New Mexico Regulatory Update – Ozone Precursor Rule
Flares, Combustors, and Cameras for Emissions Control and Compliance
Ozone Precursor Rule Summary
The New Mexico Environment Department’s (NMED) Ozone Precursor Pollutants rule (rule 20.2.50 NMAC Oil and Gas Sector – Ozone Precursor Pollutants) went into effect on August 5, 2022. The rule establishes standards for emissions of “ozone precursors,” including volatile organic compounds (VOCs), and oxides of nitrogen (NOx) with the objective of reducing ground-level ozone.
The primary objective of the Ozone Precursor Rule is to lower ozone levels to “…reduce smog, improve air quality, and create clearer visibility for our skies.”
NMED intends to achieve the objective by doing two things:
Encourage Oil & Gas operators to adopt new technologies to eliminate flaring and venting emissions.
Incentivize development and use of new technologies for leak detection and repair (LDAR) to increase the speed and accuracy of reporting.
“Our proposed ozone rule embraces the use of new and innovative approaches and technologies that are more protective of public health and the environment than those currently found in federal and state rules.” – New Mexico Environment Department, NMED Ozone Precursor Rule Fact Sheet
The new rules apply to all Oil & Gas operations in counties with high ozone levels, there is no grandfathering or loopholes, according to NMED.
Gas producing operations in counties with ozone levels approaching the federal ozone thresholds. Those counties include Chaves, Doña Ana, Eddy, Lea, Rio Arriba, Sandoval, San Juan, and Valencia. The rules do not apply to Bernalillo County, which has its own air quality regulatory agency.
Impact of Ozone Precursor Rule on Oil & Gas Operations
The NMED’s Ozone Precursor Rule complements rules issued by New Mexico’s Energy, Minerals and Natural Resources Department that went into effect in 2021, which limit venting and flaring.
The rules apply to existing and new equipment.
Primary features of the new rules include:
Burner Management Systems for all flares and combustors. All flares and combustors must be equipped with a Burner Management System (BMS), to eliminate the incidences of unlit pilot flares venting raw methane to the atmosphere.
Although dehydrators and heater-treaters are exempted, leading operators are taking the time to equip all their fired equipment, not just flares and combustors with an automatic BMS for safety reasons. There have been multiple incidents related to field personnel sustaining injuries when attempting to manually reignite pilot flames.
Auto-ignition and monitoring. The rule requires that BMS units must be automatic, in that if they detect the lack of a pilot flame, then they commence an automatic re-ignition sequence.
LDAR technologies. NMED describes its approach to Leak Detection and Repair (LDAR) as “innovative” and “technology neutral,” by allowing operators to use satellites, air ships, drones and fence-line monitoring. Leak detection must occur monthly and if leaks are found they must be fixed within 15 days.
Continuous compliance. Operators are also required to maintain records and demonstrate continuous compliance.
Keep in mind that this article covers only certain provisions of the rule and is not a comprehensive review of all applicable regulatory requirements.
Platinum Solutions for Compliance and Environmental Performance
Platinum is unabashedly pro-Oil & Gas because of the good our industry does to provide reliable and affordable energy to power our modern way of life and provide good jobs for hard working people. Our promise is to help our customers harness the full potential of their well sites.
We offer a comprehensive lineup of solutions to help Oil & Gas operators comply with the Ozone Precursor Rule and other environmental regulations impacting Oil & Gas production systems.
The ideal state is one where the only flame on the well site is the pilot!
Automatic Burner Management Systems. Platinum Burner Management Systems feature reliable auto-reignition. Without automatic re-ignition, a field operator has to be physically present and manually light the pilot, which can be a risky practice.
Data log for continuous compliance. Our BMS systems enable you to record essential data to log the runtime of the pilot. We use a second counter. From the moment you turn on the pilot, it monitors the presence of a flame, when and if a flame goes out and goes into a reignition sequence.
Additionally, Platinum BMS units are equipped with a USB port, so you can capture and download important data to a memory stick or flash drive. This data can be used to demonstrate continuous compliance.
Modbus communications for remote monitoring and reporting. Platinum BMS units can be connected to your SCADA system, allowing you to monitor a flare pilot flame on a well site near Carlsbad from a high rise in Houston. The internal second counter can activate an alert if the flare or combustor goes down, keeping you aware of reignitions and the pilot flame status.
Without Modbus capability, a field operator must visually inspect the pilot to know if it is out.
Professional and timely LDAR services. Our experienced LDAR technicians use advanced Optical Gas Imaging technology and traditional equipment to locate leaks and dispatch repair teams. Our professionals use the FLIR GFX 320 cameras, which is the only camera recognized by the state of New Mexico for LDAR.
High-performance Vapor Recovery Units (VRUs). Platinum VRUs punch above their class, typically moving 30% more gas volume for the same horsepower rating as competing units, because of our innovative design and quality materials. Our VRUs can capture low pressure gas from oil and produced water storage tanks, flare scrubbers, water knockouts, and other sources of fugitive emissions so you can convert these gas streams into revenue while reducing emissions.
The Platinum Difference
Our core competency in Facilities Optimization sets us apart. We work with operators in the Permian Basin of all sizes, from companies having only a handful of wells to supermajors. As a result, we leverage the experience gained with larger operators, build best practices into our products and services, and then disseminate that knowledge to our smaller customers.
A well site or facility with an optimized configuration will help you harness its full potential, maximizing its long-term economic value and environmental performance.
Contact us today at firstname.lastname@example.org to learn more about our solutions and how we can help you meet the Ozone Precursor Rule requirements and harness the full potential of your well site.