Jump to content

bluestar

Members
  • Posts

    1,679
  • Joined

  • Last visited

  • Days Won

    35

Posts posted by bluestar

  1. When I head back up to my place in Holland in a couple weeks, be happy to get together and provide some feedback. Also, Paul's advice in general is pretty good. He is right about still size,  but it is no deal breaker, you can always store the strips as low wines or run the spirit still 2/3 or so full.

    • Thanks 1
  2. On 5/20/2019 at 3:15 PM, dhdunbar said:

    ...

    But I generally try to avoid interesting fights.   And I might be missing something.  I can't be sure that I am not.

    I understand your reasoning, and I would concur. The only reason we have done otherwise, is that the one verbal inquiry we made to the TTB said no, and generally one is advised to follow advice from the TTB (although they can and do make mistakes). So, my current belief is that there is a reasonable argument to consider it not disallowed, but no place in the CFR where it is explicitly allowed.

  3. 2 hours ago, dhdunbar said:

    Nor am I, but it does appear in the proposed regulations.  §5.74(a)(3), as proposed,  provides, "(3) If spirits are aged in more than one oak barrel (for example, if a whisky is
    aged 2 years in a new charred oak barrel and then placed into a second new charred oak barrel for an additional 6 months,) only the time spent in the first barrel is counted towards the ‘‘age.’’ 

    I don't know how TTB would conclude that this sort of requirement is necessary.  Transfer from new to new would seem to be a "no harm, no foul sort" of play - expensive, for sure- but not one that would lead to deception in age statements.   

    The chart in the NPR that describes the impact "on rulings, industry circulars, and other public guidance documents issued over the years by TTB and its various predecessor agencies" lists no document that is superseded by §5.74(a)(3), so, if the list in the table is complete, you will not find the requirement "in the CFR or other TTB communication."  

    I conclude that either this is a brand new rule - which some above say it is not - or it emerges from a private letter ruling that someone issued in the past.  I don't plan on commenting because it seems to be a rule of little consequence to any of my clients, but it would be interesting to know the impetus that lead to the question and the logic behind the answer. 

    Thanks, you are pointing out where the proposed regulation makes overly clear that you can not sum the ages. But my question to @gabericharde was where in the CFR he can cite that you ARE allowed to do it. I am not aware of it. I believe the proposed change is to make clearer the current interpretation of the current regulation, especially if that interpretation may have been true for some time. I do understand how one could argue, with no indication otherwise, that if moved from one new charred oak barrel to another, the product is always aged in a new charred oak barrel, and one could sum it. Similarly, if moved from a new charred oak barrel into a used barrel, including the barrel it was in initially, one could argue it has not been stored in a used charred oak barrel, etc. Also note that Chapter 8 of the BAM does not address this issue, either. Now, there is one hint or suggestion that we should NOT assume it can not be summed: in the case of age statements in used cooperage, foreign producers will often move from one barrel to another during the period of aging, and that is allowed as part of the total age statement. I have also checked the rulings, and have not found it either. Maybe someone else has?

  4. Oh, I should add, some of the more expensive units are also explosion proof for this application. Which means, the cost to properly install them is also high, since they will need to be wired in using contained solid conduit meeting those requirements. And, if you are locating the sensor where everything else is required to be explosion proof (like your lights, electrical outlets, power and control wiring), then certainly you want your sensor to be explosion proof as well. If you want to put the sensor close to the still, for example, this will likely be the case. Probably not an issue if being used in a storage area for barrels. But if used near the still, you want to use it to do more than turn on a fan: you should also have it failsafe to kill heating power to the still. I don't think the RKI PS2 is explosion proof, so it would not qualify. RKI does make remote sensors that are explosion proof, akin to the Q8 mentioned elsewhere by @starcat.

    Finally, original poster asked about tying into fire alarm. Again, there are a fair number of less expensive units available for that now (although more expensive than the cheap home units), offered by the same companies that sell the smoke and CO alarms currently used in fire alarm installations, and for the same purpose: to detect combustible gas. In some areas, this is becoming a requirement anywhere that gas-fired heaters, boilers, ovens, and stoves are located.

