Brian

please review bottom of post! Reference Doc below https://www.regulations.gov/document?D=TTB-2018-0007-0001 Notice No. 176: Modernization of the Labeling and Advertising Regulations for Wine, Distilled Spirits, and Malt Beverages 1. Subpart A—General Provisions Proposed subpart A includes several sections that have general applicability to part 5, including a revised definitions section, a section that defines the territorial extent of the regulations, sections that set forth to whom and to which products the regulations in part 5 apply, a section that identifies other regulations that relate to part 5, and sections addressing administrative items such as forms and delegations of the Administrator. Proposed § 5.1, which provides definitions of terms used in part 5, has some changes from the regulatory text that appears in current § 5.10. In addition to the proposed amendments discussed above in section II B of this document, TTB proposes to modify the definition of “age” to simplify it and to make clear that spirits are only aged when stored in or with oak. The wood contact creates chemical changes in the spirits, which is the aging process. Thus, for example, spirits stored in oak barrels lined with paraffin are not “aged.” Additionally, TTB proposes to add a definition of “American proof,” which cross references the definition of “proof.” The term “American proof” is used in some circumstances to clarify that the proof listed on a certificate should be calculated using the standards in the part 5 regulations, not under another country's standards. TTB proposes to amend the definition of “distilled spirits” to codify its longstanding position that products containing less than 0.5 percent alcohol by volume are not regulated as “distilled spirits” under the FAA Act. TTB also proposes to add a definition of “grain,” which would define the term to include cereal grains as well as the seeds of the pseudocereal grains: amaranth, buckwheat, and quinoa. TTB has received a number of applications for labels for products using pseudocereals, and TTB also notes that the FDA has proposed draft guidance allowing the seeds of pseudocereals to be identified as “whole grains” on labels (see 71 FR 8597, February 17, 2006). Finally, TTB proposes to define the term “oak barrel,” which is used with regard to the storage of certain bulk spirits. TTB and its predecessor agencies have traditionally considered a “new oak container,” as used in the current regulations, to refer to a standard whiskey barrel of approximately 50 gallons capacity. Accordingly, TTB proposes to define an oak barrel as a “cylindrical oak drum of approximately 50 gallons capacity used to age bulk spirits.” However, TTB seeks comment on whether smaller barrels or non-cylindrical shaped barrels should be acceptable for storing distilled spirits where the standard of identity requires storage in oak barrels.

What is a BARREL? Below is the reference for the TTB asking for comment on proposed rule changes for the definition of "barrel", etc. (see very bottom of post) Anyone in the beverage industry has an open invitation to steer the TTB's definition and subsequent enforcement of rules impacting our businesses. Anyone using barrels in their business should (must?) be commenting on this proposed rule. These rules effect the definition of grain, barrel (and allowed sizes), proof, oak container, and aging. Anyone using a barrel smaller than 50-53 gallons should (must) be commenting on this proposed rule. Anyone trying to get to market faster by using barrels smaller than 53G to preform experiments or uses in steer the profile of their products by dosing with "over-oaked" or non-oak species should be commenting on this rule making. If your want to use barrels composed on non-oak species in the heads, interleaved staves of non-oak with oak staves or any non-standard aging system such as the "Squarrell" which uses a stainless steel frame with replaceable oak or other species panels. This non-round solution allows significant cost reduction and reduced impact on harvesting of oak and square/rectangular increased storage density. The TTB is as bound by tradition as any of our institutions. It was created to provide guidance for how our industry is allowed to grow and change with the hindsight of tradition as a reference. If the constraints of the TTB rules seem limited and restricted and in fact are slowing innovation and growth, this is the time to speak up. Notice No. 176: Modernization of the Labeling and Advertising Regulations for Wine, Distilled Spirits, and Malt Beverages 1. Subpart A—General Provisions Proposed subpart A includes several sections that have general applicability to part 5, including a revised definitions section, a section that defines the territorial extent of the regulations, sections that set forth to whom and to which products the regulations in part 5 apply, a section that identifies other regulations that relate to part 5, and sections addressing administrative items such as forms and delegations of the Administrator. Proposed § 5.1, which provides definitions of terms used in part 5, has some changes from the regulatory text that appears in current § 5.10. In addition to the proposed amendments discussed above in section II B of this document, TTB proposes to modify the definition of “age” to simplify it and to make clear that spirits are only aged when stored in or with oak. The wood contact creates chemical changes in the spirits, which is the aging process. Thus, for example, spirits stored in oak barrels lined with paraffin are not “aged.” Additionally, TTB proposes to add a definition of “American proof,” which cross references the definition of “proof.” The term “American proof” is used in some circumstances to clarify that the proof listed on a certificate should be calculated using the standards in the part 5 regulations, not under another country's standards. TTB proposes to amend the definition of “distilled spirits” to codify its longstanding position that products containing less than 0.5 percent alcohol by volume are not regulated as “distilled spirits” under the FAA Act. TTB also proposes to add a definition of “grain,” which would define the term to include cereal grains as well as the seeds of the pseudocereal grains: amaranth, buckwheat, and quinoa. TTB has received a number of applications for labels for products using pseudocereals, and TTB also notes that the FDA has proposed draft guidance allowing the seeds of pseudocereals to be identified as “whole grains” on labels (see 71 FR 8597, February 17, 2006). Finally, TTB proposes to define the term “oak barrel,” which is used with regard to the storage of certain bulk spirits. TTB and its predecessor agencies have traditionally considered a “new oak container,” as used in the current regulations, to refer to a standard whiskey barrel of approximately 50 gallons capacity. Accordingly, TTB proposes to define an oak barrel as a “cylindrical oak drum of approximately 50 gallons capacity used to age bulk spirits.” However, TTB seeks comment on whether smaller barrels or non-cylindrical shaped barrels should be acceptable for storing distilled spirits where the standard of identity requires storage in oak barrels.

