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Everything posted by Patio29Dadio

  1. Nothing in the fire code that I am aware of. Although the fire code does not definitively cover wood barrels. There is a general interpretation that wood barrels are outside of the MAQ code for containers holding spirits (the 240 gallon limit for a sprinklered control room when container is closed). In some jurisdictions they demand that the barrel storage be included and thus force the expensive C1D1 code compliance instead of the C1D2 that all craft distilleries should strive for. The thinking is that a wooden barrel would collapse from fire before it would become a bomb like would a stainless steel vessel... thus keeping the wooden barrel out of the MAQ. Now, I there is a high-piled combustible stacking code that might play a part in determining barrel size (class 1B and 1C flammable liquid). Each jurisdiction might vary and it matters if sprinklered or not, but it is a general limit of two standard 53 G barrels on racks stacked horizontal... maybe three if sprinklered. Also depends on the roof height. So a larger barrel might be an issue there.
  2. Nice concrete and corrugated bar!
  3. Go to Automation Direct. I am using Prosense RTD temp probes. These are NEMA 4x and generate so little current that they are explosion-proof without needing the certification. They measure changes in resistance between a high-conductivity wire and a ceramic core. They don't get any power other than what they generate. The wire is expensive.... about $1.20 per ft. The probes are about $80-$100 each. Now the next step is a digital display. Those can vary but expect at least $100 each. And you will need an enclosure with all the wiring, etc. So your analog temp gage replacement just became an expensive move.
  4. I am building my 3-tank system right now. 1600 gallon stainless tank to receive hot water from condenser and pre-condenser output. Let sit over night to cool. Pump to 1600 gallon poly tank in the morning. Now the stainless tank is empty and ready for another run. Other 1600 insulated poly tank is chilled to 60 degrees constant by my 6-ton portable chiller. After day of run, pump water from non-insulated poly tank to refill the insulated tank and let chiller do its thing overnight. Might add a cooling tower in the future. Most days my process uses 1000 - 1200 gallons of chilled water, so I have plenty of capacity in these 1600 gallon tanks. I use some of the hot water from the stainless tank for cleaning. The plumbing runs to all the chilling needs (stills, mash tun, fermenters, crash chiller, etc.) have a three-way valve to use city water when needed. And of course a big back-flow preventer to keep the process water out of my potable water. The next steps are to hard plumb and automate the water transfer and have the chiller pull in make-up water for the 1600 gallon insulated tank using an adjustable float valve. Never want to run out of chilled water!!!!! The city water is a bit over 60 degrees most of the year. If water were cheap and plentiful I would probably not worry about sending it down the drain. Even so, the cost of chilling and pumping might end up costing me more in energy than the water would otherwise cost. But we get to point out the environmental benefits with a closed-water cooling system.
  5. Interesting. Just make sure you hire a certified valuation analyst to figure out what your business should sell for. Starting a distillery is a 4-5 year effort for most, and that should be part of the valuation. I am sure the buyers are coming to you for that reason. And a established distillery with revenue adds another level. I think there are different paths to brand development... all taking money and depending on your business model there may be better paths than this one. However, I would vet every real offer as just another business plan assessment.
  6. Latest... they are fighting the “blend” part because the two allowed/recognized blend types are: 1. Straight whiskeys from the same state. (No formula required) 2. A product that is a blend of at least 51% straight whiskey/s plus GNS (even though the description does not require GNS, that is the intent of this type... a product with other stuff blended to the straight whiskey.) A formula is required for this. My approach was to apply for #2 but just skip adding any of the other stuff... something that seems to be allowed in the specification of the type Blended Straight Bourbon Whiskey. But when my formula is only multiple straight bourbon whiskeys they put it as a type Type Whiskey/Bourbon... basically negating the need for a formula. They want me to remove the world “Blend” and “blended” from all the parts of the label, because, they say, that they don’t want the consumer to be confused. And I tell them if I label it Straight Bourbon Whiskey while it is a blend of more than one Stright Bourbon Whiskeys from different states, that seems to: 1. Be misleading to the consumer as the consumer will naturally assume it is one bourbon. 2. Eliminate a key description of the uniqueness of the product... being a blend of different straight bourbons and not a single expression. I have a name of a specialist to talk to and will try to reach him next week to talk this through. From my perspective, they should allow it to be a Straight Bourbon Whiskey but accept the fanciful name “Capital Blend Bourbon Whiskey” as long as I remove “Blended Straight Bourbon Whiskey” from the label. Otherwise I have to call it Capital Straight Bourbon Whiskey... and that misses the point. Learning that there are number of COLA gray areas and undocumented standards known by the TTB agent and not otherwise documented in any definitive way. And I have A LOT of experience dealing with federal regulations.
