SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 4694 December 15, 2005

B

- 1 Final Staff Report with Appendices For Revised Proposed Rule 4694 

# APPENDIX B

Emissions Reduction Analysis for

Rule 4694 (Wine Fermentation & Storage Tanks)

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

Appendix B: Emissions Reduction Analysis for Rule 4694 December 15, 2005

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- 2 Final Staff Report with Appendices For Proposed Rule 4694 I. SUMMARY

This appendix details the emission reduction analysis for Draft Rule 4694. The detailed

calculations shown later produced the following results.

• Total volatile organic compound (VOC) emissions in 2002, from wine fermentation, are estimated to range from 660 to 788 tons per year. Proposed exemptions in Draft Rule 4694 would result in 624 to 745 tons of the to tal VOC emissions being subject to control requirements.

• Draft VOC control requirements would require operators to reduce their baseline fermentation VOC emissions by 35%, annually. This would equate to annual
emission reductions of 218 to 261 tons, for a daily reduction of 0.6 to 0.72 tons per day.

• As presented in the Extreme Ozone Attainment Demonstration Plan , October 2004, the 2008 planning baseline emissions from wineries is 2.1 tons per day, and planned emission reductions for Rule 4694 are 0.7 ton s per day, for a planned emission reduction of 33%.

II. INTRODUCTION

Seventy percent of the State of California’s wine production occurs within the San Joaquin Valley Air Basin (SJVAB) 1 . The majority of wine production in the SJVAB occurs at large wine ries, each with annual wine production capacities of tens of millions of gallons. In 2002, 18 wineries had annual permitted production volumes ranging from 5 million to greater than 50 million gallons 2 each. These wineries accounted for 95% of

the Distri ct’s VOC 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 per winery and 58% of the wineries had annual production volumes of
less than 2,0 00 gallons.

Red and white wines differ significantly in their respective production processes, affecting fermenter use and associated VOC emissions. Red wines are fermented at high temperatures (70 o F to 80 o F), in contact with skins, seeds, and pulp. Fermentation of red wine typically occurs within three to four days. White wines are fermented at low temperatures (45 o F to 65 o F), with little contact with skins, seeds, and pulp. Fermentation of white wines occurs over a period of seven to ten days. The resulting emissions factor for red wines (6.2 lb VOC/1000 gallons) is almost 2.5 times greater than emission factors for white wine (2.5 lb VOC/1000 gallons) and fermenter throughput for red wine is about twice that of equal sized white wine fermenters

.

This report presents the estimated annual VOC emissions baseline and anticipated emission reductions associated with implementing the exemptions proposed in section

1 U.S. Department of the Treasury, Alcohol and Tobacco Tax Bureau, 2002 Alcohol Production Statistics

2 California Department of Alcoholic Beverage Control, Licenses Database, 2002SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 4694 December 15, 2005

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- 3 Final Staff Report with Appendices For Revised Proposed Rule 4694 4.0 and the emission reduction requirements presented in Section 5.0. Methods used

to c alculate emission reductions, and associated assumptions are discussed.

III. BACKGROUND

In commercial wineries, fermentation commonly occurs in fixed

- roof steel tanks (fermenters) by inoculation of must 3 with yeast. Fermenters in use at large wineries operating in the SJVAB range in size from about 25,000 gallons to 600,000 gallons. Most fermenters are equipped with a manhole at the top (approximately three feet in diameter) that is open during fermentation. Emissions are vented through the manhole

wi thout the aid of mechanical equipment (e.g., fans).

Fermentation temperature affects the characteristics of the wine. Large wineries control tank temperatures through use of cooling jackets and/or heat exchangers (i.e., wine is

re

- circulated from the bot tom of the tank through a heat exchanger, and back into the tank). T hermostats and computerized controls can maintain temperatures of must and wine within one or two degrees. Red wines are normally fermented at relatively high temperatures (70 o F to 80 o F), over a period of three to four days. White wines are typically fermented at lower temperatures (45 o F to 65 o F), and therefore fermentation takes longer, about seven to ten days.

