RULE 4695 BRANDY AGING AND WINE AGING OPERATIONS (Adopted September
17, 2009)

1.0 Purpose

The purpose of this rule is to limit vola tile 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 wi ne 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 CAR B): 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 reducti on achievable, taking into account environmental, energy, and economic impacts by each cl ass or category of source." BARCT requirements are generally more st ringent 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, incl uding but not limited to , hoods, ducts, fans, booths, and vents which are used to c ontain, capture, or transport an air pollutant to an emissions control device.

3.7 Combined Capture and Control Efficien cy (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 c onsisting of a capture system and control

device.

SJVUAPCD 4695 - 1 09/17/20093.10 Environmental Protection Agency (EPA): the United States Environmental Protection Agency.

3.11 Fan Inlet Pressure Control Point: th e pressure monitor point for controlling the induced draft fan for purposes of ma intaining negative pressure on the warehouse adequate to ensure the ware house 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 l eak 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 Pr essure: the maximum value of negative gauge pressure as measured at the Fa n 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 Ru le 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 consid ered 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 Met hod 204. Any permanent opening in the enclosure that remains ope n 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 wi ne into and out of the warehouse for access with wheeled and motorized maintenance equipment.

3.19 Normal Operation: the period duri ng which a warehouse is operating while meeting the minimum requirements for a permanent total encl osure pursuant to
EPA Method 204 and while the VOC em ission control system is fully operational.

SJVUAPCD 4695 - 2 09/17/20093.20 Operational and Maintenance Functi ons: operational and ma intenance functions include the transport of barrels into and out of the ware house, repair of warehouse internal equipment or any ot her operational or maintenance reason for opening the non-personnel access doors (p rimarily 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 defi ned 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 pe rsonnel 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, wh ich contains 1/2 of its volume as ethanol, measured at 60 degrees Fahrenheit.

3.25 Reasonable Available Control Tec hnology (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: termin ation of operations.

3.28 Total Annual Aging Inventory (TAAI): average of calendar year inventory. Brandy aging and aging wine inventories are calcula ted 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 hol ding brandy and/or wine are kept for aging.

SJVUAPCD 4695 - 3 09/17/20093.31 Wine: as defined in Rule 4694, the liquid produc t 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 w ith a Potential To Emit of less than 10 tons of VOC

per year.

4.2 This rule shall not a pply 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 bra ndy or wine aging opera tion, operators shall implement record keeping according to S ection 6.1, and shall implement each of the following RACT work practices:

5.1.1 Prevent and minimize the unnece ssary occurrence of brandy or wine exposure to the atmosphere.

5.1.2 Prevent and minimize the occurre nce 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 wate r 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 w ith the RACT work practices in either Section 5.2.1 or 5.2.2, or the requireme nts of Section 5.8.

5.2.1 Maintain the wine agi ng warehouse such that the daily average temperature, averaged over a cale ndar year, does not exceed 70 degrees Fahrenheit, or

5.2.2 Implement a control technol ogy to reduce the Uncontrolled Aging Emissions (UAE), as calculated using the equation in Section 5.4 and the

SJVUAPCD 4695 - 4 09/17/2009Aging Emission Factor (AEF) of 0.02783 pounds ethanol per gallon, by

at least 50%.

5.3 For a Stationary Source with a br andy aging operation that equals or exceeds both the applicable inventory and emissi on thresholds listed in Table 1, the operator shall implement BARCT by comp lying with Section 5.1 and either

Section 5.3.1 or 5.3.2.

5.3.1 Comply with all of the requi rements 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 pe r 50 gallons, as calculated using the equation in Section 5.4, and as approved by the

APCO.

Table 1. Brandy aging a nd 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 Inve ntory, 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 va lue 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 valu e of 3%, unless the actual loss by volume is demonstrated to be less.