  7. Just got off the phone with a nice and knowledgeable TTB person. We looked at the High West COLA approvals and was told they were wrong. Oops... I hope I did not make any trouble for them! But you are correct in that it was the font size of "Bourbon Whiskey" that caused the correction request because they thought it conflicted with the actual type. The change is to remove the "A BLEND OF STRAIGHT BOURBON WHISKEYS" line and to change BOURBON WHISKEY to "BLENDED STRAIGHT BOURBON WHISKEY". Then my fanciful name will be "Capital Blend". Said they should not have a problem with the "California"... told me to include a comment that it is expected that some or all of the source will be distilled in California.
  8. Thanks JailBreak and Julius. I appreciate your help and advice. As I understand, STRAIGHT BOURBON WHISKY can be a blend of more than one STRAIGHT BOURBON WHISKY as long as from the same state. This then supports the distilled in state labeling requirement. However, I was going for BLENDED BOURBON WHISKEY which requires only a minimum of 51% of straight bourbon bourbon whiskey and can include harmless flavoring and coloring (which I will never add). The alternative is A BLEND OF STRAIGHT BOURBON WHISKIES which is the actual product I am intending to make but originally TTB did a "needs correction" that sent me to the previous. Looking at High West American Prairie Bourbon, they are classified as STRAIGHT BOURBON WHISKEY BLENDS (#3 above I believe). And in terms of labeling, for the High West product the Fanciful name does not include the word "straight" and the tag line below the fanciful name is exactly as mine "A Blend of Straight Bourbon Whiskeys". Also, there is no "state of distillation" on the labels and there is a "Bottled by High West Distillery, Park City, UT" line on the label. See below for the comparison. I am going back to TTB with this and will let you know how it turns out.
  9. I have two products, a blended bourbon whiskey and a blended rye whiskey. As I can tell, both are qualified as a separate type under the class of Whiskey: BLENDED BOURBON WHISKY OR BOURBON WHISKY - A BLEND and BLENDED RYE WHISKY OR RYE WHISKY - A BLEND Definition: Blended whisky produced in the U.S. containing not less than 51% on a proof gallon basis (excluding alcohol derived from added harmless coloring, flavoring or blending materials*) straight bourbon [or straight rye] whisky. My fanciful names are "Something Blend Bourbon Whiskey" and "Something Blend Rye Whiskey". Under that name on the front label is "A Blend of Straight Bourbon Whiskeys" and "A Blend of Straight Rye Whiskeys" respectively. On the back label is a bit of puffery reading: "[fanciful name] is a marriage of one or more straight bourbon [or rye] whiskeys." I have been around the block with TTB with several "needs corrections" that seem to contradict the previous. This last one is: A class and type such as 'Rum," "Tequila," "Brandy," etc. must appear on your brand label. 27 CFR 5.22 and 5.35 Additional Clarification: Per your remarks, "This product is a blend of one or more Straight Rye Whiskeys." If that is the case, the correct designation is "A Blend of Straight Rye Whiskies," or "Blended Straight Rye Whiskies." The information included in your attachment(s) and/or the "notes to specialist field" has been reviewed; however, the correction(s) that we requested must still be made. Additional Clarification: Your Brand Label contains two designations. If the spirit is "A Blend of Straight Rye Whiskies," (or "Blended Straight Bourbon Whiskeys") that would be the designation. The Brand Label should not contain two different designations. ("Rye Whiskey" and "A Blend of Straight Rye Whiskeys" And finally and brand new one... Your product requires a state of distillation statement. The state of distillation may appear as: "DISTILLED IN ___" or the state may appear with the class and type, such as "___ STRAIGHT BOURBON WHISKY". 27 CFR 5.36(d) Additional Clarification: If "California" will appear on the label, than a State of Distillation statement should also appear on the label please. The problem here is that the source of this final product is from more than one distillery and more than one state. The back has the "bottled by us" text. The front of the label includes the word "California" because that is where my distillery is located. I look at High West for an example and even though they have been distilling 0% of their juice, they have no specific "distilled by" and Utah, Park city on their label. From my perspective I think I must be getting a young and confused analyst assigned me, because nothing makes sense per the regs and standards I can find. BLEN
  10. I am about ready to tear my hair out going back and forth with TTB over our COLA permit for a blended bourbon and rye product. Their needs correction responses are contradictory and don't seem to apply to other similar products. Does anyone have the name and contact information for a distilled spirits COLA expert consultant I can hire for help here?