A key distinction in the production of red or white wines is the point in the process that pressing, the separation of the juice from the skins, pulp and seeds, occurs. With very few exceptions, grapes have clear juice; the color in wine comes from pigmentation

contained in the skins. The longer the contact between skins a nd juice, the more color

is extracted from the skins. To make most white wines, winemakers press the juice from the grapes before fermentation, separating the stems, skins, pips and pulp from the juice. The juice is then sent to a fermenter where the win emaker initiates fermentation by inoculating the must with yeast. In one variation, as in the production of blush wines, after crushing the grapes go into a settling tank. While in the settling tank the grapes are chilled and may sit for up to 24 hours o f skin contact before being pressed and then fermented.

To make most red wines, winemakers press the juice from the grapes after fermentation. Crushed grapes are pumped into a fermenter and the winemaker initiates fermentation by inoculating the must w ith yeast. During fermentation, the skins and solids in the must will float to the top of the liquid, forming a solid cap . This leaves only the portion of juice underneath the cap in contact with the skins. To insure more color

extraction wine makers us e a variety of methods to enhance contact between the cap and juice. After enough color and tannin are extracted, the free run liquid is pumped to another tank and the must sent to a press where the entrained liquid is extracted. The

solids are discarded and the pressed wine may be added back to the free run or

3 Must is any unfermented juice or mixture of juice, pulp, skins, and seeds prepared from grapes or other fruit.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 4 Final Staff Report with Appendices For Revised Proposed Rule 4694 otherwise processed. Depending on the style of red wine being produced, pressing may occur before fermentation is complete. After transfer and pressing, the temperature of the wine is lowered to below 60 o F. Depending on the desired properties of the wine, the winemaker may allow fermentation to continue until there is no residual sugar, or stop the process. After fermentation, wine undergoes several additional processing steps to achieve the de sired characteristics. Additional processing may include clarification, blending, and aging.

Emissions Characterization

Wine production is predominantly a seasonal event, coinciding with the grape harvest season. Within the San Joaquin Valley, about 9 7% of wine production occurs in the months of August through December. Fermentation is at its peak during September through October. About 74% of wine fermentation occurs within those months. During the peak of the grape harvest, wineries processing mil lions of gallons of wine annually will operate 24 hours per day, seven days of the week. For a given fermenter, it is possible to run one fermentation batch after another throughout the harvest season.
Between each batch, the fermenter is sterilized in a ccordance with U.S. Food and Drug Administration requirements and readied for a new fermentation batch.

Seasonal throughput for a single fermenter varies from year to year and winery to winery. Assuming a fermentation season of 60 to 90 days, and a bat ch time of 5 days for red wine and 10 days for white wine, theoretical throughput for a single fermenter

could be 12 to 18 batches for red wine and six to nine batches for white wine. According to the Wine Institute 4 5 , this theoretical throughput is seld om achieved. The Wine Institute estimates that over 85% of wineries process 6 batches or less per tank, and 67% process 4 batches or less 6 . According to a Wine Institute survey of nine large wineries operating in the District, the maximum number of batch es for red and white wine was 18 and 8 batches respectively.

Quantitative characterizations of fermentation emissions will vary from winery to winery and within a winery. Emissions produced during fermentation depend upon process parameters, such as su gar content of the must, degree of temperature control, and type of wine being produced. During the fermentation process, glucose and fructose in must undergo reaction by yeast activity and produce ethanol and carbon dioxide (CO 2 ). The

amount of ethanol emitted to the atmosphere depends on the fermentation temperature and duration, the sugar content of the must, and the volume of must. Because of their higher fermentation temperatures, shorter fermentation periods, and the presence of the cap, fermentati on emissions per batch are higher for red wines than white wines.

