EQUIPMENT AND PROCESSPRECERTIFICATION PROGRAM

EVALUATION OF THE AIR QUALITY PERFORMANCE CLAIMSFOR THE LOKRING TECHNOLOGY

LOKRING FITTINGS

(SS40 STAINLESS STEEL AND MAS-3000 CARBON STEEL SERIES)

JUNE 2000

Equipment: Lokring Fittings SS40 StainlessSteel and MAS-3000 Carbon SteelSeries

Applicant: Lokring Technology960 Gateway DriveBurlington, Ontario, L7L 5K7 Canada

Applicant Contact: Mr. David SchatzTitle: National Technical ManagerPhone Number: (201) 505-0707E-mail: dschatz@wabtec.comWebsite: www.lokring.com

Application Number: 09159801Executive Order Number: G-096-029-033Executive Order Date: June 12, 2000

Air Resources Board Contact: Mr. Todd SterlingPhone Number: (916) 445-1034E-mail: tsterlin@arb.ca.govARB Website: www.arb.ca.govPrecertification Website: www.arb.ca.gov/eqpr/eqpr.htm

ABSTRACT

The purpose of this report is to document the California Air Resources Board’s(ARB’s) evaluation and verification of the air quality-related claims made byLokring Technology concerning its SS40 Stainless Steel and MAS-3000 CarbonSteel Series Fittings.

In an effort to make progress towards attaining healthy air quality in California,regulations restrict emissions of volatile organic compounds (VOCs) from a broadspectrum of activities. Volatile organic compounds (VOCs) are emitted directlyas by-products of combustion-related activities or as emissions from sourcessuch as petro-chemical operations and solvent-containing products. Thereduction of VOC emissions from all sources is part of California’s clean airstrategy to achieve and maintain healthy air quality in California.

As part of its Equipment and Process Precertification (Equipment Precertification)Program application package, Lokring Technology requested that the ARBevaluate its proposed performance claim with respect to the fact that Lokring

fittings control VOC emissions from pipe by forming a metal-to-metal seal withoutthe use of O-rings or other elastometric seals.

Upon successful completion of the requirements associated with the ARB’sEquipment Precertification Program, a report is issued with two companiondocuments— an Executive Order and a certificate. These documents serve asofficial records that the ARB has independently verified the applicant’sperformance claims. Executive Orders earned under the ARB’s EquipmentPrecertification Program are valid for three years from the date issued,presuming the holder complies with: 1) the terms and conditions identified in thisreport; and 2) the general requirements discussed in the EquipmentPrecertification Program Guidelines and Criteria.

After review of the documents discussed throughout this report, the ARBrecommends that a Precertification certificate be issued to the Lokring

Technology for its SS40 Stainless Steel and MAS-3000 Carbon Steel SeriesFittings.

CALIFORNIA ENVIRONMENTAL PROTECTION AGENCYAIR RESOURCES BOARD

EQUIPMENT AND PROCESSPRECERTIFICATION PROGRAM

EVALUATION OF THE AIR QUALITY PERFORMANCE CLAIMSFOR THE LOKRING TECHNOLOGY

LOKRING FITTINGS

(SS40 Stainless Steel and MAS-3000 Carbon Steel Series)

JUNE 2000

TABLE OF CONTENTS

Contents Page

I. INTRODUCTION----------------------------------------------------------------1

II. GENERAL INFORMATION --------------------------------------------------1A. Equipment Precertification Program Background-------------------1B. Relationship to Air Quality------------------------------------------------2C. Health and Environmental Impacts-------------------------------------3D. Manufacture/Ownership Rights -----------------------------------------3

III. SUMMARY OF SCOPE -------------------------------------------------------3

IV. STATEMENT OF CLAIMS ---------------------------------------------------3

V. DESCRIPTION OF TECHNOLOGY ---------------------------------------3

VI. TECHNICAL EVALUATION -------------------------------------------------4A. Description of Field Testing ----------------------------------------------4B. Description of Test Results ----------------------------------------------6

VII. EVALUATION OF CLAIMS --------------------------------------------------7

VIII. QUALITY MANAGEMENT ---------------------------------------------------8A. Practices and Standards--------------------------------------------------8B. Installation and Maintenance Requirements -------------------------8C. Other Certifications/Approvals ------------------------------------------9D. Warranties -------------------------------------------------------------------9

IX. ENVIRONMENTAL AND ECONOMIC BENEFITS ---------------------9

X. RECOMMENDATIONS -------------------------------------------------------9

XI. PRECERTIFICATION CONDITIONS ------------------------------------ 10

Figures

Figure 1 - Types of Lokring Fittings ---------------------------------------5

Appendices

Appendix A – Materials Available for EvaluationAppendix B – Definition of Volatile Organic CompoundsAppendix C – Volatile Organic Compounds Emissions CalculationsAppendix D – Lokring Technology’s Warranty

I. INTRODUCTIONThis report discusses the Lokring

Technology with respect to thedesign of its Lokring fittings SS40stainless steel and MAS-3000carbon steel series (Lokring

fittings), the performance claims tobe verified by the Air ResourcesBoard (ARB), the emissions testingresults, and the findings andrecommendations of the ARB staffconcerning this technology.

