40 CFR Part 60, Subpart OOOO & TCEQ GOPs | PART II

40 CFR Part 60, Subpart OOOO (Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution) regulatory happenings are in abundance!  I posted my blog titled “3 Actions You Need to Know About 40 CFR Part 60, Subpart OOOO” only days ago.  I now find myself writing a sequel.  At the rate in which developments are occurring, I suspect I will be writing a few more in the not so distant future.  Thus, I decided to shorten the title of this blog and simply put a Roman numeral at the end.  40 CFR Part 60, Subpart OOOO Must Know updates are provided below with NO frills, NO fillers, and NO additives.

In the March 23, 2015 Federal Register, the U.S. EPA proposed Oil and Natural Gas Sector: Definitions of Low Pressure Gas Well and Storage Vessel.  The two (2) actions addressed by this proposal concern the definition of “low pressure gas well” and provisions related to storage vessels “installed in parallel” or “connected in parallel”.

Low Pressure Gas Well

The U.S. EPA is re-proposing for notice and comment the same definition of ‘‘low pressure gas well’’ that was finalized in 2012 and also soliciting comment on an alternative definition presented by a petitioner in 2014.  The alternative definition would be “a well where the field pressure is less than 0.433 pounds per square inch per foot (psi/ft) times the vertical depth of the deepest target reservoir and the flow-back period will be less than three days in duration”.  U.S. EPA is soliciting comment on both the EPA definition and the alternative definition of low pressure gas well.  Specifically, U. S. EPA seeks comment on the following:

• Which reduced emission completions (RECs) are technically infeasible on low pressure gas wells,
• What are the specific well characteristics or other technical factors that make RECs technically infeasible on low pressure gas wells,
• Which RECs could be performed on low pressure gas wells, and
• What specific well parameters or drilling techniques should be considered in determining whether an REC would be technically feasible and how these factors could be used to define ‘‘low pressure gas well.’’

Storage Vessels In Parallel

U.S. EPA is proposing to amend §60.5365(e) by removing the language relative to storage vessels “installed in parallel” or “connected in parallel”.  Furthermore, U.S. EPA is also proposing to amend the definition of “returned to service” and “storage vessel” to remove similar verbiage.  Alternatively, U.S. EPA is seeking comment on other approaches to help avoid or discourage installation or operation of storage vessels that would unnecessarily reduce the potential to emit (PTE) of a single storage vessel.

U.S. EPA has indicated that the basis for the removal of these terms is that they unintentionally incorporated storage vessels beyond their intent.  A recent petition for administrative reconsideration stated that multiple storage vessels situated next to each other, connected in parallel, and sometimes operated in parallel/series is commonplace within the oil and gas industry. Furthermore, the petition affirmed that these types of storage vessel configurations have existed within the industry for decades.  Thus, these storage vessels were not “installed in parallel” or “connected in parallel” decades ago to reduce the PTE of a single storage vessel.

On March 6, 2015, the Texas Commission on Environmental Quality (TCEQ) announced its Request for Public Comments and Hearing Announcement on Oil and Gas General Operating Permits 511, 512, 513, and 514.

TCEQ Oil and Gas General Operating Permits (GOPs) Numbers 511, 512, 513 and 514

The draft GOPs contain revisions based on recent federal and state rule changes, including updates to requirements and the addition of terms.  The draft GOPs, including cover letters, terms, tables, statement of basis, compliance assurance monitoring and periodic monitoring can be found on the TCEQ permitting website at the hyperlink provided above.

Comments concerning the proposed 40 CFR Subpart OOOO provisions must be received by U.S. EPA on or before April 22, 2015.  The public comment period concerning the TCEQ Oil and Gas GOPs closes April 7, 2015.  Time is ticking…Get moving!  Be sure to stay tuned for 40 CFR Subpart OOOO Must Know | PART III.

Please contact JP Kleinle (610) 933-5246, extension 120 or at jkleinle@all4inc.com to discuss the content of this blog or any other oil and gas related topics.