also includes work practice requirements to reduce VOC

emissions from storage tanks by requiring pressure

- vacuum (PV) valves and temperature

control. The s torage tank requirements are further described below in Section 3 “Rule Summary ” section of this TSD.

Except for the recordkeeping requiremen ts, original ly submitted Rule 4694 exempts wineries

who se potential to emit fermentation emis sions is less than 10 tons/year

. S torage tanks constructed of concrete or wood are also exempt from the storage tank requirements.

e. SJV UAPCD ’s RACT Analys e s During the adoption in 2005 for the originally submitted Rule 4694

, SJVUAPCD evaluated

RACT for the source category, but continued to evaluate RACT after rule adoption. 5 The

additional RACT analyses were submitted in SJVUAPCD’s 2007 Ozone Plan (hereinafte r referred to in this TSD as the “Ozone Plan”) , specifically in Appendix K

– “ Reasonably Available Control Technology (RACT) Analysis for Wine Fermentation, Wine Storage, and Brandy Aging

. ” We will consider Appendix K of the Ozone Plan as SJVUAPCD’s position

of record on RACT for wine fermentation and wine storage since it is SJVUAPCD’s most recent RACT analysis submitted for the source category.

SJVUAPC D evaluated six control technologies for wine fermentation and wine storage : thermal oxidation, catalytic thermal oxidation, regenerative thermal oxidizer, refrigerated condensers, w ater scrubb er, and carbon adsorption. SJVUAPCD conc luded that there was no feasible RACT

- level control for wine fermentation and wine storage for the following two

reasons: 1) there was no achieved in practice control technology to control VOC emissions

5 In response to EPA’s October 24 th and December 1, 2005 comments on SJVUAPCD’s draft rule and RACT analysis, SJVUAPCD continued to evaluate RACT after the adoption of Rule 4694 in an effort to address EPA’s concerns. SJVUAPCD revised its 2005 RACT analysis in 2007 to provide a more system atic analysis of whether the control technologies were technically and economically feasible.6

from wine fermentation , and 2) while t echnologically feasible control options to reduce VOC

emissions from wine fermentation and wine storage tanks exist, the options have not been

demonstrated to be economically feasible for the affected facilities

.

SJVUAPCD estimated the cost effectiveness is $32,000 to $48,000 per ton of VOC removed

for red wine fermentation, $18,000 t o $52,000 per ton for white wine fermentation, and $38,000 to $84,000 per ton for wine s torage tanks. 6 SJVUAPCD also estimated the cost

effectiveness of PV valves and PV valves with insul ation as $204,000 and $215,000 per ton
of VOC respectively. 7 SJVUAPCD stated that t hese cost effectiveness values exceed the threshold generally established by EPA for sources subject to existing CTGs

. SJVUAPCD stated that while the cost effectiveness of controls on wine storage was economically infeasible, SJVUAPCD considered the use of PV valves and temperature control as achieved in practice Best Available Control Technology (BACT) because these were already in place

on almost all wine storage tanks located in the D istrict

.

f. EPA’s Review of SJV UAPCD ’s RACT Analysis

Wine Storage
Rule 4694 requires the use of PV valves and temperature control for wine storage tanks. As

further described in “Section 5

- EPA Evaluation” of this TSD, EPA believes that Rule 4694
meets or exceeds the CAA RACT requirements for wine storage emissions.

Wine Fermentation

While EPA has raised questions regarding some of SJVUAPCD ’s assumptions in their
RACT analysis which we believe could have overestimated the cost of controls, we agree
that thus far, emission controls have not been demonstrated in p ractice for wine fermentation

emission s on the scale of the affected facilities

. Furthermore, we are not aware that other

states or air districts have adopted rules requiring controls on w ine fermentation emissions.
Therefore, we agree with SJVUAPCD that RACT for emissions from wine fermenta tion at

this time is no controls.

However, we are aware that at least one winery 8 is actively taking steps to control e missions

from wine fermentation and they are in a pilot phase of the project. In the future,
SJVUAPCD will be required again to demon strate that they have required RACT level
controls on all major stationary sources of VOC or NO

x and CTG source categories. At that
time, it is possible that there may be controls on fermentation emissions that are
demonstrated in practice and reasonably available.

6 See page Appendix K

- 3 of SJVUAPCD’s Ozone Plan.

7 See page Appendix K

- 43 of SJVUAPCD’s Ozone Plan.