4 Art Caputi, The Wine Institute; Letter to the Dist rict, July 18, 2005

5 The Wine Institute, Survey of Fermenter Usage Patters for Nine Large Wineries in the Central Valley, June

2004

6 Robert P. Koch , Wine Institute, Letter to the District, July 19, 2005SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 5 Final Staff Report with Appendices For Revised Proposed Rule 4694 Concomitantly, VOC concentrations and airflow rates for red wines reach higher peak values and vary more significantly than those encountered in white wine fermentation.

Ethanol is the mos t abundant VOC emitted during wine production. Other compounds emitted during fermentation include acetaldehyde, isoamyl alcohol, isobutyl alcohol,
methanol, n

- propanol, and hydrogen sulfide. Emissions of these species are substantially less than emitted ethanol, however it is worth noting that acetaldehyde is classified as hazardous air pollutant.

A general depiction of emissions generation over the course of a fermentation batch is shown in Figure

- 1. It has been noted, “the conditions of this fermenta tion are for illustrative purposes and are not typical of most wine fermentation” (Williams, 1983, p. 1606). However, basic characteristics of the diagram have been supported by test data (Fielder and Bumala, 1982; Todd et al., 1988, 1990): i.e., emissio ns and air flow rates vary significantly over the course of a fermentation batch, reaching a peak in the middle of the batch and then declining towards the end of the batch.

Figure

- 1 . Depiction of emissions generation ove r the course of an isothermal fermentation at 21.1 o C = 70 o F, as
predicted by modeling. Figure is from Heredia (1993), citing Williams and Boulton (1983). CO 2 evolution rate and ethanol emission rates are per liter of liquid fermented; airflow rates are p roportional to CO 2 evolution.

Another source of fugitive emissions is working loses associated with bulk wine storage. After fermentation, wine is transferred a number of times between storage tanks to perform various polishing operations such as “rackin g” (decantation for separation of sediment), filtration, malolactic fermentation (breakdown of malic acid to lactic acid and carbon dioxide), and bottling operations. Since the bottling process is a year

- round operation, each batch of wine will have a def inite residence time in storage, prior toSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 6 Final Staff Report with Appendices For Revised Proposed Rule 4694 bottling, which includes the time spent in performing the various post

- fermentation polishing processes. The post

- fermentation polishing operations result in “working losses” from the storage tanks since they requ ire draining and filling the tanks several times. Storage prior to bottling generates “breathing losses” from the tanks.

Emission Factors

A. Wine Fermentation

On January 26, 2004, District staff published a Preliminary Draft Staff Report and

conducted a Scoping Meeting to present the revised emissions inventory and to solicit public comment on the rule development project. These efforts identified concerns that the emissions factors recommended by STI overstated the emissions inventory. STI

recommend ed using emissions factors of 10

- lb ethanol/1000 gallons of red wine

fermented and 3

- lb ethanol/1000 gallons white wine fermented. These emission factors were higher than emissions factors presented in a US EPA guidance document (AP

- 42 Section 9.12.2). E missions factors presented in AP

- 42 are 4.6 and 1.8 lb/1000 gallons for red and white wines respectively.

In developing their recommendations, STI reviewed the studies supporting the AP

- 42

emission factors. STI identified several technical issues with th e supporting studies, concluding that the data likely understated actual emissions. STI identified two studies that appeared technically sound; one study characterizes emissions from white wines, the other, emissions from red wines. The emissions factors proposed by STI were

based on those two studies 7

.

District staff considered STI’s technical assessment of the supporting studies to be sound, but had reservations regarding the use of emissions factors based on such a

limited data set. An alternative to AP

- 42 emission factors and those proposed by STI are emissions factors prepared by California Air Resources Board (CARB) 8 . The CARB

emission factors are 6.2

- lb/1000 gal and 2.5

- lb/1000 gal for red and white wines respectively. These emissions factors ar e based on the stoichiometric model developed by professors Williams and Boulton, UC Davis. The foundation of the Williams and Boulton model is their thesis that ethanol loss occurs independent of fermentation rate; being driven by total sugar conversion and fermentation temperature. There are uncertainties in the model, and the model may understate emissions from red wine fermentations, however, the model has demonstrated relatively good correlation to

known data sets.

