As federal regulations continue to change and become more stringent, Oil and Gas companies must conform to these guidelines in order to stay compliant.
One new federal regulation, the 40 CFR 60.18 requirement, demands that all emission sources resulting from maintenance, start-up, and shut down (MSS) activities must be processed by the plant flare beginning January 5, 2014. This new regulation is driving change in the energy industry as American Oil and Gas companies are forced to reduce their emissions across locations and now must process MSS activities via the flare.
As one of the largest natural gas processors, this leader in the midstream segment operates a large gas processing plant in Midland, TX. This client understood the immediate need to meet the new 40 CFR 60.18 federal regulation by 2014. None of their current flare stakes were fully compliant for processing MSS activities. In order to achieve compliance under the new regulation, this natural gas processor needed to re-direct maintenance blow- downs associated with the inlet machine and turbines from atmospheric release into the flare systems for processing. Additionally, plant shutdown procedures now require smokeless processing by the flare. To become compliant and increase their level of safe operation, the client turned to Halker Consulting (“Halker”) to update and baseline their engineering drawings.
Halker developed a comprehensive initial phase for the flare study project which included recommendations for locations of future tie-points and drawing sets that provide a global view and understanding of the flare systems to be used for meetings, training purposes, and engineering.
Halker identified and created the following deliverables to study the three existing plant flare systems:
Halker developed a strong relationship with this client over the course of the first project phase.
Halker provided the client with a number of positive recommendations that will allow them to meet the new federal requirement on time which include:
After Halker completed Phase 1, they began work on phase 2 which is still in progress. This phase of the project involves creating flare header simulations to analyze
flow to stack for MSS connections (planned) and ESD (unplanned) events to determine if the existing headers and stacks were adequate.
As a part of phase 2, Halker specified new equipment consistent with the phase 1 recommendations. The selected equipment will complete the construction packages that detail the routing of new blowdown sources to flare headers and the installation of new flare knockouts and stacks. With the installation of the equipment upgrades, the plant will be capable of processing all MSS activities and stay fully compliant when considering the upcoming regulation. Halker also assembled a local team in Midland, TX to execute both project phases cost efficiently and effectively and meet aggressive federal regulation deadlines.
Halker’s whole-systems approach helped this client optimize their existing infrastructure to maximize production and profit through safe and compliant engineered solutions. Halker provided valuable documentation that also helped the client make informed decisions regarding facility operation.