  5. 20 hours ago, vsaks said:

    You can use another cheaper alarm if
    1. The alarm can be calibrated
    2. The range is suitable for your use
    3. The sensor being used is stable enough that it doesn't drift
    Even the RKI PS2 needs to be periodically calibrated. We used 2000 ppm Hydrogen and 4000 ppm Hydrogen as surrogates to calibrate at 10% and 20% LEL of ethanol as recommended by RKI (though my research indicated that it should have been 2800 ppm and 5600 ppm Hydrogen).

    You need to match the LEL equivalence. 10% LEL of ethanol is the same as 9% LEL methane, 13% LEL propane, or 14% LEL n-butane. Double those for 20% LEL ethanol.
    An off the shelf alarm at 5% of methane will trigger at 6% LEL ethanol. Not sure if you really want that.
     

    Everything you said is correct. But as you note, everything needs to be calibrated, or nothing. If you get a unit that can read out ppm or %LEL, you can calibrate. What would be wrong with triggering at 6% LEL ethanol, if 10% is required? You are not prevented from being more stringent. Note, I agree, if you can afford the fancier units, it is a better choice, and if your FM or insurance company requires it, then there you go. But wouldn't it be better for many small distilleries (vast majority) operating without any combustible sensors be operating with what is easily and cheaply available?

  6. 21 hours ago, Thatch said:

    Yes, what does your insurance company and AHJ mandate.  Ours liked the RKI and fans turning on.  We also have audible and visual alarms.  Your insurance company and AHJ may not care.  Sometimes this is not about logic but instead about dotting the i's and crossing the t's.

    As I said, the difference is certification. Many of these cheaper units have audible alarm, visual alarm, relay for turning fans on, and some even display the nominal ppm or %LEL of the combustible gas. Note these units have come onto the market in the past couple years for use in homes and RVs for fuel gas detection. Most are Chinese manufacture. Like other consumer versions, rather than replace the sensor periodically (which you must do as part of the maintenance and calibration of the more expensive units), you replace the whole unit in most cases every couple years.

  7. While more expensive alarms like the RKI PS2 are fully certified and calibrated, it is not clear they will be any more useful than a cheaper combustible gas LEL detector. There are many on the market today meant to detect methane/butane/propane. The cross sensitivity of the detectors used for these between ethanol and butane or methane is close to 1, hence they will likely detect ethanol vapor at the same levels as these other gases. Also, the LEL for these gases ranges from 1% to 5%, and ethanol is 3.3%, so an alarm designed to go off at 10% LEL for general combustible gas is likely to be suitable for use with ethanol. Some of these can be purchases for less than $20, and in addition to an audible and visible alarm, may have a relay output. Is there any reason why one or more of these can not be used instead of something like the RKI PS2 that costs $400+?

  8. Keep in mind, that when you transfer to a new barrel, the clock stops on aging. Now, what is unclear (we have a query to the TTB on this) is if you aged in a small barrel for a short time then transferred to a larger new barrel and aged for a much longer time, could you use the time in the second barrel as the aging time? Potentially yes, because you could treat the time in the first barrels as simple storage of spirit prior to aging. But what you can't do is sum the two periods, in any case.

  9. On 2/16/2019 at 12:32 PM, addemkay said:

    I am trying to find the wording in the laws that allows sales of non-alcoholic items in a tasting room for Illinois. When we had our state inspector come out, he stated that we were unable to sell any kind of merchandise beyond our spirits we will be producing. Every distillery I've been to has sold promotional items (glasses, tshirts, hats, etc) so I assumed it was allowed. I can't seem to find any legislation stating one way or the other...

    In Illinois you are restricted to selling only your own ALCOHOL products, there is no limitation in the state law from selling non-alcohol products. Almost EVERY distiller with a tasting room in Illinois does this. I am not sure who from the state inspected you, but I would give a call to the ILCC right away for clarification. Some of the state inspectors have no prior experience with distilleries, and will visit you based on geography. You should let them know who inspected you, so they can be updated.

    By the way, even the limitation on selling your own alcohol products will possibly change this year in Illinois. The ICDA has been moving legislation through the state house that will create 2 new craft distillers permits, and one will be a "still-pub" license, like a brew pub, allowing your to sell alcohol purchased from a distributor, in addition to your own direct sale of product.

    Sorry, I don't recognize the name. You should add info to your profile if you plan to interact much here, it is helpful to you and to those exchanging info with you. Also, are you already an ICDA member? If not, send me your contact info, I strongly encourage you to join.