https://www.driveswarehouse.com/ FYI.....these can be specified to run on single phase 240VAC.....thought de-rating is required they will work fine.

DISCUS has an Industry based document that may be applicable. I would STRONGLY suggest you pay the nominal fee and get this publication. "Recommended Fire Protection Practices for Distilled Spirits Beverage Facilities 3rd Edition"

FIRE PROTECTION DOCUMENT---- DISCUS has an Industry based document that may be applicable in Canada. I would STRONGLY suggest you pay the nominal fee and get this publication. "Recommended Fire Protection Practices for Distilled Spirits Beverage Facilities 3rd Edition" Elsewhere in this forum lurk PE's who are familiar with the safety requirements and have successfully guided folks over this hurdle. Excised from the DISCUS document....to wet you whistle... 4-7 ALARM SYSTEMS AND WATCH SERVICE 4-7.1 Fire and evacuation alarm systems should be considered for each facility. Operations involve the production and handling of flammable alcohol along with utilization and storage of other combustible materials. These alarm systems will help with timely identification and notification of potential fire or other emergencies and will facilitate a quicker response by both private and public emergency services (fire, police, etc.). These systems also provide a mechanism to notify all personnel of the need to evacuate the buildings or area. Building, fire, or life safety codes or fire authorities may mandate installation of these systems. Refer to NFPA 72, National Fire Alarm Code and NFPA 101, Life Safety Code. 4-7.2 Proper installation of fire alarm system components, such as automatic fire detectors (smoke, heat, optical, etc.), manual activation devices, waterflow switches, alarm notification appliances, control panels etc., is critical to their satisfactory operation. Installation, testing and acceptance of the components and systems should conform to industry standards and practices. Refer to NFPA 72, National Fire Alarm Code and NFPA 101, Life Safety Code. 4-7.3 All fire alarm system wiring, initiating devices, detectors, alarm appliances, etc., should be listed for use in accordance with the classification of the area in which they are installed. Refer to NFPA 72, National Fire Alarm Code and NFPA 70, National Electric Code. Refer to Chapter 6. 4-7.4 Monitoring (supervision) of the fire

in the bottom of my columns the downward liquid flow seals the down of the column which then drains from near the bottom of the column this "backup" functions as a kind of trap with separation from the in flow of high temperature vapor.....the tube returning to the pot was not uncovered.....

is it possible you are driving it too hard and not allowing for the entire column to stabilize or the defleg is too cold and rejecting too much product and flooding the plates?....happen to have a laser temperature gun to check temps of plates as vapor goes higher and higher?

my pots had a return well into the pot....the path was up through the helmet and over to the bottom of the column....the liquid from the downcomers draining out of the very bottom of the column and the vapor input 3-4 inches off of the very bottom of the column.....so when running the "seal" was the liquid in the bottom of the column... What is the diameter of the return to the pot? ru not doing something like mis-configuring the valves right? so another silly question: did the manufacturer commission your still....has it been wonkly from day one? If you have a grain in mash the return could be plugged with solids from previous runs and not allowing a return...

if the liquid return path is above the liquid line in the pot, both paths could be feeding vapor....

Are there two paths to the column....1) for vapor and 2) for condensed liquid being returned to the pot?

https://www.zoro.com/search?q=flowmeter&page=3 zoro has a bunch to consider depending on your needs

http://www.omega.com/pptst/FP2001-R.html Grainger... FILL-RITE 6 to 40 gpm Liquid Mechanical Flowmeter Item # 30J080 Mfr. Model # 900CDBSPT Catalog Page # N/A UNSPSC # 41112501 Make sure you have approval for all wetted parts to ethanol (solvent).....you should consider EX or ATEX rated considering you have a potentially flammable/explosive situation

