Starting on July 1, 2024, facilities located in Chaves, Doña Ana, Eddy, Lea, Rio Arriba, Sandoval, San Juan, and Valencia counties subject to the New Mexico Environment Department’s (NMED) Ozone Precursor Rules (20.2.50 NMAC) are required to generate their initial compliance database report. All affected facilities must develop and implement a robust data system capable of storing necessary information for each source and uploading it within three (3) days of monitoring events by August 5, 2024. To meet the requirements, sources must utilize approved technologies that provide accurate time/date stamps and GPS locations.
NMED emphasized the increasing significance of leveraging technology in the oil and gas sector to meet regulatory obligations. With the help of innovative data management systems, facilities can streamline their monitoring processes, enhancing efficiency and accuracy in reporting. The strict deadline set by NMED will require affected facilities to invest in the infrastructure necessary to comply with data storage and reporting demands. As part of the effort to reduce emissions from Oil and Gas operations subject to Part 50, the NMED has posted a guidance document outlining technology options for collecting compliance monitoring information to help owners and operators comply with the compliance database requirements of the rule.
Infrared cameras and GPS
One of the most common technologies already in use is an infrared camera, which can easily log data with latitude and longitude information. Optical Gas Imaging (OGI) infrared cameras are used to assist in leak detection, maintenance, and repairs. Additionally, they are frequently used in emission testing and monitoring activities, and they already record many of the relevant data components for Part 50. Infrared cameras currently used as part of existing maintenance or monitoring programs are a viable option for meeting the Part 50 data collection requirements, as they would not require any additional effort or equipment from the owner or operator. A list of suggested infrared camera manufacturers can be found on the NMED’s website.
If a facility is not required to monitor emissions as part of an inspection activity, Global Positioning System (GPS) units are one of the most cost-effective options available. With GPS augmentation methods and field developments, commercial GPS is widely used in numerous applications. Commercial GPS stores high-quality coordinate (latitude and longitude) and date/time data locally that can be easily accessed via Bluetooth, USB, and/or a PC.
Smart devices for smart data
NMED also noted that smart devices such as mobile phones and tablets can also be used to store both geographical and temporal data. Even in remote locations, smartphones can deliver data of a high quality in both the spatial and temporal dimensions because of advancements in technology and the assistance of the Global Navigation Satellite System (GNSS).
NMED also released a memo with conditional approval to use drones for optical gas imaging (OGI) monitoring required under Part 50. The potential of OGI-by-drone lies in its ability to access difficult-to-monitor or unsafe-to-monitor areas with ease. These unmanned drones can fly over facilities, capturing detailed infrared images that aid in the detection of hydrocarbon emissions. This innovative approach promises to not only improve monitoring accuracy but also reduce operational costs and enhance safety for personnel. NMED’s memo, published on July 18, 2023, outlines the conditions under which OGI monitoring, when conducted by drones, will be conditionally approved under Part 50.
Apart from the suggested devices, NMED recommends a few reliable software/technology options that work across multiple platforms and can manage multiple users’ input. ArcGIS Field Maps, CompanyCam, GPS Map Camera, Solocator, and Mergin Maps are all recommendations from the NMED. Each of these solutions have the potential to meet the requirements mandated by Part 50.
Digital Solutions support
Trinity’s EHS Digital Solutions (DGS) can also assist with many of the compliance requirements listed under Part 50. Backed by extensive expertise in regulatory requirements, information technology, and industry practices, the EHS Digital Solutions team is uniquely positioned to deliver cost-effective solutions to meet the complex data management needs of various industries. DGS advises clients on selecting the most suitable technology to address their specific EHS requirements, whether for individual users or enterprise-wide implementation. DGS can guide organizations in planning and implementing solutions that align with their functional needs, project timelines, budget constraints, and seamless integration with existing systems. Please feel free to call the Trinity Albuquerque Office at 505.266.6611 for any questions about the Ozone Precursor Rule, monitoring technologies, or to get in touch with DGS.
Additional information regarding Part 50 guidance and implementation can be found on the NMED’s Ozone Precursor Rule page including a template for compliance reporting. In addition, Trinity will be hosting an Environmental Workshop, in October, designed to cover the most pressing regulatory issues facing local Oil and Gas facilities and newer subjects such as Environmental, Social & Governance (ESG) and Environmental Justice (EJ). This course will also cover OCD Venting and Flaring Rules, and NMED Ozone Precursor Rules including detailed insights on compliance, important deadlines, and reporting mandates.
Trinity will also conduct an introductory workshop designed to provide an overview of air quality regulations and permitting options for oil and gas industries in New Mexico. This interactive course includes case studies, dynamic review and calculation exercises to maximize course output.
