New Mexico Administrative Code
Title 20 - ENVIRONMENTAL PROTECTION
Chapter 2 - AIR QUALITY (STATEWIDE)
Part 50 - OIL AND GAS SECTOR - OZONE PRECURSOR POLLUTANTS
Section 20.2.50.122 - PNEUMATIC CONTROLLERS AND PUMPS
Universal Citation: 20 NM Admin Code 20.2.50.122
Current through Register Vol. 35, No. 18, September 24, 2024
A. Applicability: Natural gas-driven pneumatic controllers and pumps located at well sites, tank batteries, gathering and boosting stations, natural gas processing plants, and transmission compressor stations are subject to the requirements of 20.2.50.122 NMAC.
B. Emission standards:
(1) A new natural gas-driven
pneumatic controller or pump shall comply with the requirements of 20.2.50.122
NMAC upon startup.
(2) An existing
natural gas-driven pneumatic pump shall comply with the requirements of
20.2.50.122 NMAC within three years of the effective date of this
Part.
(3) An owner or operator
shall ensure that its existing natural gas-driven pneumatic controllers comply
with the requirements of 20.2.50.122 NMAC according to the following schedule:
Table 1 - WELL SITES, STANDALONE TANK BATTERIES, GATHERING AND BOOSTING STATIONS
|
Total Historic Percentage of Non-Emitting Controllers |
Total Required Percentage of Non-Emitting Controllers by January 1, 2024 |
Total Required Percentage of Non-Emitting Controllers by January 1, 2027 |
Total Required Percentage of Non-Emitting Controllers by January 1, 2030 |
|
> 75% |
80% |
85% |
90% |
|
> 60-75% |
80% |
85% |
90% |
|
> 40-60% |
65% |
70% |
80% |
|
> 20-40% |
45% |
70% |
80% |
|
0-20% |
25% |
65% |
80% |
Table 2 - TRANSMISSION COMPRESSOR STATIONS AND GAS PROCESSING PLANTS
|
Total Historic Percentage of Non-Emitting Controllers |
Total Required Percentage of Non-Emitting Controllers by January 1, 2024 |
Total Required Percentage of Non-Emitting Controllers by January 1, 2027 |
Total Required Percentage of Non-Emitting Controllers by January 1, 2030 |
|
> 75% |
80% |
95% |
98% |
|
> 60-75% |
80% |
95% |
98% |
|
> 40-60% |
65% |
95% |
98% |
|
> 20-40% |
50% |
95% |
98% |
|
0-20% |
35% |
95% |
98% |
(4)
Standards for natural gas-driven pneumatic controllers:
(a) new pneumatic controllers shall have an
emission rate of zero. A natural gas driven pneumatic controller replacing an
existing natural gas driven pneumatic controller at an existing facility is an
existing pneumatic controller for purposes of Section 20.2.50.122
NMAC.
(b) owners and operators of
existing pneumatic controllers shall meet the required percentage of
non-emitting controllers within the deadlines in tables 1 and 2 of Paragraph
(3) of Subsection B of 20.2.50.122 NMAC, and shall comply with the following:
(i) by July 1, 2023, the owner or operator
shall determine the total controller count for all controllers subject to each
table separately at all of the owner or operator's affected facilities that
commenced construction before the effective date of this Part. The total
controller count for each table must include all emitting pneumatic controllers
and all non-emitting pneumatic controllers, except that pneumatic controllers
necessary for a safety or process purpose that cannot otherwise be met without
emitting natural gas shall not be included in the total controller count. This
final number is the total historic controller count. Controllers identified as
required for a safety or process purpose after July 1, 2023, shall not affect
the total historic controller count.
(ii) determine which controllers in the total
controller count for each table are non-emitting and sum the total number of
non-emitting controllers and designate those as total historic non-emitting
controllers.
(iii) determine the
total historic non-emitting percent of controllers for each table by dividing
the total historic non-emitting controller count by the total historic
controller count and multiplying by 100.
(iv) based on the percent calculated in (iii)
above for each table, the owner or operator shall determine which provisions of
tables 1 and 2 of Paragraph (3) of Subsection B of 20.2.50.122 NMAC apply and
the replacement schedule the owner or operator must meet.
(v) if an owner or operator meets at least
seventy-five percent total non-emitting controllers using the calculation
methodology in Subparagraph (b) of Paragraph (4) of Subsection B of 20.2.50.122
NMAC by January 1, 2025, for either or both table 1 or table 2, the owner or
operator is not thereafter subject to the requirements of tables 1 and/or 2 of
Paragraph (3) of Subsection B of 20.2.50.122 NMAC.
(vi) if after January 1, 2027, an owner or
operator's remaining pneumatic controllers are not cost-effective to retrofit,
the owner or operator may submit a cost analysis of retrofitting those
remaining units to the department. The department shall review the cost
analysis and determine whether those units qualify for a waiver from meeting
additional retrofit requirements.