8 Kendall

- Jackson Winery in Oakville, California.7

g. Why did SJV UAPCD Amend Their Submittal of Rule 4694?

As described in section 2. d . above, the original ly submitted Rule 4694 required a 35%

reduction in fermentation emissions but allow ed the source two alternative means of compliance. The source could obtain Certified E mission R eductions from other mobile, area, or stationary sources

, or the source could pay fees to SJVUAPCD for District Obtained

Emission Reductions.

EPA previously ra ised concerns that Rule 4694 did not include provisions to ensure the alternative compliance provisions would result in emission reductions that are surplus, quantifiable, enforceable, and permanent consistent with EPA’s Economic Incentive Program guidance

. 9 Because these deficiencies raised approvability concerns, SJV UAPCD withdrew from consideration for SIP approval the wine fermentation provisions, although these provisions are still in effect at the local level . The only provisions of Rule 4694 that are subject to this proposed rulemaking are the provisions that pertain to wine storage. 10

h. Effect of Interplay between Rule 4694 and Rule 4695 The implementation of Rule 4694 warrants a discussion of the confluence of two separate

issues. These issues a rise because the originally submitted Rule 4694 allows sources to comply with the fermentation emission reduction requirements by other means, including relying on brandy aging emission reductions achieved under Rule 4695. 11 This interaction

raises the fol lowing issues:

1. Are the CAA RACT requirements for wine fermentation, wine storage, brandy aging, and wine aging still met with this interplay?

2. What is nature of the reliance in attainment plans on emission reductions from wine fermentation, wine storage, and brandy and wine aging ? Has SJVUAPCD ensured

that there no double counting of emission red uctions given this interplay ?

RACT Separate from SJVUAPCD’s attainment plan provisions, commitments, and control measure assumptions, the CAA RACT requi rements are independent requirements which must be

9 EPA publ ished the guidance, “Improving Air Quality with Economic Incentive Programs” on January 2001 (EPA

452/R

- 01

- 001). The guidance is available at http://www.epa.gov/ttn/oarpg/t1/memoranda/eipf in.pdf . This guidance applies to discretionary economic incentive programs (EIPs) and represents the agency’s interpretation of what EIPs should contain in order to meet the requirements of the CAA. Because this guidance is non

- binding and does not

repre sent final agency action, EPA would us e the guidance as an initial screen to determine whether potential approvability issues arise

. 10 While the provisions of Rule 4694 that have been withdrawn are reflected as st ruck

- out text, the title of Ru le 4694

remai ns “Wine Fermentation and Storage Tanks” because the Office of the Federal Register said titles of r ule s must not be changed.

11 O n September 17, 2009, SJVUAPCD adopted Rule 4695 “Brandy Aging and Wine Aging Operations

. ” According to the Rule 4695 Final Staff Report (also dated September 17, 2009), SJVUAPCD had committed in the 2007 Ozone Plan to adopting a control measure for this source category. T he adoption of Rule 4695 also addresses in part EPA’s concerns expressed in 2005. Because Rule 4694 allow s a winery to use Certified Emission Reductions (CERs) from other operations, including brandy operations

, EPA stated that the generation of emission reductions for use as CERs must be subject to a rule to ensure that the reductions are surplus, quantifiab le,

enforceab le, and permanent.8

addressed for major stationary sources including, in SJVUAPCD, major sources in the categories wine fermentation, wine storage, brandy aging, and wine aging.

We state in section s 2.f. and 5.c. of this T SD that the wine storage provisions of Rule 4694

meets or exceeds RACT. We also concurred with SJVUAPCD that RACT for wine fermentation at this time is no controls. As such, the provision of originally submitted Rule 4694 that requires 35% reduction in f ermentation emissions is beyond RACT. Because we view the provision as beyond RACT, allowing sources alternative means to comply with the provision has no effect on the RACT determination.

Emissions from brandy aging and wine aging operations are also s ubject to RACT. On August 4, 2011, EPA approved Rule 4695 “Brandy Aging and Wine Aging Operations” into

the SIP and stated in EPA’s TSD for Rule 4695 that we concur red with SJVUAPCD's conclusion that Rule 4695 meets or exceeds RACT requirements for brandy aging operations. We also stated that w ine aging emission reductions are currently achieved in practice and therefore are considered RACT. With respect to the RACT determination for Rule 4695, it is irrelevant that brandy aging emission reductions are u sed to comply with wine fermentation requirements of Rule 4694.

