RULE 4695 BRANDY AGING AND WINE AGING OPERATIONS (Adopted September 

17, 2009) 

1.0 Purpose 

The purpose of this rule is to limit volatile organic compound (VOC) emissions from 

brandy aging and wine aging operations. 

2.0 Applicability 

 

This rule shall apply to brandy aging and wine aging operations. 

3.0 Definitions 

3.1 Aging: for the purpose of this rule, to keep, in a non-temporary or transient 

manner, brandy or wine in containers with the objective of acquiring desirable 

characteristics from contact with wood. 

3.2 Air Pollution Control Officer (APCO): as defined in Rule 1020 (Definitions). 

3.3 Air Resources Board (ARB or CARB): as defined in Rule 1020 (Definitions). 

3.4 Best Available Retrofit Control Technology (BARCT): as defined in the 

California Health and Safety Code "an emission limitation that is based on the 

maximum degree of reduction achievable, taking into account environmental, 

energy, and economic impacts by each class or category of source." BARCT 

requirements are generally more stringent than RACT requirements. 

3.5 Brandy: an alcoholic beverage made from distilled wine or fermented fruit juice, 

usually 40-60% ethyl alcohol by volume. 

3.6 Capture System: equipment, including but not limited to, hoods, ducts, fans, 

booths, and vents which are used to contain, capture, or transport an air 

pollutant to an emissions control device. 

3.7 Combined Capture and Control Efficiency (CCCE): the total percent reduction 

in emissions, achieved by an emissions control system. 

3.8 Control Device: equipment that is used to reduce the amount of air pollutants in 

an exhaust stream before discharge to the ambient air. 

3.9 Emission Control System: a system consisting of a capture system and control 

device. 

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3.10 Environmental Protection Agency (EPA): the United States Environmental 

Protection Agency. 

3.11 Fan Inlet Pressure Control Point: the pressure monitor point for controlling the 

induced draft fan for purposes of maintaining negative pressure on the 

warehouse adequate to ensure the warehouse meets the criteria of a Permanent 

Total Enclosure (PTE) pursuant to EPA Method 204: Criteria for and 

Verification of a Permanent or Temporary Total Enclosure. 

3.12 Gas Leak: a reading in excess of 1,000 ppmv, above background, measured on 

a portable hydrocarbon detection instrument that is calibrated with methane. 

 

3.13 Gas-Tight: a condition without a gas leak as determined by EPA Method 21 in 

accordance with EPA Method 21. 

3.14 Inventory: the stock of an item on hand at a particular location or business. 

3.15 Maximum Allowable Negative Gauge Pressure: the maximum value of negative 

gauge pressure as measured at the Fan Inlet Pressure Control Point which 

ensures that the warehouse operates with sufficient negative gauge pressure to 

meet the criteria for a PTE pursuant to EPA Method 204: Criteria for and 

Verification of a Permanent or Temporary Total Enclosure. 

3.16 Must: as defined in Rule 4694. any unfermented juice or mixture of juice, pulp, 

skins, and seeds prepared from grapes or other fruit. Must fermented to 

produce white wines is considered to be juice. Must fermented to produce red 

wines is considered to be a mixture of juice and solids, such as pulp, skins, and 

seeds. The solid portion of the must is called pomace. 

3.17 Natural Draft Opening (NDO): as defined in EPA Method 204. Any permanent 

opening in the enclosure that remains open during operation of the facility and is 

not connected to a duct in which a fan is installed. 

3.18 Non-Personnel Access Door: openings which are required to allow routine 

movement of brandy or wine into and out of the warehouse for access with 

wheeled and motorized maintenance equipment. 

3.19 Normal Operation: the period during which a warehouse is operating while 

meeting the minimum requirements for a permanent total enclosure pursuant to 

EPA Method 204 and while the VOC emission control system is fully 

operational. 

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3.20 Operational and Maintenance Functions: operational and maintenance functions 

include the transport of barrels into and out of the warehouse, repair of 

warehouse internal equipment or any other operational or maintenance reason 

for opening the non-personnel access doors (primarily for forklift or other 

equipment access) during which time the enclosure would not qualify as a PTE. 

3.21 Permanent Total Enclosure (PTE): an enclosure, as defined in EPA Method 

204, which is a permanently installed and completely surrounds a source of 

emissions such that all VOC emissions are captured and contained for discharge 

to a control device. 

