State of California

Ambassador Hotel
Ambassador Room
3400 Wilshire Blvd.
Los Angeles, CA

May 24, 1978
10:00 a.m.

78-9-1 Consideration of a Model Rule Regarding Emissions
from Leaking Valves, Flanges, Pump and Compressor
Seals, and Other Equipment at Oil Refineries.

78-9-2 Public Hearing on Proposed Changes to Regulations
Regarding California Exhaust Emission Standards
and Test Procedures for 1980 and Subsequent Model
Motor Vehicles.

78-9-3 Continuation of Public Hearing to Consider
Establishment of State Ambient Air Quality
Standards and/or Significant Harm Levels for Vinyl

78-9-4 Other Business -
a. Executive Session - Personnel & Litigation
b. Research Proposals

ITEM NO.: 78-9-1

Emissions from Leaking Valves, Flanges, Pump and Compressor
Seals, and Other Equipment at Oil Refineries


1) All valves should be required to meet the no-leak standard
of American Petroleum Institute Standard 598 as a condition
to installation.

2) Valves already in operation should be required to meet a no-leak

3) Valves in Liquid and gas service should be subject to
mandated inspection and maintenance plan; however, the plan
for valves in liquid service should be less rigorous.

4) For Flanges, a no-lead standard and an inspection program
less rigorous than that for gas valves should be adopted.

A proposed model rule for implementing these recommendations is
presented on pages V-14 through V-16 of the report titled
Emissions from Leaking Valves, Flanges, Pump and Compressor
Seals, and Other Equipment at Oil Refineries.


February 1978, staff members of the Air Resources Board (ARB)
inspected six refineries in the Los Angeles area. These
refineries were operated by Chevron USA, ARCO, Union Oil, Shell
Oil, Mobil, and Texaco. The guiding purposes of the inspection
were: 1) to confirm whether hydrocarbon emissions from leaking
valves, flanges, and pump and compressor seals were still as
prevalent as determined by an extensive study done in 1958 by
government and industry and as determined by a less extensive
refinery study by KVB Incorporated of these emission sources in
1977, and 2) to develop and/or modify any rules to control
hydrocarbon emissions from these sources if the inspection
evidence warranted such action.

In performing this inspection, 40,121 separate pieces of
equipment were inspected for leaks, including 13,685 valves,
24,826 flanges, 803 pump seals, 134 compressor seals, 346
threaded fittings, and 327 valve outlets.

Leak occurrence frequencies for the sources identified above were
determined by ARB inspectors to be: valves (nine percent),
flanges (0.4 percent), pump seals (20 percent), and compressor
seals (11 percent). These frequencies compare to those
determined in the 1958 and KVB studies as follows: valves (13
and four percent, respectively); flanges (negligible and 0.5
percent, respectively); pump seals (36 and 32 percent,
respectively); and compressor seals (54 and 20 percent,

The emission percentage contributions from the noted device
sources into the South Coast Air Basin (SCAB) in 1977 (based on
the leak occurrence frequencies and leak rates determined in each
of the three studies and on an estimate by representative of ARCO
of approximately four times as many valves in existence in a
refinery than were previously reported to exist) are as follows:

As indicated in Table S-1, hydrocarbon emissions from valves,
flanges, and pump and compressor seals represent a significant
fraction of the total SCAB hydrocarbon emissions.

According to a study of fugitive emissions from a chemical
company, valves and pump and compressor seals leak at frequencies
comparable to or higher than frequencies at refineries.

The staff concludes:

1) The quality of valves currently in use, when supplemented
with conscientious periodic maintenance, is adequate to
allow the adoption of a standard of no leaks from all
refinery valves when a mandated inspection and maintenance
plan is applied to valves in gas service, and a mandated but
less rigorous plan is applied to valves in liquid service.
Such a no-leak standard would contribute to improvement of
the air quality in the SCAB, and would not be economically
prohibitive to the affected companies.

2) Flange technology is deemed adequate to meet a no-leak
requirement with only a marginally increased maintenance

3) Pump and compressor seals contribute 0.48 and 0.30 percent,
respectively, of hydrocarbon emissions into the SCAB.
However, at this time the staff has not obtained sufficient
information to determine the best control method to prevent
leakage from these sources.

4) Elimination of hydrocarbon emissions from leaks would
improve the safety of all subject facilities.

5) The cost-savings effect attributable to a no-leak rule for
valves and flanges in hydrocarbon service is roughly
$26,000/year for a 100,000 B/D refinery. This savings could
be reduced, however, if more frequent inspections and
repairs are needed to keep valves and flanges in a facility
leak free.

6) There are defects in the wording of South Coast Air Quality
Management District Rule 466, which pertains to controlling
hydrocarbon leakage emissions from pumps and compressors.


Page Number


A. Emissions Estimate, 1958 Study and KVB Study I-1

B. South Coast Air Basin Air Quality I-6

C. South Coast Air Quality Management District Rules I-8
Regarding Pump and Compressor Seals

D. Need for Extensive Study of Valves, Flanges, and Pump I-8
and Compressor Seals and Possible Development of
New Rules

II. Conclusions II-1

III. Recommendations III-1

IV. Inspection Program IV-1
A. Preparation IV-1
B. Inspections at Refineries IV-4
C. Inspection Results for Valves, Flanges, Pump and IV-22
Compressor Seals and Other Equipment

V. Control of Emissions V-1
A. Contribution of Emissions from Valves, Flanges, and V-1
Pump and Compressor Seals to South Coast Air Basin
B. Defects of Rule 466 V-5
C. Control Methods, Equipment Selection V-7
D. Control Methods, Inspection and Maintenance V-10
E. Proposed New Rule for Valves and Flanges V-14
F. Cost Effectiveness of Controls Required by New Rules V-16
G. Environmental Impact of Proposed New Rule for Valves V-23
and Flanges

VI. References VI-1


Appendix A South Coast Air Quality Management District A-1
Rule 466

ITEM NO.: 78-9-2

Public Hearing on Proposed Changes to Regulations Regarding
California Exhaust Emission Standards and Test Procedures for
1980 and Subsequent Model Motor Vehicles.


Adopt Resolution 78-26.


The ARB staff is proposing a number of technical changes to the
test procedures for 1980 and subsequent model light-duty,
medium-duty and heavy-duty engines and vehicles. First, the staff
proposes a test procedure for measuring non-methane hydrocarbons
using a gas chromatograph in combination with a flame ionization
detector. Second, the staff proposes that manufacturers be
required to provide an audible or visible maintenance warning
signal which will inform a vehicle operator that the exhaust gas
sensor needs servicing at 30,000 miles. Third, the staff
proposes that vehicle manufacturers submit a driveability
statement with their final application for certification and with
each running change which requires emission testing. This
statement will be based on that manufacturer's driveability
performance criteria. This measure should minimize the incentive
for tampering with the emission control system by ensuring that
new vehicles have acceptable driveability characteristics.
Finally, it is proposed that ARB test procedures be updated for
consistency with EPA procedures on a more timely and routing
basis. The staff suggests that the Board delegate to the
Executive Officer the authority to amend the Board's test
procedures to include all ongoing nonsubstantive technical
changes adopted by EPA. The Executive Officer would still be
required to publicly notice any such changes and allow adequate
time for comment.