  11. Thanks starcat. I have found some interesting reads on the difference between industrial process equipment and what falls under the jurisdiction of the local building official as per the ICC International Building Codes. Other than electrical, gas and water plumbing the conflict appears to be with the mechanical engineering application. For specific industrial process equipment, for which I make the argument that a distillery low pressure steam boiler belongs, there are often standards where the owner of the business is the AHJ (authority having jurisdiction) as the owner is the liable and responsible party that is supposed to know how the equipment will be used and hence how the equipment should be installed within the scope of the manufacturer installation specifications. Most of the building code mechanical engineering, if not all, seems to apply to the standard building and premise mechanical systems... not specific industrial manufacturing equipment. However, I don't have a problem with my local building official requiring a permit and plan check review for my steam boiler.... my problem is that they are requiring engineering-approve plans. Using this example they could make the case that they need the same for almost every other piece of equipment. For example, do they need a signed engineering plan for my air compressor and all the pneumatic lines and connections? Do they need a signed engineering plan for all my stills, mash tuns, hot liquor tanks, etc? I am the only non-engineer that understands the engineering design for these things. They are stuck on part of the code that says a "design-build contractor" can sign the plans instead of an engineer. I have a GC, but I did the design so they are saying that won't work. The GC does not do design. Nobody knows how to design the system better than me since it is my distillery. I have a meeting with them in the morning so we will see where this goes.
  12. I think I remember reading that article. I will look for it and let you know.
  13. I am having quite a go-around with my local building official over my low pressure steam boiler. They outsource plan check (small city without much brain power) and the plan-check engineer is treating it like a building HVAC system boiler and requiring complete wet-signed mechanical, plumbing and electrical engineering plans. The boiler is completely UL and ASME certified. The installing contractor is completely C4 certified with a clean contractor license. I get quotes for about $15k just for this engineering with all the mechanical, electrical and plumbing engineers telling me that I need to educate them on what is needed... how this equipment must be installed and used... because they don't have a clue and this type of thing is out of their typical scope of work. The installing company does not have an engineer on staff to take care of this, and they tell me that every manufacturing client they work with gets their boiler treated as a piece of process equipment (like a mash tun and still) and the building and mechanical code only needs to concern itself with the utility connections and anchoring. I am putting up a fight spending $15k for just checking a box for compliance outside the scope of what a building code covers. When I review the ICC International Mechanical Code for steam boilers, it does not differentiate between a building system and a piece of process equipment. However, I think both the plan checker and the city building official are way out of their pay-grade in what they are thinking they need. For example, they want a design of all steam-related process connections and claim they need to inspect them and approve them. The biggest problem is this demand for wet-signed engineering. I have provided them CAD plans of the general layout of the tank room and noted all the connections. Also have all the calculations and specs for gas, electrical and water connections. I think they just need to make sure the gas, water, electrical, stack and anchoring are all to code and and are of sufficient capacity based on the boiler manufacture's specs for the model. This is a 1.2MBtu low pressure steam boiler. Not that big of a beast. Does anyone have any similar experience making a case with the local building official that the steam boiler is process equipment like a still and they need to back down a bit?
  14. Go find yourself a CVA (certified valuation accountant/analyst) and have them value the business before you consider any offers. Generally a business is worth less than what the seller thinks it is worth, so you are generally going to pay for the CVA costs in the saving in the sales price for the business. A good CVA helps the seller understand how his business is valued and how it is not valued and saves you from that conflict of not agreeing on price.
  15. More than likely they had some claim that has caused them to evaluate their client portfolio and attempt some risk management. I had one carrier quote that would only cover us if we promised to move our barrels to another building. Even though the barrel room is a separate, sprinkled, control room. The rep admitted that he was getting this handed him from underwriters because of a previous claim where a still fire took out the barrel stock stored RIGHT NEXT TO THE STILL IN THE SAME ROOM! But they could not accept barrels in another control room away from the production area. They are reactive that way.
