32-7 NO301 SALT WATER DISPOSAL

32-7 No301 Salt Water Disposal is a single-facility saltwater disposal (SWD) operation registered under NAICS 211130 (Natural Gas Extraction), headquartered in Navajo City, New Mexico. EPA ECHO data as of May 4, 2026 records one facility (ID 110022768860), zero formal violations in the trailing 24 months, and a derived penalty exposure of $3,760,000 calculated from the five-year total prorated to a 24-month window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That number demands context. The most recent permit action on file dates to August 10, 2009, and ECHO lists zero active permits at the reporting date — a configuration that typically signals either a closed permit cycle, operation under New Mexico Oil Conservation Division authority rather than a federal NPDES program, or a reporting lag [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The entity is privately held with no SEC CIK, so Item 1A and Item 7 disclosures are unavailable for comparison against measured compliance data. SWD operations in New Mexico are governed primarily under N.M. Admin. Code § 19.2.100.61, which vests oversight of produced-water handling with the New Mexico Oil Conservation Division [source: https://www.law.cornell.edu/regulations/new-mexico/N-M-Admin-Code-SS-19.2.100.61]. Peer benchmarking within NAICS 211120/211130 tells a sharper story: penalty exposures run materially higher at Greka Bell Compressor Plant ($26.16M) and Red Hills Gas Processing Plant ($19.13M), placing 32-7 No301 in the lower quartile of penalty exposure among upstream gas peers tracked in ECHO [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That relative quiet does not mean the regulatory environment is static. Regional pressure on produced-water disposal is intensifying, as documented in recent E&E News and Insurance Journal coverage of Texas and New Mexico rulemaking [source: https://www.eenews.net/articles/why-2-oil-states-are-slow-to-embrace-wastewater-recycling/], and the trajectory matters as much as the current count.

The compliance footprint for 32-7 No301 Salt Water Disposal is narrow by design: a single injection well site handling produced brine from natural gas extraction, with federal oversight routed primarily through the Underground Injection Control (UIC) program under the Safe Drinking Water Act and state oversight through the New Mexico Oil Conservation Division per N.M. Admin. Code § 19.2.100.61 [source: https://www.law.cornell.edu/regulations/new-mexico/N-M-Admin-Code-SS-19.2.100.61]. ECHO's exporter file lists the facility under ID 110022768860 with zero quarters of non-compliance recorded in the last eight quarters, yielding a violation_count_24mo of zero under the standard derivation viol_24mo = min(qtrs_with_nc, 8) [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The past 24 months show no new federal enforcement actions logged against this facility. The $3,760,000 penalty figure in the ECHO summary is a prorated derivation from a five-year rolling total (penalty_24mo = total_5yr × 24/60), meaning the underlying penalty event pre-dates the 24-month window but continues to weight the exposure calculation. ECHO's public interface should be consulted directly for the underlying case docket, because the exporter bundle does not itemize the original action [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No active NPDES, RCRA, or Title V CAA permits are indicated; the 2009 permit record is the last dated instrument in the file [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Sustained absence of an active permit record, combined with a non-zero penalty carry-forward, is consistent with a facility operating under state UIC primacy where federal enforcement data is populated only on escalation.

State-level context has shifted meaningfully over the 24-month window. Insurance Journal reported on April 24, 2026 that Texas is tightening rules on so-called zombie wells after a more-than-50% increase in toxic wastewater leaks from abandoned oil sites [source: https://www.insurancejournal.com/news/southcentral/2026/04/24/867247.htm]. E&E News documented in an April 2026 report that Texas and New Mexico regulators are reviewing produced-water recycling and surface-discharge pathways, with regulators in both states requesting additional containment and monitoring assurances before approving river or field discharge [source: https://www.eenews.net/articles/why-2-oil-states-are-slow-to-embrace-wastewater-recycling/]. High Country News reported on February 12, 2026 that New Mexico is pursuing multi-million-dollar fines against the federal Department of Energy for groundwater-standard violations at legacy facilities — a signal of the state's broader posture toward groundwater enforcement that applies equally to injection-well operators [source: https://hcn.org/articles/new-mexico-demands-fix-for-federal-nuclear-waste-management]. These vectors collectively raise the regulatory baseline against which a single-well SWD operator will be measured going forward, irrespective of the current zero-violation count in ECHO.

ECHO reports zero formal violations against facility ID 110022768860 in the trailing 24 months ending May 4, 2026 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No CWA, CAA, or RCRA case dockets appear in the exporter bundle for this period. The $3,760,000 figure in the penalty_total_24mo field is derived by proration from the five-year total and therefore reflects penalty assessments that originated before the 24-month cutoff but remain within the five-year rolling window used by ECHO's summary export. The underlying assessment program, docket number, and resolution date are not itemized in the exporter file; full case characterization requires a direct query to ECHO's Enforcement Case Search [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No federal consent decree, administrative order, or Section 309 CWA assessment against this specific legal entity surfaced in the Exa court-records search. The Exa bundle returned CWA matters involving Salt Lake County, Utah [source: https://www.epa.gov/enforcement/salt-lake-county-utah-clean-water-act-settlement] and American Natural Processors, Inc. [source: https://19january2021snapshot.epa.gov/sites/static/files/2018-04/documents/anp-cafo.pdf], neither of which involves 32-7 No301. The Department of Justice record referenced in Exa regarding an SWD operator pleading guilty to multiple felony charges is a separate North Dakota case and is not attributable to this facility [source: https://www.justice.gov/usao-nd/pr/operator-saltwater-disposal-well-pleads-guilty-multiple-felony-charges-connection]. Absent an active NPDES permit in the exporter record, future enforcement risk is concentrated at the state UIC level under the New Mexico Oil Conservation Division rather than at the federal EPA level [source: https://www.law.cornell.edu/regulations/new-mexico/N-M-Admin-Code-SS-19.2.100.61].