District and CARB staff worked tog ether to improve the methodology used to estimate the emissions inventory. Those discussions resulted in the following conclusions:

7 Sonoma Technology, Inc. (2003) Emissions Inventor y Methodology

– Wine Fermentation

8 Emissions Inventory Procedural Manual, Section 5.1, Air Resources Board, 1997SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 4694 December 15, 2005

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- 7 Final Staff Report with Appendices For Revised Proposed Rule 4694 ß The emissions factors derived from the Williams and Boulton model are considered more representative than other known emis sion factors and will be used for emissions inventory purposes.

ß Wine fermentation activity data will be based on county level production data obtained from the U.S. Department of the Treasury, Alcohol and Tobacco Tax Bureau (TTB).

ß The percentage of red a nd white wine fermented will be based upon the California Grape Crush Report. The Crush Report contains crush data by grape type. Albeit, not all grapes crushed are used to produce wine, however, the relative difference between the amounts of grapes crus hed is assumed to be maintained, whether used to produce wine or juice.

B. Bulk Storage

After fermentation, wine is transferred a number of times between storage tanks to perform various finishing 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. Since the bottling process is a year

- round operation, each batch of wine will have a definite residence time in storage , before bottling, which includes the time spent in performing the various post

- fermentation finishing processes. The post

- fermentation operations result in “working losses” from the storage tanks since they require draining and filling the tanks several times. Storage before bottling generates “breathing losses” from the tanks.

Since ethanol in water constitutes an organic liquid, the US EPA “TANKS” program can be utilized to determine the estimated VOC (ethanol) emissions. However, obtaining

accurate results from the TANKS program requires that the organic liquid be accurately characterized in terms of vapor pressure of the liquid and the composition of the equilibrium vapor phase. Since ethanol and water are highly polar compounds, they

form a non

- id eal mixture, i.e., the mixture does not follow Raoult’s law. As a result, direct estimation of vapor pressure and equilibrium vapor phase concentration, based on pure component properties, is not practical and experimental data are required.

To effective ly utilize TANKS to estimate VOC emissions from wine storage, experimental data supplied by the Wine Institute for the vapor pressure of ethanol over wine were used, along with the assumption that water will behave ideally (a good assumption since the liqu id phase is over 95% water on a molar basis). District staff calculates an emission factor for wine storage of 0.372 lb EtOH/1000 gal wine processed, based on a “typical” San Joaquin Valley wine storage scenario.

In 2002, 337,968,011 gallons of wine were fermented in the District. As illustrated in the following calculation, storing all of the 2002 wine fermentation in the District until bottled,SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 4694 December 15, 2005

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- 8 Final Staff Report with Appendices For Revised Proposed Rule 4694 would result in annual storage emissions of 62.9 tons of VOC. Not all wine fermented in

the District is bott led in the District, thus actual storage emissions are likely lower than

estimated.

ton 62.9 lb 2,000 ton 1

gal 1000 ethanol lb 0.372 gal 1 337,968,01 = x x

According to District Permit To Operate application data, there are 4,086 tanks used for storing bulk wine in the District. Two operational pra ctices currently in place on bulk wine storage tanks, in use at large wineries in the District, are use of pressure

- vacuum relief valves and temperature control 9 . As illustrated in the following calculations, average annual storage emissions per tank equa l 30.8 lbs per year, or 0.08 lbs per day. District staff considers use of pressure

- relief valves, and temperature control to constitute reasonable available control technology (RACT) for bulk wine storage tanks.

lb/tank 30.8 tanks 4086 ton lb 2000

year tons 62.9

= x

ar lb/tank/ye 0.08 day/year 365 lb/tank 30.8

=

Alcohol Production and Emissions from Wine Fermentation

According to TTB production statistics, 338 million gallons of wine were fermented and almost 26 million gallons of brandy were produced in the SJVAB during 2002. Additionally, over 26 mil lion gallons of distilled spirits were produced in the SJVAB (Table

- 1).

