When is the first EPA OOOOb annual report due?

After EPA’s 2025 deadline extensions, no annual report under Subpart OOOOb is due before November 30, 2026. Later annual reports are typically due within 90 days after each compliance period ends. Confirm your facility’s applicability and compliance dates against the current Federal Register text.

Where do OOOOb annual reports get filed?

Electronically through EPA’s CEDRI interface via the Central Data Exchange (CDX). Paper filing is not the default path for these reports.

Does SCADA replace OGI or Method 21 LDAR surveys?

No. Continuous facility monitoring complements LDAR programs; it does not replace required optical gas imaging or Method 21-style surveys. SCADA supplies operating evidence and deviation timestamps that support the annual report.

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

Key Takeaway

Under EPA NSPS Subpart OOOOb, no annual report is due before November 30, 2026. That date is the first filing cliff for many new, modified, or reconstructed oil and gas sources. Operators need a CEDRI-ready data trail — LDAR events, control-device operating limits, process-controller status, and flare/ECD evidence — not a last-minute spreadsheet.

Quick Answer

EPA’s NSPS Subpart OOOOb (40 CFR Part 60) applies to crude oil and natural gas sources that are constructed, modified, or reconstructed after December 6, 2022. After deadline extensions finalized in 2025, no annual report under Subpart OOOOb is due before November 30, 2026. Subsequent annual reports are generally due no later than 90 days after the end of each annual compliance period. Reports go through EPA’s CEDRI / CDX electronic system.

Why November 30, 2026 matters now

Two months before that date, compliance teams are not “starting a report” — they are proving that monitoring systems already collected the right tags all year. If SCADA only shows a VRU run bit and a handwritten LDAR log, the report becomes a reconstruction project. Tie this work to methane and flare monitoring automation and flare NHV monitoring under OOOOb.

What the annual report is really asking for

Identification of OOOOb-affected facilities at the site/lease
Compliance period covered and deviations / malfunctions
Control-device operating evidence (pilot/flame, NHV or alternative demonstration where applicable, covers/closed vent systems)
Process-controller / pneumatic equipment status toward zero-emission standards (see pneumatic controller conversion)
Storage vessel, equipment-leak / OGI or Method 21 program results as applicable
Records that support CEDRI fields — timestamps, instrument IDs, and who accepted a change

SCADA and field data that make CEDRI filing possible

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

Operator checklist before November 30, 2026

Confirm which pads/facilities are OOOOb-affected (construction / modification / reconstruction after Dec 6, 2022).
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 October 2026.

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.

Frequently Asked Questions