HILCORP - HUERFANITO UNIT 98N

Hilcorp Energy Company operates the Huerfanito Unit 98N within the San Juan Basin of northwestern New Mexico under NAICS 211130 (Natural Gas Extraction). EPA ECHO aggregates tied to the two associated facility registry IDs (110046351372, 110046351461) show zero formal quarters with non-compliance flags over the trailing 24 months, alongside a derived five-year penalty allocation of $7.52 million apportioned to that same window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That figure traces directly to two federal actions that closed within six weeks of each other in late 2024. The first, announced October 17, 2024, was a Clean Air Act settlement with EPA and the Department of Justice covering New Mexico stationary-source operations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. The second, filed November 21, 2024, was a Pennsylvania Clean Air Act consent decree carrying a $1.275 million civil penalty [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Hilcorp is privately held. No 10-K or 10-Q disclosures exist for independent reconciliation against EPA enforcement records — a structural gap that limits the depth of any financial cross-check. Hilcorp's corporate responsibility and environmental stewardship pages frame its legacy-asset thesis around extending production from previously developed fields to limit greenfield expansion [source: https://www.hilcorp.com/corporate-responsibility/] [source: https://www.hilcorp.com/corporate-responsibility/environmental-stewardship/]. That framing sits alongside a concrete capital commitment: San Juan Basin Royalty Trust disclosures dated February 20, 2026 describe a $14 million, 32-project capital plan for 2026, covering drilling and workovers in the basin where Huerfanito Unit 98N sits [source: https://www.prnewswire.com/news-releases/san-juan-basin-royalty-trust-announces-hilcorps-2026-capital-plan-302693218.html] [source: https://www.stocktitan.net/news/SJT/san-juan-basin-royalty-trust-announces-hilcorp-s-2026-capital-9bkvvdhfu3si.html]. This briefing reconciles those disclosures with federal enforcement records and the current litigation surface.

The compliance record attached to Hilcorp's New Mexico upstream footprint is dominated by a single federal-state Clean Air Act resolution that closed in late 2024, with residual remediation activity at San Juan Basin wellsites tracked by the New Mexico Oil Conservation Division (OCD). EPA's facility-level aggregation returns zero formal quarters with non-compliance across the two Huerfanito Unit 98N registry IDs (110046351372, 110046351461). The $7.52 million 24-month penalty figure in the ECHO export is a pro-rata allocation from the broader five-year enforcement envelope attributable to Hilcorp Energy Company operations in New Mexico [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The past 24 months break into three distinct phases. Phase one: on October 17, 2024, EPA and DOJ announced a settlement resolving Clean Air Act and New Mexico Air Quality Control Act violations at Hilcorp's oil and gas production operations across the state, requiring emissions controls and mitigation of past releases [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Phase two came five weeks later. On November 21, 2024, the United States and the Commonwealth of Pennsylvania filed Case 2:24-cv-01596 in the Western District of Pennsylvania; Hilcorp agreed to a $1.275 million civil penalty plus compliance projects tied to Clean Air Act violations at western Pennsylvania oil and gas sites [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]. Phase three runs through 2025 and into early 2026, when operational disclosures shifted to capital planning: Hilcorp's 2025 program spent $8.3 million on drilling and workovers in the San Juan Basin, followed by the $14 million, 32-project program announced for 2026 [source: https://www.stocktitan.net/news/SJT/san-juan-basin-royalty-trust-announces-hilcorp-s-2026-capital-9bkvvdhfu3si.html].

State-level remediation records add a fourth thread. New Mexico OCD documents a Timberwolf Environmental status report dated May 5, 2021 covering OCD Incident No. NCS1901627746 at the San Juan 28-7 Unit 183M in Rio Arriba County — a site on federal BLM-managed land adjacent to the Huerfanito unit footprint, with quarterly remedial reporting continuing under OCD District 3 oversight [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf]. Two additional operational items sit outside New Mexico but are relevant at the parent-company level. In April 2026, the Alaska House rejected a Senate-backed measure to apply corporate income tax to Hilcorp and other private oil companies [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/] [source: https://alaskapublic.org/news/politics/alaska-legislature/2026-04-14/alaska-house-rejects-senate-effort-to-impose-corporate-taxes-on-hilcorp]. Separately, a tank incident at Hilcorp's Fairfield Township facility in Columbiana County, Ohio drew fire crew response in late April 2026 [source: https://dailydispatch.com/fire-news/ohio/crews-respond-to-tank-incident-at-hilcorp-in-columbiana-county/] [source: https://www.wkbn.com/news/local-news/fairfield-twp-news/crews-respond-to-incident-at-hilcorp/].