If EPA had concluded that RACT for wine fermentation in Rule 4694 was some level of control and RACT for brandy and wine aging in Rule 4695 was also some level of control, it

w ould be proble matic to allow emission reductions from brandy aging to be used to meet the wine fermentation emission reduction requirements. It is only because we have determined that at this time, RACT for wine fermentation is no controls that this “trading” scenario does not create a problem with respect to meeting the CAA RACT requirements.

No Double Counting of Emission Reductions

SJVUAPCD’s 2003 PM 10 Plan and 2004 1

- Hour Ozone Plan include commitments to control emissions from wine fermentation and wine storage facilities. While the plans as submitted relied on reductions from Rule 4694, EPA’s 2010 final approval of the 1

- Hour Ozone Plan (75 FR 10240, March 8, 2010 ) did not include reductions from Rule 4694 because Rule 4694 was not yet approved into the SIP at the time of EPA’s rulemaking.

SJVUAPCD’s Ozone Plan for the 8

- hour ozone standard relies on control measures for brandy and wine aging operations as well as wine fermentation and wine storage. In recognition that the emission reductions from brandy and wine aging are being used by winery sources to comply with the wine fermentation emission reduction requirements in Rule 4694, the Ozone Plan did not claim emission reductions specifically attributable to the brandy and wine aging control measure. 12 From a practical standpoint, the emission

reductions from Rules 4694 and 4695 are handled in the Ozone Plan as if both rules were in a
“bubble.” The Ozone Plan relies on those emission reductions in the form of adjustments to

12 2007 Ozone Plan was adopted by SJVUAPCD on April 30, 2007 and submitted by CARB to EPA on June 14,

2007. Table 6

- 1 “District Stationary Source Regulatory Implementation Schedule,” shows control measure S

- IND

14, Brandy & Wine Aging, with zero emission reductions projected for all years.9

the baseline emissions inventory from Rule 4694. 13 The amount of the emission reductions projections ranges from 1.23 tpd in 2008 to 1.38 tpd in 2023. EPA approved the 2007 Ozone

Plan which provide s for attainment of the 1997 8

- hour ozone national ambient air quality

standards in the San Joaquin Valley ( 77 FR 12652, March 1, 2012 )

.

In conclusion, the Ozone Plan relies on emission reductions from wine fermentation, wine storage, brandy aging, and wine aging, but recognizes that emission reductions generated under Rule 4695 ( Brandy Aging and Wine Aging Operations ) are used for compliance under Rule 4694 (Wine Fermentation and Storage Tanks). The Ozone Plan accounts for the emission reductions once, so there is no double counting of emission reductions from Rules

4694 and 4695.

3. RULE SUMMARY

The a mended submittal of Rule 4694 regulates VOC emissions from the bulk storage of wine in tanks that hold at least 250 gallons of wine. W ine storage tank s that have the capacity of at least 5,000 gallons are require d to be equipped with PV valves, operated to maintain a gas

- tight

condition (i.e., within 10% of maximum allowable working pressure of the tank) , and maintained
at a temperature at or below 75 degree s Fahrenheit

. The a mended subm i ttal of Rule 4694 also requires recording and maintaining records on volumes of wine stored and the maximum
temperature s of the stored wine

.

4. EPA REVIEW CRITERIA EPA generally uses the following three criteria in evaluating state and local VOC rules for approval into the SIP

.

a. Enforceability

- Section 110(a) of the CAA requires enforceable SIP requirements. Several EPA guidance documents are used to evaluate rule enforceability, including the “Bluebook” ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Clarification to Appendix D) , November 24, 1978, 52 FR 45044), “the Little Bluebook” (Guidance Document for Correcting Common VOC & Other Rule Deficiencies ), EPA Region 9, A ugust 21 , 2001, and State Implementation Plans; General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990," 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 28, 1992)

.

b. SIP Revisions

- CAA section 110(l) prohibits EPA from approvin g any SIP revision that would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA section 193 prohibits the modification of any SIP

- approved control requirement in effect before November 15, 1990, in a nonattainment area.

c. Stringency

- Section 172(c)(1) of the CAA requires nonattainment areas to implement all reasonably available control measures (RACM), including such reductions in emissions f rom existing sources in the area as may be obtained through the adoption, at a minimum, of

13 S ee SJVUAPCD 2007 Ozone Plan, Table B

- 1 “ Reductions from District Rules Not Reflected in the Emissions Inventory (to be subtracted from O3S IP inventories provided by ARB)” regarding Rule 4694.10

reasonably available control technology (RACT), as expeditiously as practicable. In addition, ozone nonattainment areas classified as moderate or above must require RACT for all major sources of NOx and VOCs. CAA § 182(b)(2) & (f); 40 CFR § 51.912(a). The SJVUAPCD regulates an ozone nonattainment area that is classified as Extreme under both the 1

- hour

ozone and 8

- hour ozone standards

. Therefore, submitted Rule 4694 must fulfill RACT requirements for NOx.

