HILCORP - SADIE WEST 2M

Hilcorp Energy Company operates the Sadie West 2M site (EPA facility ID 110046351489) within its San Juan Basin portfolio, headquartered in Farmington, New Mexico. The facility-level ECHO extract records zero formal violations in the trailing 24 months but assigns a derived penalty allocation of $3.76 million, reflecting the pro-rata share of Hilcorp's multi-site settlements apportioned across San Juan assets [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That allocation is anchored by the October 17, 2024 Clean Air Act settlement in which Hilcorp agreed to a $9.4 million civil penalty covering well-completion emissions in the San Juan Basin, including operations on Jicarilla Apache and Navajo Nation lands [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Two additional federal actions within the 24-month window round out the compliance picture. A November 21, 2024 Pennsylvania CAA settlement carried a $1.275 million civil penalty [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary], and an October 9, 2024 RCRA hazardous waste penalty added $223,000 [source: https://epa.gov/newsreleases/hilcorp-pays-223000-epa-penalty-hazardous-waste-violations]. Those three actions, announced within roughly six weeks of one another, produced aggregate federal civil penalties of approximately $10.9 million. Against that backdrop, Hilcorp's own 2025 San Juan disclosure reports an 81% reduction in methane emissions from 2023 to 2024 and $104 million in state and local royalties and taxes paid during 2024 [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 appear on EDGAR, which confines forward-risk analysis to operator-published materials and agency filings.

The compliance record for Hilcorp's New Mexico operations — of which Sadie West 2M is one wellsite — is defined by the San Juan Basin CAA action finalized October 17, 2024. EPA and DOJ framed the case as the first federal action against an oil and gas producer for CAA and New Mexico Air Quality Control Act violations tied specifically to well-completion operations, meaning the process of bringing gas to surface after drilling [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. The $9.4 million civil penalty is split between EPA and the state of New Mexico. Injunctive relief requires updated emissions controls across completion operations throughout the basin [source: https://nmpoliticalreport.com/2024/10/18/hilcorp-agrees-to-pay-9-4-million-amid-allegations-of-clean-air-act-violations/].

The trailing 24 months show a tightly clustered enforcement sequence. On October 9, 2024, EPA announced a $223,000 RCRA penalty tied to hazardous waste handling [source: https://epa.gov/newsreleases/hilcorp-pays-223000-epa-penalty-hazardous-waste-violations]. Eight days later, on October 17, the New Mexico CAA settlement landed [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. Then, on November 21, 2024, EPA, DOJ, and the Pennsylvania Department of Environmental Protection finalized a $1.275 million CAA settlement addressing western Pennsylvania oil and gas production sites, with injunctive-relief project costs layered on top of the civil penalty figure [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Three programs — CAA twice, RCRA once — produced roughly $10.9 million in aggregate federal civil penalties across a six-week span.

Operational developments over the same window extend the compliance surface beyond formal settlements. On May 4, 2026, the Anchorage Daily News reported Hilcorp's decision to exit the Yukon Flats exploration program after drilling one of two planned wells on Indigenous-owned land, a program that drew 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/]. An Ohio tank incident at a Fairfield Township facility on approximately April 28, 2026 drew fire-crew response to Hilcorp's site on Fairfield School Road [source: https://www.wkbn.com/news/local-news/fairfield-twp-news/crews-respond-to-incident-at-hilcorp/]. NGO tracker Big Gas Polluters named Hilcorp "Polluter of the Month" in August 2025, citing the company's trade-association activity around federal methane emission penalties [source: https://biggaspolluters.org/polluter-of-the-month-hilcorp/]. None of these operational items has, as of the ECHO extract date of May 4, 2026, produced additional docketed federal violations against Sadie West 2M specifically [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Action 1 — New Mexico CAA / Well Completions (October 17, 2024). Program: Clean Air Act § 111 (NSPS OOOO/OOOOa) and New Mexico Air Quality Control Act. Counterparties: EPA, DOJ, New Mexico Environment Department. Civil penalty: $9.4 million, split between federal and state treasuries. Allegations: failure to control volatile organic compound and methane emissions during well-completion activities in the San Juan Basin, including operations on Jicarilla Apache and Navajo Nation lands. Outcome: consent decree with injunctive relief governing completion-phase emissions controls [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement] [source: https://nmpoliticalreport.com/2024/10/18/hilcorp-agrees-to-pay-9-4-million-amid-allegations-of-clean-air-act-violations/].

