HILCORP ENERGY COMPANY - WIND RIVER BASIN (530) GATHERING & BOOSTING

Hilcorp Energy Company operates the Wind River Basin (530) Gathering & Boosting facility (EPA Facility ID 110070082463) within a broader upstream and midstream footprint that makes it the largest privately held oil and gas producer in the United States [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf]. EPA ECHO data as of May 4, 2026 attributes zero formal quarterly noncompliance findings to the Wind River Basin site over the trailing 24 months. The derived 24-month penalty allocation stands at $3.76 million — a pro-rata share of the parent entity's five-year federal penalty exposure, not a facility-specific fine [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That figure traces directly to headline settlements elsewhere in the Hilcorp portfolio, most materially the October 17, 2024 Clean Air Act consent decree covering New Mexico operations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Two federal settlements define the compliance picture for the parent entity. On October 17, 2024, EPA and DOJ announced a $9.4 million civil penalty against Hilcorp for Clean Air Act and New Mexico Air Quality Control Act violations tied to well completion operations, filed as Civil Action 1:24-cv-01055 in the U.S. District Court for the District of New Mexico [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. Thirty-five days later, on November 21, 2024, a second settlement resolved Pennsylvania CAA violations for a $1.275 million civil penalty plus injunctive relief [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Against that enforcement backdrop, Hilcorp's 2025 San Juan community report claims an 81% reduction in methane emissions from 2023 to 2024 in that basin [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf]. The company is privately held. No 10-K or 10-Q disclosures exist to corroborate forward-looking risk statements.

The Wind River Basin (530) Gathering & Boosting facility reports emissions under EPA's Greenhouse Gas Reporting Program, Subpart W — Onshore Oil & Gas Gathering & Boosting — carrying GHGRP facility ID 1013991 [source: https://ghgdata.epa.gov/ghgp/service/facilityDetail/2022?id=1013991&ds=E&et=&popup=true]. One methodological note matters for any time-series reading: EPA flags that GHG data for facilities in this segment are not directly comparable between the 2011–2015 and 2016-onwards reporting years, owing to segment-level definitional changes [source: https://ghgdata.epa.gov/ghgp/service/facilityDetail/2022?id=1013991&ds=E&et=&popup=true]. ECHO records zero quarters of noncompliance across the trailing eight quarters at this specific facility and lists no active CWA, CAA, or RCRA permits against the facility registry ID [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The parent entity's chronological record is denser. EPA and DOJ built the New Mexico case as the first federal CAA enforcement action against an oil and gas producer specifically tied to well completion operations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. On October 17, 2024, the $9.4 million penalty was lodged alongside injunctive requirements — third-party verification, mitigation projects, and compliance monitoring — laid out across Sections IV through VIII of the consent decree [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. The Pennsylvania settlement followed on November 21, 2024, adding a $1.275 million penalty and court-ordered emissions-offset projects [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. In May 2025, Hilcorp published its San Juan community report documenting the methane reduction claim [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf].

Operational events outside the Wind River footprint continued through 2025 and into 2026. On August 27, 2025, Harvest Midstream — owned by Hilcorp founder Jeff Hildebrand — agreed to acquire $1 billion of gas gathering and processing assets from MPLX, enlarging the affiliated midstream footprint in which Wind River sits as a comparable segment [source: https://reuters.com/business/energy/jeff-hildebrands-harvest-midstream-buy-some-mplx-pipeline-assets-1-billion-2025-08-27]. In late April 2026, firefighters responded to a tank incident at Hilcorp's Fairfield-Unkefer site in Fairfield Township, Ohio at 11:18 a.m., as reported by the Ohio Department of Natural Resources [source: https://www.wytv.com/news/local-news/crews-respond-to-incident-at-hilcorp/] [source: https://morningjournalnews.com/news/local-news/2026/04/crews-respond-to-incident-at-hilcorp-2]. On May 4, 2026, Hilcorp announced it would withdraw from the Yukon Flats exploration program in Alaska after drilling one of two planned wells on Indigenous-owned land, a program that had drawn opposition from area tribes [source: https://www.adn.com/business-economy/energy/2026/05/04/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/]. The Alaska legislature in April 2026 rejected a Senate-led measure to apply corporate income tax to Hilcorp and other private oil companies, leaving the question open for future sessions [source: https://alaskapublic.org/news/politics/alaska-legislature/2026-04-14/alaska-house-rejects-senate-effort-to-impose-corporate-taxes-on-hilcorp].

Action 1 — New Mexico CAA/AQCA Consent Decree. Announced October 17, 2024. Program: Clean Air Act Sections 111 and 113, New Mexico Air Quality Control Act. Filed as United States and New Mexico Environment Department v. Hilcorp Energy Company, Civil Action 1:24-cv-01055, U.S. District Court for the District of New Mexico [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. Civil penalty: $9,400,000. The violations centered on well completion operations at oil and gas production sites — the phase at which hydrocarbons are brought to surface after drilling. EPA identifies this action as the first federal CAA/AQCA case against a producer for well completion-related noncompliance [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Injunctive relief includes compliance measures under Section V, third-party verification under Section VI, and mitigation projects under Section VIII [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. A companion EPA press release was issued the same day, October 17, 2024 [source: https://epa.gov/newsreleases/natural-gas-producer-agrees-settlement-reduce-emissions-new-mexico].

