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 (SJVUAPCD)

SJVUAPCD Rule 4694 Wine Fermentation and Storage Tanks

Prepared by: Lily Wong

April 12, 2012
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TABLE OF CONTENTS

1. Rule Identification

2. Background

a. San Joaquin Valley Nonattainment Status

b. Clean Air Act and Reasonably Available Control Technology

c. Winery Emissions in SJVAB

d. Brief Summary of Originally Submitted Rule 4694

e. SJVUAPCD’s RACT Analysis

- Wine Fermentation

- Wine Storage

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

- Wine Storage

- Wine Fermentation

g. Why did SJVUAPCD 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. References
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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, 20111

Completeness Determination: December 22, 2011

2. BACKGROUND

a. San Joaquin Valley Nonattainment Status

SJVUAPCD has primary responsibility for regulating air pollution in the San Joaquin Valley 

Air Basin (SJVAB). The SJVAB is designated nonattainment for the 1-hour ozone 

standard,

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the 1997 8-hour ozone standard, both the 1997 24-hour and annual PM2.5

standards, and the 2006 24-hour PM2.5 standard. For the 1-hour ozone standard and the 8-

hour ozone standard, the area is classified as extreme. EPA re-designated the SJVAB to 

attainment for the PM10 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 stationary sources of volatile organic compounds (VOCs) or nitrogen 

oxides (NOx) and for sources covered by a Control Techniques Guidelines documents 

(CTGs). In areas classified as extreme, major stationary sources are defined as sources that 

emit or have the potential to emit 10 tons/year of VOC or NOx. While EPA has not issued a 

CTG for wine fermentation and storage tanks, these winery sources are major stationary 

sources of VOC emissions. Therefore, 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 which 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, 

2011 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. See 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 and 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 corresponds 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 polishing 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 Staff Report for Rule 4694,3approximately 70% of California’s wine 

production occurs within the SJVAB, and the majority of wine production in SJVAB occurs 

at large wineries with tens of millions of gallons of annual production capacity. The Staff 

Report stated that SJVUAPCD’s 2003 PM10 Plan estimates that ethanol emissions in the 

SJVAB from 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 would be 2.1 tons per day 

in 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 operating 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. Brief Summary Of Originally 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 

(Wine 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 originally submitted Rule 

4694 only addressed emissions from two activities – wine 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 aging 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 originally submitted Rule 4694

adopted December 15, 2005 is summarized below in order to provide the context for 

SJVUAPCD’s analyses. 

Originally submitted Rule 4694 applies to wineries that ferment wine or store wine in bulk 

containers, and a storage tank is defined as any container having an internal volume greater 

than 250 gallons that is used to hold wine. 

For the fermentation operations, originally 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 “Certified Emission 

Reductions” or CERs), or 3) paying a fee to SJVUAPCD, which will thereafter obtain 

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

Originally 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 storage tank requirements are further described below in Section 3 “Rule 

Summary” section of this TSD. 

Except for the recordkeeping requirements, originally submitted Rule 4694 exempts wineries 

whose potential to emit fermentation emissions is less than 10 tons/year. Storage tanks 

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

e. SJVUAPCD’s RACT Analyses

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 (hereinafter 

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. 

SJVUAPCD evaluated six control technologies for wine fermentation and wine storage: 

thermal oxidation, catalytic thermal oxidation, regenerative thermal oxidizer, refrigerated 

condensers, water scrubber, and carbon adsorption. SJVUAPCD concluded 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 24th 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 systematic analysis of whether 

the control technologies were technically and economically feasible. 
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from wine fermentation, and 2) while technologically 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 to $52,000 per ton for white wine fermentation, and

$38,000 to $84,000 per ton for wine storage tanks.6SJVUAPCD also estimated the cost 

effectiveness of PV valves and PV valves with insulation as $204,000 and $215,000 per ton 

of VOC respectively.7 SJVUAPCD stated that these 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 District. 

f. EPA’s Review of SJVUAPCD’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 practice for wine fermentation

emissions on the scale of the affected facilities. Furthermore, we are not aware that other 

states or air districts have adopted rules requiring controls on wine fermentation emissions. 

Therefore, we agree with SJVUAPCD that RACT for emissions from wine fermentation at 

this time is no controls. 

However, we are aware that at least one winery8is actively taking steps to control emissions 

from wine fermentation and they are in a pilot phase of the project. In the future, 

SJVUAPCD will be required again to demonstrate that they have required RACT level 

controls on all major stationary sources of VOC or NOx 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.
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g. Why did SJVUAPCD Amend Their Submittal of Rule 4694?

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

reduction in fermentation emissions but allowed the source two alternative means of 

compliance. The source could obtain Certified Emission Reductions from other mobile, area, 

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

Emission Reductions. 

EPA previously raised 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.

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 Because these deficiencies raised approvability concerns, SJVUAPCD 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 arise 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 following 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 reductions given this interplay?

RACT

Separate from SJVUAPCD’s attainment plan provisions, commitments, and control measure 

assumptions, the CAA RACT requirements are independent requirements which must be 

 

9 EPA published the guidance, “Improving Air Quality with Economic Incentive Programs” on January 2001 (EPA452/R-01-001). The guidance is available at http://www.epa.gov/ttn/oarpg/t1/memoranda/eipfin.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 

represent final agency action, EPA would use 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 struck-out text, the title of Rule 4694 

remains “Wine Fermentation and Storage Tanks” because the Office of the Federal Register said titles of rules must 

not be changed. 

11 On 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. The adoption of Rule 4695 also addresses 

in part EPA’s concerns expressed in 2005. Because Rule 4694 allows 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, quantifiable, 

enforceable, and permanent. 
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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 sections 2.f. and 5.c. of this TSD 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 fermentation 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 subject 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 concurred with SJVUAPCD's 

conclusion that Rule 4695 meets or exceeds RACT requirements for brandy aging 

operations. We also stated that wine 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 used 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 

would be problematic 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 PM10 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-IND14, 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 provides 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 amended submittal of Rule 4694 regulates VOC emissions from the bulk storage of wine in 

tanks that hold at least 250 gallons of wine. Wine storage tanks that have the capacity of at least 

5,000 gallons are required 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 degrees Fahrenheit. The amended submittal of Rule 4694 also 

requires recording and maintaining records on volumes of wine stored and the maximum 

temperatures 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, August 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 approving 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 from 

existing sources in the area as may be obtained through the adoption, at a minimum, of 

 

13 See SJVUAPCD 2007 Ozone Plan, Table B-1 “Reductions from District Rules Not Reflected in the Emissions 

Inventory (to be subtracted from O3SIP 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 complies 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 Revisions – The submitted rule is a new addition to the SIP, strengthening the 

requirements of the SIP. Therefore, we propose 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 met, 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. The Staff Report and 

Ozone Plan indicate that the cost effectiveness for installing PV valves and insulation is 

greater than $200,000 per ton of VOC reduced. SJVUAPCD therefore concluded that PV 

valves and insulation was too expensive and not reasonably available. 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 whether 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 the 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 economically 

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 recommends full approval of amended submittal of Rule 4695 because it complies

with all relevant CAA requirements including those regarding enforceability.

7. RECOMMENDATIONS 

We recommend that SJVUAPCD stay abreast of the efforts at the Kendall-Jackson winery 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 

evaluation of RACT for this source category.

8. REFERENCES

a. 2007 Ozone Plan adopted by SJVUAPCD on April 30, 2007 and submitted 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.