HILCORP - REID 22M

Hilcorp Energy Company's Reid 22M facility sits in the San Juan Basin near Blanco, New Mexico, one node within the operator's 11,600-plus well footprint across the region [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf]. EPA ECHO data attributes a single facility (ID 110046351390) to this slug, with an estimated $3.76 million in penalty exposure derived across a 24-month window and zero logged quarters of non-compliance in the same period [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That derived figure, however, does not exist in isolation. On October 17, 2024, EPA and DOJ announced a $9.4 million civil penalty against Hilcorp Energy Company, resolving Clean Air Act and New Mexico Air Quality Control Act violations tied to well-completion operations across the state [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Five weeks later, a second federal action landed. On November 21, 2024, EPA, DOJ, and the Pennsylvania Department of Environmental Protection lodged a consent decree requiring Hilcorp to pay $1.275 million and fund compliance projects to offset past emissions from western Pennsylvania oil and gas operations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Hilcorp is privately held. No CIK, no 10-K, and no Item 1A forward-looking environmental risk disclosure is available for this briefing. The company's own 2025 San Juan report claims an 81% reduction in methane emissions from 2023 to 2024 [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf] — a figure that sits alongside two simultaneous federal consent decrees covering Clean Air Act violations in the company's two largest operating basins. Those two data points come from different reporting frames and should be read as such.

The 24-month enforcement record for Hilcorp Energy Company is defined by two consent decrees filed within a 35-day window in late 2024, both targeting air emissions from oil and gas production. The New Mexico action — captioned United States and New Mexico Environment Department v. Hilcorp Energy Company, Civil Action No. 1:24-cv-01055 in the District of New Mexico — is described by EPA as the first Clean Air Act enforcement of its kind against an oil and gas producer addressing well-completion operations, the phase in which oil or gas is brought to the surface after drilling is complete [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Under that decree, Hilcorp agreed to pay a $9.4 million civil penalty and accept compliance and third-party verification obligations set out in Sections V through VII [source: https://www.justice.gov/enrd/media/1373866/dl?inline=].

The chronology across the prior 24 months runs as follows. On September 27, 2024, EPA published the New Mexico settlement summary. October 17, 2024 brought the formal announcement [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. EPA posted the Pennsylvania settlement summary on November 20, 2024 [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. The very next day — November 21, 2024 — the United States and the Commonwealth of Pennsylvania filed the complaint and lodged the consent decree captioned United States and Pennsylvania DEP v. Hilcorp Energy Company, Civil No. 2:24-cv-01596 in the Western District of Pennsylvania [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf]. That Pennsylvania decree carries parallel civil penalty, compliance requirement, periodic reporting, and stipulated penalty provisions [source: https://www.justice.gov/enrd/media/1377991/dl?inline=]. In May 2025, Hilcorp published its San Juan 2025 community report, citing methane reductions and community spending figures [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf].

Operational incidents in 2025 and 2026 extend the picture beyond formal enforcement. On September 6, 2025, Hilcorp disclosed a 40,000-barrel-per-day redevelopment plan for Prudhoe Bay [source: https://www.adn.com/business-economy/energy/2025/09/06/hilcorp-plans-to-squeeze-more-life-out-of-prudhoe-bay-with-40000-barrel-per-day-field/]. Then, in late April 2026, emergency crews responded to a tank incident with a reported explosion at Hilcorp's Fairfield-Unkefer site on Fairfield School Road in Fairfield Township, Ohio [source: https://www.salemnews.net/news/local-news/2026/04/crews-respond-to-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]. On May 4, 2026, the Anchorage Daily News reported Hilcorp's withdrawal from the Yukon Flats exploration program 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/].

Action 1 — New Mexico CAA/AQCA Consent Decree. Filed October 17, 2024, in the U.S. District Court for the District of New Mexico as Civil Action No. 1:24-cv-01055 [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. The programs implicated are the Clean Air Act and the New Mexico Air Quality Control Act, specifically well-completion emissions at oil and gas production operations across the state [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Civil penalty: $9.4 million [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Additional obligations — compliance requirements, third-party verification, mitigation, and reporting — are set out in Sections V, VI, VII, VIII, and IX of the decree [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. EPA characterized the case as the first CAA action of its kind against an oil and gas producer addressing well-completion operations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. That designation matters: it signals a novel enforcement theory, one that could be applied to other operators in similar basins.

Action 2 — Pennsylvania CAA Consent Decree. Complaint filed November 21, 2024, in the U.S. District Court for the Western District of Pennsylvania as Civil No. 2:24-cv-01596 [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf]. Programs: the Clean Air Act and Pennsylvania state clean air law, tied to oil and gas production operations in western Pennsylvania [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Civil penalty: $1.275 million, plus compliance projects EPA described as necessary to offset past illegal emissions — project costs are expected to run into additional sums beyond the civil penalty itself [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Structural provisions in the decree include Civil Penalty (Section IV), Compliance Requirements (Section V), Periodic Reporting (Section VI), and Stipulated Penalties (Section VIII) [source: https://www.justice.gov/enrd/media/1377991/dl?inline=].

ECHO-level outcome at the Reid 22M node. ECHO's export for facility ID 110046351390 attributes zero quarters-with-noncompliance across the 24-month window and a $3.76 million 24-month penalty figure derived by prorating a five-year total (penalty_24mo = total_5yr × 24/60) [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The penalty allocation at the Reid 22M record should be read as a derived share of corporate-level CAA resolution dollars — not a standalone fine issued against that specific facility.