Action 2 — Pennsylvania CAA Stationary Source (November 21, 2024). Program: Clean Air Act and Pennsylvania state clean air law. Counterparties: EPA, DOJ, Pennsylvania DEP. Civil penalty: $1.275 million. Allegations: noncompliance with federal and state clean air regulations at western Pennsylvania oil and gas production operations. Outcome: the settlement requires compliance projects and emissions-offset projects whose costs exceed the civil penalty figure itself [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Action 3 — RCRA Hazardous Waste Penalty (October 9, 2024). Program: Resource Conservation and Recovery Act. Counterparty: EPA. Civil penalty: $223,000. Outcome: administrative resolution of hazardous waste handling allegations [source: https://epa.gov/newsreleases/hilcorp-pays-223000-epa-penalty-hazardous-waste-violations]. Combined federal civil penalties within the 24-month window total approximately $10.898 million across these three actions. The $3.76 million figure in the ECHO extract for Sadie West 2M reflects the exporter's pro-rata derivation (penalty_24mo = total_5yr × 24/60) rather than a site-specific fine, per the stated methodology [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Sadie West 2M (New Mexico, facility ID 110046351489). The ECHO extract lists zero active permits and zero formal violations in the trailing 24 months at this wellsite. The EJ index average of 0.0 reflects either absent or unreported EJScreen linkage in the exporter row. The $3.76 million allocated penalty is a derived pro-rata figure tied to Hilcorp's broader 5-year penalty total rather than any site-specific adjudication [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

San Juan Basin completion wells (New Mexico, multi-site). These are the operational units directly implicated in the $9.4 million October 2024 CAA settlement. EPA characterized the action as the first federal CAA case against an oil and gas producer tied specifically to well-completion emissions, with named exposure on Jicarilla Apache and Navajo Nation lands [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Western Pennsylvania oil and gas production sites. Covered by the November 21, 2024 settlement, these sites are the basis for the $1.275 million CAA penalty and mandated compliance and emissions-offset projects [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Fairfield Township, Ohio facility. On approximately April 28, 2026, fire crews responded to a tank incident at Hilcorp Energy Company on Fairfield School Road. No federal enforcement docket entry tied to the incident appears in the ECHO extract as of May 4, 2026 [source: https://www.wkbn.com/news/local-news/fairfield-twp-news/crews-respond-to-incident-at-hilcorp/] [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Yukon Flats exploration well (Alaska, Indigenous-owned land). On May 4, 2026, ADN reported Hilcorp's withdrawal from the Yukon Flats program after drilling one of two planned wells, in a program that drew sharp 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/]. Hilcorp's Prudhoe Bay expansion plans, targeting an additional 40,000 barrels per day, remain active as of September 2025 [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/].

Methane. The 2024 New Mexico settlement centered on methane and VOC emissions released during well completions. EPA framed the action by stating that oil and gas production is a leading source of methane, a short-lived climate pollutant with warming potency many multiples that of CO2 over a 20-year horizon [source: https://nmpoliticalreport.com/2024/10/18/hilcorp-agrees-to-pay-9-4-million-amid-allegations-of-clean-air-act-violations/]. The exposure pathway is direct atmospheric release from completion flowback and fugitive wellhead leakage. The EJ dimension is concrete: completion sites in the San Juan Basin sit adjacent to Jicarilla Apache and Navajo Nation lands, where methane co-emissions of VOCs and hazardous air pollutants carry a localized air-quality burden on those communities [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Volatile organic compounds (VOCs). Co-released with methane during completion and ongoing production, VOCs contribute to ground-level ozone formation. EPA's action required completion-phase emissions controls as injunctive relief, consistent with NSPS OOOO/OOOOa requirements for reduced-emission completions [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Hazardous waste constituents (RCRA Subtitle C). The October 2024 $223,000 RCRA penalty addressed hazardous waste handling at Hilcorp operations. Exposure pathways for mishandled oilfield hazardous waste include soil contamination, groundwater migration, and worker inhalation or dermal contact during transfer [source: https://epa.gov/newsreleases/hilcorp-pays-223000-epa-penalty-hazardous-waste-violations].

Within the upstream and midstream NAICS 211xxx peer cohort pulled from the ECHO exporter, Sadie West 2M's derived $3.76 million 24-month penalty allocation sits materially below the top three peer penalty totals. Those range from $16.1 million at HP Gas Pad to $26.2 million at Greka Bell Compressor Plant, with Red Hills Gas Processing Plant at $19.1 million [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Sadie West 2M also records zero formal 24-month violations at the site level, matching Greka Bell and diverging from Red Hills and HP Gas Pad, each of which registered eight quarters with noncompliance. EJ index averages are reported as 0.0 across the cohort in the extract. That figure reflects exporter linkage methodology rather than confirmed absence of EJ exposure — the New Mexico settlement language establishes that Hilcorp completion activity does occur adjacent to Jicarilla Apache and Navajo Nation lands [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Hilcorp Energy Company is privately held and does not file Form 10-K or 10-Q with the SEC; no CIK is assigned and no EDGAR-based forward risk factor disclosures are available for this briefing. Forward-looking environmental risk must therefore be inferred from operator-published materials and agency filings. The 2025 San Juan report references ongoing methane reduction work and expanded production from legacy assets [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf], while the October 2024 EPA/DOJ consent decree imposes injunctive relief on completion-phase emissions that will govern future New Mexico operating conduct [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. State-level tax exposure is also evolving. On April 13, 2026, the Alaska House rejected a measure to apply corporate income tax to Hilcorp and other private oil companies — an outcome that preserved current tax treatment but signals continuing legislative attention to the company's private status [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/].