This report is organized into severalsections. The proceeding section,General Information, providesbackground information on theARB’s Equipment and ProcessPrecertification (Precertification)Program. The next three sections:Summary of Scope; Statement ofClaims; and Description ofTechnology; discuss the breadth ofour evaluation, the performanceclaims, and a detailed description ofthe Lokring fittings.

The following two sections:Technical Evaluation and Evaluationof Claims present detailedinformation on our technical reviewand assessment of the Lokring

fittings. The sections entitled:Quality Management andEnvironmental and EconomicBenefits provide supportinginformation on the Lokring

Technology’s procedures to producefittings that meet the company’sclaims and a brief assessment of thepotential environmental andeconomic impacts of the technology.

Finally, the remaining sections:Recommendations andPrecertification Conditions discuss

the ARB staff’s determination of theperformance of the Lokring fittingsrelative to the company’s claims.These sections also provideguidance with respect to the specificconditions that must be met for thecertificate to remain valid for threeyears. Appendix A contains a listingof the information that we relied uponto conduct our evaluation. Theremaining appendices contain someof the detailed information thatsupports the evaluation in this report.

II. GENERAL INFORMATIONUnder the regulations established forthe program, equipment orprocesses eligible for Precertificationmust: 1) have an air quality benefit;2) be commonly-used or have thepotential to be commonly-used in thenear future (market ready); and 3)not pose a significant potentialhazard to public health and safetyand the environment. Furthermore,to be eligible, applicants for theprogram must demonstrate that theyhave sufficient control over themanufacture of the equipment orprocess to ensure that they canconsistently and reliably produceequipment which performs at leastas well as that considered in thisevaluation.

A. Equipment PrecertificationProgram BackgroundThe Equipment PrecertificationProgram is a voluntary statewideprogram for manufacturers ofcommonly-used equipment orprocesses. A precondition for entryinto the program is that theequipment has an air quality benefit.On June 14, 1996, the ARB adoptedsection 91400 of the California Code

of Regulations which incorporatesthe Criteria for Equipment andProcess Precertification (Criteria).The regulation and Criteria wereapproved by the California Office ofAdministrative Law on October 31,1996 and became effective onNovember 30, 1996.

Under the Equipment PrecertificationProgram, manufacturers request thatthe ARB conduct an independentthird-party verification ofperformance claims which focus onthe air quality benefits of itsequipment or process. If the claim isverified, the manufacturer is free torefer to the results of the ARB staff’sevaluation in its marketing literature.Upon successful completion of theverification process, the ARB staffnotifies air pollution control and airquality management districts(Districts) in California of itsdetermination. As a result of theARB’s notification, the Districts havean advanced opportunity to becomefamiliar with the performance of theequipment or process.

On September 8, 1998, the ARBreceived a request from Lokring

Technology that the ARB staffdetermine if Lokring fittings wereeligible for the EquipmentPrecertification program. Afterreceiving confirmation from the ARBstaff that the Lokring fittings wereeligible for the program, Lokring

Technology submitted aPrecertification application packageon September 15, 1999. As part ofour review of the applicationpackage, we evaluated the results ofemissions testing programs andother information concerning the

performance of the Lokring fittingsto determine whether the claimswere verifiable.

B. Relationship to Air QualityAs defined by the ARB and theUnited States EnvironmentalProtection Agency (U.S. EPA),volatile organic compounds (VOCs)are any compounds containing atleast one atom of carbon, except theexempt compounds listed inAppendix B. Volatile organiccompounds (VOCs) are emitteddirectly as by-products of incompletecombustion or as emissions fromsources such as petro-chemicaloperations and solvent-containingproducts. Through a series ofcomplex reactions, VOCs function aschemical precursors to the formationof tropospheric (ground-level) ozone.

