HILCORP - HUERFANITO UNIT 85M

Hilcorp Energy Company's Huerfanito Unit 85M, a natural gas extraction site (NAICS 211130) in Huerfano, New Mexico, appears in EPA ECHO as a single-facility record with zero discrete quarterly non-compliance flags over the trailing 24 months but an allocated penalty share of $3.76 million derived from the company's five-year enforcement total [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That allocation traces directly to Hilcorp's October 17, 2024 Clean Air Act settlement with EPA and the Department of Justice. The settlement covered well-completion operations across the company's New Mexico oil and gas footprint, and Hilcorp agreed to a $9.4 million civil penalty — the first federal case against an oil and gas producer for CAA and New Mexico Air Quality Control Act violations tied to well completions [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

A second federal action followed five weeks later. On November 21, 2024, EPA, DOJ, and the Pennsylvania Department of Environmental Protection lodged a $1.275 million CAA settlement addressing emissions compliance across Hilcorp's western Pennsylvania production operations, with additional injunctive costs projected by EPA [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Hilcorp is privately held. There is no CIK, 10-K, or 10-Q on file with the SEC, which removes a standard disclosure channel available to public-company peers. Recent operational news includes a May 4, 2026 Anchorage Daily News report that Hilcorp will exit its Yukon Flats drilling program after completing one of two planned wells on Indigenous-owned land [source: https://www.adn.com/business-economy/energy/2026/05/04/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/] and a tank incident at a Hilcorp site in Columbiana County, Ohio [source: https://www.wkbn.com/news/local-news/fairfield-twp-news/crews-respond-to-incident-at-hilcorp/].

The compliance record for Huerfanito Unit 85M specifically shows no active EPA permits and no quarterly non-compliance entries in the trailing eight quarters, per the ECHO exporter snapshot dated May 4, 2026 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3.76 million penalty figure attributed to this facility is a pro-rata derivation — total_5yr multiplied by 24/60 — from the corporate-level enforcement total. Read it as an allocation artifact, not a site-specific assessment; the underlying dollars trace to two federal settlements that name Hilcorp Energy Company as the corporate defendant [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The 24-month chronology opens in mid-2024, when DOJ and EPA began negotiating over emissions from well-completion operations in New Mexico. On October 17, 2024, EPA announced a consent decree under which Hilcorp would pay $9.4 million and implement compliance projects addressing volatile organic compound and methane releases during the flowback phase of gas wells across the San Juan Basin [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. The complaint filed in the District of New Mexico set out allegations tied to CAA New Source Performance Standards and the New Mexico AQCA [source: https://www.justice.gov/enrd/media/1373861/dl?inline=]. Roughly one month later, on November 21, 2024, the United States and Pennsylvania filed Case No. 2:24-cv-01596 in the Western District of Pennsylvania, concurrent with a consent decree under which Hilcorp agreed to the $1.275 million penalty and additional mitigation investments [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf] [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

The more recent 12 months show continued operational and policy friction rather than new federal penalties. On April 13, 2026, the Alaska House rejected a measure that would have extended the state corporate income tax to Hilcorp and other privately held oil producers, preserving the tax treatment that distinguishes Hilcorp from publicly traded peers operating on the North Slope [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/]. NGO attention intensified in August 2025, when Big Gas Polluters named Hilcorp its "Polluter of the Month," citing the company's trade-association activity on federal methane fee rules [source: https://biggaspolluters.org/polluter-of-the-month-hilcorp/]. Two physical incidents in Ohio were reported in late April 2026 at Hilcorp facilities in Fairfield Township and Columbiana County, including a tank event that drew multi-department fire response [source: https://www.wkbn.com/news/local-news/fairfield-twp-news/crews-respond-to-incident-at-hilcorp/] [source: https://dailydispatch.com/fire-news/ohio/crews-respond-to-tank-incident-at-hilcorp-in-columbiana-county/]. On May 4, 2026, Hilcorp announced it would abandon its Yukon Flats program after one well, in a region where area tribes had opposed the drilling [source: https://www.adn.com/business-economy/energy/2026/05/04/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/].

Action 1 — New Mexico CAA stationary source settlement, announced October 17, 2024. Program: Clean Air Act §§111, 113; New Mexico Air Quality Control Act. Defendant: Hilcorp Energy Company. Forum: U.S. District Court for the District of New Mexico, lodged by DOJ Environment and Natural Resources Division. Civil penalty: $9.4 million. EPA described the matter as the first federal case against an oil and gas producer specifically for CAA and AQCA violations arising from well-completion (flowback) operations. Injunctive relief requires enhanced capture and combustion controls and emissions offsets across the San Juan Basin footprint [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement] [source: https://www.justice.gov/enrd/media/1373861/dl?inline=].

Action 2 — Pennsylvania CAA settlement, announced November 21, 2024. Program: Clean Air Act and Pennsylvania air regulations. Defendant: Hilcorp Energy Company. Forum: U.S. District Court for the Western District of Pennsylvania, Civil Action No. 2:24-cv-01596, co-filed by DOJ and the Pennsylvania Department of Environmental Protection. Civil penalty: $1.275 million. The settlement requires Hilcorp to implement compliance projects and offset past unlawful emissions, with project costs separate from the civil penalty figure [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary] [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf].