  16. I am in the middle of designing my plumbing pipe runs to two stills both with a dephlegmator and condenser. Eventually I will be adding a closed loop 3-tank system where I save the hot water from a run, use some of it for cleaning let it cool overnight, pump it to the holding tank in the morning where it will be pumped through a chiller at night to the insulated cold water tank for consistent 60 degree F chilling water for the next day operation. But for now I am just imputing city water (which is pretty close to 60 degrees most of the year) and saving the output to a hot water tank for cleaning, and sending some through a UV/filter/RO/variable-TDS system for mash and/or proofing water... and sending the excess down the drain. My question is related to the input runs to the pre-condenser and primary condenser. Option #1 is to plumb input water to both and each with a ball valve (no automated controls yet). Option #2 is to take the output water from the condenser to the input of the pre-condenser with a 3-way valve to control and divert the input to the pre-condenser flowing from the condenser output. I hear from some that option #2 is preferable as too cold water into the pre-condenser results in more difficult control. But my thinking is that with our water temp pretty consistent, a direct and separate water line to the pre-condenser is preferred as the condenser output water temp will be yet another variable to deal with. Any thoughts and advice will be welcome here.
  17. Roger - Appreciate the comment. And I agree with this above. That is why I like to read about other's protocols. I consider myself a gourmet cook. I read cooking-related articles and recipes not with any interest to copy them, but to gain understanding and inspiration for my own creative approach. Us craft people, no matter what the product, are better off with a wide and deep understanding of all the alternatives. I know a lot more than I did several years ago, but I will never know all that I can to make me a more creative and resourceful craft producer. I view it like a ladder we are all climbing where higher up are increasing levels of competency. I like reading the questions of people that might be further down the ladder than me (as well as those from the more mastering distillers at the top) because I know there are bits that I might have missed on my own climb. Also, there is a principle that true knowledge is best realized when you can teach others. Teaching is one the best ways to really learn. IMO!
  18. Question about a planned grain bill of 50% unmalted barley and 50% hard winter wheat. Will I have problems with lautering vs using malted barley?
  19. Somebody told me this four years ago when I started my business plan. So I doubled my estimates of cost and time. Should have doubled it again. Here is the way I look at it now... do something else if you don’t have at least $2M to drop before breaking even but more like $3M for most projects... depending where you live. And lower your expectations for selling wholesale beyond your local and maybe regional markets. Find a way to make your distillery a retail destination selling drinks and food. This rules are different state-to-state, so some might not have this option. But it is really the only reasonable way to create a successful distillery business... unless you are marvelous and lucky creating a brand and products that push others off the shelf.
  20. Roger dude... really? Personally I get something out of posts like Georgeous’s. Note all the variables. There is no right way. And any distillery should have a mindset that he/she will be learning about a better way until they are no longer distilling.
  21. I second this. Exogenous enzymes are your friend of conversion consistency. Did you acquire your malted rye and barley malt from the same place and is it from the same grain batch?
  22. This thing is terrible timing for me. Transfer permits pending. COLA's pending. Another business is also impacted, but that is another story for another forum. One question... is ADI or any other Association doing something like this? Those Brewers seem to have their act together. This shutdown is also impacting the big distillers I assume. Especially for transfers. How can the private label guys survive without being able to source juice from MGP, etc? TTB_Mnuchin-Ltr-regarding-shutdown-1.24.19.pdf
  23. I have been using Rinnai for years and with no problems. FOR INDOOR APPLICATIONS ONLY RUC80i .................. REU-KBD2530FFUD-US RUC90i .................. REU-KBD2934FFUD-US RUC98i .................. REU-KBD3237FFUD-US FOR OUTDOOR APPLICATIONS ONLY RU80e ................... REU-KB2530WD-US RU90e ................... REU-KB2934WD-US RU98e ................... REU-KB3237WD-US
  24. I think you will need to rely on an attorney to answer that. But I believe the answer is no. I think the tied house rules flow to a spouse... but not other relatives. I know of situations where distillers in states without self-distribution options had a relative become a distributor to help them move products... but they have to be separate entities without any cross ownership.
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