Repeated exposure to ozone maycause permanent damage to thelungs. Even at relatively lowconcentrations, ozone triggers avariety of health problems includingchest pains, coughing, nausea,throat irritation, and congestion. Itcan also worsen bronchitis, heartdisease, emphysema, asthma, andreduce lung capacity. Ozoneinterferes with the ability of plants toproduce and store food, makingthem more susceptible to disease,insects, and other pollutants.

Districts in California do not requirethat an air quality permit be obtainedprior to the installation of equipmentsuch as Lokring fittings. However,Districts do require that air qualitypermits be obtained for facilities thathandle and store hydrocarbons. Thereduction of VOC emissions is part

of California’s clean air strategy toachieve and maintain healthy airquality in California.

C. Health and EnvironmentalImpactsAs part of our evaluation, staffconducted a cursory review of thepotential environmental impactsassociated with Lokring fittings.Based on this review, we concludedthat Lokring fittings would not likelypresent health impacts significantlydifferent from those associated withother fittings that are currently inwide use throughout California.Please note that Lokring

Technology, its distributors, and/orinstallers of Lokring fittings arerequired to meet all applicable healthand safety standards with respect tothe manufacture, installation, andmaintenance of Lokring fittings.

D. Manufacture/Ownership Rights

The recommendations in this reportare contingent upon Lokring

Technology having the legal rights toproduce and/or market Lokring

fittings. Lokring Technologydocumented its ownership of theserights in its Eligibility Request,received by the ARB on September8, 1998.

III. SUMMARY OF SCOPELokring Technology claims thatLokring fittings connect pipeforming a metal-to-metal seal withoutthe use of O-rings or otherelastometric seals. The fittings areused to seal pipes transmittingmaterials such as VOCs. Most VOCemissions resulting from thehandling and storage of

hydrocarbons are leaks from processequipment and evaporation fromopen areas. Generally, the control ofVOC emissions involves the use ofefficient air pollution controlequipment (including state-of-the-artfittings), modifying processes,increasing monitoring and inspectionfrequency, and improvingmaintenance practices.

IV. STATEMENT OF CLAIMSThe following is the claim verified byARB staff concerning Lokring

Technology’s Lokring fittings. Theverification of this claim is predicatedon the presumption that Lokring

fittings are manufactured, installed,and maintained in accordance withthe instructions contained in Lokring

Technology ‘s LP-105 InstallationProcedure.

Lokring Technology’s Lokring

SS40 stainless steel and MAS-3000 carbon steel series fittings(1/4 inch through 3 inch) installedon qualified matching pipe(meeting ASTM specifications)have a helium leak rate that is nogreater than 1 x 10-9 standardcubic centimeters per secondwhich is equivalent to anestimated volatile organiccompound emission rate that isno greater than 2.4 x 10-12

kilograms per hour (4.6 x 10-8

pounds per year).

V. DESCRIPTION OFTECHNOLOGY

Lokring fittings are used in refinery,petrochemical, and chemical plantpiping systems, and utilities basedon manufacturer’s specifications.The Lokring fittings connect small

diameter piping without threading orwelding. Lokring fittings areavailable in various configurationsand dimensions. Figure 1 shows aschematic of the various types ofLokring fittings including a cross-sectional view of a coupling.

Lokring fittings are designed to beused for field fabrication, rapidrepair, installation in tight accessareas, and tie-ins to shop fabricationpiping. The installation of Lokring

fittings can be completed in sixminutes. Lokring fittings areinstalled with hydraulic tooling andform a metal-to-metal seal withoutthe use of O-rings or otherelastometric seals. Lokring fittingsare installed without open flamemaking them suitable for installationsin operating areas where welding isnot feasible due to explosiveatmospheres as well asenvironments where the use of athreaded connection is notacceptable.

Lokring fittings rely on a patentedelastic strain pre-load technology topermanently join small diameternominal pipe (1/4 inch through 3inch) without threading or welding.During installation, following insertionof the pipe end into the Lokring

fittings, hydraulic tooling is used toadvance each swage ring axiallyover the Lokring fitting’s body,radially compressing (swaging) theLokring fitting’s body on to theoutside diameter of the pipe. As thepipe is compressed first elasticallyand then plastically by the swagingaction of the Lokring fittings, thecircumferential sealing lands

machined in the bore of the Lokring

fittings body grip and seal the pipeouter diameter (OD), forming ametal-to-metal seal without the useof O-rings or other elastomeric seals.A detailed description of theinstallation instructions for Lokring

fittings is available in its LP-105Installation Procedure. The Lokring

Technology requires a qualified orcertified pipe fitter (installer) to installLokring fittings.

