HILCORP - HUERFANITO UNIT 99E

Hilcorp Energy Company operates the Huerfanito Unit 99E, a crude petroleum extraction site in the San Juan Basin near Bloomfield, New Mexico, carrying EPA Facility Registry ID 110007143260. EPA ECHO data attributes a 24-month penalty allocation of $3.76 million to the facility, derived from the company's five-year enforcement total, with zero quarters of reported noncompliance logged against the unit itself and no active permits on file since the last permit action dated May 12, 1999 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That allocation traces directly to Hilcorp's October 17, 2024 settlement with EPA and the U.S. Department of Justice. The settlement resolved Clean Air Act and New Mexico Air Quality Control Act violations tied to well completion operations across the operator's New Mexico footprint. Under its terms, Hilcorp agreed to pay a $9.4 million civil penalty plus injunctive relief [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

One month later, on November 21, 2024, Hilcorp entered a separate $1.275 million civil penalty settlement with EPA, DOJ, and the Pennsylvania Department of Environmental Protection. That action covered Clean Air Act and state air violations at western Pennsylvania oil and gas production operations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Two consent decrees. Thirty-five days apart. Combined civil penalties of $10.675 million. Hilcorp is privately held and does not file 10-K or 10-Q reports with the SEC; public disclosures are limited to its Corporate Responsibility webpage and operator filings channeled through the San Juan Basin Royalty Trust (NYSE: SJT). That trust's February 20, 2026 8-K disclosed a $14.0 million 2026 capital plan covering 32 drilling and repair projects in the San Juan Basin, up from $8.3 million actually spent in 2025 [source: https://www.stocktitan.net/sec-filings/SJT/8-k-san-juan-basin-royalty-trust-reports-material-event-2ec23fc7f9e9.html].

The Huerfanito Unit 99E appears in EPA's Facility Registry under ID 110007143260 with its most recent permit action dated May 12, 1999 and no active permits currently on file [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. ECHO's derivation methodology distributes the operator's five-year penalty history across associated facility IDs. The resulting $3.76 million 24-month allocation at this unit is a mathematical attribution — not a site-specific violation count — and ECHO logs zero quarters of noncompliance against the unit over the trailing 24 months, with zero listed top pollutants. That profile is consistent with a low-throughput production lease rather than an enforcement focal point [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The enforcement arc relevant to this allocation begins on October 17, 2024, when DOJ and EPA announced a consent decree addressing Hilcorp's New Mexico well completion activities. EPA described the action as the first of its kind against an oil and gas producer for Clean Air Act and New Mexico AQCA violations associated with bringing wells online after drilling. The settlement required a $9.4 million civil penalty plus injunctive compliance measures [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. The Pennsylvania settlement followed thirty-five days later. Filed November 21, 2024 in the U.S. District Court for the Western District of Pennsylvania as Case 2:24-cv-01596, it covered Clean Air Act violations at western Pennsylvania production operations, carrying a $1.275 million civil penalty and required compliance projects designed to offset past emissions [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].

Operational developments over the same 24-month window add further texture. A February 20, 2026 8-K from the San Juan Basin Royalty Trust announced Hilcorp's 2026 capital plan of $14.0 million across 32 drilling and workover projects in the basin, following actual 2025 spend of $8.3 million — a 69 percent year-over-year increase in planned outlay [source: https://www.prnewswire.com/news-releases/san-juan-basin-royalty-trust-announces-hilcorps-2026-capital-plan-302693218.html]. In April 2026, news outlets reported a tank incident at Hilcorp's Fairfield-Unkefer location on Fairfield School Road in Fairfield Township, Ohio. The Ohio Department of Natural Resources confirmed the event at 11:18 a.m.; Columbiana Assistant Fire Chief Frank Nulf separately described it as an explosion near a Hilcorp Energy facility [source: https://www.wkbn.com/news/local-news/fairfield-twp-news/crews-respond-to-incident-at-hilcorp/] [source: https://www.wfmj.com/news/local-news/columbiana_city/crews-respond-to-explosion-near-columbiana-gas-facility/article_e912c6d3-2b82-4b3e-8ec4-9ce88a1fb02b.html]. That Ohio incident falls outside the Huerfanito unit's geographic scope but is relevant to the operator's aggregate risk profile. Separately, the Alaska legislature in April 2026 rejected a Senate measure that would have applied the state corporate income tax to Hilcorp and similarly structured private oil producers, preserving the company's existing tax posture in Alaska [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/].

Action 1 — New Mexico Clean Air Act Stationary Source Settlement. Announced October 17, 2024 by EPA and DOJ. Program: CAA and New Mexico Air Quality Control Act. Facilities: Hilcorp oil and gas production operations in New Mexico, specifically well completion operations conducted after drilling. Outcome: civil penalty of $9.4 million plus injunctive compliance measures. EPA characterized the matter as the first CAA and AQCA action against an oil and gas producer focused specifically on the completion phase of well development [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Action 2 — Pennsylvania Clean Air Act Settlement. Announced November 21, 2024. Program: CAA and Pennsylvania state clean air law. Facilities: Hilcorp oil and gas production operations in western Pennsylvania. Court: U.S. District Court for the Western District of Pennsylvania, Case No. 2:24-cv-01596, Plaintiffs United States of America and Commonwealth of Pennsylvania Department of Environmental Protection v. Hilcorp Energy Company [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf]. Outcome: civil penalty of $1.275 million plus compliance projects to offset past illegal emissions, with project costs disclosed in the EPA settlement summary [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Action 3 — ECHO-attributed penalty at Huerfanito Unit 99E. The $3.76 million 24-month figure at this site reflects EPA ECHO's proportional allocation formula — penalty_24mo = total_5yr × (24/60) — applied to the operator-level penalty history. No site-specific quarters of noncompliance are recorded against FRS ID 110007143260 in the current export [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No RCRA or CWA enforcement actions specific to this unit appear in the retrieved record set.

