Wine Fermentation Emission Controls

2018 CAPCOAEngineering Symposium

Michael GoldmanEngineering Division Manager

Santa Barbara CountyAir Pollution Control District

October 30, 2018

1

Presentation Overview

• Background• Emission Controls in Santa Barbara

– Terravant Wine Company– Central Coast Wine Services

• AIP BACT Determination• Wine Institute Appeal• Wine Institute Settlement

2

Air Emissions from Wineries• Fermentation produces carbon dioxide and

ethanol

• Oak Barrel Aging – “The Angel’s Share”

• Ethanol is a volatile organic compound (VOC)

• VOC is a precursor pollutant to ozone and PM10 –both nonattainment

• Emissions coincide with peak ozone season

3

The Fermentation Process• Batch process – “fermentation

cycle”

• Yeast is added to grape juice to initiate fermentation

• Emission rates vary over cycle

• Fermentation cycle duration– 7 days red wines– 15 days white wines

4

Barrel Room Aging• The Angel’s Share

• Ethanol evaporates throughpores of the oak barrels

• Losses range from 1-5%

• Dependent upon barrel room:– Temperature – Relative humidity

• A 10,000 barrel room has annual emissions of ~8 tpy

5

California Wine Regions

California has 4 major winemaking regions:

• North Coast

• Central Valley

• Central Coast

• South Coast

6

Scale and Types of Wineries

7

Boutique/Small Wineries

8

Rancho Sisquoc WineryMelville Winery

Industrial Sized Wineries

Cambria Winery

9

Terravant Wine Company

Wine Refineries

E&J Gallo - Livingston

10

E&J Gallo - Modesto

Fermentation Emissions ComparisonWinery / Project Tankage VOC Emissions

(lb/day)VOC Emissions

(ton/year)GHG Emissions

(tons/year)

Melville Winery Not tracked 6 0.4 10

CCWS / 400-Series Tanks 40 Tanks / 564,000 gallons 499 11.2 1,592

E&J Gallo / Fresno 1 12 Tanks / 4,200,000 gallons

14,532 30.2 4,293

11

1 SJVAPCD ATCs: C-447-330-1 thru C-447-341-1 (10/23/15)

Wineries in Santa Barbara County

• 114 wineries in the County

• 97 qualify for 1-ton permit exemption (85% no permit)

• 17 require APCD permit

12

13

Emission Controls in Santa BarbaraTerravant Wine Company

Buellton, CA

14

Terravant Wine Company• Custom crush wine center

• 211 fermentation tanks

• 838,000 gallon tank capacity

• Dozens of wineries and wine brands

• 5,400 oak barrel storage room

15

Terravant Permit History• New facility permitted in 2008

• Designed and installed an emission control system to allow for maximum production without triggering offsets

• Control system in operation since 2008

16

Control System Usage at Terravant• Counter-current packed bed scrubber

• Water scrubbing liquid

• General room ventilation system routes fermentation and storage room emissions to scrubber

• Ethanol from the scrubber is oxidized to CO2 and H20 using hydrogen peroxide and UV light

• Operated at all times during fermentation activities

17

18

19Terravant packed bed scrubber

20Packed bed scrubber UV accelerator lamp

21Packed bed scrubber blower

22Packed bed scrubber control panel

23Fermentation room ventilation ducting

System Performance/Challenges• Initial testing showed scrubber achieved 64% control

(2008)

• System was re-engineered, and testing the following year showed scrubber achieved 91% control (2009)

• Control efficiency declined in subsequent years (2010 – 2014)

• Performance issues attributed to improper maintenance24

Current Status• Enhanced maintenance program

initiated in 2015

• System operational and source tested twice per fermentation season (modified EPA Method 18)

• Since 2015, system has achieved an average 83% control

• Expansion project may be in the works

25

Emission Controls in Santa BarbaraCentral Coast Wine Services

Santa Maria, CA

26

Central Coast Wine Services• Custom crush wine center

• 143 fermentation tanks

• 1.4 million gallon tank capacity

• 2,500 oak barrel storage room

27

Central Coast Permit History

• Permitted in 2009 to bring existing facility into compliance

• Operated several years with emission limits set just below offset thresholds

• Implemented daily recordkeeping to ensure the emission limits were not exceeded

28

Control System Usage at Central Coast

• Emission control systems voluntarily installed and operated to reduce emissions below offset thresholds