(c) owners and operators of existing natural
gas driven pneumatic controllers shall demonstrate compliance with tables 1 and
2 of Paragraph (3) of Subsection B of 20.2.50.122 NMAC, on January 1, 2024,
January 1, 2027, and January 1, 2030, as follows:
(i) determine which controllers are emitting
(excluding pneumatic controllers necessary for safety or process reasons
pursuant to Subparagraph (d) of Paragraph (4) of Subsection B of 20.2.50.122
NMAC) and sum the total number of emitting controllers for table 1 and table 2
facilities separately.
(ii)
determine the percentage of non-emitting controllers by using the following
equation for table 1 and table 2 facilities separately:
Total Percentage of Non-Emitting Controllers =
100 - ((total emitting controllers / total historic controller count) x 100)
(iii) compliance is demonstrated if the Total
Percentage of Non-Emitting Controllers calculated pursuant to Subparagraph (c)
of Paragraph (4) of Subsection B of 20.2.50.122 NMAC is less than or equal to
the value for that year in the Total Historic Percentage of Non-Emitting
Controllers row (as calculated pursuant to Subparagraph (b)(i)-(iv) of
Paragraph (4) of Subsection B of 20.2.50.122 NMAC) in table 1 or table 2, as
applicable, of Paragraph (3) of Subsection B of 20.2.50.122 NMAC.
(d) No later than January 1, 2024,
a pneumatic controller with a bleed rate greater than six standard cubic feet
per hour is permitted when the owner or operator has demonstrated that a higher
bleed rate is required based on functional needs, including response time,
safety, and positive actuation. An owner or operator that seeks to maintain
operation of an emitting pneumatic controller as excepted for process or safety
reasons under Subparagraph (a)(i) of Paragraph (4) of Subsection B of
20.2.50.122 NMAC must prepare and document the justification for the safety or
process purpose prior to the installation of a new emitting controller or the
retrofit of an existing controller. The justification shall be certified by a
qualified professional or inhouse engineer.
(e) Temporary pneumatic controllers that emit
natural gas and are used for well abandonment activities or used prior to or
through the end of flowback, and pneumatic controllers used as emergency
shutdown devices located at a well site, are not subject to the requirements of
Subsection B of 20.2.50.122 NMAC.
(f) Temporary or portable pneumatic
controllers that emit natural gas and are on-site for less than 90 days are not
subject to the requirements of Subsection B of 20.2.50.122 NMAC.
(5) Standards for natural
gas-driven pneumatic diaphragm pumps:
(a) new
pneumatic diaphragm pumps located at natural gas processing plants shall have
an emission rate of zero.
(b) new
pneumatic diaphragm pumps located at well sites, tank batteries, gathering and
boosting stations, or transmission compressor stations with access to
commercial line electrical power shall have an emission rate of zero.
(c) existing pneumatic diaphragm pumps
located at well sites, tank batteries, gathering and boosting stations, natural
gas processing plants, or transmission compressor stations with access to
commercial line electrical power shall have an emission rate of zero within two
years of the effective date of this Part.
(d) owners and operators of pneumatic
diaphragm pumps located at well sites, tank batteries, gathering and boosting
stations, or transmission compressor stations without access to commercial line
electrical power shall reduce VOC emissions from the pneumatic diaphragm pumps
by ninety-five percent if it is technically feasible to route emissions to a
control device, fuel cell, or process. If there is a control device available
onsite but it is unable to achieve a ninety-five percent emission reduction,
and it is not technically feasible to route the pneumatic diaphragm pump
emissions to a fuel cell or process, the owner or operator shall route the
pneumatic diaphragm pump emissions to the control device within two years of
the effective date of this Part.
C. Monitoring requirements:
(1) Pneumatic controllers or diaphragm pumps
not using natural gas or other hydrocarbon gas as a motive force are not
subject to the monitoring requirements in Subsection C of 20.2.50.122
NMAC.
(2) No later than January 1,
2023, the owner or operator of a facility with one or more natural gas-driven
pneumatic controllers subject to the deadlines set forth in tables 1 and 2 of
Paragraph (3) of Subsection B of 20.2.50.122 NMAC shall monitor the compliance
status of each subject pneumatic controller at each facility.
(3) The owner or operator of a natural
gas-driven pneumatic controller shall, on a monthly basis, conduct an AVO or
OGI inspection, and shall also inspect the pneumatic controller, perform
necessary maintenance (such as cleaning, tuning, and repairing a leaking
gasket, tubing fitting and seal; tuning to operate over a broader range of
proportional band; eliminating an unnecessary valve positioner), and maintain
the pneumatic controller according to manufacturer specifications to ensure
that the VOC emissions are minimized.