Lokring stainless steel couplingsand carbon steel repair couplings aredesigned with a “thru-bore” feature,which permits the coupling to slidecompletely over the prepared pipeend. This facilitates the repair ofexisting piping by eliminating theneed to “spring” the cut pipe endsapart axially to install the coupling.All stainless steel and carbon steelLokring fittings have an internalshoulder, which acts as a stop forthe pipe when the pipe is insertedinto the Lokring fittings.

Lokring carbon steel fittings (MAS-3000 series) are designed for use oncarbon steel pipe to ASTM A-106and A-53. Lokring stainless steelfittings (SS40 series) are designedfor use on stainless steel pipe toASTM A-312 and carbon steel pipeto ASTM A-106 and A-53.Specifications are in accordance withthe Lokring Technology’s test planTP-1190-01.

VI. TECHNICAL EVALUATIONA. Description of Field TestingLokring fittings were subjected to abattery of accelerated environmentaland mechanical tests by Lawrence

Cross-Sectional View of a Coupling

Figure 1 – Types of Lokring Fittings

Livermore National Laboratory(LLNL) and Deposition and Leak

Detection Services Inc. (DLDS) inCalifornia. Test parameters includedburst, bending, fatigue, tensile,torsion, thermal cycling, thermalshock, vibration, corrosion, firetesting and gas leak. The gas leaktest evaluated the Lokring fittingsability to resist helium leakage fromoutside to inside (inboard test) andfrom inside to outside (outboardtest).

The gas leak test results were usedto estimate a VOC emissions rate forthe Lokring fittings. The gas leaktesting protocol for the Lokring

fittings employed the U.S. EPAReference Method 21 in conjunctionwith the procedure described in theU.S. EPA Protocol for GeneratingUnit Specific Emissions Estimatesfor Equipment Leaks for VolatileOrganic Compounds and VolatileHazardous Air Pollutants. Heliumwas chosen as the test gas becauseit is one of the lightest commercialgases available. It is an appropriatesurrogate for detecting VOCemissions, all of which are heavier.

The inboard test method was inaccordance with the requirements ofASTM E498-73. Lokring testsamples were placed on a vacuummonitor (mass spectrometer) withthe inside of the sample evacuatedto approximately 1x10-5 torr as thehelium was introduced from theoutside. The system was monitoredfor five minutes.

The outboard test method was inaccordance with the requirements of

ASTM E493-73. Lokring sampleswere internally pressurized withhelium gas and placed in a vacuumchamber that was attached to amonitor (mass spectrometer). Theinternal pressure was 4,500 poundsper square inch (psi). The areainside the chamber was thenevacuated to approximately 1x10-5

torr. The system was monitored for15 minutes.

LLNL conducted the inboard andoutboard tests using 1/2 -inch ODtube, 304 stainless steel Lokringsamples. The limit of detection(LOD) of the LLNL massspectrometer was 1 x 10-9 standardcubic centimeters per second (stdcc/sec).

DLDS conducted the inboard andoutboard tests using one 1/2 -inchOD tube, 304 stainless steel and one5/8-inch OD tube, 316L stainlesssteel Lokring samples. DLDS alsoconducted both tests on 1/2 -inchand 1-1/2-inch NPS pipe samples.The LOD of the DLDS massspectrometer was 2 x 10-11 stdcc/sec.

B. Description of Test ResultsIn the positive pressure and vacuumtests, neither LLNL nor DLDS wereable to detect helium from theLokring Technology’s Lokring

fittings at the LOD of the massspectrometers. As shown inAppendix C, the ARB staff used theLODs of the two test results tocalculate estimated VOC emissionrates for the Lokring fittings.Methane was chosen as thesurrogate for expressing the VOCemission rate.

Using the LLNL test results (nosamples detected at the LOD of1 x 10-9 std cc/sec), the ARB staffcalculated an estimated emissionrate of 2.4 x 10-12 kilograms per hour(kg/hr) or 4.6 x 10-8 pound/year(lb/yr). Using the DLDS Inc. testresults (no samples detected at theLOD of 2 x 10-11 std cc/sec), the ARBstaff calculated an estimatedemission rate of 4.8 x 10-14 kg/hr or9.3 x 10-10 lb/yr. As mentionedpreviously, DLDS Inc. used a massspectrometer with a lower LOD toconduct tests than that used byLLNL. Therefore, ARB staff used theLLNL results as a conservative basisfor the verification of the Lokring

Technology’s claim.

