Since the issuance of the GCP-Oil & Gas permit over four months ago, the New Mexico Environment Department (NMED) has updated both the Registration Form and the Air Emissions Calculation Tool (AECT) requiring more detailed information and demonstration of compliance with the permit itself. The NMED will stop accepting the previous version of the Registration Form after 10/13/2018 and the newest version of the AECT must be used after 9/10/18 (30 days after its 8/10/18 issuance).

Newer versions of the initial Registration Form place a much larger emphasis on demonstrating compliance with the minimum stack parameters set forth in the GCP-O&G Permit. These stack parameters are based on the facility-wide lb/hr NOx emissions and have been proven to be one of the most difficult requirements for applicants to meet under the GCP-O&G. The newer Registration Form also includes Tables 4, 5, and 6 which require the stack parameters, allowable fuels, fuel sulfur content for combustion units, and tank data. These tables are reminiscent of Table 2-H, 2-J, and 2-L in Part 2 of the Universal Application form used for NSR permitting.

Additionally, newer versions of the Registration Form contain an entire section labeled “Verification of Compliance with Stack Parameter Requirements” requiring applicants to ensure their facility's stack parameters meet the requirements of the GCP-O&G as set forth in Condition A202.I. The applicant is required to sum their facility's lb/hr NOx emissions - this excludes flares and thermal oxidizers, but requires the lb/hr NOx emissions from Enclosed Combustion Devices (ECDs) to be doubled when added to the facility-wide emissions. The minimum stack parameters are then based on the previously-mentioned facility-wide total NOx lb/hr emission rate. Table 1 of the GCP-O&G details the stack parameters for engines while Table 2 details the parameters for turbines. Heaters and reboilers are allowed to comply with the requirements of either Table 1 or 2 of the permit.

In short, these stack parameter requirements were developed as a surrogate to demonstrate compliance with the National Ambient Air Quality Standards (NAAQS) in lieu of performing air dispersion modeling for each facility. The permit goes into more detail in describing the options for units which do not meet the minimum requirements. This has been one of the greatest challenges for many applicants who are required to rethink their facility design if the units do not meet the minimum requirements. It should be noted; however, that applicants do have the option of raising a unit's stack height if the unit does not comply with the minimum temperature or exit velocity requirements (Condition A202.I). Other requirements that can pose a challenge to applicants include the flare height and H2S requirements (Condition A207.C), SO2 limitations imposed on ECDs and Thermal Oxidizers (TOs) (Condition A208.A), and the fact that combustion emissions due to malfunction events are not authorized under the permit (Condition A107.C).

Lastly, the NMED has recently posted a spreadsheet to their website detailing all of the facilities currently permitted either under a GCP-1 or GCP-4. As a reminder, current GCP-1 and GCP-4 permit holders have nine months from the issuance of the GCP-O&G permit to make a determination and inform the NMED whether or not the facility will qualify for the GCP-O&G or will instead apply for a regular Part 72 construction permit. The deadline for notifying the NMED is January 27, 2019.

For assistance in determining GCP-O&G applicability, completing permitting applications or transitioning currently permitted GCP-1 or GCP-4 facilities, please contact the Trinity Albuquerque office by calling (505) 266-6611.