Overview of the NM Air Quality – Ozone Precursor Pollutants Regulation

NMED OpenEnviro Map of Methane Hotspots (Red, Orange, Yellow are higher emissions)

My previous post was on tropospheric ozone, a precursor to this discussion on methane emission regulations and explanation why the regulations title is about ozone. The New Mexico Ozone Precursor Pollutants regulation is the New Mexico Environment Department (NMED) component of a two part state regulation developed from the NM Methane Advisory Panel. The NM Energy, Minerals and Natural Resources Department (EMNRD) co-developed the Natural Gas Waste Rules establishing the other regulation for reporting production and disposition of gas from wells.

The NMED Ozone Precursor regulation’s goal is to establish emission standards for volatile organic compounds (VOC) and nitrogen oxides (NOx) for oil and gas production, processing, compression, and transmission sources. Not that government regulations are hard to read, but buried in the four and a half pages of definitions is a key component of the regulation called “Potential to emit (PTE)”. Any source of VOC or NOx gasses from a source that by physical or operational design can emit an air pollutant falls in the PTE category. Owners and operators of a crude oil or natural gas production and processing equipment have to determine if their equipment has the Potential to Emit, and if so they must keep records of regular inspections and operational and accidental emissions from those sources.

This regulation is directed entirely at the oil and gas industries and is limited to those counties falling in the Permian and the San Juan Basin’s with the exception of Dona Ana and Valencia county containing population centers and NG transmission centers. Note: NG distribution is not covered by the regulation. The types of gas sources regulated beyond those self-defined as PTE’s and having their own sections in the regulation are:

• Stationary Engines and Turbines

• Centrifugal Compressor Seals

• Control Devices and Closed Vent Systems (including flares, ECD’ and TO’s)

• Equipment Leaks and Fugitive Emissions

• Natural Gas Well Liquid Unloading

• Glycol Dehydrators

• Natural gas-fired Heaters greater than 20 MMBtu/hr

• Hydrocarbon Liquid Transfers

• Pig Launching and Receiving

• Pneumatic Controllers and Pumps

• Storage Vessels

• Well Workovers and retrofits

• Produced Water Units and Flowback Vessels

Each of these sources of VOC’s and NOx gasses must be inspected and reported to the NMED. The methods and instrumentation to accomplish the inspections is contained within each section, though overall every subsection must to generate a Compliance Database Report (CDR) of the inspection findings. The equipment identification, location, make, and model are all recorded along with the measurement. Although onerous, there are compliance database and/or maintenance software tools that every reputable operation should already be utilizing to track their equipment conditions. (A quick search on Computerized Maintenance Management Systems should result in numerous hits). Every aspect of the regulation has a two year phase in period. Industry has several opportunities to develop their own processes to meet the reporting requirements and can submit them for review and approval. With the introduction of the NMED and ENMRD policies, time will tell if NM emission hot spots can be controlled.

What Happened to that Ozone Hole Anyway?

NASA July 2022. Total ozone over the Antarctic pole. Purple and blue are areas there is the least ozone.

Climate Change experts are celebrating this week the potential deal to move forward with the largest US bill supporting climate change initiatives that includes methane emission programs. New Mexico is already years ahead on this project, and this week the New Mexico Environment Department is set to implement the new methane emission regulation called the Oil and Gas Sector – Ozone Precursor Pollutants. A quick search of their website about methane emissions comes up blank because they have chosen to not to regulate methane, but ozone instead. As confusing as it sounds, it turns out to be a broad solution to control emissions of Volatile Organic Compounds (VOC’s) and Nitrogen Oxides (NOx). Let me explain: In other posts, I’ve included methane emission reductions as one of “three-things” we should do now to mitigate climate change so I am planning a not too deep-dive into this new regulation in future posts. But first let’s take a shallow dive into ozone.

We don’t have to go too far back in history to learn about the 1987 Montreal Protocol on Substances that deplete the ozone layer, chlorofluorocarbons. They were commonly found in refrigerants. But wait, wasn’t that to increase ozone to patch the ozone hole, not decrease emissions of greenhouse gasses? It turns out ozone in the upper atmosphere (stratosphere) is a good thing because it blocks ultraviolet light which can cause skin cancer, cataracts and environmental calamities. But, ozone in the lower troposphere layer including the air we breathe causes throat and lung irritation aggravating asthma and emphysema. You can find your local ozone level by visiting the EPA site at www.airnow.gov. A quick scan this afternoon, most of the regions with high ozone in the lower atmosphere appear to be in regions impacted by wildfires. Tropospheric ozone even affects plants by inhibiting photosynthesis which reduces the desirable ability to convert carbon dioxide to oxygen.