Steam is not a popular as it once was and it may be hard to find a local plumber or PE that can guide you through the layers to build a safe, inspected, code compliant and efficient system. Probably could be looking at efficiency as the underlying factor. How fast can you get to operating pressure? Is your code compliant boiler room large enough to service the tubes? Can they be changed out by a local company (or on site engineer) or would the re-tubing require fairly exotic tools and factory support and re-certification inspection? Look at the used market. We found a great boiler nearly new but it was 2500 miles away.... You could consider hiring a chemical treatment company to come in a add boiler/steam (buffering) chemicals and perform monthly testing to reduce the corrosion of the tubes and steam lines with controlled blow down systems. Boilers need combustion air supplied from the outside of the building and isolation from sources of fuel. Are you going with low pressure steam or high pressure steam? High pressure steam is quite a bit hotter and may allow you do do cool stuff like generate clean steam for direct injection or flash cooking but may require a higher hurdle for licensing, operation and inspection. So what is your time line and expansion plan or are you just trying to get out of the dirt? You might want to review the inspection/operating/pressure certification (AHJ) license requirements for what ever system you use.

http://www.spiraxsarco.com/Pages/Applications-Overview.aspx bottom of page....your local library may have reference material or you can sign up for their "bible" http://info.spiraxsarco.com/access-our-product-handbook-gateway

http://www.spiraxsarco.com/Resources/Pages/Steam-Engineering-Tutorials/introduction/steam-the-energy-fluid.aspx

You can use two smaller boilers each with its own set point so only one will run when you are in the 'heart' or the low demand portion of the day and both will operate under startup conditions like the start of the day or a mash cook. There are modulating burners (powerflame, etc.) that can be set to a given PSI and hold that PSI over the course of the day. Honeywell has a boiler control that has high and low set points and a sensitivity band to control within a smaller (+,-) differential range so there is less of a steam impulse. I set up a PSI meter that allowed the distillers to monitor the steam pressure and control the gate valves against their demand around the available PSI, this could be a simple low pressure steam gauge your plumber can add to the steam line.

http://www.chemsep.com/

GW Kent is another supplier....

http://www.rkiinstruments.com/product/beacon-200/ you need to pick the gas you want to track/alarm

Affordable Distillery Equipment has some small agitators....could try a damper to reduce the level of heat being exhausted...

Ward has always been helpful with any issue we have had.....have you sent the photos over to them? I think they would want to sell you a burner with a lot more jets or re-jet with what you have.....how do you adjust the flame once you do get to temperature? Does the control have a safety that will stop gas flow if the pilot or flame fails? Is the flame color mostly blue which would indicate good air/gas mix....

https://www.gpo.gov/fdsys/pkg/CFR-2012-title27-vol1/xml/CFR-2012-title27-vol1-part30-subpartC.xml Using NMR could be useful for tracking congeners in real time and if you are really flush with cash take a look at https://www.alpha-mos.com/. This little bit of kit can analyze in near real time both liquid and head space components and interpret them against your defined set of alcohols and congeners.....think mass spectrometer without hiring a PhD scientist to operate, maintain and interpret your in process congener targets creating an easily understood (by mere mortals) spider graph. The big boys have adopted these gorgeous toys. Two companies that I know of make electronic instruments capable of the TTB approved level of resolution: www.rudolphresearch.com http://www.anton-paar.com/corp-en/products/group/density-meter/ I think both of these instruments can be traced to international standards that are also referenced by the US TTB. My personal favorite is the Rudolf instrument as they have been extraordinarily supportive and have a solution that can resolve densities of beverages that have sugar added. I am located on the east coast and factory representatives have been to my location on several occasions. We were one of their first clients and bought the instrument around the point where the TTB approved the Rudolph for US Federal tax gauging. If you are lucky enough to be able to afford one of these instruments, they are truly a time saver and an "insurance policy" against any proofing error that could bring down the ire of your tax authority. The use of precision glass hydrometers is possible but because temperature becomes such a factor at the TTB required resolution it makes it very time consuming to perform the measurement. The Anton Paar DMA-35 is very useful in day to day operations. It will produce nearly instantaneous temperature compensated density (no sugar correction that I know of). This is very handy if you are one of the people that actually makes their own GNS (or are purchasing GNS from the Borg) this is very handy to keep around the still for day to day in process proofing.

could use a closed loop heat exchanger to run to a cooling tower and "dump" the heated non-contact cooling water to ambient. To get below ambient you could run through an adsorption chiller (http://yazakienergy.com/) . This thing isn't cheap but cools uses heat as an energy source but may net out using less energy than brute force (compressed Freon) chillers with glycol loop and helps with ur green backstory. could store this now chilled water in an insulated tank for your next condenser run in an A/B system....one active one being chilled for the next distillation run could collect some of the non-contact cooling water out of the condensers for pre-heated water for the next mash send me a PM and I can send you a drawing.....

these guys make a relatively inexpensive proportioning valve....will operate with low pressure steam and water (must check specification!!)...spring closing could present issues for running over temperature condenser if you buy the normally spring closed variant and loose power.....seems like jumper would allow 0-10VDC or 4-20ma control.....little tricky sorting out the valve body (from 1/2" on up) and the control specs.....be sure of your specification. (me4840) http://pdf.directindustry.com/pdf/spartan-peripheral-devices/me4640-me4740-me4840-me4940/16884-496545.html

https://www.stilldragon.org/discussion/1450/my-pid-experiments