The estimated VOC emissionscalculated using the LODs of theLLNL and DLDS results are wellbelow the existing leak controlrequirements of Districts inCalifornia. For example, the SouthCoast Air Quality ManagementDistrict ‘s Rule 1173 (FugitiveEmissions of VOCs) states that anyliquid or gas leak over 50,000 partsper million detected by districtinspection shall constitute a violation.The allowable leakage rate isapproximately 0.30 kg/hr [5 millilitersper minute (5 ml/min)] based on 50drops/min (10 drops is approximately1 ml).

VII. EVALUATION OF CLAIMSThis section presents additionalinformation relating to the claimverified by the ARB as part of thisevaluation. The ARB staff verificationof this claim is based on theevaluation of the information listed inAppendix A. As stated earlier, the

ARB’s evaluation andrecommendations presented in thisreport are predicated on theexpectation that Lokring fittings aremanufactured, installed, andmaintained in accordance with theinstructions contained in Lokring

Technology’s LP-105 InstallationProcedure. The claim language isprecise because it directly correlateswith the supporting documentationincluded with the applicationpackage. Below the claim aresupporting comments, which may beused to interpret the significance ofthe claim verified in this report. Toassist the reader, the claim isdisplayed in bold text.

Lokring Technology’s Lokring

SS40 stainless steel and MAS-3000 carbon steel series fittings(1/4 inch through 3 inch) installedon qualified matching pipe(meeting ASTM specifications)have a helium leak rate that is nogreater than 1 x 10-9 standardcubic centimeters per secondwhich is equivalent to anestimated volatile organiccompound emission rate that isno greater than 2.4 x 10-12

kilograms per hour (4.6 x 10-8

pounds per year).

With respect to VOC emissions, theLokring fittings should beconsidered to be non-welded, metal-to-metal seals without the use of O-rings or other elastometric seals.The emission rate presented in theclaim was estimated assuming thathelium is an appropriate testing gassurrogate for VOC emissions. Inaddition, the LOD (1 x 10-9 stdcc/sec) of the LLNL test results was

used as the basis for estimating theemission rate for the Lokring fittingsof 2.4 x 10-12 kg/hr (4.6 x 10-8 lb/yr).

VIII. QUALITY MANAGEMENTA. Practices and StandardsLokring Technology has extensivequality management practices andstandards for its Lokring fittings.The standards are described in detailin the Thermo Sealed Castings Ltd.& Unity Machining, QualityAssurance Manual, Revision D,October 22, 1998. Lokring fittingsquality system is registered to theISO 9001 and QS 9000 standards.The Manual contains establishedquality management practices for thefollowing areas:

- Quality System, Contract Review,Design Control, Data Control

- Inspection and Testing, TestStatus, Process Control, ProductIdentification

- Measuring and TestingEquipment, Control ofNonconforming Product

- Corrective and Prevention Action,Handling, Storage, Packagingand Delivery

- Control of Quality Records andAudits, Training and Services

- Statistical Techniques, Sector-specific Requirements

- Customer-specific Requirements

The ARB staff reviewed the Lokring

Technology’s Standard PracticeInstructions (SPI 4.1, Rev 03) as apart of the evaluation of the Lokring

fittings. As a result of the evaluation,ARB staff has determined that thequality management program issufficiently comprehensive to support

precertifying the Lokring

Technology’s Lokring fittings.

B. Installation and MaintenanceRequirements

The requirement for the installationand maintenance of Lokring

Technology’s Lokring fittings arecontained in the LP-105 InstallationProcedures for Lokring Carbon andStainless Steel Fittings.

The Lokring fittings installationequipment consists of a Loktool Kitand a hydraulic power supply. Thecorrect selection and maintenance ofLoktool installation tooling is criticalto a safe and successful application.The Loktool kits are identified by asimple code, which denotes theenclosed Loktool head, theappropriate fitting series, and pipesizes for which the tool is to be used.The tool needs to be cycled severaltimes without Lokring fittings toassure that quick disconnects arefully secured, and no air is trapped inthe system. The power supplyneeded to install Lokring fittingsconsists of a 15 foot flexiblehydraulic hose and one of three10,000 pounds per square inch (psi)rated hydraulic pumps (electric,pneumatic or manual).

There are three visual inspectionsperformed after installation ofLokring fittings: 1) visual verificationof installation and inspection marks;2) verification that the swage ring ofthe fitting is compressed against thetool flange; and 3) verification thatthe trailing edge of the fitting body isprotruding from underneath theswage ring. After installation andvisual inspection, the Lokring

fittings are system pressure checkedaccording to industry standards suchas API or ASME B31.1 and B31. 3,examination, inspection and testing.Typical post installation tests includehydrostatic (water), or pneumaticair/nitrogen, or helium tests to verifysuccessful installation.