3.22 Personnel Access Door: a door, with a maximum opening of 21 square feet, 

intended solely for occasional personnel access to the warehouse for 

maintenance or monitoring activities. 

3.23 Potential To Emit: as defined in Rule 2201 (New and Modified Stationary 

Source Review Rule). 

3.24 Proof Gallons: one liquid gallon of proof spirits, which contains 1/2 of its 

volume as ethanol, measured at 60 degrees Fahrenheit. 

3.25 Reasonable Available Control Technology (RACT): for existing sources, those 

emission limits that would result from the application of demonstrated 

technology to reduce emissions. 

3.26 Stationary Source: as defined in Rule 2201 (New and Modified Stationary 

Source Review Rule). 

3.27 Shutdown: termination of operations. 

3.28 Total Annual Aging Inventory (TAAI): average of calendar year inventory. 

Brandy aging and aging wine inventories are calculated separately, based on 

TTB Form 5110.11 for brandy and Form 5120.17 for wine. The calculation is 

as follows: 

TAAI = ∑ MI ÷ 12 months/year. 

where: 

TAAI = Total Annual Aging Inventory in gallons per year. 

MI = Monthly Inventory in gallons. 

3.29 Volatile Organic Compound (VOC): as defined in Rule 1020 (Definitions). 

3.30 Warehouse: for the purposes of this rule, the building, enclosure, or other area 

in which containers holding brandy and/or wine are kept for aging. 

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3.31 Wine: as defined in Rule 4694, the liquid product obtained from fermented 

must. 

4.0 Exemptions 

4.1 Except for recordkeeping requirements of Section 6.1.3, this rule shall not apply 

to any Stationary Source with a Potential To Emit of less than 10 tons of VOC 

per year. 

4.2 This rule shall not apply to wine storage tanks subject to Rule 4694 (Wine 

Fermentation and Storage Tanks), Section 5.2. 

5.0 Requirements 

5.1 For a Stationary Source with a brandy or wine aging operation, operators shall 

implement record keeping according to Section 6.1, and shall implement each of 

the following RACT work practices: 

5.1.1 Prevent and minimize the unnecessary occurrence of brandy or wine 

exposure to the atmosphere. 

5.1.2 Prevent and minimize the occurrence of leaks and spills of brandy or 

wine. 

5.1.3 Implement immediate clean up of leaks and spills of brandy or wine by 

rinsing the leaks or spills with water and washing the rinse into a proper 

drain. 

5.1.4 Implement corrective actions to prevent a reoccurrence of a similar 

brandy or wine leak or spill. 

5.2 For a Stationary Source with a wine aging operation that equals or exceeds both 

the applicable inventory and the emission thresholds listed in Table 1, operators 

shall also comply with the RACT work practices in either Section 5.2.1 or 

5.2.2, or the requirements of Section 5.8. 

 5.2.1 Maintain the wine aging warehouse such that the daily average 

temperature, averaged over a calendar year, does not exceed 70 degrees 

Fahrenheit, or 

5.2.2 Implement a control technology to reduce the Uncontrolled Aging 

Emissions (UAE), as calculated using the equation in Section 5.4 and the 

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Aging Emission Factor (AEF) of 0.02783 pounds ethanol per gallon, by 

at least 50%. 

5.3 For a Stationary Source with a brandy aging operation that equals or exceeds 

both the applicable inventory and emission thresholds listed in Table 1, the 

operator shall implement BARCT by complying with Section 5.1 and either 

Section 5.3.1 or 5.3.2. 

5.3.1 Comply with all of the requirements of Section 5.5 through 5.7, 

inclusive, or 

5.3.2 Implement an alternate control measure that is demonstrated, using 

production data or the Test Methods of Section 6.2, to produce a brandy 

UAE of less than or equal to 0.3 proof gallons per 50 gallons, as 

calculated using the equation in Section 5.4, and as approved by the 

APCO. 

 

Table 1. Brandy aging and wine aging thresholds

Product 

Type 

Total Annual Aging 

Inventory 

(gallons per year) 

Uncontrolled Aging 

Emissions (lbs/yr) 

Brandy 40,000 8,000 

Wine 590,000 16,000 

5.4 Uncontrolled Aging Emission (UAE) threshold determinations shall be 

calculated using the following formula: 

UAE = TAAI * AEF 

Where: 

UAE = Uncontrolled Aging Emissions (ethanol), in pounds per year. 

