NSPS OOOO and OOOOa Annual Reporting
November 28, 2017

Certain oil and gas production facilities with applicable requirements in 40 CFR 60 Subpart OOOO and OOOOa are required to submit an annual report to the USEPA and State environmental agency (if the State has delegation). Most states have EPA delegation to administer these two rules. 

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The annual reports for each are due before the dates listed below for affected facilities subject to NSPS OOOO or OOOOa.

  • OOOO: January 15 each year.
    • The initial annual report was due January 15, 2014, for the period of October 15, 2012 - October 14, 2013. The NSPS OOOO report due January 15, 2018 covers the period of October 15, 2016 – October 14, 2017.
  • OOOOa annual reports due October 30 each year.
    • The initial annual report was due October 30, 2017, for the period of August 2, 2016 – August 1, 2017.

Depending on the State regulatory agency, Part 70/Title V permitted facilities may include the NSPS OOOO required report in the Part 70/Title V annual reports which is typically due by March 31 each year covering the previous calendar year.

Report Certification

For all annual reporting, a certification by a responsible official of truth, accuracy, and completeness. This certification must state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

Report Electronic Submission

EPA regulations in 40 CFR Part 60 require affected sources to electronically submit performance test reports, notification reports, and periodic (annual) reports to EPA. Based on guidance from EPA, this includes NSPS annual reports.

The EPA developed its Compliance and Emissions Data Reporting Interface (CEDRI) to submit these reports. CEDRI is located on EPA's Central Data Exchange (CDX). The CDX Web is the application used by EPA programs and various stakeholders to manage environmental data transmitted to EPA and so meet EPA's electronic reporting requirements.

An EPA Central Data Exchange (CDX) account is required for electronic submission of these reports. This includes the responsible officials that certify the reports and report preparers.

Regulatory Supplied Reporting Templates

At this time, the EPA has not posted any template documents for NSPS OOOO reporting. Contact your State environmental regulatory agency for guidance on NSPS OOOO reporting.

The Colorado Department of Public Health and Environment (CDPHE) has prepared a form for submitting NSPS OOOO annual reports: Go to link: CDPHE OOOO annual compliance report form.

Future NSPS OOOO and OOOOa reports will be submitted via EPA’s Compliance and Emissions Data Reporting Interface (CEDRI) system that each of the States will have access to. Go to Link: Compliance and Emissions Data Reporting Interface (CEDRI)

The EPA posted an Oil and Gas 60.5420a(b) Annual Report (Spreadsheet Template) to be used for reporting NSPS OOOOa reporting data.

The Spreadsheet Template has data fields that will fulfill the reporting requirements in 40 CFR 60.5420a(b) Reporting requirements.

These cover the following applicable emission sources (affected facilities).

  • Site Information
  • Wells
  • Centrifugal Compressors
  • Reciprocating Compressors
  • Natural Gas Pneumatic Controllers
  • Natural Gas Pneumatic Pumps
  • Storage Vessels
  • Fugitive Emissions Components 

NSPS OOOOa Guidance

The EPA has published a guidance document available online entitled: Small Entity Compliance Guide for Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources 40 CFR Part 60 Subpart OOOOa. Go to Document LINK to download.

Get Prepared and Stay in Compliance

HY-BON/EDI can assist your company with NSPS OOOO and OOOOa compliance. Our thorough understanding of oil and gas processes and expertise with storage tank emission controls (VRUs, VRTs, VCUs) and leak monitoring makes us a leader in providing certainty to your compliance needs.

Our IQR (Identify, Quantify and Rectify) services include fugitive leak monitoring (LDAR) that meets NSPS OOOOa requirements. Our IQR services can also assist with emission controls selection for your facility.

Contact us today 'JSQfz$O|D5r]#[7X`Yw48W/QM! and 'JSQfz$O|D5rGZwK]#[v'@3Z7iI*}!aP=g5.