(4) Within two years of the effective date of
this Part, the owner or operator's data systems shall contain the following for
each in-service natural gas-driven pneumatic controller:
(a) natural gas-driven pneumatic controller
unique identification number;
(b)
type of controller (continuous or intermittent);
(c) if continuous, design continuous bleed
rate in standard cubic feet per hour;
(d) if intermittent, bleed volume per
intermittent bleed in standard cubic feet; and
(e) if continuous, design annual bleed rate
in standard cubic feet per year.
(5) Upon the effective date specified for the
facility in 20.2.50.116 NMAC, the owner or operator of a natural gas-driven
pneumatic diaphragm pump shall, on a monthly basis, conduct an AVO or OGI
inspection and shall also inspect the pneumatic pump and perform necessary
maintenance, and maintain the pneumatic pump according to manufacturer
specifications to ensure that the VOC emissions are minimized.
(6) The owner or operator of a natural
gas-driven pneumatic controller shall comply with the requirements in Paragraph
(3) of Subsection C or Subsection D of 20.2.50.116 NMAC applicable to the
facility type at which the pneumatic controller is installed on the effective
date specified in 20.2.50.116 NMAC. During instrument inspections, operators
shall use RM 21, OGI, or alternative instruments used under Subsection D of
20.2.50.116 NMAC to verify that intermittent controllers are not emitting when
not actuating. Any intermittent controller emitting when not actuating shall be
repaired consistent with Subsection E of 20.2.50.116 NMAC.
(7) Prior to any monitoring event, the owner
or operator shall date and time stamp the event, and the monitoring data entry
shall be made in accordance with the requirements of this Part.
(8) The owner or operator shall comply with
the monitoring requirements in 20.2.50.112 NMAC.
D. Recordkeeping requirements:
(1) Non-emitting pneumatic controllers and
diaphragm pumps are not subject to the recordkeeping requirements in Subsection
D of 20.2.50.122 NMAC.
(2) The
owner or operator shall maintain a record of the total controller count for all
controllers at all of the owner or operator's affected facilities that
commenced operation before the effective date of this Part. The total
controller count must include all emitting and non-emitting pneumatic
controllers.
(3) The owner or
operator shall maintain a record of the total count of natural gas-driven
pneumatic controllers necessary for a safety or process purpose that cannot
otherwise be met without emitting VOC.
(4) The owner or operator of a natural
gas-driven pneumatic controller subject to the requirements in tables 1 and 2
of Paragraph (3) of Subsection B of 20.2.50.122 NMAC shall generate a schedule
for meeting the compliance deadlines for each pneumatic controller. The owner
or operator shall keep a record of the compliance status of each subject
controller. On or before January 1, 2024, January 1, 2027 and January 1, 2030,
the owner or operator shall make and retain the compliance demonstration set
forth in Subparagraph (c) of Paragraph (4) of Subsection B of 20.2.50.122
NMAC.
(5) The owner or operator
shall maintain an electronic record for each natural gas-driven pneumatic
controller. The record shall include the following:
(a) pneumatic controller unique
identification number;
(b) time and
date stamp, including GPS of the location, of any monitoring;
(c) name of the person(s) conducting the
inspection;
(d) AVO or OGI
inspection result;
(e) AVO or OGI
level discrepancy in continuous or intermittent bleed rate;
(f) record of the controller type, bleed
rate, or bleed volume required in Subparagraphs (b), (c), (d), and (e) of
Paragraph (4) of Subsection C of 20.2.50.122 NMAC.
(g) maintenance date and maintenance
activity; and
(h) a record of the
justification and certification required in Subparagraph (c) of Paragraph (4)
of Subsection B of 20.2.50.122 NMAC.
(6) The owner or operator of a natural
gas-driven pneumatic controller with a bleed rate greater than six standard
cubic feet per hour shall maintain a record documenting why a bleed rate
greater than six scf/hr is necessary, as required in Subsection B of
20.2.50.122 NMAC. This demonstration shall be completed by July 1, 2023 for
controllers with a bleed rate greater than six scf/hr and as necessary for
controllers with a bleed rate less than or equal to six scf/hr.
(7) The owner or operator shall maintain a
record for a natural gas-driven pneumatic pump with an emission rate greater
than zero and the associated pump number at the facility. The record shall
include:
(a) for a natural gas-driven
pneumatic diaphragm pump in operation less than 90 days per calendar year, a
record for each day of operation during the calendar year.
(b) a record of any control device designed
to achieve at least ninety-five percent emission reduction, including an
evaluation or manufacturer specifications indicating the percentage reduction
the control device is designed to achieve.
(c) records of the engineering assessment and
certification by a qualified professional or inhouse engineer that routing
pneumatic pump emissions to a control device, fuel cell, or process is
technically infeasible.
(8) The owner or operator shall comply with
the recordkeeping requirements in 20.2.50.112 NMAC.
E. Reporting requirements: The owner or operator shall comply with the reporting requirements in 20.2.50.112 NMAC.
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