TAAI = Total Annual Aging Inventory, in gallons per year. 

AEF = Aging Emission Factor, in pounds ethanol per gallon. 

Brandy default AEF = 0.1986 pounds ethanol per gallon, 

calculated from the default value of 3 proof gallons per 50 

gallons barrel loss by volume, unless the actual loss by volume 

is demonstrated to be less. 

Wine default AEF = 0.02783 pounds ethanol per gallon, 

calculated from the default value of 3%, unless the actual loss 

by volume is demonstrated to be less. 

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5.5 Operators complying with Section 5.3.1 shall conduct all brandy aging 

operations in a warehouse that is certified and maintained as a Permanent Total 

Enclosure (PTE) pursuant to EPA Method 204: Criteria for and Verification of 

a Permanent or Temporary Total Enclosure. The warehouse shall be certified 

as a PTE within 90 days of initial startup by a District-approved independent 

certifying entity (Air Resources Board Independent Contractors Approved under 

the California Code of Regulations, Title 17, Section 91207.) 

5.5.1 Warehouses shall 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 and 

Maintenance Functions and/or when the VOC control device is shutdown 

for scheduled routine maintenance. The total annual cumulative duration 

for all operational or maintenance functions and/or shutdowns shall not 

exceed eight (8) percent of the time during which the operations occur or 

a maximum of 701 hours/year which ever is less. This period shall 

include periods of downtime required to perform scheduled routine 

maintenance. Scheduled maintenance shall not exceed three (3) percent 

of the total operating hours per year or 240 hours per year, whichever is 

less. 

5.5.2 A Maximum Allowable Negative Gauge Pressure at the Fan Inlet 

Pressure Control Point, adequate to ensure maintenance of a continuous 

negative gauge pressure in the warehouse as required to qualify the 

warehouse as a Permanent Total Enclosure pursuant to EPA Method 

204, shall be demonstrated, established, and recorded at startup. The Fan 

Inlet Pressure Control Point shall continuously operate with a negative 

gauge pressure equal to or exceeding this value (more negative) except 

for periods when the non-personnel access doors are opened for 

equipment access for operational or maintenance functions. 

5.5.3 Each Personnel Access Door shall be equipped with an automatic closure 

device to minimize the time that the door is open. Personnel access doors 

shall be opened only as required for access to or exit from the enclosure, 

minimizing the duration of the opening, and shall not be propped open. 

5.5.4 Each Non-Personnel Access Door shall be equipped with a motoractuated door and controls which will minimize the time the door 

remains open during access and exit and shall be integrated with the 

continuous monitoring system to record the time periods that the door is 

open. 

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5.6 Except for the periods of downtime required to perform scheduled routine 

maintenance, the warehouse’s VOC emissions shall be continuously vented 

through a VOC emission control device that has been approved, in writing, by 

the APCO and which achieves a control efficiency of at least 98 percent, by 

weight, as determined pursuant to Section 6.2.3. Routine scheduled 

maintenance which requires shutdown of the VOC emission control device shall 

not be performed during the months of July, August, or September.

5.7 Monitoring 

5.7.1 The operator of any brandy aging operation shall have the operation 

equipped with a continuous, automatic, monitoring system which 

monitors the pressure at the Fan Inlet Pressure Control Point, monitors 

critical operation parameters of the control device, such as the 

combustion chamber temperature, and records the time of opening for all 

non-personnel access doors. 

5.7.2 Each month the operator shall demonstrate that operation of the 

warehouse with the Maximum Allowable Negative Gauge Pressure at the 

Fan Inlet Pressure Control Point is adequate to maintain the qualification 

of the warehouse as a PTE pursuant to EPA Method 204 by manually 

measuring and recording facial velocity at the largest Natural Draft 

Opening (NDO) on the warehouse and confirming a minimum facial 

velocity of 200 feet per minute. After 12 consecutive months of 

demonstrating the adequacy of the established Maximum Allowable 

Negative Gauge Pressure, the monitoring frequency can be reduced to 

once per calendar quarter. 