Table

- 1. Gallons of Alcoholic Beverage Produced in the San Joaquin Valley, 2002 10

County Wine Brandy Distilled Spirits

Fresno 103,725,752 19,491,659 15,260,235

Kern 10,393,071 3,89 6,020 602,040 Kings 0 0 0

Madera 29,482,509 393,045 4,205,903

Merced 67,423,044 2,065,043 2,803,643 San Joaquin 63,323,587 84 3,229,566

Stanislaus 51,752,044 0 0

Tulare 11,868,004 0 0

Totals 337,968,011 25,845,851 26,101,387

9 Art Caputi, The Wine Institute; Bob Calvin, Canandaigua Winery, Telephone Conversations with Daniel Barber, San Joaquin Valley Air Polluti on Control District, 2004.

10 U.S. Department of the Treasury, Alcohol and Tobacco Tax Bureau 2002 Alcohol Production StatisticsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 9 Final Staff Report with Appendices For Revised Proposed Rule 4694 Based on the 2002 Crus h Report, approximately 58.5 percent of total grapes crushed were for red wine and approximately 41.5 percent were crushed for white wine. Applying Crush Report percentages to TTB production statistics shows 198 million gallons of red wine and 140 million gallons of white wine were produced in the District during 2002 (Table

- 2).

Table

- 2. Gallons of Red and White Wine Fermented in the San Joaquin Valley, 2002

County Red Wine White Wine

Fresno 60,679,565 43,046,187

Kern 6,079,947 4,313,124
Kings 0 0

Ma dera 17,247,268 12,235,241

Merced 39,442,481 27,980,563
San Joaquin 37,044,298 26,279,298

Stanislaus 30,274,946 21,477,098

Tulare 6,942,782 4,925,222

Totals 197,711,296 140,256,725

Applying the respective emissions factors (6.2

- lb/1000 gal for red w ine and 2.5

- lb/1000 gal for white wine) to District wine fermentation estimates results in an annual VOC emissions inventory for wine fermentation of 788 tons per year, Table

- 3.

Table

- 3. Annual Fermentation Emissions in the San Joaquin Valley, 2002

Count y VOC Emissions from

Red Wine (tons) VOC Emissions from

White Wine (tons)

Fresno 188 54

Kern 19 5
Kings 0 0

Madera 53 15

Merced 122 35
San Joaquin 115 33

Stanislaus 94 27

Tulare 22 6

Totals 613 175

Averaged over 365 days, annual daily VOC emissi ons are 2.2 tons per day. However, wine fermentation is seasonal, corresponding to the grape harvest. In the SJVAB, fermentation typically occurs over a 90 to 120

- day period, resulting in peak seasonal daily averages of 8.8 to 6.6 tons VOC per day.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 4694 December 15, 2005

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- 10 Final Staff Report with Appendices For Revised Proposed Rule 4694 The Wine Institute has opined that actual emissions may be overstated because use of the Crush Report does not account for red grape varietals that could be fermented as

blush wines 11 . Blush wines are fermented similar to white wines, and would have

similar em issions. A Wine Institute survey of seven large wineries in the District shows that in 2004, about 38% of the wine produced in the Valley was red wine and 62% was

white wine 12 . If these production statistics are representative of all wine production in

th e District, total annual VOC emissions from wine fermentation are estimated to be 660 tons. The District is in the process of permitting wine fermentation and storage tanks. Emissions data gather through the permitting process will be used to update the emissions inventory. Where inclusion may improve clarity of this report, emissions estimates are presented as ranges, reflecting differences in Crush Report and Wine

Institute statistics.