C. Other Certifications/ApprovalsLokring fittings conform to ASMEB31.3 and B31.1 standards utilizingASTM materials of construction.Lokring fittings also comply withstandards for the United StatesNavy, United States Coast Guard,Lloyds of London, and hold aCanadian Registration number(0A0481.987065432YT) which isrequired by the provinces of Canadaprior to installation of Lokring fittingsin pressure containing systems.

D. WarrantiesLokring Technology provides a one-year warranty for its Lokring fittings.A copy of the warranty is provided inAppendix D.

IX. ENVIRONMENTAL ANDECONOMIC BENEFITS

As part of our review, we evaluatedthe potential air quality impacts ofLokring fittings. The use ofLokring fittings, in accordance withmanufacturer’s instructions, willcontrol emissions from pipeconnections and are at minimumequivalent to a welded fitting withrespect to the potential foremissions.

As part of our evaluation, the ARBstaff also visited a refinery inSouthern California where Lokring

fittings were installed on “steam” and

“condensate” lines. The ARB staffobservation under operatingconditions indicated that the installedfittings (MAS-3000 carbon steelseries) are leak-tight, metal-to-metalseals without the use of O-rings orother elastomeric seals. The ARBstaff verified that the installedLokring fittings (3-inch NPS, MAS-3000 carbon steel series) performedsuccessfully in the refinery’s “steam”and “condensate” line without anyleakage during the site visit. Thecustomer claimed that they weresatisfied with the performance of theLokring fittings.

X. RECOMMENDATIONSAfter evaluating the informationdiscussed in this report, the ARBstaff recommends that Lokring

fittings be precertified under itsPrecertification Program.Specifically, we have independentlyverified the claims of Lokring

Technology concerning its Lokring

fittings as presented in the claimssection of the report.

By accepting Precertification underthe ARB’s program, Lokring

Technology assumes, for theduration of the three-yearPrecertification period, responsibilityfor maintaining the quality of themanufactured equipment andmaterials at a level equal or betterthan was provided to obtain thisPrecertification. Precertificationunder the ARB’s program is alsocontingent on the recipient agreeingto be subject to quality monitoring bythe ARB, as provided by law.

The ARB makes no express orimplied warranties as to the

performance of the manufacturer’sproduct or equipment. Nor, does theARB warrant that the manufacturer’sproduct or equipment is free fromany defects in workmanship ormaterial caused by negligence,misuse, accident, or other causes.The ARB staff believes, however thatLokring Technology‘s Lokring

fittings will achieve the performancelevels presented in the claimssection of this report. Ourdetermination is based on ourevaluation of the data submitted byLokring Technology as well as theother information identified in thisreport. Our recommendations arepredicated on the expectation thatinstallation and maintenance areperformed in accordance withLokring Technology’s LP-105Installation Procedures.

XI. PRECERTIFICATIONCONDITIONS

The recommendations in this reportare conditional upon Lokring fittingsbeing manufactured, installed, andmaintained, in accordance withLokring Technology’s instructionsfor their use, as contained in

Lokring Technology’s LP-105Installation Procedures. A copy ofthese instructions must be providedto each installer and user of Lokring

fittings prior to installation. In orderfor the Precertification to remainvalid, Lokring Technology mustretain the manufacturing rights forLokring fittings.

APPENDIX A

MATERIALS AVAILABLE FOR EVALUATION

MATERIALS AVAILABLE FOR EVALUATION

1. Request to determine Eligibility for the ARB Equipment PrecertificationProgram from Mr. David Schatz of Lokring Technology to Mr. Richard Coreyof the ARB transmitting the Eligibility Request Form, September 8, 1998.

2. Letter from Mr. Richard Corey of the ARB to Mr. David Schatz of Lokring

Technology notifying Lokring Technology that the Lokring fittings wereeligible for the ARB Equipment Precertification Program, and transmitting anestimate of fees required for precertification and an application form,October 6, 1998.

3. Application for the ARB Equipment Precertification Program from Mr. TerryWoods of Lokring Technology to Mr. Richard Corey of the ARB, transmittingan application fee and the ARB Precertification Program application (withattached Lokring Technology Application Guide: Organizational InformationAgreement; Patented or Pending Information; Product Development andData; Performance Claim and Support Data; Required Documents Design;Mass Balance; Range of Operating Conditions; Permits; Other Certifications;Health and Safety Work; Work Safety Issues; User Manuals; QualityManagement Practices; Warranties; Customer References; Lokring

Technology Sample of Projects and Applications), September 13, 1999.

