NSPS OOOO and OOOOa Annual Reporting - revised 22 Nov. 2019
November 28, 2017

(Updated 22 November 2019)

 

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 State environmental agencies have EPA delegation to administer these two rules. 

DSC_2076(1).jpg

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, 2020 covers the period of October 15, 2018 – October 14, 2019.
  • OOOOa annual reports due October 30 each year.
    • The initial annual report was due October 30, 2019, for the period of August 2, 2018 – August 1, 2019.

Depending on the State regulatory agency, Part 70/Title V permitted facilities may include the NSPS OOOO/OOOOa 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 Submission

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 website 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.

A CDX account is required for electronic submission of these reports. This includes the responsible officials that certify the reports and report preparers.

Contact your EPA regional office and State environmental agency to obtain the correct contact information and method (e.g., CDX, email, hardcopy) required for submitting your NSPS OOOO and OOOOa reports.

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)

At this time, submittal of NSPS OOOO and OOOOa reports via CEDRI is voluntary.

The EPA posted a draft Oil and Gas 60.5420a(b) Annual Report (Spreadsheet Template) that can be used for reporting NSPS OOOOa reporting data. At the time of this blog posting, the spreadsheet is still in DRAFT form and has not been finalized. After the reporting form is finalized, then its use will be required to be submitted via CEDRI.

The NSPS OOOOa 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 Document

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 the guidance document.

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.

 


Cimarron Energy Acquisition of HY-BON/EDI

Cimarron’s acquisition of HY-BON/EDI in July 2019 means that our environmental product and services offered to our oil and gas customers are further strengthened. This includes the following:

  • BTEX combustor unit for glycol dehydrators
  • Mobile glycol reclamation system
  • Vapor Recovery Units (VRU)
  • Vapor Recovery Towers (VRT)
  • Flares
  • Enclosed Combustion Devices (ECD)
  • Leak Detection and Repair (LDAR) services
  • Vent gas measurement services
  • Field service
  • Parts

For more information on our products and services, you can contact us at +1 (844) 746-1676 or visit https://www.cimarron.com.