Action 1 — New Mexico Clean Air Act Stationary Source Settlement (announced October 17, 2024). EPA and DOJ resolved alleged Clean Air Act and New Mexico Air Quality Control Act violations at Hilcorp's oil and gas production operations across the state. The settlement requires compliance controls at stationary sources, mitigation of past emissions, and payment of a civil penalty; EPA's case summary page is the authoritative public record [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Program: CAA. Outcome: consent decree with injunctive relief plus penalty. This action is the principal driver of the $7.52 million 24-month penalty allocation reflected in ECHO for the Huerfanito Unit 98N registry IDs [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Action 2 — Pennsylvania Clean Air Act Settlement, Case 2:24-cv-01596, W.D. Pa. (filed November 21, 2024). The United States, at the request of the EPA Administrator, together with the Pennsylvania Department of Environmental Protection, sued Hilcorp Energy Company for CAA violations at western Pennsylvania production operations [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf]. Hilcorp agreed to pay a $1.275 million civil penalty and to implement compliance projects expected to cost additional amounts to offset past emissions [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Program: CAA. Outcome: consent decree plus $1.275 million monetary penalty. This matter does not attach to the Huerfanito Unit 98N registry IDs but is material to the enterprise-level compliance profile.

Action 3 — State-level remediation, San Juan 28-7 Unit 183M, Rio Arriba County, NM (OCD Incident No. NCS1901627746). Timberwolf Environmental submits quarterly status reports on behalf of Hilcorp to New Mexico OCD District 3 in Aztec, documenting ongoing remedial activities on BLM-administered land [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf]. Program: state release/remediation (not federal RCRA or CWA). Outcome: corrective action ongoing; no federal penalty attached in the current ECHO export.

Action 4 — Operational incident, Columbiana County, Ohio (late April 2026). Local news coverage reports a tank incident at Hilcorp's Fairfield Township site that drew fire crew 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/]. No federal enforcement filing has posted to EPA as of this briefing date.

Huerfanito Unit 98N (FRS 110046351372 and 110046351461), Huerfano/San Juan County, New Mexico. ECHO records zero quarters with non-compliance across both registry IDs over the trailing 24 months, no active permits listed in the current export, and an EJ index average of 0.0 — a field value that indicates missing or suppressed EJSCREEN aggregation rather than a favorable demographic reading [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $7.52 million 24-month penalty allocation is a pro-rata share of enterprise-level CAA settlement value attributed to the New Mexico operations footprint [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

San Juan 28-7 Unit 183M, Rio Arriba County, NM. This adjacent San Juan Basin site sits on federal BLM-administered land and is tracked under New Mexico OCD Incident No. NCS1901627746, with Timberwolf Environmental submitting quarterly remedial status reports to OCD District 3 in Aztec, NM [source: https://ocdimage.emnrd.nm.gov/Imaging/FileStore/santafe/NF/20220706/nCS1901627746_07_06_2022_02_50_33.pdf]. It is not one of the two Huerfanito registry IDs but provides relevant context for the basin-level compliance picture.

FRS Facility 110046478398, San Juan Basin. EPA's Facility Registry Service detail page confirms this as a separate registered facility within Hilcorp's basin footprint, useful for cross-referencing program participation [source: https://frs-public.epa.gov/ords/frs_public2/fii_query_detail.disp_program_facility?p_registry_id=110046478398].

Hilcorp western Pennsylvania operations (multiple sites). The November 2024 federal complaint identifies oil and gas production operations in western Pennsylvania as the locus of CAA violations resolved through Case 2:24-cv-01596; these sites are outside the Huerfanito unit but material at the parent-company level [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf].