Reid 22M (Blanco, New Mexico) — the only ECHO facility attached to this slug, carrying ID 110046351390, zero logged non-compliance quarters in the 24-month window, and a derived $3.76 million penalty share [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The site sits in the San Juan Basin, where Hilcorp operates more than 11,600 producing wells across 2,047,000-plus gross acres [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf]. ECHO's EJ index average for this facility reports as 0.0, indicating either missing block-group linkage or unpopulated EJSCREEN fields in the export — not an affirmative finding of low environmental exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

New Mexico well-completion sites (statewide) — the broader set of Hilcorp well-completion operations in New Mexico is the direct subject of the October 2024 CAA/AQCA consent decree [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Individual ECHO IDs are not enumerated in the research bundle, but the decree's compliance provisions apply across covered sources as defined in Section III [source: https://www.justice.gov/enrd/media/1373866/dl?inline=].

Western Pennsylvania oil and gas production operations — covered by the November 2024 consent decree lodged in W.D. Pa. Case No. 2:24-cv-01596 [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf]. The decree requires compliance projects beyond the $1.275 million civil penalty, with total project costs expected to exceed that figure [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Fairfield-Unkefer site, Fairfield Township, Ohio — on or about April 28, 2026, at 11:18 a.m., Ohio Department of Natural Resources personnel and local firefighters responded to a tank incident on Fairfield School Road. Separate local reporting described an explosion near the Columbiana gas facility at the same location [source: https://www.salemnews.net/news/local-news/2026/04/crews-respond-to-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]. No formal enforcement record tied to that incident appears in the research bundle as of this writing.

Prudhoe Bay / Yukon Flats, Alaska — Hilcorp disclosed in September 2025 a 40,000-barrel-per-day Prudhoe Bay redevelopment plan [source: https://www.adn.com/business-economy/energy/2025/09/06/hilcorp-plans-to-squeeze-more-life-out-of-prudhoe-bay-with-40000-barrel-per-day-field/]. By May 2026, the company announced a pullout from Yukon Flats after completing one of two planned wells on Indigenous-owned land, following documented tribal opposition [source: https://www.adn.com/business-economy/energy/2026/05/04/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/].

ECHO's export lists no ranked top pollutants at the Reid 22M facility record [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The enforcement record fills that gap directly. Methane and associated volatile organic compounds from well-completion operations are the central pollutants in the New Mexico CAA/AQCA decree. Well completions release natural gas and entrained VOCs as the well is brought to production — a discrete, high-volume emission event that the decree targets specifically [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Hilcorp's own San Juan report frames methane reduction as its lead environmental metric, reporting an 81% reduction from 2023 to 2024 [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf].

The Pennsylvania decree addresses a different but overlapping pollutant profile. Emissions from oil and gas production operations regulated under the federal Clean Air Act and Pennsylvania state clean air law include storage-tank VOC venting, fugitive emissions from valves and connectors, and combustion-source pollutants [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. The complaint filed at 2:24-cv-01596 sets out the federal statutory basis for those specific claims [source: https://www.epa.gov/system/files/documents/2024-11/hilcorp-24-cv-1596-complaint.pdf].

A third pollutant pathway surfaces through the April 2026 Fairfield Township, Ohio event. At 11:18 a.m. on or about April 28, 2026, local fire officials and ODNR responded to a tank incident with a reported explosion on Fairfield School Road. The acute inhalation exposure pathway for first responders and nearby residents is the primary concern documented in contemporaneous reporting [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]. On environmental-justice dimensions, the Yukon Flats program drew tribal opposition because the wells were drilled on Indigenous-owned land — a fact pattern documented in contemporaneous reporting from the Anchorage Daily News [source: https://www.adn.com/business-economy/energy/2026/05/04/with-one-of-two-wells-drilled-hilcorp-to-pull-out-of-yukon-flats/].

Within the NAICS 21111x crude petroleum and natural gas extraction peer set, Reid 22M's derived 24-month penalty share of $3.76 million sits well below the top three peers by penalty total: Greka Bell Compressor Plant at $26.16 million, Red Hills Gas Processing Plant at $19.13 million, and HP Gas Pad at $16.13 million [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Reid 22M and Greka Bell each carry zero logged non-compliance quarters in the window. Red Hills and HP Gas Pad each carry the maximum of eight. All four records report an EJ index average of 0.0 — a result that reflects EJSCREEN field population in the ECHO export rather than an affirmative finding of low environmental exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Hilcorp Energy Company is privately held. No SEC CIK, no 10-K, and no Item 1A forward-looking environmental risk disclosure is available in the research bundle for this briefing. In lieu of SEC disclosure, the company's own corporate responsibility page frames forward-looking risk in terms of late-life asset extension and the pace of the energy transition, stating that renewable energy supply will rise while "oil and gas demand will plateau and eventually enter a long, slow decline" [source: https://www.hilcorp.com/corporate-responsibility/]. That framing is the only publicly available forward-looking risk statement from the company. Ongoing federal compliance obligations, third-party verification requirements, and stipulated-penalty exposure under the New Mexico decree (1:24-cv-01055) and the Pennsylvania decree (2:24-cv-01596) represent the documented forward-looking regulatory risk surface for this record [source: https://www.justice.gov/enrd/media/1373866/dl?inline=] [source: https://www.justice.gov/enrd/media/1377991/dl?inline=].