WildEarth Guardians filed a September 26th Petition (“Petition”) requesting that the United States Environmental Protection Agency (“EPA”) Administrator object to the initial Clean Air Act Title V Operating Permit for the Lucid Energy Delaware, LLC, Big Lizard Compressor Station (“Station”).
The Station is located in Lea County, New Mexico and is stated to include oil and gas processing activities.
42 U.S.C. § 7661d(a) requires that states submit each Title V Operating Permit to EPA for review. The federal agency has 45 days to object to the issuance of the Permit if it determines it is not in compliance with the applicable requirements of the Clean Air Act. If EPA does not object to a Permit, the Clean Air Act provides that any person may petition the EPA Administrator, within 60 days of the expiration of the 45-day review, to object to the Permit. If EPA does not object to a Permit, Section 505(b)(2) provides that any person may petition the EPA Administrator, within 60 days of the expiration of the 45-day review period, to object to the Permit.
The New Mexico Environmental Department’s Air Quality Bureau is stated to have approved an initial Title V permit for the Station on July 29th.
The Station activities are stated to include:
- Gathering oil and gas from adjacent wells in the area
- Processing and compressing gas for pipeline transport
- Collecting liquids into tanks for loading into trucks
Air emission sources are stated to include:
- Gas-fired compressor engines
- Dehydration units
- Amine units
- Fugitive emissions
- Venting activities
WildEarth Guardians objects on the basis that the permit:
- Fails to ensure Lucid complies with applicable Title V permitting requirements under 40 C.F.R. § 70. The Permit inappropriately allows Lucid to submit an incomplete Title V permit renewal application and continue to operate with an expired initial Title V permit, contrary to the Clean Air Act and New Mexico’s rules implementing Title V;
- Fails to ensure the Big Lizard Station operates in compliance with applicable requirements, including the New Mexico State Implementation Plan. Namely, the Permit fails to ensure operation of the facility will not cause or contribute to exceedances of national ambient air quality standards (“NAAQS”) for ground-level ozone, the key ingredient of smog; and
- Fails to require sufficient periodic monitoring to ensure compliance with applicable emissions limits. Specifically, the Permit requires the Big Lizard Station to comply with volatile organic compound (“VOC”) limits on emissions during venting, yet prescribes no actual monitoring to assure compliance with this limit.
A copy of the Petition can be downloaded here.