4. Letter from Mr. Richard Corey of the ARB to Mr. Terry Woods of Lokring

Technology notifying Lokring Technology that the ARB had received itsapplication (with attached Lokring Technology Application Guide) andapplication fee, that its application was sufficiently complete, October 8, 1999.

5. Memorandum from Mr. Raymond E. Menebroker of the ARB’s StationarySource Division to Mr. George Lew of the ARB’s Monitoring and LaboratoryDivision requesting assistance in the evaluation of the testing information forLokring fittings, October 18, 1999.

6. Letter from Mr. Terry Woods of Lokring Technology to Ms. Kitty Martin of theARB, transmitting the revised claim language of Lokring fittings,October 21, 1999.

7. Letter from Mr. Richard Corey of the ARB to Mr. Mark Crossman of Lokring

Technology documenting the ARB staff site visit (October 13, 1999) to arefinery in Southern California to observe installed Lokring fittings,October 29, 1999.

8. Memorandum from Mr. George Lew of the ARB’s Monitoring and LaboratoryDivision to Mr. Raymond E. Menebroker of the ARB’s Stationary Source

Division commenting on the evaluation of the performance of Lokring fittings,November 8, 1999.

9. Fax transmittal from Mr. Al McKay of Lokring Technology to Mr. HafizurChowdhury of the ARB providing the Lokring fittings Test Reports fromLawrence Livermore National Laboratory and Deposition and Leak DetectionServices, Inc., January 1, 2000.

10. Letter from Mr. Richard Corey of the ARB to Mr. David Schatz of Lokring

Technology notifying Lokring Technology with an invoice for the finalpayment, April 28, 2000.

11. Electronic mail transmittal from Mr. Al McKay of Lokring Technology to Mr.Hafizur Chowdhury of the ARB providing the updated version of Lokring

Technology Standard Product Warranty, May 2, 2000.

12. UPS mail delivery by Mr. Andrew Bonnema of Lokring Technology to Mr.Hafizur Chowdhury of the ARB providing composite Lokring fittings drawingin a Zip Disk, May 8, 2000.

13. Code of Federal Regulations, Title 40, Part 60, Appendix A, Reference TestMethod 21, Determination of Volatile Organic Compound Leaks, U.S.Government Printing Office Washington, D.C., June 22, 1990.

14. U.S. EPA Protocol for Generating Unit Specific Emissions Estimates for Equipment Leaks for Volatile Organic Compounds and Volatile Hazardous Air Pollutants (Document 450/3-88-010), 1988.

APPENDIX B

DEFINITION OF VOLATILE ORGANICCOMPOUNDS

DEFINITION OF VOLATILE ORGANIC COMPOUNDS

The United States Environmental Protection Agency and the California AirResources Board define volatile organic compounds as any compound thatcontains at least one atom of carbon, except the following exempt compounds.

acetoneethanemethyl acetateparachlorobenzotrifluoride (1-chloro-4-trifluoromethyl benzene)perchloroethylene (tetrachloroethylene)carbon monoxide carbon dioxidecarbonic acid metallic carbides or carbonatesammonium carbonatemethanemethylene chloride (dichloromethane)1,1,1-trichloroethane (methyl chloroform)trichlorofluoromethane (CFC-11)dichlorodifluoromethane (CFC-12)1,1,2-trichloro-1,2,2-trifluoroethane (CFC-113)1,2-dichloro-1,1,2,2-tetrafluoroethane (CFC-114)chloropentafluoroethane (CFC-115)chlorodifluoromethane (HCFC-22)1,1,1-trifluoro-2,2-dichloroethane (HCFC-123)1,1-dichloro-1-fluoroethane (HCFC-141b)1-chloro-1,1-difluoroethane (HCFC-142b)2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124)trifluoromethane (HCFC-23)1,1,2,2-tetrafluoroethane (HFC-134)1,1,1,2-tetrafluorethane (HFC-134a)pentafluoroethane (HFC-125)1,1,1-trifluoroethane (HFC-143a)1,1-difluoroethane (HFC-152a)cyclic, branched, or linear completely methylated siloxanescyclic, branched, or linear, completely fluorinated alkanescyclic, branched, or linear, completely fluorinated ethers with no unsaturationscyclic, branched, or linear, completely fluorinated tertiary amines with nounsaturationssulfur-containing perfluorocarbons with no unsaturations and with the sulfurbonds to carbon and fluorine