  10. On 4/23/2019 at 9:48 PM, ZimDist said:

    Sorry for such a simple question

    when you say saturated. Do you mean leave what ever is in it after you drain it?

    we started with 430litres drained it, got a net amount of 410 so still 20litres in the Colums.

    so we should leave this and get the Benidorm in the next run?

    You can leave it full, or leave it wet with vodka and sealed, so that the "empty" porous parts of the bed will eventually become fully saturated with the vapor from the vodka. What you want to avoid is rinsing with water or entirely drying it out. Leaving it standing with just water risks bacterial contamination, leaving higher proof spirit in the column, sealed, should prevent that.

  11. 3 hours ago, ZimDist said:

    I am definitely going to target 50% not he next run.

    Do we leave ro water in the filters when not using so the carbon doesn't dry out?

    I would recommend leaving it saturated with vodka at proof you were filtering.

  12. 9 hours ago, Southernhighlander said:

    If you are not a good distiller than being a good business person is not going to matter very much.  Having owned many successful business, one of the first things that I learned was that if you don't have a good product you are not going to get very far.  However the reverse is true as well.  If you are a shitty business person or if you are dishonest you will never succeed, no matter how good your product is.  

    We will have to agree to disagree on some things, and can agree on others. The last sentence above I certainly agree with the first clause, but maybe not the the second. And the first sentence I am not sure I agree with. I think there are plenty of successful small producers of spirits out there with low quality product, but marketed well and the right price point, can still be successful, if we define success as making a profit. You don't even have to be a distiller at all, just repackage product appropriately. And there are people that go to the grave having conducted business dishonestly, but successfully. Too many sadly.

  13. It is not unusual to lose a very small amount of ethanol in any processing step, but that is about 10x greater drop in proof than would normally be acceptable. That said, your charcoal filter will have to saturate with ethanol until it stabilizes, and what ABV that it will stabilize at is specific to your charcoal. Once it is stabilized, you should not see much drop in ABV. General rule though is NOT to do the final adjustment of proof before filtration, but afterwards, with filtered water. So, once stabilized, try filtering at 45% or 50% ABV, then proofing down just before bottling.

    If you are wondering why your charcoal might pull out so much ethanol, it depends on how hydrophobic/hydrophilic the charcoal is. More hydrophobic charcoal will tie up more ethanol as it stabilizes. Some charcoals are processed, for example with acids, to make them less hydrophobic.

  14. 47 minutes ago, Stumpy's said:

    The industry is definitely doing some strange things. While the OP is a bit of a rant, it is certainly based in valid claims. The leadership council at the 2nd largest spirits distributor in the country said last year, that they expect within 10 years, 80% of existing craft distilleries will close their doors. Whether that is "gut feel" or based in statistics, I don't know, but it was brought up when "craft" became a topic in their meeting. Also, when you see a brand like Death's Door sell its equipment (200k cs/year capacity) and a 20k case per year brand for 2.5 million to the highest bidder, you have to wonder what is going on in the industry.

    The distributors are probably right. They saw the same thing first time around with craft breweries, and craft distilleries look more like craft breweries the first time around, not like the renaissance of craft breweries today, which have a much higher success rate. But the example you raise of Death's Door is interesting, too, because it shows that a poorly run business can fail even with a great brand and decent product. What we need to be doing now as the first few craft distillers fail and new ones evermore start up, is getting info out on those failures so that we can do lessons learned. I am less concerned about how many new craft distillers are not good distillers than how many are not good business people.

  15. 23 hours ago, Rum said:

    Thanks. We currently store it in 275 gallon totes. We buy a truckload at a time currently so we would be going through it at the same speed. The totes are kept closed and so far we haven't had any major problems. I'm a bit worried to have it all in one tank in case it does get active. 

    Having never run into the problem before, I'm not certain how to plan for it. :) How does one plan for that?

    Release valve/plugs. Keep it stored cool.

  16. On 12/20/2018 at 3:25 PM, Backset said:

    Just wondering if anyone has any experience with Distilamax RM or SR and what their results were with a mollases based rum?  Or just experiences with any style rum. Thanks

    Anyway, to answer your original question, if you want lots of aromatics and flavors in your molasses rum, we really liked RM. SR is intended for clean whites.

×
×
  • Create New...