State of California
AIR RESOURCES BOARD
Ventura County APCD Headquarters
Supervisors' Chambers
800 South Victoria Avenue
Ventura, California
May 21, 1981
10:00 a.m.
AGENDA
Page
81-10-1 CONTINUATION OF PUBLIC HEARING TO FURTHER 001
CONSIDER Proposed Revisions to Source Testing
Fees and Requirements Specified in Article 2,
Subchapter 5, Chapter 1, Part III, Title 17,
of the California Administrative Code.
81-10-2 Public Meeting to Consider a Suggested Control 071
Measure for the Control of Emissions of Photo-
chemically Reactive Organic Compounds from Seals
on Pumps and Compressors in Refineries.
81-10-3 Public Meeting to Consider a Suggested Control 194
Measure for the Control of Emissions of Photo-
chemically Reactive Organic Compounds from Oil
and Gas Production Operations and Gas Processing
Plants.
81-10-4 Other Business
a. Closed Sessions
1. Personnel (as authorized by State Agency Open
Meeting Act).
2. Litigation (Pursuant to the attorney-client
privilege).
b. Research Proposals
c. Delegations to Executive Officer
SMOKING NOT PERMITTED AT MEETINGS OF THE CALIFORNIA AIR RESOURCES
BOARD.
ITEM NO.: 81-10-1
Proposed Revisions to Source Testing Fees and Requirements
Specified in Article 2, Subchapter 5, Chapter 1, Part III, Title
17, of the California Administrative Code.
SUMMARY AND STATEMENT OF REASONS FOR PROPOSED RULEMAKING
BACKGROUND
Section 41512 of the Health and Safety Code grants the Air
Resources Board (ARB or the Board) and local air pollution
control districts the authority to adopt by regulation fees to
cover the cost of securing samples of air pollution emissions as
authorized by Section 41510 of the Health and Safety Code.
In 1978, the Board adopted Article 2 (Sections 91200 through
91206), Subchapter 5, Chapter 1, Part III of Title 17, California
Administrative Code (hereafter referred to as Article 2), which
implements Section 41512 of the Health and Safety Code.
Primarily, these provisions specified fees and procedures for
charging of fees under Section 41512. Article 2 contains no
provision for compliance testing by an independent testing
service.
In 1980, the Legislature enacted Assembly Bill 3067 (Statutes
1980, Chapter 1283), which became effective January 1, 1981.
This bill limits the scope of Section 41512 to authorize fees
only for testing conducted for the purpose of determining
compliance with permit conditions or with any State or local law,
regulation, or order relating to air pollution. Additionally,
the bill adds a provision to Section 41512 which requires the ARB
to adopt, by April 1, 1981, procedures by which an operator may
request that sampling for compliance be conducted by an
independent testing service, and authorizes the Board to deny
such a request for good cause.
The amendments and new regulations the Board is considering may
be separated into two groupings. First, in response to Assembly
Bill 3067, ARB staff is proposing amendments to the current
sections in Article 2 to bring the provisions into conformance
with the limitation of fees to compliance testing only. Staff is
also proposing several additional changes to the existing
regulations to update and clarify them. Second, the Board will
consider adopting new sections in Article 2 (Sections 91206
through 91220) to implement, interpret, and make specific the
provisions in Assembly Bill 3067 regarding requests for
compliance testing by an independent testing service.
ITEM NO.: 31-10-2
Public Meeting to Consider a Suggested Control Measure for the
Control of Emissions of Photochemically Reactive Organic
Compounds from Seals on Pumps and Compressors in Refineries.
SUMMARY AND STATEMENT OF REASONS FOR PROPOSED APPROVAL OF
SUGGESTED CONTROL MEASURE.
The staffs of the South Coast Air Quality Management District
(SCAQMD) and the Air Resources Board (ARB) have lead
responsibility for the development of a suggested control measure
to control fugitive emissions of hydrocarbon compounds from
seals on pumps and compressors in refineries. This report
presents the suggested control measure and discusses the
necessity, technical feasibility, and cost/effectiveness of the
measure.
Pumps and compressors in hydrocarbon service in refineries leak a
conservatively estimated 11 tons of hydrocarbon compounds into
the atmosphere daily in California. The emissions contribute to
formation of atmospheric photochemical oxidants, including ozone.
The four air basins in which petroleum refineries are located --
San Francisco Bay Area, South Coast, San Joaquin Valley, and
south Central Coast -- are federal nonattainment areas for ozone
and also experience numerous violations of the state ambient air
quality standard for oxidant. None of these air basins is
expected to achieve ozone attainment status by 1982. In
particular, the Board of the SCAQMD and the ARB have found that
attainment in the South Coast Air Basin by 1987, the deadline set
by the Clean Air Act, will be very difficult to achieve.
Accordingly, reductions of emissions of hydrocarbon compounds are
needed in these air basins. The State Implementation Plan
contains a commitment to adopt controls to achieve such
reductions from seals on pumps and compressors in refineries.
The U.S. Environmental Protection Agency (EPA) has designated as
reasonably available control technology the control of
hydrocarbon compound emissions from seals on pumps and
compressors in petroleum refineries. The control has been
described in a control technology guideline document as periodic
inspections by the seal operator with a hydrocarbon analyzer and
reduction of any leakage which causes the analyzer to register
over 10,000 parts per million (ppm) as hexane.
The staffs of the ARB and SCAQMD conclude that a measure of the
type recommended by EPA would be reasonable and cost-effective.
The staffs have prepared a control measure embodying the EPA
recommendations and other provisions. That control measure, as
approved by the Technical Review Group for the Suggested Control
Measure Development Process, is presented herein for the Board's
consideration. It is recommended that the Board approve the
measure as a suggested control measure.