Action 2 — Pennsylvania CAA Settlement. Announced November 21, 2024. Program: Clean Air Act plus Pennsylvania state air regulations, negotiated jointly with EPA, DOJ, and the Pennsylvania Department of Environmental Protection. Civil penalty: $1,275,000 [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. The settlement addressed oil and gas production operations in western Pennsylvania, resolving violations of federal and state clean air regulations. It additionally requires compliance projects and offsets for past emissions, with projected project costs disclosed by EPA in its settlement summary [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Facility-level (Wind River Basin 530). ECHO records zero quarters of noncompliance across CWA, CAA, and RCRA over the trailing 24 months at EPA Facility ID 110070082463 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3.76 million 24-month figure in the ECHO extract is a derivation — total five-year penalty exposure prorated across 24 of 60 months — rather than a facility-specific fine, as documented in the derivation note of the ECHO exporter [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Operational incident — Ohio. A tank incident occurred at the Fairfield-Unkefer site in Fairfield Township, Ohio at 11:18 a.m. in late April 2026, with local fire crews and the Ohio Department of Natural Resources responding [source: https://www.wytv.com/news/local-news/crews-respond-to-incident-at-hilcorp/]. No federal enforcement filing had been published as of the May 4, 2026 ECHO data cut.

Wind River Basin (530) Gathering & Boosting (Wyoming) — EPA Facility ID 110070082463, GHGRP ID 1013991. Classified under Onshore Oil & Gas Gathering & Boosting (Subpart W). ECHO shows zero 24-month violations and no active permits in the extract [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. EPA cautions that pre-2016 and post-2016 GHG data are not directly comparable due to segment-definition changes [source: https://ghgdata.epa.gov/ghgp/service/facilityDetail/2022?id=1013991&ds=E&et=&popup=true].

New Mexico oil and gas production footprint (San Juan Basin and associated production). Subject of the October 17, 2024 CAA/AQCA consent decree. The facility set — characterized in EPA materials as the company's New Mexico oil and gas production operations — is the source of the $9.4 million civil penalty and the associated injunctive regime [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement] [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. The scale of the underlying operation is substantial: Hilcorp reports 119,000-plus BOEPD net daily production, more than 11,600 producing wells, and over 2,047,000 gross acres under production in its San Juan operations [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf].

Western Pennsylvania oil and gas production. Subject of the November 21, 2024 settlement with EPA, DOJ, and Pennsylvania DEP; $1.275 million civil penalty plus compliance projects [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Fairfield-Unkefer site, Fairfield Township, Ohio. A tank incident on a Monday at 11:18 a.m. in late April 2026 drew local fire crews and Ohio Department of Natural Resources response [source: https://morningjournalnews.com/news/local-news/2026/04/crews-respond-to-incident-at-hilcorp-2].

Yukon Flats exploration program, Alaska. Hilcorp drilled one of two planned exploration wells on Indigenous-owned land before announcing on May 4, 2026 that it would exit the program; area tribes had registered opposition throughout the drilling program [source: https://www.adn.com/business-economy/energy/2026/05/04/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/].

Methane and associated volatile organic compounds (VOCs) sit at the center of the New Mexico enforcement action. The consent decree targets emissions from well completion operations — the phase at which oil and gas are brought to surface after drilling — a known source of fugitive methane and VOC releases [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Methane is a short-lived climate forcer with a 20-year global warming potential materially higher than CO2. VOCs contribute to ground-level ozone formation, a regulated criteria pollutant under the CAA [source: https://epa.gov/newsreleases/natural-gas-producer-agrees-settlement-reduce-emissions-new-mexico]. Hilcorp's own San Juan disclosure states an 81% reduction in methane emissions from 2023 to 2024 in that basin [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf].

Hazardous air pollutants (HAPs) and NOx from engine and compressor sources define the Pennsylvania picture. The November 21, 2024 settlement addresses CAA stationary-source violations at production operations — a category that typically encompasses HAP and NOx emissions from compressor engines, dehydrators, and storage tanks [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Exposure pathways include inhalation in communities adjacent to production pads and compressor stations.

The April 2026 Fairfield Township, Ohio incident adds a third pollutant category. The Ohio Department of Natural Resources described it as a tank incident — at oil and gas sites, that category typically involves crude, condensate, or produced water [source: https://www.wytv.com/news/local-news/crews-respond-to-incident-at-hilcorp/]. ECHO does not list top pollutants for the Wind River Basin facility in the current extract [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip], and EJ index data is not populated for the facility in the available dataset, limiting quantitative community-exposure characterization.

Within the NAICS 211120 peer set in the ECHO extract, Hilcorp's Wind River Basin (530) facility reports zero 24-month violations and a derived $3.76 million 24-month penalty allocation — below the three highest-penalty peers in the same NAICS code. Those peers are Greka Bell Compressor Plant at $26.16 million derived with zero violations, Red Hills Gas Processing Plant at $19.13 million derived with eight violations, and HP Gas Pad at $16.13 million derived with eight violations [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. All peer penalty figures are pro-rated from five-year totals under the same ECHO derivation methodology and therefore reflect parent-entity enforcement exposure rather than facility-level fines [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Hilcorp Energy Company is privately held; no SEC 10-K Item 1A risk factors or Item 7 MD&A disclosures are available for citation. The most concrete forward-looking regulatory exposure visible in the public record runs through the multi-year term of the October 17, 2024 New Mexico consent decree (Civil Action 1:24-cv-01055), which carries ongoing compliance, reporting, third-party verification, and mitigation obligations [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. The injunctive projects under the November 21, 2024 Pennsylvania settlement add a parallel compliance track [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. State-level fiscal exposure in Alaska remains open: the Alaska House on April 13, 2026 rejected a Senate measure to apply corporate income tax to Hilcorp and other private oil companies, leaving the tax-structure question available for subsequent legislative sessions [source: https://www.adn.com/politics/alaska-legislature/2026/04/13/alaska-house-rejects-measure-to-apply-corporate-income-tax-to-hilcorp-and-other-private-oil-companies/].