EPA OOOOb Annual Reporting Deadline: What Oil and Gas Operators Must File by November 30, 2026

Quick Answer

EPA’s NSPS Subpart OOOOb (40 CFR Part 60) applies to crude oil and natural gas facilities for which construction, modification, or reconstruction commenced after December 6, 2022. After deadline extensions finalized in late 2025 (Federal Register), no annual report under Subpart OOOOb is due before November 30, 2026 — owners/operators have until that date to submit reports that would otherwise have been due earlier. Depending on each affected facility’s compliance-period start, more than one annual report may be due on that same cliff date. Annual reporting content and electronic submission are addressed in 40 CFR 60.5420b via EPA’s CEDRI / CDX system (OOOOb annual-report spreadsheet template). After November 30, 2026, subsequent annual reports are due no later than 90 days after the end of each annual compliance period (the extension did not change how those periods are defined).

Why November 30, 2026 matters now

In the weeks before that date, compliance teams are not “starting a report” — they are proving that monitoring systems already collected the right tags for every compliance period being filed. If SCADA only shows a VRU run bit and a handwritten LDAR log, the CEDRI package becomes a reconstruction project. Tie this work to methane and flare monitoring automation and flare NHV monitoring under OOOOb. (Existing-source emission guidelines under Subpart OOOOc are a separate state-plan track — do not confuse them with OOOOb NSPS reporting for post–Dec 6, 2022 sources.)

What the annual report is really asking for

• Identification of OOOOb-affected facilities (and the periods covered) at the site/lease
• Deviations / malfunctions and other reportable events for each period
• Control-device operating evidence (pilot/flame, NHV or alternative demonstration where applicable, covers/closed vent systems)
• Process-controller / pneumatic equipment status relative to applicable standards (zero-emission process-controller compliance dates are extended separately — see pneumatic controller conversion)
• Storage vessel, equipment-leak / OGI or Method 21 program results as applicable
• Records that support CEDRI template fields — timestamps, instrument IDs, and who accepted a change

Use EPA’s current OOOOb annual-report spreadsheet template in CEDRI; field lists evolve — map historian tags to the live template, not a stale checklist.

SCADA and field data that make CEDRI filing possible

1. Time-series evidence: Pilot/flame status, VRU suction/ discharge, tank pressure, and control-device alarms retained long enough to cover each compliance period being reported.
2. Event archive: Flameouts, VRU trips, hatch alarms, and bypasses with start/stop times — not just a daily rollup.
3. Configuration audit: Who changed setpoints or disabled an interlock, and when (pair with EFM / API 21.1 audit-trail discipline on measurement systems).
4. Export path: CSV/historian extracts mapped to the facility list and CEDRI columns well before the cliff date, not the week of the deadline.

Operator checklist before November 30, 2026

• Confirm which pads/facilities are OOOOb-affected (construction / modification / reconstruction commenced after Dec 6, 2022).
• List every annual report that must be caught up by Nov 30, 2026 — not only the “latest” period.
• Map each affected facility to the SCADA tags and LDAR records that support the report.
• Close gaps on flare/ECD evidence and process-controller inventories.
• Dry-run a CEDRI package with legal/EH&S — do not discover missing months of flame status in the final weeks before the deadline.

NFM Consulting helps Texas producers wire OOOOb-relevant evidence into pad and facility SCADA so annual reports are exports, not archaeology. Request a compliance-data readiness review.