Well Closure Compliance Timeline — Subpart OOOOb

Ideal sequence

Operations notifies EHS at the close decision; EHS files the plan and the 60-day notice; the 60-day clock runs alongside normal job prep; Operations plugs no earlier than notice plus 60 days; EHS runs the OGI survey, updates the plan with the video, keeps the records, and reports it.

1. Close decision and handoffOperations decides to plug all wells at the site and immediately notifies EHS with well IDs, coordinates, the cessation date, and a target plug window. Do not book a rig yet.
2. EHS sets the clocksEHS opens the closure file, confirms the permanent-cessation date (starts the 30-day plan clock), and back-schedules the notice from the target plug date.
3. File the closure planEHS submits the plan to EPA within 30 days of cessation, signed by the certifying official.
4. File the intent-to-close noticeEHS submits the notice at least 60 days before plugging begins. Filing sets the hard floor for the plug date.
5. Release to scheduleEHS confirms the earliest legal plug date (notice date plus 60 days) and releases Operations to schedule the job.
6. Plug the wellsAfter the 60-day clock has run, plugging begins on or after the earliest legal plug date. Record the date closure activities began.
7. Post-closure OGI surveyAfter all closure activities are complete, survey each closed well, eliminate any imaged emissions, resurvey until clean, and capture the closure video. No fixed number-of-days deadline, but schedule it as the immediate next step — periodic monitoring keeps running until it is done.

What “cessation of production” means

The rule does not define this term. Read it as the permanent end of production from all wells at the site, tied to the decision to close — not a temporary shut-in, not the rig arrival date, and not the day the site is finished for good.

• Live well: the cessation date is the day you shut it in for good. The decision meeting is the predicate, but production ceases at the valve, not the meeting.
• Already shut-in well: the cessation date is the documented decision date that converts a temporary shut-in into permanent closure.
• Temporary shut-in is not cessation. A well idle for years is still monitored under OOOOb; the 30-day clock starts only when the operator permanently takes the wells out of service to close them.
• Rig arrival is a separate milestone (date you began well closure activities). The plan and 60-day notice must already be filed before the rig lands.

How long can you wait to plug? A floor, not a deadline

The 60-day notice sets the earliest you may begin plugging; OOOOb sets no latest date. Plugging can begin at day 60 or any time after — the federal air rule does not force it at the 60-day mark and sets no maximum. But filing the notice early buys you nothing, and three things mean you cannot just file it and sit for years:

• The notice ends nothing. The site’s periodic fugitive monitoring, recordkeeping, and annual reports continue until all of paragraph (l) is complete — that is, until you plug and pass the OGI survey. Waiting ten years means ten years of continued monitoring for that site.
• Your plan commits you. The closure plan must include a schedule for completing all activities (60.5397b(l)(1)(iii)), and you report status against it every year (60.5420b(b)(9)(iv)(A)). A plan and notice filed for an imminent closure, then a decade of inaction, is a reportable gap from your own schedule and an enforcement flag. The notice should correspond to a real, scheduled plug date, not a placeholder filed years early.
• No near-term intent means no closure decision. If you do not actually intend to plug soon, the well is a temporary shut-in / inactive affected facility, the OOOOb closure clocks should not have started, and you remain in ordinary OOOOb monitoring. The closure pathway is for when you commit to plug.
• Texas is where the real limit bites. Under RRC Statewide Rule 15 / 14(b)(2), plugging of each dry or inactive well must commence within one year after operations cease unless the Commission approves a plugging extension. The extension is not automatic: it needs a current P-5 organization report, RRC compliance, a good-faith claim to a continuing right to operate, surface-equipment cleanup (Form W-3C), and a plugging-extension application (Form W-3X) backed by financial assurance, renewed each P-5 cycle. Beginning in 2027, Texas caps inactive status at 15 years for wells inactive more than 15 years and completed over 25 years ago, and limits repeated extensions.

Bottom line: OOOOb imposes no maximum after the 60-day notice, but it gives you nothing for filing early, and the RRC will not let a well sit unplugged for years without annual plugging extensions and financial assurance. File the OOOOb closure plan and 60-day notice when you actually intend to plug within your plan’s scheduled window — not years ahead.

Who does what

1. Operations
   Decides to close, hands off to EHS at least 75 days before the desired rig date, schedules and performs plugging after EHS release, files RRC W-3A (5 days before plug) and W-3 (within 30 days after).
2. EHS
   OOOOb compliance owner; manages the federal clocks, prepares and files the plan and notice, runs the OGI survey, keeps records, files the annual report.
3. Certifying official
   Signs the truth-and-accuracy certification on the plan, the notice, and the annual report.
4. OGI crew
   Performs the post-closure optical gas imaging survey of each closed well.

Pick one cessation-date convention and apply it consistently: permanent shut-in for a producing well, decision date for an already-shut-in well, always tied to a dated record. Keep prior temporary-shut-in history separate. This tool is a planning aid only — not legal advice. Confirm all interpretations with qualified counsel or the EPA regional office before relying on results.