How to Rise to the Occasion of New Mexico’s New Emissions Rule

November 11, 2022

By: Kaleb Meihls

New Mexico has upped the regulatory ante and increased the number of LDAR inspections oil and gas companies must conduct at their facilities within the state. That’s because New Mexico’s Ozone Precursor Pollutants rule (NMAC 20.2.50) went into effect on August 5th, 2022. The rule—which can be read in full here—establishes more stringent statewide emissions standards for oil and gas companies operating (production, processing, compression and transmission facilities) in the state’s nonattainment ozone areas. These emissions standards apply to your company if it operates a facility that:

  1. Has the potential to emit (PTE) between 2 and 25 tons of Volatile Organic Compounds (VOCs) annually
  2. Is in any of the following New Mexico counties:
  • Chaves
  • Don Ana
  • Eddy
  • Lea
  • Rio Arriba
  • Sandoval
  • San Juan
  • Valencia

The added burden NMAC 20.2.50 brings to LDAR inspection and reporting

From a monitoring standpoint, facilities that meet the above criteria are now subject to what will likely amount to an increased number of inspections throughout the year. The type of facility and the facility’s PTE determine inspection and reporting frequency. For example, operators of well sites and standalone tank batteries within 1,000 feet of an occupied area or with a VOC PTE equal to or greater than 25 tpy must perform quarterly LDAR inspections.

Meanwhile, natural gas processing plants and gathering and boosting stations with a PTE less than 25 tpy VOC must be inspected quarterly. If a processing plant or compressor station has a PTE equal to or greater than 25 tpy VOC, inspection frequency increases to monthly.

Inspection schedule for well sites and standalone tank batteries

PTE < 2 tpy VOCPTE ≥ 2 tpy VOCPTE < 5 tpy VOCPTE ≥ 5 tpy VOC
AnnuallySemi-annuallySemi-annuallyQuarterly

Inspection schedule for gathering and boosting stations and natural gas processing plants

PTE < 25 tpy VOCPTE ≥ 25 tpy VOC
QuarterlyMonthly

The LDAR inspections required under the new rule must include thief hatches, closed vent systems, pumps, compressors, pressure relief devices, open-ended valves, valves, flanges, connectors, piping, and associated equipment.

For many companies, increased monitoring requirements could mean more  labor hours, technology investments, and/or greater quantities of data to process. You may be tempted to tackle this added burden with your existing resources, even if you currently find yourself scrambling to ensure your LDAR program’s regulatory compliance.

Montrose can help you transform this regulatory burden into an opportunity to not only deploy a more robust LDAR program—but a far more efficient one as well.

Level up your LDAR program to comply with New Mexico’s latest rule and prepare for future regulatory demands

If you’re currently using Method 21 for your LDAR monitoring program, Montrose can help you ramp up your LDAR inspection efforts quickly. With our expertise in the Alternativ Work Practice (AWP), using Optical Gas Imaging (OGI) and other technologies, we have the knowledge and means to help you conduct monthly or quarterly inspections with minimal increase to  labor and time spent. Our OGI technicians in the region are ready to come on site and make your LDAR program more efficient and cost-effective.

We’re already helping processing plants in surrounding areas implement AWP for its efficiency gains over traditional Method 21. We can do the same for you.

We can help make your data collection and reporting more efficient as well. With our proprietary TARGET ONLINE leak tracker software, you can centralize data and manage the entire reporting process in a single digital platform. Within this program, your inspection pictures and videos are annotated to show both leak leaks and repairs, once made. The software eliminates the need to parse data and track leaks in time-consuming tools, such as spreadsheets, while making it far easier to document New Mexico and federal compliance through workflow automation.

Let’s rise to meet New Mexico’s emission standards

Montrose can help get your LDAR program up to speed. Contact us, and let’s partner together.

Kaleb Meihls – Business Development Manager, Montrose Environmental
Kaleb Meihls is a business development manager for Montrose Environmental, specializing in LDAR compliance and OGI. He has 14 years of experience in the environmental industry with various positions, including field operations manager, project manager, account executive, and director of business development. This diverse portfolio has contributed to his vast understanding of the environmental services industry.

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