SJVUAPCD 4695 - 5 09/17/20095.5 Operators complying with Secti on 5.3.1 shall conduct all brandy aging operations in a warehouse that is certifie d and maintained as a Permanent Total Enclosure (PTE) pursuant to EPA Method 204: Criteria for a nd Verification of a Permanent or Temporary Total Enclosure. The warehouse shall be certified as a PTE within 90 days of initial st artup by a District-a pproved independent certifying entity (Air Resour ces Board Independent C ontractors Approved under the California Code of Regula tions, Title 17, Section 91207.)

5.5.1 Warehouses shall c ontinuously meet the criteria for Normal Operation except for periods when the Non-Pe rsonnel 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 f unctions and/or s hutdowns shall not exceed eight (8) percent of the time during which the operations occur or a maximum of 701 hours/year which ev er is less. This period shall include periods of downtime require d 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 wa rehouse as required to qualify the

warehouse as a Permanent Total En closure 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 exceedi ng this value (more negative) except for periods when the non-pers onnel 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 th e door is open. Personnel access doors shall be opened only as required for acce ss 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 whic h 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.

SJVUAPCD 4695 - 6 09/17/20095.6 Except for the periods of downtime required to perform scheduled routine maintenance, the warehouse’s VOC emi ssions shall be continuously vented through a VOC emission control device that has been approved, in writing, by

the APCO and which achieves a control e fficiency 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, auto matic, monitoring system which monitors the pressure at the Fan Inle t Pressure Control Point, monitors critical operation parameters of th e 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 sha ll demonstrate that operation of the

warehouse with the Maximum Allowabl e Negative Gauge Pressure at the

Fan Inlet Pressure Control Point is ad equate to maintain the qualification of the warehouse as a PTE pursu ant to EPA Method 204 by manually measuring and recording facial velo city at the largest Natural Draft Opening (NDO) on the warehouse a nd confirming a minimum facial velocity of 200 feet per minute. After 12 consecutive months of demonstrating the adequacy of th e established Maximum Allowable Negative Gauge Pressure, the monito ring frequency can be reduced to once per calendar quarter.

5.8. Operators, who conduct wine agi ng 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 e quipped and operated with a pressure-vacuum relief valve meeting all of th e following requirements:

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

the maximum allowable worki ng 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 va lve shall be permanently labeled with the operating pressure settings, and

SJVUAPCD 4695 - 7 09/17/20095.8.1.4 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 th e 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 75 o Fahrenheit during wine aging operations.

5.8.2.1 Temperature of the aging wine sh all be determined and recorded at least once per week.

5.8.2.2 For each batch of aging wine , operators shall achieve the temperature of 75 o F 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 opera tion shall maintain records, including,

but not limited to:

6.1.1 Daily and annual r ecords of the hours of operation indicating time,
duration, and reason of all periods of outage fo r a VOC control system, including maintenance. Records of annual cumulative hours of Normal Operation shall be maintained.

6.1.2 All maintenance activities requi ring a shutdown of a VOC control device, including the maintenance activ ity, time and date of shutdown of a VOC control device, and th e duration of the shutdown.

6.1.3 Records of throughput and the gallons lost while aging. Annual summaries of all filling and dumping operations sha ll be maintained to allow annual determination of total pr oof gallons and gallons lost from each aging operation. All gauging sh all be in accordance with the methods and procedures of the Gauging Manual of the Alcohol and Tobacco Tax and Trade Bureau, Depa rtment 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 y ears, and shall be made available for District, ARB, or EPA inspection, upon request.

SJVUAPCD 4695 - 8 09/17/20096.2 Test Methods

The following test methods shall be us ed 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 s ource test purposes shall be determined using EPA Method 25 or Method 18 or BAAQMD ST-32, except when the outlet

concentration must be be low 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 dete rmined 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 pe rcent, is the ratio of the weight of VOC removed by the control devi ce 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

SJVUAPCD 4695 - 9 09/17/20096.3 Compliance Testing

6.3.1 Source testing shall be conducte d 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 sha ll 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 test ed 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 bra ndy or wine aging operation unless compliance with the applicable requirements of this rule is demonstrated.

SJVUAPCD 4695 - 10 09/17/2009