Chapter 4B Flaring in New Mexico: A Year's Worth of OCD Flaring Data

• Jurisdiction: United States

Chapter 4B Flaring in New Mexico: A Year's Worth of OCD Flaring Data

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Jennifer Knowlton, PE ConocoPhillips Artesia, NM

JENNIFER KNOWLTON is the Supervisor of Permian Emissions - New Mexico at ConocoPhillips. Her background includes midstream operations, upstream operations and consulting. Jennifer has more than 20 years of experience mitigating risk and advancing organizational performance through strong leadership, vast knowledge of air quality and compliance and refined project management capabilities. Jennifer excels in implementing complex regulations and programs while ensuring continuity of business operations. Jennifer and her team are currently implementing new air quality regulations under the New Mexico Oil Conservation Division Venting and Flaring rule, the Ozone Precursor rule and draft NSPS Quad Ob/c regulations. Jennifer holds bachelor's and master's degrees in environmental engineering, a master's degree in environmental law and policy and is a registered professional engineer (P.E.) in multiple states. She is an authoritative voice within the U.S. oil and gas industry with expertise across a wide range of regulatory topics, including greenhouse gas record keeping, NSPS Subpart OOOOa, LDAR programs and major source permitting. Jennifer enjoys traveling and being a drop in mom to her two sons who are attending college at Arizona State University and Colorado State University.

The World Bank classifies flaring by three categories: routine, non-routine, and safety. The World Bank definitions are (Group):

• Routine: Flaring during normal oil production operations in the absence of sufficient facilities or amenable geology to re-inject the produced gas, utilize it on-site, or dispatch it to a market. Routine flaring does not include safety flaring, even when continuous.
• Safety: Flaring to ensure safe operation of the facility.
• Non-Routine: All flaring other than routine and safety. Non-routine flaring is typically intermittent and of short duration. It is either planned or unplanned.

Public focus is on routine flaring. Historically, some operators flared due to a lack of regulatory penalties and insufficient gas sales pipeline capacity; operators could produce more oil rather than curtail production.

In January 2019, Gov. Michelle Lujan Grisham signed an Executive Order (EO) for New Mexico state agencies to develop strategies and regulations to reduce statewide greenhouse gas emissions. The EO ordered the Energy, Minerals and Natural Resources Department's (EMNRD) Oil Conservation Division (OCD) and New Mexico Environment Department (NMED) to develop regulations to reduce methane emissions from oil and gas operations. (Grisham, 2019) On May 25, 2021, the OCD promulgated the Venting and Flaring of Natural Gas Rule (Waste Rule). (Division, 2022) NMOCD is the regulatory agency responsible for regulating oil and gas operations in New Mexico. In separate rulemaking, the NMED will also restrict methane emissions from oil and natural gas operations from an air quality perspective, specifically the Ozone Precursor rule. Together, this regulation package is called the "Methane Rules."

The rule requires oil and gas operators to minimize waste gas vented or flared during oil and gas production, processing, and transportation. The Waste Rule addresses new categories of waste gas from drilling operations, completion operations, oil and gas...