OK, so now we know ozone in the stratosphere is good and the troposphere is a bad thing, where does tropospheric ozone come from? Ground level ozone, is not emitted directly into the air, but is created by chemical reactions between oxides of nitrogen (NOx) and volatile organic compounds (VOC). This happens when pollutants are emitted by cars, power plants, industrial boilers, refineries, chemical plants, and oil and gas production. All these sources chemically react in the presence of sunlight to produce ozone. Depending on your desire to study a little chemistry you can read this bulletin by Michael Sanderson to learn how ozone is created. https://www.envchemgroup.com/climate-change-methane-and-ozone.html, So by measuring ozone, regulators don’t focus on a single hydrocarbon like methane, but a whole number of hydrocarbon gas emissions. Remember from my previous posts that not all methane comes from the oil and gas industry. There are natural sources like wetlands, permafrost, the oceans and other man-made sources like cattle, rice paddies, and everything organic that we throw into the landfill. I keep focusing on the oil & gas industry because there is so much potential to reduce emissions economically.

So what happened to that ozone hole anyway? We are not out of the woods yet though the stratosphere ozone layer is expected to fully recover by about 2040, thanks to the Montreal Protocol of 1987, which phased out the use of CFCs. The international treaty that saved the Earth’s ozone layer is often considered one of the most successful environmental efforts. Maybe the new Inflation Reduction Act of 2022 will be the start of another.

Would you give “The Shirt off Your Back” to mitigate Climate Change?

Can you believe the cloths we wear significantly impact the environment? 100 billion items of clothing are produced globally each year, and it’s been estimated the US throws away 11 million tons of textile waste annually. The United Nations Environment Program collects remarkable statistics for the clothing / fashion industry: 10% of global carbon emissions are attributed the fabric industry life cycle, 24,500 billion gallons of water as well as 20% of worldwide wastewater in the making of textiles, and meanwhile nearly 90% of clothing products are discarded or burned.

Organic fibers join those landfill wastes that emit CO2 and methane that I’ve posted previously, but synthetic fibers which make up 67% of all fabrics basically never go away. “Almost every piece of plastic ever produced still exists.”

Just like all the various fabrics available, plastic recycling is not a one stream solution. While we sort our plastics into the seven recycle classifications there are thousands of types of plastic. Plastic recycling is typically accomplished by two methods, Thermolysis or heat processing and Chemolysis, chemical depolymerization. Thermolysis includes pyrolysis and gasification and in the crudest from incineration. Incineration is typically avoided in the US due to the carcinogenic products and environmental contamination but can be an avenue to collect energy when other processes don’t work. Chemolysis is basically a reverse reaction of making plastic but not all plastics can be broken down with this process.

Global policy changes have begun to address the plastic waste issue and China’s 2018 National Sword policy put a ban on the import of plastic waste and then the 2019 Basel Convention places restrictions and prohibitions on plastic waste shipments for the 53 participating countries. Not surprising one country did not ratify the Basel Amendments, the USA. Both policies have impacted the ability of the US to ship domestic plastic waste to other countries which was our previous solution, but they have fostered the growth of waste plastic recycling processes.

Plastic recycling alone doesn’t solve the fabric challenges. We love the warmth and softness of fleece and fuzzy fabric Recent discoveries have found microfabrics and microplastics everywhere: waste water, the oceans, and even inside the human body. These plastics never biodegrade and appear to be with us for the duration.

So, what can we do? Recycling is going to take some time to make any real impact in plastic reduction. With that said some clothing lines are providing recycled fabrics. The consumer power of purchasing these items drives the demand for more recycled cloths. Natural fibers have always been an option and new textile process are making natural fibers more versatile. New campaigns to reuse clothing by organizations like: Recycle for Change, Planet Aid, USAGAIN, and Green America accept donations. An effort to change fashion industry practices is underway by the Geneva Environment Network to address the full gamut of the Sustainability Development Goals. For more information You can see their white paper at https://unece.org/fileadmin/DAM/RCM_Website/RFSD_2018_Side_event_sustainable_fashion.pdf.