5.8. Operators, who conduct wine aging in a non-porous tank as allowed under 

Section 5.2, shall comply with all of the following requirements: 

5.8.1 The tank shall be equipped and operated with a pressure-vacuum relief 

valve meeting all of the following requirements: 

5.8.1.1 The pressure-vacuum relief valve shall operate within 10% of 

the maximum allowable working pressure of the tank, 

5.8.1.2 The pressure-vacuum relief valve shall operate in accordance 

with the manufacturer’s instructions, 

5.8.1.3 The pressure-vacuum relief valve shall be permanently labeled 

with the operating pressure settings, and 

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5.8.1.4 The pressure-vacuum relief valve and tank shall remain in a 

gas-tight condition except when the operating pressure of the 

tank exceeds the valve set pressure. A gas-tight condition shall 

be determined by measuring the gas leak in accordance with 

the procedures in EPA Method 21. 

5.8.2 The temperature of the aging wine shall be maintained at or below 75o

Fahrenheit during wine aging operations. 

5.8.2.1 Temperature of the aging wine shall be determined and recorded 

at least once per week. 

5.8.2.2For each batch of aging wine, operators shall achieve the 

temperature of 75oF or less within 60 days after the start of the 

aging process. 

6.0 Administrative Requirements 

 

6.1 Recordkeeping: 

Operators of a brandy or wine aging operation shall maintain records, including, 

but not limited to: 

6.1.1 Daily and annual records of the hours of operation indicating time, 

duration, and reason of all periods of outage for a VOC control system, 

including maintenance. Records of annual cumulative hours of Normal 

Operation shall be maintained. 

6.1.2 All maintenance activities requiring a shutdown of a VOC control 

device, including the maintenance activity, time and date of shutdown of 

a VOC control device, and the duration of the shutdown. 

6.1.3 Records of throughput and the gallons lost while aging. Annual 

summaries of all filling and dumping operations shall be maintained to 

allow annual determination of total proof gallons and gallons lost from 

each aging operation. All gauging shall be in accordance with the 

methods and procedures of the Gauging Manual of the Alcohol and 

Tobacco Tax and Trade Bureau, Department of the Treasury (27 CFR 

30). 

6.1.4 All required monitoring of Section 5.7. 

6.1.5 All records shall be retained for a minimum of five years, and shall be 

made available for District, ARB, or EPA inspection, upon request. 

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6.2 Test Methods 

The following test methods shall be used to determine compliance with the 

provisions of this rule. Alternate test methods may be used provided they are 

approved by the APCO, ARB, and EPA. 

6.2.1 Determination of PTE: EPA Method 204: Criteria for and Verification 

of a Permanent Total Enclosure as specified in 40 CFR 51, Appendix M. 

6.2.2 VOC emissions for source test purposes shall be determined using EPA 

Method 25 or Method 18 or BAAQMD ST-32, except when the outlet 

concentration must be below 50 ppmv in order to meet the standard, in 

which case EPA Method 25A may be used. 

6.2.3 Determination of Control Efficiency of VOC Emission Control Systems 

shall be made using the following methods: 

6.2.3.1 The control efficiency of a VOC emission control system’s 

VOC control device shall be determined using EPA Methods 2, 

2A, or 2D for measuring flow rates and EPA Methods 25, 

25A, or 25B, EPA Method 18, or BAAQMD ST-32, as 

applicable, for measuring total gaseous organic concentrations 

at the inlet and outlet of the control device. 

6.2.3.2 Control Device Efficiency, in percent, is the ratio of the weight of 

VOC removed by the control device from the effluent stream 

entering the control device to the weight of VOC in the effluent 

stream entering the control device, both measured simultaneously, 

shall be calculated by the following equation: 

Control Device Efficiency (%) = [(Wc-Wa) ÷ Wc] x 100 

Where: 

Wc = weight of VOC entering the control device 

Wa = weight of VOC discharged from the control device 

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6.3 Compliance Testing 

6.3.1 Source testing shall be conducted using the methods and procedures 

specified in Section 6.2. The District must be notified at least 30 days 

prior to any compliance source test, and a source test plan must be 

submitted for approval at least 15 days prior to testing. 

6.3.2 The results of each source test shall be submitted to the District within 

60 days after the date the source testing is completed. 

6.3.3 Emission control systems shall be initially source tested for compliance 

with the applicable requirements of this rule no later than January 1, 

2012, and not less than once every five (5) years, thereafter. 

6.3.4 VOC emissions during the source test shall be calculated as the 

arithmetic average of three 30-consecutive-minute test runs. 

7.0 Compliance Schedule 

On and after January 1, 2012, no person shall conduct a brandy or wine aging operation 

unless compliance with the applicable requirements of this rule is demonstrated. 

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