APPENDIX C

VOLATILE ORGANIC COMPOUNDSEMISSIONS CALCULATIONS

VOLATILE ORGANIC COMPOUNDS EMISSIONS CALCULATIONS

Our objective is to calculate the Volatile Organic Compounds (VOCs) emissionsbased on the limits of detection (LOD) of 2 x 10-11 std cc/sec and 1 x 10-9 stdcc/sec of the mass spectrometers of the testing laboratories, Deposition andLeak Detection Services (DLDS) and by Lawrence Livermore NationalLaboratory (LLNL) in California. Both laboratories conducted leak tests onLokring fittings. Methane (CH4) was chosen as the surrogate for expressing theVOC emission rate. The calculation is based on standard ambient temperature(20°C). We will use both LODs to calculate the VOC emissions in kilograms perhour (kg/hr) and pounds per year (lb/yr). The following equations will be used forboth calculations.

VOC (kg/hr) = [EH / (MV@ std cc/sec)] x (MWCH4) x CF……………..…………(1)

VOC (lb/yr) = VOC (kg/hr) x CF………………………………………………...(2)

Where,EH = Emissions of helium = 1 x 10-9 std cc/sec (reported as helium

LOD)MWCH4 = Molecular weight of methane = (1 x 12)C + (1 x 4)H = 16 g/moleT = Standard temperature = 20°CCF = Conversion Factors for converting to kg/hr or to lb/yrMV = Molar volume at normal conditions = 22.4 L/mole

Therefore,MV@ std cc/sec = (22.4 L/mole) x [(20 +273)°K / 273°K] x (1000 cc/L)

= 24041.0 std cc/mole

Calculation using Lawrence Livermore National Laboratory’s Limit ofDetection:

VOC (kg/hr) = [EH / (MV@ std cc/sec)] x (MWCH44) x CF= (1 x 10-9 std cc/sec) x (mole/24041.0 std cc) x (16 g/mole) x (kg/1000g) x (3600 sec/hr)= 2.4 x 10-12 kg/hr

VOC (lb/yr) = VOC (kg/hr) x CF= (2.4 x 10-12 kg/hr) x (8760 hr/yr) x (2.2 lb/kg)= 4.6 x 10-8 lb/yr

VOC(kg/hr) = 2.4 x 10-12 kg/hr

VOC(lb/yr) = 4.6 x 10-8 lb/yr

Calculation using Deposition and Leak Detection Services Limit ofDetection:

In this case, we will use EH = 2 x 10-11 std cc/sec (reported as helium LOD)

VOC (kg/hr) = [EH / (MV@ std cc/sec)] x (MWCH44) x CF= (2 x 10-11 std cc/sec) x (mole/24041.0 std cc) x (16 g/mole)

x (kg/1000g) x (3600 sec/hr)= 4.8 x 10-14 kg/hr

VOC (lb/yr) = VOC (kg/hr) x CF= (4.8 x 10-14 kg/hr) x (8760 hr/yr) x (2.2 lb/kg)= 9.3 x 10-10 lb/yr

VOC(kg/hr) = 4.8 x 10-14 kg/hr

VOC(lb/yr) = 9.3 x 10-10 lb/yr

APPENDIX D

LOKRING TECHNOLOGY’S WARRANTY

LokringTM

Standard Product Warranty

“Lokring warrants that goods delivered hereunder shall be free from defects in materialand workmanship under normal use and service for a period of 1 (one) year fromshipment. If during such one (1) year period, (i) Lokring is notified promptly upondiscovery of defect in the goods, including a detailed description of such defect,(ii) Lokring is afforded opportunity to inspect such goods at the installation site prior toany attempt to repair or retrofit and if requested to do so, Buyer returns such goods toLokring for further examination. FOB destination: and (iii) examination of such goodsby Lokring determines that such goods were defective and such defects were not causedby accident, abuse, misuse, neglect, alteration, improper installation, repair or alterationat other than the direction of Lokring, improper testing or use contrary to instruction ofLokring, then within a reasonable time Lokring shall at its sole option either repair,replace, or credit the customer for such goods. Any goods replaced under this warrantyshall be returned to the customer transportation charges prepaid and Lokring willreimburse the customer for any transportation charges incurred under section (ii) above.The performance of this warranty does not extend the warranty period of any goodsbeyond the period applicable to the goods originally delivered.

In no event shall Lokring be liable for claims for any other damages whatsoever (whetherdirect, immediate, foreseeable, consequential, or special) suffered by Buyer or anyoneelse arising out of any breach by Lokring. This express warranty is in lieu of andexcludes all other warranties, guarantees, and/or representations, expressed or implied.”

TM Trademark of Wabtec Corporation.