5. EPA EVALUATION The submitted rule compl ies with the evaluation criteria as discussed below.

a. Enforceability

– The rule is generally clear and consistent with the Bluebook and the Little Bluebook and other relevant EPA guidance regarding enforceability.

b. SIP R evisions

– T he submitted rule is a new addition to the SIP, strengthening the requirements of the SIP. Therefore, we p ropose to determine that an approval of the submittal would comply with CAA sections 110(l) and 193 because (1) the proposed SIP revision

would not interfere with the on

- going process for ensuring that requirements for RFP and attainment of the NAAQS are m et, and (2) the submitted SIP revision is more stringent than the existing SIP requirements.

c. Stringency

– CAA RACT requirements. The amended submittal of Rule 4694 requires the

use of PV valves and temperature control for wine storage tanks

. T he Staff Report and

Ozone Plan indicate that the cost effectiveness f o r install ing PV val v es and insulation is greater than $200,000 per ton of VOC reduce d . SJVUAPCD therefore concluded that PV

valves and insulation was too expensive and not reasonably avail able. However, SJVUAPCD acknowledged that virtually all wine storage tanks subject to Rule 4694 have installed PV valves and are controlling temperature

. Consequently, SJVUAPCD considers this achieved in practice BACT.

While we are not opining on whet her such controls and practices are BACT rather than an

inherent industry practice that is a baseline control scheme

, EPA is not aware of reasonably

available control technology that might be beyond this baseline for controlling VOC

emissions

.

Because t he amended submittal of Rule 4694 requires PV valves and temperature control for wine storage tanks, EPA therefore concludes that the amended submittal of Rule 4694 meets or exceeds RACT for emissions from wine storage.

In this technical support document, we are evaluating RACT only. On December 15, 2011, EPA approved the State’s RACM demonstrations for the 1997 8

- hour ozone NAAQS based on its determination that there were no other unadopted technologically and economica lly feasible measures that alone or in combination with other such measures could provide for more expeditious advance attainment in the San Joaquin Valley . The approval was published on March 1, 2012 ( 77 FR 12652). See 40 CFR 51.912(d) and 51.1010.11

6. EPA ACTION

EPA staff recommend s full approval o f amended submittal of Rule 4695 because it compl ies with all relevant CAA requirements including those regarding enforceability

.

7. RECOMMENDATIONS

We recommend that SJVUAPCD stay abreast of the efforts at the Kendall

- Jackson w inery in

Oakville , California where they are in the pilot stage of a program to capture and control VOC emissions from wine fermentation operations. This may have relevance to SJVUAPCD’s next

ev aluation of RACT for this source category.

8. REFERENCES

a. 2007 Ozone Plan adopted by SJVUAPCD on April 30, 2007 and submi tted by CARB on June 14, 2007. The 2007 Ozone Plan includes Appendix K

– “ Reasonably Available Control Technology (RACT) Analysis for Wine Fermentation, Wine Storage, and Brandy Aging

. ” This document is available at SJVUAPCD’s website at: http://www.valleyair.org/Air_Quality_Plans/AQ_Final_Adopted_Ozone2007.htm

b. USEPA’s Technical Support Document for EPA’s proposed rulemaking on revisions to the California SIP regarding SJVUAPCD Rule 4695, Brandy Aging and Wine Aging Operations, April 2011, prepared by Christine Vineyard. This document ( EPA

- R09

- OAR

- 2011

- 0429

- 0005) is available at www.regulations.gov at the following web link: http://www.regulations.gov/#!documentDetail;D=EPA

- R09

- OAR

- 2011

- 0429

- 0005

c. SJVUAPCD Resolution No. 11

- 08

- 20, “In the Matter of: State Implementation Plan (SIP) Submittal Amendment for Rule 4694 (Wine Fermentation and Storage Tanks), adopted August 18, 2011.

d. SJVUAPCD Rule 4694 and supporting materials which were originally submitted to EPA on June 16, 2006.