New EPA Definition Affecting Green Completions and Storage Vessels


On August 12th the EPA finalized amendments to new source performance standards (NSPS) for the Oil and Natural Gas Sector under 40 CFR part 60, subpart OOOO. See 80 FR 48262 (Volume 80, Number 155 | Pages 48262–48268). The rule is effective 8/12/2015. Specifically, the new rule changes the definitions of low pressure gas well and storage vessel.

Subpart OOOO Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution

Section 60.5365(e)(4) is revised to read as follows:

60.5365(e)(4) For each new, reconstructed, or modified storage vessel with startup, startup of production, or which is returned to service, affected facility status is determined as follows: If a storage vessel is reconnected to the original source of liquids or is used to replace any storage vessel affected facility, it is a storage vessel affected facility subject to the same requirements as before being removed from service, or applicable to the storage vessel affected facility being replaced, immediately upon startup, startup of production, or return to service.

Low pressure gas well means a well with reservoir pressure and vertical well depth such that 0.445 times the reservoir pressure (in psia) minus 0.038 times the true vertical well depth (in feet) minus 67.578 psia is less than the flow line pressure at the sales meter.

Returned to service means that a Group 1 or Group 2 storage vessel affected facility that was removed from service has been:

(1) Reconnected to the original source of liquids or has been used to replace any storage vessel affected facility; or

(2) Installed in any location covered by this subpart and introduced with crude oil, condensate, intermediate hydrocarbon liquids or produced water.

Storage vessel means a tank or other vessel that contains an accumulation of crude oil, condensate, intermediate hydrocarbon liquids, or produced water, and that is constructed primarily of nonearthen materials (such as wood, concrete, steel, fiberglass, or plastic) which provide structural support. A well completion vessel that receives recovered liquids from a well after startup of production following flowback for a period which exceeds 60 days is considered a storage vessel under this subpart. A tank or other vessel shall not be considered a storage vessel if it has been removed from service in accordance with the requirements of 60.5395(f) until such time as such tank or other vessel has been returned to service.