32-7 No301 Salt Water Disposal (New Mexico, facility ID 110022768860) is the sole site associated with the entity. ECHO reports an EJ index average of 0.0, which in the exporter schema indicates either that demographic screening data was not appended to the facility record or that the site sits in a census block group where the EJScreen national percentile was not computed. That zero should not be read as an affirmative finding of zero exposure. The facility's last permit date of August 10, 2009, combined with zero active permits and zero 24-month violations, describes an operationally quiet federal compliance profile [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Peer comparisons sharpen the picture. Greka Bell Compressor Plant (NAICS 211120, single facility) carries a $26.16M prorated 24-month penalty exposure with zero logged violations — a pattern similar to 32-7 No301 in that the penalty is carried forward from an earlier case rather than from recent enforcement activity [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Red Hills Gas Processing Plant (NAICS 211130, two facilities) shows eight quarters of non-compliance and $19.13M in 24-month penalty exposure. That is the highest active-violation count in the peer set and a materially different risk profile from 32-7 No301 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

HP Gas Pad (NAICS 211120, single facility) reports eight quarters of non-compliance and $16.13M in 24-month penalty exposure, also indicating continuing compliance issues rather than carry-forward-only exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Bluewater, New Mexico Disposal Site appears in regional coverage as a DOE-managed UMTRCA Title II location and is not operated by 32-7 No301, but it is geographically relevant to New Mexico groundwater-enforcement posture and to how state regulators are framing injection-site liability more broadly [source: https://www.energy.gov/lm/bluewater-new-mexico-disposal-site].

ECHO's top_pollutants array for facility 110022768860 is empty, consistent with a UIC-class SWD operation that does not report to TRI or NPDES DMR systems [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That blank field does not mean the produced water is clean. Three pollutant classes are relevant to exposure analysis for this facility type.

First, high-salinity brine — total dissolved solids often exceeding 100,000 mg/L — carries chloride, sodium, calcium, and magnesium loads that degrade freshwater aquifers on release. Insurance Journal documented on April 24, 2026 that Texas is specifically responding to toxic wastewater leaks from legacy wells as the triggering concern behind its new rulemaking [source: https://www.insurancejournal.com/news/southcentral/2026/04/24/867247.htm].

Second, dissolved hydrocarbons — benzene, toluene, ethylbenzene, and xylene, collectively known as BTEX — are commonly present in produced water at concentrations that exceed federal drinking-water standards. E&E News reporting notes that regulators in New Mexico and Texas are requiring additional treatment assurances before approving any surface discharge of cleaned produced water into rivers or agricultural fields [source: https://www.eenews.net/articles/why-2-oil-states-are-slow-to-embrace-wastewater-recycling/].

Third, naturally occurring radioactive material (NORM) and heavy metals including arsenic, barium, and strontium concentrate in produced-water streams and do not disappear through simple evaporation. Utah State University research published in April 2026 documents that metal-laden dust from drying saline lakebeds is absorbed by plants, soils, and human bodies, illustrating precisely the exposure pathway that emerges when brine-affected soils desiccate [source: https://www.usu.edu/today/story/new-research-toxins-from-great-salt-lake-dust-absorbed-by-plants-soils-human-bodies]. EJ implications for a Navajo City, New Mexico location include proximity to tribal lands and to aquifers used for domestic and agricultural supply. The ECHO EJ index of 0.0 in the exporter record does not substitute for a direct EJScreen query on the facility coordinates, and analysts should conduct that query independently.

Within the NAICS 211120/211130 peer set surfaced in the ECHO exporter, 32-7 No301's $3.76M 24-month penalty exposure sits roughly an order of magnitude below Greka Bell ($26.16M), Red Hills ($19.13M), and HP Gas Pad ($16.13M). Its zero-violation count matches Greka Bell while diverging sharply from Red Hills and HP Gas Pad, each of which show eight quarters of non-compliance [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The peer-set EJ index of 0.0 across all four entities reflects exporter-file limitations rather than a uniform demographic finding and should be re-queried via EPA's EJScreen tool for operational use.

No SEC 10-K Item 1A disclosure is available for 32-7 No301 Salt Water Disposal because the entity is privately held with no CIK on file. Forward-looking environmental risk for this facility class is therefore characterized using external regulatory signals rather than issuer disclosures. New Mexico and Texas regulators are actively tightening produced-water handling rules. New Mexico is specifically demanding remediation and fines for groundwater violations in concurrent matters [source: https://hcn.org/articles/new-mexico-demands-fix-for-federal-nuclear-waste-management], while Texas is responding to a 50% increase in leaking zombie wells with new rulemaking [source: https://www.insurancejournal.com/news/southcentral/2026/04/24/867247.htm]. Operators dependent on UIC Class II injection capacity face rising permit-renewal scrutiny under state primacy regimes governed by N.M. Admin. Code § 19.2.100.61 [source: https://www.law.cornell.edu/regulations/new-mexico/N-M-Admin-Code-SS-19.2.100.61]. A zero-violation count today does not lock in that status as regulators revise monitoring and reporting thresholds for produced-water injection across the region.