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          Texas Natural Resource Conservation Commission

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.