Temporal Variation

Although wine fermentation is seasonal, corres ponding to the grape harvest, actual fermentation volumes reported by the TTB for 2002 shows that some fermentation occurs throughout the year (Table

- 4). While fermentation occurred year round in 2002, ninety

- seven (97) percent occurred within the months of August through December. Fermentation peaked during September and October, accounting for 75 percent of the annual fermentation. The months in which the majority of wine is fermented coincides with the months when the SJVAB experiences the greatest ex ceedance of the NAAQS

for one

- hour ozone, in terms of both frequency and in magnitude.

Table

- 4. Monthly Distribution of Wine Fermentation Activity in the SJVAB 13

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Fermentation (Million Gallons) 1.5 2.2 .8 .6 1.8 1.7 1.8 22.1 125.2 126.7 34 20

Percentage 0.45 0.65 0.23 0.18 0.54 0.50 0.53 6.54 37.05 37.49 10.05 5.79

Wineries Operating in the SJVAB

The California Department of Alcoholic Beverage Control (ABC) maintains a database of all facilities permitt ed to produce alcoholic beverages in California. The ABC issues permits based on type of alcoholic beverage produced at the facility and estimated production volumes. According to the ABC permit database, 109 wineries were permitted to operate in the SJV AB during 2002, (Table

- 5).

11 Art Caput, Wine Institute, Letter to the District, July 18, 2005

12 Art Caputi, The Wine Institute; Letter to the District, Jul y 18, 2005

13 U.S. Department of the Treasury, Alcohol and Tobacco Tax Bureau 2002 alcohol production statisticsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 4694 December 15, 2005

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- 11 Final Staff Report with Appendices For Revised Proposed Rule 4694 Table

- 5. Number of Wineries Permitted to Operate in the San Joaquin Valley, 2002
Permitted Production Volume (Million Gallons)

≤ 0.002 0.1 to

0.2 1 to

3 5 to

9 12 to

19 26 to

37 ≥ 50 Total

Wineries per Category 63 13 15 5 7 3 3 109

Percent of Total

Number of Wineries 58 12 14 5 6 3 3

Percent of Total

Permitted Production 0.13 0.43 4.9 7.5 25.5 22.3 39.3

Of the 109 wineries operating in the SJVAB in 2002, 58% of the wineries had annual production volumes of less than 2,000 gallons and 70% of the wineries had annual production volumes of less than 200,000 gallons. Assuming VOC emissions resulting from wine fermentation are directly proportional to a facility’s permitted produc tion volume, in 2002, 17% of the wineries (18 facilities) accounted for 95% of the District’s emissions from wine fermentation. Permitted production for those facilities ranged from 5 million to 50 million gallons of wine.

Fermenter Usage

The District h as begun the process of permitting wine fermentation and storage tanks but complete statistics of fermenters operating within the District are not available. Currently, the District has received permit application data from the thirteen largest

wineries 14

. Of 4,534 tanks reported by these facilities, 3,076 are designated for use as fermenters. The majority of fermenters are made of coated mild

- steel or stainless steel; about 6% of the fermenters contained in the District’s permit database were made of

con crete. Fermenter volume ranges from about 1,000 to 600,000 gallons, with an average volume of 150,000 gallons.

Modern wine production occurs in steel fermenters fitted with a variety of process controls, i.e., temperature controls, including jackets thro ugh which refrigerant can be pumped, thermostats, and computerized controls that can maintain the temperature of the must within one or two degrees. Wine is a food product and fermenters are operated consistent with U.S. Food and Drug Administration (US F DA) food safety requirements. Sanitation procedures include sterilization of fermenters between each batch. In the case of red wine fermenters, equipment used to transport solids to the presses, and the presses themselves are sterilized consistent with U S FDA requirements. Industry representatives have stated that sterilization of fermenters is mainly a manual process, using portable equipment that is moved from tank to tank.