Huerfanito Unit 99E (Bloomfield, NM; FRS ID 110007143260). The facility is a single crude petroleum extraction site in San Juan County. No active permits are on file; the latest permit action dates to May 12, 1999. ECHO records zero 24-month noncompliance quarters and an EJ index average of 0.0 in the extract [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. San Juan Basin operations associated with this unit fall within the geographic reach of the October 2024 New Mexico CAA settlement [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Hilcorp New Mexico well completion sites (statewide). These are the sites named in the October 17, 2024 DOJ-EPA consent decree covering CAA and AQCA violations during post-drilling well completion. The settlement is the first CAA action against an oil and gas producer focused specifically on completion operations. It carries a $9.4 million civil penalty [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Hilcorp western Pennsylvania production operations. Covered by the November 21, 2024 settlement filed as 2:24-cv-01596 in the Western District of Pennsylvania, resolving CAA and Pennsylvania law violations with a $1.275 million civil penalty and required compliance projects [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].

Fairfield-Unkefer site, Fairfield Township, Ohio. On an April 2026 weekday morning, the Ohio Department of Natural Resources confirmed a tank incident at 11:18 a.m. at this Hilcorp location on Fairfield School Road. Columbiana Assistant Fire Chief Frank Nulf described the event as an explosion [source: https://www.wkbn.com/news/local-news/fairfield-twp-news/crews-respond-to-incident-at-hilcorp/] [source: https://www.wfmj.com/news/local-news/columbiana_city/crews-respond-to-explosion-near-columbiana-gas-facility/article_e912c6d3-2b82-4b3e-8ec4-9ce88a1fb02b.html].

San Juan Basin Royalty Trust properties (operated by Hilcorp). Trust-held interests in the San Juan Basin are scheduled for $14.0 million in 2026 capital spending across 32 drilling, recompletion, and facilities projects, following $8.3 million actually spent in 2025 [source: https://www.stocktitan.net/sec-filings/SJT/8-k-san-juan-basin-royalty-trust-reports-material-event-2ec23fc7f9e9.html] [source: https://www.prnewswire.com/news-releases/san-juan-basin-royalty-trust-announces-hilcorps-2026-capital-plan-302693218.html].

Methane and volatile organic compounds (VOCs). The New Mexico CAA and AQCA settlement targeted well completion emissions — the phase in which gas and liquid hydrocarbons can vent or flare before permanent production equipment is installed. Compounds released during that window include methane and associated VOCs such as benzene, toluene, ethylbenzene, and xylenes [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. VOC exposure pathways in San Juan Basin communities include ambient inhalation near well pads and downwind of compressor stations. ECHO's current extract lists no top pollutants for FRS ID 110007143260, so community-level exposure for the Huerfanito unit itself is not quantified in the retrieved data [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Nitrogen oxides (NOx) and hazardous air pollutants. The Pennsylvania CAA complaint filed as W.D. Pa. 2:24-cv-01596 addressed emissions from oil and gas production operations. CAA stationary source rules for this sector regulate NOx, VOCs, and hazardous air pollutants from storage tanks, dehydrators, and engines [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf]. NOx contributes to ground-level ozone formation, which carries documented respiratory effects for exposed populations.

Produced water constituents. Crude petroleum extraction at legacy San Juan Basin sites can generate produced water containing chlorides, hydrocarbons, and naturally occurring radioactive materials; EPA's Facility Registry Service tracks these permitting categories [source: https://frs-public.epa.gov/ords/frs_public2/fii_query_detail.disp_program_facility?p_registry_id=110046478398]. The EJ index average of 0.0 reported in ECHO for the Huerfanito unit reflects the rural, low-density demographic profile of the immediate area. It does not indicate an absence of exposure pathways [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Within the NAICS 211120 and adjacent 211130 peer set ordered by 24-month penalty total, the Huerfanito Unit 99E's $3.76 million ECHO-allocated penalty sits materially below all three comparators. Greka Bell Compressor Plant carries $26.16 million despite logging zero violation quarters — a pattern structurally similar to Huerfanito's own operator-level allocation dynamic. Red Hills Gas Processing Plant shows $19.13 million across eight violation quarters, and Azalea Battery shows $16.13 million also across eight quarters. All four facilities report an EJ index average of 0.0 in the current ECHO extract [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The Huerfanito unit's zero 24-month noncompliance quarters distinguish it from Red Hills and Azalea, reinforcing that its penalty figure is an operator-level proportional allocation rather than the product of site-specific enforcement activity.

Hilcorp Energy Company is privately held, and no 10-K Item 1A risk factor disclosure is on file with the SEC; CIK is not applicable. The nearest SEC-filed forward-looking environmental context is the San Juan Basin Royalty Trust 8-K of February 20, 2026, which outlines Hilcorp's operator-level 2026 capital plan of $14.0 million for 32 projects in the basin, up from $8.3 million actually spent in 2025. That 69 percent increase in planned capital signals continued drilling, recompletion, and facilities activity — all of which remains subject to New Mexico AQCA and federal CAA stationary source requirements cited in the October 2024 consent decree [source: https://www.stocktitan.net/sec-filings/SJT/8-k-san-juan-basin-royalty-trust-reports-material-event-2ec23fc7f9e9.html] [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].