In New Mexico, unauthorized releases from oil and gas operations are governed by the Oil Conservation Division's release rule, 19.15.29 NMAC. The rule sets out two categories of reportable release — major and minor — and each carries its own notification deadline and paperwork. Getting the category right, fast, is the first compliance decision an operator makes after a spill.
Major vs. Minor: The Definitions That Drive Everything
A major release is an unauthorized release of 25 barrels or more of liquids (excluding gases), or a gas release exceeding 500 MCF. Critically, volume is not the only trigger — a release of any size is classified major if it:
- results in a fire, or is the result of a fire
- may, with reasonable probability, reach a watercourse
- may, with reasonable probability, endanger public health
- substantially damages property or the environment
- may, with reasonable probability, be detrimental to fresh water
A minor release is anything reportable that is not major: more than 5 but less than 25 barrels of liquids, or more than 50 but less than 500 MCF of gas.
The Deadlines
Major Release
Verbal or e-mail notification within 24 hours of discovery to the OCD environmental bureau chief and the appropriate district office — followed by written notification on form C-141 within 15 days.
Minor Release
Written notification on form C-141 filed with the appropriate division district office within 15 days of discovery.
Reporting Is Only Step One
Filing the C-141 does not close the matter. The responsible party must remediate the release and work through the corrective action framework in 19.15.29.8 through 19.15.29.13 NMAC — site assessment, characterization, remediation planning, closure procedures, and restoration and reclamation standards. For releases affecting soil or groundwater, this is where most of the actual cost and schedule lives, and where early containment decisions pay off most.
In practice, the sequence that keeps operators out of trouble looks like this: stop the source and contain the release immediately, classify it against the definitions above, make the 24-hour call if there is any reasonable argument the release is major, and start documenting everything — volumes, areas affected, photos, and response actions — because that record feeds both the C-141 and the eventual closure demonstration.
Disclaimer: This guide is general information, not legal advice. Release classification and reporting obligations depend on site-specific facts. Confirm requirements with the New Mexico Oil Conservation Division or qualified counsel. Rule text: 19.15.29 NMAC.
Quick Answers
What counts as a "major release" in New Mexico?
Under 19.15.29 NMAC, a major release is an unauthorized release of 25 barrels or more of liquids, or more than 500 MCF of gas. A release of any volume is also major if it results in a fire (or is the result of a fire), may with reasonable probability reach a watercourse, may endanger public health, substantially damages property or the environment, or may be detrimental to fresh water.
How quickly must a major release be reported to the OCD?
Verbally or by e-mail within 24 hours of discovery, to the OCD environmental bureau chief and the appropriate district office, followed by written notification on form C-141 within 15 days.
Do minor releases have to be reported?
Yes. A minor release — more than 5 but less than 25 barrels of liquids, or more than 50 but less than 500 MCF of gas — requires written notification on form C-141 within 15 days of discovery.
Is reporting the end of the operator’s obligation?
No. The responsible party must also remediate the release, which can include site assessment, characterization, a remediation plan, closure, and restoration/reclamation under 19.15.29.8 through 19.15.29.13 NMAC.