As stated previously, large wineries in the SJV have annual wine production ca pacities of tens of millions of gallons. Fermenters at these facilities are typically designed to serve as both fermenters and storage tanks . Industry representatives have stated that

14 All Fermenter and Storage Tank Statistic’s compiled from Permit Database Query, October 19, 2005SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 12 Final Staff Report with Appendices For Revised Proposed Rule 4694 the selection of a given tank for a given fermentation batch may be de pendent upon several operational parameters, i.e., type of wine being produce (white versus red), production of varietal wines, or appellations, availability of tanks in use, and planned capacity for storage

.

Fermenters used to produce red wines have desi gn features not found in fermenters exclusively used to produce white wines. When producing red wines, the juice is fermented in contact with the solids. Red wine fermenters are designed and equipped to manage the solids during fermentation and to transp ort the solids to presses where entrained wine is separated from the solids, after or during fermentation. Fermenters exclusively used to ferment white wines lack these features because solids are separated from the juice before the start of fermentation.

Storage Tank Usage

Of the 4,534 wine fermentation and storage tanks contained in the District’s permit database, 4,085 tanks are designated for use as storage tanks. The sum of reported fermentation tanks and storage tanks exceeds the total number of r eported tanks by 2,627 tanks. This is reflective of the practice of using select tanks for both fermentation and storage. The majority of storage tanks are made of coated mild

- steel or stainless steel; about 3% are made of concrete. Storage tanks are es sentially fermenters with the manway closed. Previously presented information on construction and processing controls of fermenters applies to storage tanks. After fermentation, wine is transferred about six times between storage tanks to perform various polishing operations such as “racking” (decantation for separation of sediment), filtration, and malolactic fermentation (breakdown of malic acid to lactic acid and carbon dioxide). Because heat has deleterious effects on wine quality winemakers carefull y control tank temperatures to maintain the quality of the product and to facilitate certain process operations. Storage temperatures are often maintained near the freezing point of the wine. Temperature control is achieved through use of cooling jackets and/or heat exchangers (i.e., wine is

re

- circulated from the bottom of the tank through a heat exchanger, and back into the tank). An insulating foam layer blankets tank exteriors.

As wine is pumped into or out of a tank, the pressure in the vapor space increases or decreases, respectively. Atmospheric temperature changes cause an expansion or contraction of the vapors in this space, again resulting in pressure increases or decreases. Storage tanks are fitted with pressure

- vacuum relief valves that ser ve to maintain tank vapor

- space pressures within safe pressure and vacuum operating design

limits of the tank.

Emissions From Bulk Wine Storage

As previously presented, District staff calculates an emission factor for wine storage in the central valley o f 0.372 lb EtOH/1000 gal wine processed. The analysis demonstrates that emissions from wine storage tank are primarily influenced by theSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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- 13 Final Staff Report with Appendices For Revised Proposed Rule 4694 number of volume exchanges that occur. Emission reductions resulting from use of

pressure

- vacuum relief valves (PVR) and temperature control were evaluated by performing two runs with TANKS 4.0. Both analyses are based on a 100,000

- gallon storage tank containing a water/ethanol mixture having a 0.2816 mol fraction of ethanol.

Run

- 1 simulated an average ambient temperat ure of 75 degrees Fahrenheit, no temperature control, and no PVR. Run

- 2 run simulated temperature control and use of PVR. Breathing losses were calculated to be 68.29 lb/year for Run

- 1, and 65.19 lb/year

for Run

- 2, for a delta of 3.1 pounds. Annual etha nol emission reductions attributed to use of a PVR on wine storage tanks was calculated as follows:

EtOH mol EtOH lb 46.02

vapor mol EtOH mol 0.2816

lb 25.90 vapor mol 1

year vapor

- lb 3.1

gal 100,000 emissions EtOH

x x x =

Multiplying the resulting emissions factor of 0.016 lb EtOH/1000 gallons times a total annual production volume of 338,000,000 gal lons results in an emission reduction attributable to use of PVR of 3 tons per year.

