NoDart is a revolutionary new system created by a team of oil and gas industry professionals who saw a problem with the EPA compliance for the oil and gas wells and holding tanks. Despite the advancements in seals and technology, the antiquated process for sealing wells and tanks has been the same for over 75 years causing environmental liabilities, fines, and law suits.

There are millions of storage tanks worldwide that store petroleum or hazardous substances that need to be properly sealed and tracked. NoDart system focuses on addressing compliance laws in order to protect the environment and human health as well as avoid fines and litigation.

3162.7-5 Site security on Federal and Indian (except Osage) oil and gas leases. An amendment published at 81 FR 81420, November 17, 2016.

SECTION 3173.2 STORAGE AND SALES FACILITIES—SEALS
(a) All lines entering or leaving any oil storage tank must have valves capable of being effectively sealed during the production and sales phases unless otherwise provided under this subpart. During the production phase, all appropriate valves that allow unmeasured production to be removed from storage must be effectively sealed in the closed position. During any other phase (sales, water drain, or hot oiling), and prior to taking the top tank gauge measurement, all appropriate valves that allow unmeasured production to enter or leave the sales tank must be effectively sealed in the closed position (see Appendix A to subpart 3173). Each unsealed or ineffectively sealed appropriate valve is a separate violation.

(b) Valves or combinations of valves and tanks that provide access to the production before it is measured for sales are considered appropriate valves and are subject to the seal requirements of this subpart (see Appendix A to subpart 3173). If there is more than one valve on a line from a tank, the valve closest to the tank must be sealed. All appropriate valves must be in an operable condition and accurately reflect whether the valve is open or closed.

SECTION 3173.3 OIL MEASUREMENT SYSTEM COMPONENTS—SEALS
Section 3173.3 of the final rule identifies a nonexclusive list of the components used in LACT meters or Coriolis oil measurement systems (CMS) that must be effectively sealed to indicate whether tampering may have occurred.

SECTION 3173.5 REMOVING PRODUCTION FROM TANKS FOR SALE AND TRANSPORTATION BY TRUCK
Section 3173.5, paragraphs (a) and (b), of the final rule make clear that, at the completion of either a single or a multiple truckload sale, the driver of the load(s) must possess all the information that is required in § 3174.12. Under paragraph (c), once the seals are broken, the purchaser or transporter is responsible for the entire contents of a tank until it is resealed.

SECTION 3173.7  HOT OILING, CLEAN-UP, AND COMPLETION OPERATIONS
Section 3173.7(a) of the final rule requires that specific information be recorded when hydrocarbons are removed from storage and used on the lease, unit PA, or CA for hot oiling, clean-up, and completion operations, including the volume of hydrocarbons removed from storage and expected to be returned to storage. Paragraph (b) requires operators to consider as sold, and to measure following the requirements of this final rule, any production used from storage for hot oiling, line flushing, or completion operations on a different lease, unit PA, or CA.

Under Order 3, the operator was required to record only the date, seal number removed, new seal number installed, and the reason for removing oil for hot-oiling, clean-up, or completion operations. 

(a)Definitions. Appropriate valves. Those valves in a particular piping system, i.e., fill lines, equalizer or overflow lines, sales lines, circulating lines, and drain lines that shall be sealed during a given operation.

Effectively sealed. The placement of a seal in such a manner that the position of the sealed valve may not be altered without the seal being destroyed.
Production phase. That period of time or mode of operation during which crude oil is delivered directly to or through production vessels to the storage facilities and includes all operations at the facility other than those defined by the sales phase.

Sales phase. That period of time or mode of operation during which crude oil is removed from the storage facilities for sales, transportation or other purposes.

Seal. A device, uniquely numbered, which completely secures a valve.
(b)Minimum Standards. Each operator of a Federal or Indian lease shall comply with the following minimum standards to assist in providing accountability of oil or gas production:

(1) All lines entering or leaving oil storage tanks shall have valves capable of being effectively sealed during the production and sales operations unless otherwise modified by other subparagraphs of this paragraph, and any equipment needed for effective sealing, excluding the seals, shall be located at the site. For a minimum of 6 years the operator shall maintain a record of seal numbers used and shall document on which valves or connections they were used as well as when they were installed and removed. The site facility diagram(s) shall show which valves will be sealed in which position during both the production and sales phases of operation.

Violation	Assessment amount per violation ($)
1. An appropriate valve on an oil storage tank was not sealed, as required by § 3173.2	$1,000
2. An appropriate valve or component on an oil metering system was not sealed, as required by § 3173.3	$1,000
3. A Federal seal is removed without prior approval of the AO or AR, as required by § 3173.4	$1,000