New Mexico Ozone Precursor Rule

New Mexico Environmental Department Effective Date – August 5, 2022

Who is affected by the Ozone Precursor Rule?

  • Facilities located in New Mexico Counties: Chaves, Dona Ana, Eddy, Lea, Rio Arriba, Sandoval, San Juan, and Valencia.
  • Crude oil and natural gas production and processing equipment associated with operations that extract, collect, separate, dehydrate, store, process, transport, transmit, or handle hydrocarbon liquids or produced water in the counties specified
  • Located at well sites, tank batteries, gathering and boosting stations, natural gas processing plants, and transmission compressor stations, up to the point of the local distribution company transfer station.
  • However, oil transmission pipelines, oil refineries, natural gas transmission pipelines (except transmission compressor stations), and saltwater disposal facilities are NOT subject.

What equipment/processes will have monitoring, testing, or inspection requirements?

  • Engines and Turbines
  • Compressor Seals
  • Control Devices
  • Glycol Dehydrators
  • Heaters
  • Pneumatic controllers and pumps
  • Storage vessels
  • Flowback vessels
  • Produced water management units
  • Preproduction operations
  • Any equipment with potential leak and fugitive emissions
  • Natural gas well’s liquid unloading transfers
  • Hydrocarbon and liquid transfers
  • Pig launching and receiving activities
  • Well workovers

To clarify, what are examples of specific equipment requirements in the Rule?

Natural Gas-Fired Spark-Ignition Engines

  • Applicability: Portable and stationary natural gas-fired spark ignition engines, compression ignition engines, and natural gas-fired combustion turbines located at wellhead sites, tank batteries, gathering and boosting stations, natural gas processing plants, and transmission compressor stations, with a horsepower rate greater than 500.
  • Action Items: In fact, the owner or operator of an existing natural gas-fired spark-ignition engine must complete an inventory of engines by January 1, 2023. Prepare the schedule below to ensure engines do not exceed the emission standards:
    • Firstly, 35% of the company’s existing engines meet the emission standard by January 1, 2025
    • Additionally, an extra 35% of the company’s existing engines meet the emission standards by January 1, 2027
    • Finally, the remaining 35% of the company’s existing engines meet the emission standard by January 1, 2029

Pig Launching and Receiving

  • Applicability: Individual pipeline pig launcher and receiver operations with a PTE equal to or greater than one tpy VOC located within the property boundary of, and under common ownership or control with, well sites, tank batteries, gathering and boosting stations, natural gas processing plants, and transmission compressor stations are subject.
  • Action Item: The owner or operator of affected pipeline pig launcher and receiver operations shall capture and reduce VOC emissions from pigging operations by at least 95% within 2-years. When using a combustion control device, it must have a minimum design combustion efficiency of 98%.
  • Action Item: The owner or operator conducting a pig launching and receiving operation shall: (a) employ BMPs to minimize the liquid present in the pig receiver chamber and to minimize emissions to the atmosphere after receiving the pig in the receiving chamber and before opening the receiving chamber; (b) employ a method to minimize emissions, such as installing a liquid ramp or drain, routing a high-pressure chamber to a low-pressure line or vessel, using a ball valve type chamber, or using multiple pig chambers;  (c) recover and dispose of receiver liquid in a manner that minimizes emissions to the atmosphere; and (d) ensure that the material collected is returned to the process or disposed of in a manner compliant with state law.
  • Monitoring: The owner or operator of an affected pig launching and receiving site shall inspect the equipment for leaks using AVO, RM 21, or OGI on either: (a) a monthly basis if pigging operations at a site occur monthly or more frequently; or (b) before the commencement and after the conclusion of the pig launching or receiving operation, if less frequent.

Finally, click here to read the full rule.

For more information, please contact:

Laura Worthen Lodes
Vice President of Mid-Continent Operations
Phone: 405.702.1618
Email: laura.worthen-lodes@altamira-us.com

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