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Natural Resources Compliance 16 items

Oil & Gas Methane LDAR Program Checklist (NSPS OOOOb)

Assess a Leak Detection and Repair (LDAR) program for oil and natural gas facilities under EPA New Source Performance Standards Subpart OOOOb, covering fugitive monitoring, repair, and recordkeeping.

40 CFR 60 Subpart OOOOb40 CFR 60 Subpart OOOOaEPA Method 21EPA OGI Appendix K

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Program Design & Applicability

  • Has the applicability of NSPS OOOOb (or OOOOa) been determined for each affected facility based on construction, modification, or reconstruction date? *
  • Is a written monitoring plan maintained that identifies the monitoring method, frequency, and site-specific procedures? *
  • Does the monitoring plan include a sitemap and identification of fugitive emissions components? *

Fugitive Emissions Monitoring

  • Are periodic fugitive emissions surveys conducted at the required frequency for the well site or compressor station type? *
  • Is optical gas imaging (OGI) performed in accordance with Appendix K, or Method 21 performed at the applicable leak-definition threshold? *
  • Are survey instruments calibrated and calibration records retained? *
  • Date of the most recent completed fugitive emissions survey. *

Repair & Resurvey

  • Is a first attempt at repair of each identified leak made within the required timeframe (typically 30 days)? *
  • Is final repair completed and the component resurveyed to confirm the leak is resolved? *
  • Is any leak that cannot be repaired within the timeframe placed on a delay-of-repair list with justification?

Equipment Standards

  • Are storage vessels with potential VOC emissions at or above the threshold controlled to at least 95% reduction? *
  • Have natural-gas-driven pneumatic controllers been replaced or configured to zero-emission where required? *
  • Are associated gas and completion emissions routed to a sales line, control device, or beneficial use rather than routine flaring? *

Recordkeeping & Reporting

  • Are records of each monitoring survey, leak found, and repair retained for at least 5 years? *
  • Are annual reports submitted through CEDRI (Compliance and Emissions Data Reporting Interface)? *
  • Have any super-emitter events identified by third-party notification been investigated and reported?

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