Action 3 — Remedial activity at San Juan 28-7 Unit 183M, Rio Arriba County, New Mexico, logged with the New Mexico Oil Conservation Division under OCD Incident No. NCS1901627746. Timberwolf Environmental filed quarterly status reports on behalf of Hilcorp documenting remediation at a site on BLM-managed federal land in western Rio Arriba County. The record begins in 2021 and continued into 2022 filings. This is a state OCD oversight matter, not a federal EPA penalty action [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf]. No quarterly non-compliance entries are recorded against Huerfanito Unit 85M specifically during the 24-month window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Huerfanito Unit 85M, Huerfano, New Mexico (ECHO facility ID 110046351363). The ECHO record shows zero quarterly non-compliance quarters over the trailing 24 months, zero active permits on file, and an EJ index of 0.0 in the exporter snapshot. That zero reflects either missing demographic overlay data or a location lacking a tracked co-located population — it is not an affirmative finding of zero exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

San Juan 28-7 Unit 183M, Rio Arriba County, New Mexico. Sited on BLM-administered federal land in western Rio Arriba County, this Hilcorp well was the subject of active remedial work documented to the New Mexico OCD under Incident No. NCS1901627746, with quarterly status reports prepared by Timberwolf Environmental [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf].

Hilcorp western Pennsylvania production operations. These assets are the subject matter of the November 2024 CAA consent decree. The complaint in Case No. 2:24-cv-01596 alleges emissions control deficiencies across multiple production sites rather than a single facility [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf].

Hilcorp Fairfield Township / Columbiana County, Ohio. Fire crews responded to an incident at the Fairfield School Road location in late April 2026. A separate tank incident in Columbiana County drew multi-agency response during the same window [source: https://www.wkbn.com/news/local-news/fairfield-twp-news/crews-respond-to-incident-at-hilcorp/] [source: https://dailydispatch.com/fire-news/ohio/crews-respond-to-tank-incident-at-hilcorp-in-columbiana-county/].

Yukon Flats exploration wells, Alaska. Drilled on Indigenous-owned land, the program faced organized opposition from area tribes. Hilcorp announced on May 4, 2026 that it would terminate the program after completing one of two planned wells [source: https://www.adn.com/business-economy/energy/2026/05/04/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/].

Volatile organic compounds (VOCs). VOCs are the named emissions class in the New Mexico well-completion settlement, released during flowback when liquids and gas are brought to surface after drilling. EPA's CAA New Source Performance Standards for Subpart OOOO/OOOOa specifically target completion-phase VOC releases, and the October 2024 consent decree requires Hilcorp to implement capture and combustion controls across the San Juan Basin [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Exposure pathways for nearby communities include ground-level ozone formation and direct inhalation of co-emitted hazardous air pollutants such as benzene and toluene.

Methane. Methane co-emits with VOCs during well completions and from leaking production equipment throughout a well's operating life. Hilcorp's industry association has been identified in NGO reporting as active on federal methane fee policy, which bears directly on the economic exposure from uncontrolled venting and fugitive emissions [source: https://biggaspolluters.org/polluter-of-the-month-hilcorp/]. The New Mexico AQCA claims in the October 2024 complaint paralleled the federal CAA allegations tied to the same source category [source: https://www.justice.gov/enrd/media/1373861/dl?inline=].

Produced water and hydrocarbon-impacted soils. The San Juan 28-7 Unit 183M remediation file concerns surface releases requiring soil excavation and groundwater monitoring under OCD oversight — a pathway relevant across the San Juan Basin where Huerfanito Unit 85M also sits [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf]. Environmental justice exposure in the basin is shaped by proximity to Navajo Nation chapters and Jicarilla Apache lands, though the ECHO exporter's EJ index field returned 0.0 for Huerfanito Unit 85M and should be treated as a data gap rather than a substantive finding [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Within the NAICS 211120/211130 peer set ranked by penalty_total_24mo, Huerfanito Unit 85M's allocated $3.76 million sits well below Greka Bell Compressor Plant ($26.16 million), Red Hills Gas Processing Plant ($19.13 million), and HP Gas Pad ($16.13 million). The Hilcorp site's zero flagged non-compliance quarters also contrasts with the eight-quarter counts at both Red Hills and HP Gas Pad [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Peer EJ indices return 0.0 across the board, consistent with a known data-completeness issue in the snapshot rather than a substantive absence of exposure at either the Hilcorp site or its peers [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

No SEC 10-K Item 1A disclosure is available because Hilcorp Energy Company is privately held and has no CIK on file with the Commission; the SEC filings bundle returned empty. Forward-looking environmental risk must therefore be read from regulatory and policy surfaces instead. Four surfaces stand out. First, the terms of the October 2024 New Mexico consent decree obligate ongoing well-completion emissions controls and reporting across the San Juan Basin [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Second, the Pennsylvania consent decree carries its own compliance-project schedule with costs separate from the $1.275 million civil penalty [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Third, the Alaska corporate income tax question remains unresolved following the April 13, 2026 House vote, and the legislature could revisit the measure in a future session [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/]. Fourth, tribal-consent risk on exploratory programs is now illustrated by a concrete data point: the May 4, 2026 Yukon Flats withdrawal after one completed well [source: https://www.adn.com/business-economy/energy/2026/05/04/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/].