Hilcorp Fairfield Township / Columbiana County, Ohio. A tank incident in late April 2026 prompted fire-service response at this site; no federal enforcement action has posted as of the briefing date [source: https://dailydispatch.com/fire-news/ohio/crews-respond-to-tank-incident-at-hilcorp-in-columbiana-county/].

The ECHO top-pollutants field for the Huerfanito Unit 98N registry IDs is empty in the current export, so the pollutant profile below is reconstructed from the underlying CAA settlement documentation rather than from facility-level emissions inventory rows [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Pollutant 1 — Volatile organic compounds (VOCs). The New Mexico CAA settlement addresses stationary-source emissions from oil and gas production equipment, a category EPA regulates under New Source Performance Standards Subparts OOOO and OOOOa for VOC control [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. VOCs are ozone precursors. Chronic exposure pathways for nearby communities run through inhalation and secondary ozone formation — a documented concern across the Four Corners region, where basin-wide production density amplifies cumulative loading.

Pollutant 2 — Methane. Hilcorp's trade association activity around federal methane emission penalties was the subject of NGO coverage published in August 2025 [source: https://biggaspolluters.org/polluter-of-the-month-hilcorp/]. Methane is a potent short-lived climate forcer. It also serves as a co-emitted marker for fugitive VOC releases from upstream equipment leaks, making its measurement relevant to both climate accounting and local air-quality assessment.

Pollutant 3 — Hazardous air pollutants (HAPs) co-emitted with natural gas production, including benzene. The Pennsylvania complaint alleges CAA violations at production operations subject to HAP control requirements [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf]. Benzene is classified as a known human carcinogen under EPA's Integrated Risk Information System. Exposure pathways for residential receptors near wellpads include ambient inhalation and, in limited cases, groundwater ingestion where well-casing integrity is compromised. EJ implications for the San Juan Basin specifically include proximity of production infrastructure to Navajo Nation chapters and Rio Arriba County communities. The current ECHO EJSCREEN aggregation for the Huerfanito registry IDs returns 0.0 and should be treated as a data gap rather than a confirmed low-exposure reading [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Within the NAICS 211120/211130 peer set ordered by 24-month penalty total, Huerfanito Unit 98N ($7.52 million allocated, 0 non-compliance quarters) ranks below Greka Bell Compressor Plant ($26.16 million, 0 non-compliance quarters), Red Hills Gas Processing Plant ($19.13 million, 8 non-compliance quarters), and Azalea Battery ($16.13 million, 8 non-compliance quarters) [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The Huerfanito facilities resemble Greka Bell in one specific pattern: elevated penalty allocation without formal non-compliance-quarter flags. That combination typically indicates penalties driven by consent-decree resolution of enterprise-level CAA matters rather than by recurring facility-level quarterly violations. Red Hills and Azalea Battery present a different profile entirely — both show high penalty totals and eight non-compliance quarters, which is the statutory maximum in the 24-month window, consistent with chronic facility-level compliance issues rather than a single resolved settlement. EJ index averages report as 0.0 across all four peer entries, reflecting a data-availability gap in the current ECHO export rather than a confirmed demographic reading.

Hilcorp Energy Company is privately held and files no 10-K; accordingly, no Item 1A forward-looking environmental risk language is available for direct citation. The closest proxy in the current research bundle is the San Juan Basin Royalty Trust's February 20, 2026 announcement of Hilcorp's 2026 capital plan — $14 million across 32 drilling and workover projects in the San Juan Basin, following $8.3 million deployed in 2025 — which signals continued capital deployment into the production footprint that includes the Huerfanito Unit 98N and remains subject to the October 17, 2024 New Mexico CAA consent decree [source: https://www.prnewswire.com/news-releases/san-juan-basin-royalty-trust-announces-hilcorps-2026-capital-plan-302693218.html] [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. That consent decree's injunctive requirements run concurrently with an expanding drilling program — a combination that warrants monitoring as new wellpads come online. Separately, Alaska legislative activity in April 2026 on corporate income tax applicability to Hilcorp represents a forward tax-and-regulatory variable at the parent level [source: https://alaskapublic.org/news/politics/alaska-legislature/2026-04-14/alaska-house-rejects-senate-effort-to-impose-corporate-taxes-on-hilcorp].