• One NoMoVo installed in 2013

• One EcoPAS and second NoMoVo installed in 2015

29

NoMoVo Control System• Counter-current wet scrubber

• Water scrubbing liquid

• Piping manifold1 connected to closed-top fermentation tanks routes fermentation emissions to the control system

• Release of gas from wine fermentation used to drive emissions toward the control system (passive)

• Slurry shipped offsite to an approved facility for disposal

301 https://youtu.be/LiMFH7MVIcs

31NoMoVo control system NoMoVo temperature control panel

32NoMoVo tank piping and P/V valveNoMoVo slurry level gauge

33NoMoVo isolation valve

EcoPAS Control System• Glycol chilled tube-in-shell condenser

• Piping manifold connected to closed-top fermentation tanks routes fermentation emissions to the control system

• Release of gas from wine fermentation used to drive emissions toward the control system (passive)

• Aromatic condensate is a usable by-product or is shipped offsite to an approved facility for disposal

34

35EcoPAS control system

36EcoPAS tank piping and P/V valve

37EcoPAS manifold piping

AIP BACT DeterminationCentral Coast Wines Services (CCWS)

Authority to Construct 15044 August 2017

38

400-Series Tank Project

• 40 stainless steel tanks

• 7,527 – 20,736 gallons each

• 563,690 gallon total capacity

• Project subject to New Source Review - BACT

39

Achieved-in-Practice Determination• BACT definition has three parts:

– The most effective emission control that has been achieved-in-practice (AIP) for the type of equipment comprising such stationary source, or

– Any other emission control that is technologically feasible and cost-effective, or

– The most stringent limitation contained in any State Implementation Plan.

• District policy defines AIP as a “proven track record of reliability”

• Both controls were operated successfully for a reasonable amount of time: 2 - 3 full fermentation seasons.

40

Achieved-in-Practice Determination (contd.)• Data analyses by the District, EPA and CARB confirmed

effectiveness of the NoMoVo and EcoPAS controls.

• AIP does not require the control technology to meet a prior BACT requirement, just that the controls have operated successfully for a reasonable period of time.

• Basis documented in the District’s AIP BACT Memo 1

41

1 https://www.ourair.org/wp-content/uploads/Winery-Achieved-in-Practice-Memo-Revised-6-1-2018.pdf

Authority to Construct 15044• Permit Authorized:

– Fermentation in all 400-series tanks– 50% increase in wine fermentation capacity– Installation of new oak barrel storage room (2,500 bbls)

• Required use of control systems as AIP BACT

• Control systems required to meet 67% control efficiency over entire fermentation season via mass balance approach

• No source testing

• CCWS voluntarily added the controls to the entire facility

42

43

CARB BACT / Technology Clearinghouse

Wine Institute Appeal

44

Wine Institute AppealWine Institute appealed the permit and raised a myriad of incorrect and misleading technical claims:

45

Insufficient Track Record

Use on All Tank Sizes

Use on All Wine Types

Use Over a Full Fermentation Cycle

Performance Standard Basis

Not Consistent with Policy

Performance Based on Theory

Economic Analysis

Wine Quality & Contamination

Source Testing Necessary

San Joaquin Valley Memo

EPA Views are Inconclusive

https://www.ourair.org/wine-institute-permit-appeal-archive/

CARB Input“In summary, CARB staff agrees with the District’s findings: the performance standards and the control technologies used to meet the performance standard are properly designated as achieved-in-practice BACT for control of VOC from wine fermentation tanks.”

- Richard W. Corey, Executive OfficerCalifornia Air Resources Board

46

Wine Institute Settlement

47

Wine Institute Settlement1. AIP determination limited to class and category:

– Closed-top tanks 30,000 gallons or less

2. AIP Memo updated 1:– Notation that all fermentation occurs indoors at CCWS– Notation that control systems have not been used on tanks less

than 1,100 gallons in size at CCWS

3. Wine Institute withdrew appeal and agreed to not appeal future permit actions (including individual members)

481 Not part of the BACT Determination.

Wine Institute Settlement (cont.)• APCD offered class and category settlement in November

2017 – WI initially rejected offer

• First AIP BACT Determination for winery controls

• Size limit was implied due to technology transfer requirements

• Closed-top tank limit was implied due to control system operating principles

49

Conclusions• Emission controls for wineries work

• The emission controls are cost effective

• District’s should think outside the box when confronted with unique operating conditions

• Seek input from CARB and EPA on complex issues

50

Questions?

51