If approved by the Board, the suggested control measure will be
forwarded to appropriate air pollution control districts for
consideration as an amendment or addition to their rules when
necessary for attainment and maintenance of the state and
national ambient air quality standards for oxidant and ozone,
respectively. The suggested control measure would become an
enforceable regulation only after adoption into the regulations
of a district. Approval by the Board of the suggested control
measure does not create an enforceable regulation.
The major requirements of the proposed control measure are:
1. Seals on pumps and compressors which handle photochemically
reactive organic fluids in petroleum refineries must be
inspected quarterly by the operators using hydrocarbon
analyzers and observed weekly for visible leakage. Any
visible leakage must be inspected with a hydrocarbon
analyzer;
2. Emissions of photochemically reactive organic compounds from
seal leaks which exceed 10,000 ppm registered as hexane on a
hydrocarbon analyzer must be reduced to register at or less
than 10,000 ppm within two working days if spare equipment
is available or during the next process unit shutdown (but
not later than one year after detection) if spare equipment
is not available;
3. The Air Pollution Control Officer may inspect any seal or
seal fluid system within five days after the scheduled date
of any operator's inspection. Any leak then found
registering over 75,000 ppm as hexane on a hydrocarbon
analyzer which has not been recorded as a leak by the
operator shall be a violation of the rule. Failure of the
operator to conduct the scheduled inspections is also a
violation of the rule; and
4. Quarterly inspections must commence within one quarter after
the adoption of the rule by a local district. Effective
July 1. 1983, emissions from leaks must be limited to 10,000
ppm as hexane on a hydrocarbon analyzer. However, if a pump
or compressor is equipped with double seals or tandem seals
and an externally supplied inter-seal flush system,
emissions from leaks must be controlled to no more than
75,000 ppm by July 1, 1983, and to no more than 10,000 by
January 1, 1987.
The only environmental effect of adoption of rules reflecting the
suggested control measure would be a reduction of hydrocarbon
compound emissions by nine tons per day in the state. No
significant adverse environmental impacts of this measure have
been identified.
The sources of information used to develop the proposed control
measure include the following: empirical data on seal leak
frequencies and rates from the EPA, ARB staff, and Bay Area Air
Quality Management District; the EPA, including the Control
Techniques Guideline (CTG) document "Control of Volatile Organic
Compound Leaks from Petroleum Refinery Equipment, June 1978;
visits by the SCAQMD and ARB staffs to refineries and other
facilities; journal articles on pump and compressor seals and
emissions therefrom; contacts by telephone and letter with
industrial experts on seals; and workshops on leal leakage
control rules held by the SCAQMD, the BAAQMD, and the ARB staff.
ITEM NO.: 81-10-3
Public Meeting to Consider a Suggested Control Measure for the
Control of Emissions of Photochemically Reactive Organic
Compounds from Oil and Gas Production Operations and Gas
Processing Plants.
SUMMARY AND STATEMENT OF REASONS FOR PROPOSED APPROVAL OF
SUGGESTED CONTROL MEASURE:
BACKGROUND
Federal and state laws have established health-based ambient air
quality standards for ozone and oxidant, respectively. In many
areas of California, these federal and state standards are not
being met and are not expected to be met by 1982.
Federal law requires states to develop and implement "as
expeditiously as practicable" all reasonably available control
measures to reduce photochemical oxidants in nonattainment areas.
See, e.g., 1977 Clean Air Act, Section 172(b). EPA recommends
the adoption of "all reasonably available control technologies"
in nonattainment areas.
The Air Resources Board (ARB) is given broad authority under the
Health and Safety Code to coordinate, encourage, and review the
efforts of local districts in their efforts to attain and
maintain state and national ambient air quality standards. See,
e.g., Health and Safety Code Sections 39003, 39500, 39600, 39602,
39605, and 41500.
The ARB staff has estimated that fugitive hydrocarbon emissions
from valves, pipe connections, diaphragms, pumps, compressors,
hatches, sight glasses, meters, and seals in oil and gas
production fields and in gas processing plants total 60 tons of
hydrocarbon compounds per day in California, according to
conservative methods of estimation. The air basins in which the
emissions are concentrated -- South Coast, San Joaquin Valley,
and south Central Coast -- are federal nonattainment areas for
ozone and also experience numerous violations of the state
ambient air quality standard for oxidant. None of these air
basins is expected to achieve ozone attainment status by 1982.
In fact, the Board of the South Coast Air Quality Management
District and the ARB have found that attainment in the South
Coast Air Basin by 1987, the deadline set by the Clean Air Act,
will be very difficult to achieve. Accordingly, reductions of
emissions of hydrocarbon compounds are heeded in these air
basins.
The State Implementation Plan contains commitments to adopt
controls to achieve reductions of fugitive hydrocarbon emissions
in oil and gas production operations.
The Ventura County Air Pollution Control District staff, working
with the ARB staff and others, held a number of workshops with
industry regarding control of fugitive hydrocarbon emissions.
The staffs now propose that the Board approve the suggested
control measure in this report, which the staffs have found to be
technically feasible, economically reasonable, and without
significant adverse environmental impacts.
If approved by the Board, the suggested control measure will be
forwarded to appropriate air pollution control districts for
consideration as an addition to their rules when necessary for
attainment and maintenance of the state and national ambient air
quality standards for oxidant and ozone, respectively.
The suggested control measure would become an enforceable
regulation only after adoption into the regulations of a
districts. Approval by the Board of the suggested control
measure does not create an enforceable regulation.