Texas Natural Resource Conservation Commission Memorandum To: Interested Parties Through: Victoria Hsu, P.E., Director, New Source Review Permits Division Tammy Villarreal, Manager, Chemical Section, New Source Review Permits Division From: Tim Friday, Chemical Section, New Source Review Permits Division Dana Poppa Vermillion, P.E., Technical Specialist, New Source Review Permits Division Date: May 13, 1997 Subject: Equipment Leak Factors for Crude Oil Pipeline Facilities The New Source Review Permits Division has reviewed and approved a request submitted by the Texas Mid-Continent Oil and Gas Association to allow the use of the heavy oil emission factors, which are a subset of the Oil and Gas Production Operations fugitive emission factors found in the 1995 Protocol for Equipment Leak Emission Estimates, EPA-453/R-95-017, for estimating fugitive emissions at crude oil pipeline facilities. The characteristics of the crude oil handled at pipeline facilities varies greatly form the crude oil handled at oil and gas production facilities as a result of the separation process applied to raw crude. Crude oil pipeline facilities are assumed to handle only "dead" or "weathered" crude, which does not contain appreciable solution gas and can be stored at atmospheric pressure without rapid volatilization. In addition, crude oil transported through pipeline facilities has lower temperatures and thus has lower vapor pressures, than the "live" crude processed at oil and gas production facilities. In light of this information, the heavy oil emission factors are sufficiently conservative for use in estimating fugitive emissions from crude oil pipeline facilities. The heavy oil equipment leak emission factors for Oil and Gas Production Operations are given below. All factors are in units of lbs/hour/component. Equipment Type Crude Oil Pipeline/Heavy Oil Emission Factors Connectors 0.0000165 Flanges 0.00000086 Open Ended Lines 0.000309 Pumps 0.00113 1 Valves 0.0000185 Other 2 0.0000683 1 No Heavy Oil Pump emission factor was derived during API's Oil and Gas Production Operations study. The given factor is the SOCMI Without Ethylene, Heavy Liquid Pump factor with a 93 percent AVO reduction credit applied per current guidance for extremely heavy liquids. 2. "Other" equipment types include relief valves, compressors, diaphragms, drains, dump arms, hatches, instruments, meters, polished rods and vents. The American Petroleum Institute (API) is currently developing equipment leak factors for pipelines transporting crude oil and other petroleum liquids. An initial evaluation of the data collected for the API pipeline study indicates that the heavy oil factors for crude oil production facilities are essentially equal to or higher than the preliminary emission factors generated in API's current crude oil pipeline study. Additional guidance on estimating fugitive emissions from pipeline facilities will likely be forthcoming when the aforementioned API study is completed. Potentially applicable state or federal regulations may require that crude oil pipeline facilities implement a leak detection and repair (LDAR) program employing instrument monitoring. The appropriate reduction credits associated with any instrument assisted LDAR program may be applied to the above referenced emission factors. If you should have any questions, please contact Mr. Tim Friday at (512) 239-1568 or Ms. Dana Poppa Vermillion, P.E., at (512) 239-1280.