Meeting EPA Scrutiny: Vent Gas & Safeguarding Upgrades for South Midland Basin 9,000 BBL/d Oil Battery

CUE EPCM conducted a Vent Gas System and Safeguarding Study for our clients’ South Midland Basin CTB facility, recommending upgrades to improve system efficiency, overpressure protection, and fire safety. Key actions included regulator replacements and fire detection system installation.

Project Spotlight: Meeting EPA Scrutiny: Vent Gas & Safeguarding Upgrades for South Midland Basin 9,000 BBL/d Oil Battery

CUE EPCM was engaged to conduct a comprehensive study on our clients’ Vent Gas System (VGS) and safeguarding measures at their South Midland Basin CTB facility. The goal was to ensure compliance with state and federal air emissions regulations and assess the facility’s overpressure protection capabilities.  Being subject to the scrutiny of the EPA under a consent decree, our client required auditable level documentation to demonstrate that their facility will never emit methane emissions under any normal operating condition.

Vent Gas System Evaluation
We evaluated the system’s ability to handle normal operational emissions and found that the existing equipment, including the 4” regulator and vapor recovery unit (VRU), needed upgrades to optimize performance. Key findings include:

  • The potential peak vapor flow rate (PPIVFR) was calculated at 25,301 SCFH gas, with the existing 4” regulator unable to adequately handle the required pressures, causing marginal flare system efficiency.

  • Recommendations included replacing the 4” regulator with a 6” valve to reduce tank pressure and improve system efficiency.

  • We also suggested replacing the inadequate 2” blanketing gas regulator to ensure the system meets necessary flow rates.

Safeguarding Study
We assessed the adequacy of the Vent Control System (VCS) for overpressure protection during emergency scenarios. While existing pressure relief devices (PRDs) were found suitable for gas blow-by and vacuum protection, they were insufficient for fire emergency loads. Recommendations included:

  • Installing fire detection in the tank farm area to mitigate pool fire risks.

  • Updating standard operating procedures to minimize tank farm inventory during emergencies.

  • Enhancing PRV capacity to meet fire emergency relief requirements.

This study provided our client with actionable recommendations to enhance facility safety, system efficiency, and compliance with emissions regulations.

Interested in quality engineering services for your upcoming oil and gas development? Contact us today to discuss how we can help ensure the success of your next project.


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