The New Mexico Environment Department (NMED) has once again updated the GCP-Oil & Gas Registration Form and is requiring more detailed information, and supporting documentation to demonstrate compliance with the permit. The NMED will not accept previous versions of the Registration Form after September 19, 2019. However, applicants should begin using the updated forms immediately.

Perhaps the most substantial change is that the newer versions of the Registration Forms are modeled after the Universal Application Forms. The tables in Section 2 were previously included in a Microsoft Word document; however, they are now compiled into a Microsoft Excel file. This should facilitate a quicker review and allow applicants to easily link supporting information, such as calculations and stack parameters to the tables themselves.

Many of the changes are relatively minor and involve clarifying language or submittal requirements. However, there are also more substantial changes which will require more time to address. For example, Section 6 has been completely revamped to include checkboxes for every supporting document that the NMED requires with the application submittal. The updated section now clarifies multiple items that must be provided with all applications (if applicable), including manufacture specifications for control equipment, liquid/gas analyses, and input/output summaries for all simulation models and software.

It should also be noted that the NMED will no longer accept NSPS JJJJ emission factors in lieu of catalyst specifications, and the liquid/gas analyses that are submitted with the application must be 1 year old or less. The Air Quality Bureau has been requesting much of this information for previous application submittals, and is hoping to minimize unnecessary communication by requiring this documentation with the initial submittal moving forward. Failure to include the applicable supporting documentation may result in application denial.

Additionally, the tables in Section 2 and the public notice have both been updated to remove Total Suspended Particulates (TSP), as the New Mexico Ambient Air Quality Standard (NMAAQS) for TSP was repealed on November 30, 2018. Hopefully, this will help avoid confusion as previous versions of the Registration Form required applicants to include TSP emissions, even though the standard had been repealed.

Furthermore, the NMED has also updated the language in the applicable state and federal regulations section for 20.2.73 NMAC regarding emission inventories. An emission inventory will be required for all minor sources in 2020, including facilities authorized under a Notice of Intent (NOI) or General Construction Permit (GCP). The agency is looking to make this new requirement abundantly clear.

For assistance in determining GCP-O&G applicability, completing permitting applications or for support associated with emission inventories, please call the Trinity Albuquerque office at (505) 266-6611.