IV. ESTIMATED REDUCTIONS

Baseline Emissions

Baseline emissions were established using an annual wine fermentation of 37,968,011 gallons 15 . As previously presented, the percentage of red and white wine has a significant effect on baseline determination. For completeness, the baseline was calculated using ARB methodology, and Wine Institute percentages. As presented in

Table

- 6, baseline annual VOC emissions from all wine fermentation are estimated to range from 673 to 788 tons.

Table

- 6 2002 Wine Fermentation Emission Baseline

Wine Type Annual Production (%) VOC Emissions (tons/year)

Scenario

- 1

Red Wine 60% 613

White Wine 40% 145

Total 788

Scenario

- 2

Red Win e 40% 398

White Wine 60% 262

Total 660

15 U.S. Department of the Treasury, Alcohol and Tobacco Tax Bureau 2002 alcohol production statisticsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 4694 December 15, 2005

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- 14 Final Staff Report with Appendices For Revised Proposed Rule 4694 Exemption of Small Wineries

Stationary sources operating in the District that have annual emissions of at least ten tons VOC or NOx are considered significant sources of air pollution. The Federal Clean

Air A ct (CAA) requires all major sources to have at least RACT level control on all devices that emit pollution at their facilities. Draft Rule 4694 would exempt small wineries (wineries with less than 10 tons annual fermentation emissions) from VOC
vapor cont rol requirements. As demonstrated below, exempting wineries with annual fermentation emissions of less than ten tons represents 5.5% of the annual baseline emissions (788 tons).

Emissions attributable to wineries with annual fermentation emissions of les s than or equal to 10 tons were determined by calculating the annual fermentation volume required to equal 10 tons VOC, and then using Table

- 5 to determine the number of wineries below the production threshold. The annual production volume was calculated using the following formula:

Where,

• 10 Tons is the annual fermentation VOC emissions threshold

• 58.5%Total and 41.5%Total are the estimated percentage of red and white wine production for all wineries

• 6.2 lb and 2.5 lb are the emission factors for red a nd white wine

Solving the equation for “Total”, results in an annual production threshold of 4.3 million gallons. Substituting the Wine Institute’s percentages for red and white wine production, and performing a similar calculation, results in an annual production threshold of 5.0 million gallons. According to the ABC permits database, about 5.4% of the total production would be exempted by a 10

- ton emissions threshold.

Total emissions affected by the 10

- ton threshold were estimated using the following

calculation:

Exemption Emissions = 5.4% x Total annual emissions

Assuming total annual emissions range from 660 to 788 tons, the small winery threshold would exempt 36 tons to 43 tons of VOC from emission control requirements.



## ( ) ( )

lbs 2000 ton 1

gal 1000 lbs

2.5 lbs 6.2 Tons 10 × × + ×

= Total 5 41 Total 5 58 %

. %

.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 4694 December 15, 2005

B

- 15 Final Staff Report with Appendices For Revised Proposed Rule 4694 Adjusted Annual Emissions Baseline

An adjusted annual emissions baseline of 624 ton to 745 tons was calculated by subtracting VOC emissions from exempted small wineries from the annual emissions

baseline.

Example: Adjusted Baseline = 660 tons

– 36 tons

Adjusted Baseline = 62 4 tons

Achievable Emission Reductions

Draft Rule 4694, Section 5.0 requires operators to achieve a 35% reduction in their

annual VOC emissions from wine fermentation. Achievable emission reductions were estimated to range from 218 tons to 261 tons VOC. Achievable emission reductions were calculated by multiplying the Adjusted Annual Emissions Baseline by 35%.

Example: Achievable Emission Reductions = (624 tons) (35%)

Achievable Emission Reductions = 218 tons annually

Average daily emission reductio ns were estimated by dividing Achievable Emission Reductions by 365 days. Average daily emission reductions were estimated to range from 0.60 tons to 0.72 tons per day. Daily reductions in this range are expected to meet

the District’s Extreme Ozone Plan commitment of 0.7 tons per day.

Example: Daily Reductions = 218 tons/365 days

Daily Reductions = 0.6 tons/daySAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 4694 December 15, 2005

B

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