HILCORP - SUNRAY G 2A AND G250 TWINNED LOCATION

Hilcorp Energy Company's Sunray G 2A and G250 twinned location (EPA FRS ID 110046351808) sits within the San Juan Basin of northwestern New Mexico, operated from the company's Aztec, NM field office. EPA ECHO data derives a 24-month penalty allocation of $3.76 million for this specific facility node, computed as a pro-rata slice (24/60) of a larger five-year penalty total attributed to the operator [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The facility itself shows zero quarters with formal noncompliance in the most recent 24-month window and no active permits recorded in the ECHO snapshot as of 2026-05-04. That $3.76 million figure traces upstream to a single, landmark enforcement action: the October 17, 2024 consent decree between EPA, DOJ, and Hilcorp covering Clean Air Act and New Mexico Air Quality Control Act violations at oil and gas production operations across the state, under which Hilcorp agreed to a $9.4 million civil penalty [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

That New Mexico action is the first federal CAA case against an oil and gas producer tied specifically to well-completion operations [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 settlement with EPA, DOJ, and the Pennsylvania DEP for $1.275 million in civil penalties, plus required mitigation work at western Pennsylvania production operations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. Two federal consent decrees in 31 days is a notable concentration of enforcement activity. Violation Tracker records 102 penalty entries against Hilcorp-owned entities since 2000, totaling $61,668,321, and the 2024 New Mexico action stands as the single largest environmental line item in that aggregate [source: https://violationtracker.goodjobsfirst.org/?order=company&page=1&parent=hilcorp-energy&sort=asc].

The compliance record at the Sunray G 2A / G250 node must be read at two elevations: the single well-pad facility and the parent operator. At the facility level, ECHO's quarterly noncompliance count for the 24-month window is zero, and no active permit identifiers are recorded in the current exporter pull [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3.76 million 24-month penalty figure carried in the ECHO summary is a derivation (total_5yr × 24/60) that reflects allocation of operator-level enforcement dollars across Hilcorp's New Mexico FRS footprint rather than a penalty adjudicated against this specific wellsite [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

At the operator level, the 24-month picture is defined by two federal actions that landed within a single calendar month. On October 17, 2024, EPA and DOJ announced the New Mexico Clean Air Act settlement resolving violations associated with well-completion operations — the flowback stage during which oil and natural gas are first brought to surface after drilling. Hilcorp agreed to a $9.4 million civil penalty and to implement compliance and mitigation projects. EPA characterizes the action as the first federal case of its kind tied to completion-stage emissions [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. On November 21, 2024, EPA, DOJ, and the Pennsylvania Department of Environmental Protection announced a parallel settlement covering CAA and Pennsylvania air-quality violations at western Pennsylvania oil and gas operations; the civil penalty was $1.275 million, with additional required mitigation projects [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Outside the two federal decrees, Violation Tracker's parent-company rollup shows 102 total penalty records against Hilcorp-owned entities since 2000, aggregating to $61,668,321. Environment-related offenses represent the dominant category after a single large government-contracting entry of $34.6 million [source: https://violationtracker.goodjobsfirst.org/?order=company&page=1&parent=hilcorp-energy&sort=asc]. The Sunray facility's FRS registration (110046351808) places it in San Juan County, NM, within the Hilcorp San Juan operating unit that self-reports 11,600+ producing wells and 2,047,000+ gross acres under production in its 2025 San Juan regional disclosure [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf]. The chronological pattern in the 24-month window — two federal CAA consent decrees resolved within 31 days of each other in late 2024, both tied to upstream gas operations — aligns with EPA's announced enforcement emphasis on completion-stage and leak-detection compliance in unconventional oil and gas production. No additional enforcement filings, state notices of violation, or media-reported incidents specific to the Sunray G 2A / G250 wellsite surfaced in the research bundle [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Action 1 — EPA / DOJ / State of New Mexico v. Hilcorp Energy Company (CAA Stationary Source Settlement). Announced October 17, 2024. Program: Clean Air Act and New Mexico Air Quality Control Act. Facilities: Hilcorp oil and gas production operations in New Mexico (multi-site; Sunray G 2A and G250 fall within the relevant FRS universe). The allegation centers on violations arising from well-completion operations — specifically the flowback phase that brings hydrocarbons to surface after drilling, a source category that had not previously been the subject of a federal CAA enforcement case against a producer. Outcome: $9.4 million civil penalty plus required compliance and mitigation projects. EPA describes this as the first federal CAA and state AQCA case against an oil and gas producer tied to completion-stage emissions [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Action 2 — EPA / DOJ / Pennsylvania DEP v. Hilcorp Energy Company. Announced November 21, 2024. Program: Clean Air Act and Pennsylvania state clean-air law. Facilities: Hilcorp oil and gas production operations in western Pennsylvania. The allegation covers failure to comply with federal and state clean-air regulations at those production operations. Outcome: $1.275 million civil penalty, plus compliance projects and mitigation projects that EPA describes as required to offset past illegal emissions [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Facility-specific enforcement at Sunray G 2A / G250 tells a different story. ECHO records zero quarters with formal noncompliance for the facility across the 24-month window and no separate facility-level consent order [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3.76 million figure is a derived allocation, not a discrete penalty assessed against this wellsite [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. For historical context, Violation Tracker's parent-level dataset lists 102 penalty records against Hilcorp-owned entities since 2000, totaling $61,668,321, including both environmental entries and one large government-contracting-related entry [source: https://violationtracker.goodjobsfirst.org/?order=company&page=1&parent=hilcorp-energy&sort=asc].

Sunray G 2A and G250 Twinned Location (San Juan County, NM; FRS 110046351808). A twinned natural-gas production pad within Hilcorp's San Juan Basin portfolio, the Sunray node sits among hundreds of co-located well-pad registrations in the Four Corners region. ECHO's current snapshot shows zero 24-month noncompliance quarters and no active permit of record; the $3.76 million 24-month penalty allocation reflects pro-rata distribution of the October 2024 state-wide CAA settlement rather than a facility-specific fine [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Hilcorp San Juan regional footprint (New Mexico / Colorado Four Corners). Hilcorp's own 2025 San Juan disclosure reports 11,600+ producing wells, 2,047,000+ gross acres under production, and 119,000+ BOEPD of net daily production in the region, positioning Sunray as one node within a dense legacy-asset grid [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf]. That scale matters for reading any single-facility ECHO figure: operator-level enforcement dollars distributed across thousands of FRS registrations will produce allocated penalty totals at individual wellsites that bear no direct relationship to site-specific violations.

Related San Juan FRS sites (illustrative). EPA's FRS facility detail report for a neighboring Hilcorp-linked registry entry (FRS 110046478398) shows the level of co-located well-pad reporting in the basin that feeds the operator-level enforcement picture [source: https://frs-public.epa.gov/ords/frs_public2/fii_query_detail.disp_program_facility?p_registry_id=110046478398].

Hilcorp western Pennsylvania operations. Covered by the November 2024 $1.275 million CAA settlement, these sites are geographically and operationally distinct from the San Juan Basin footprint. EPA's summary identifies the respondent as Hilcorp Energy Company and describes violations at the company's oil and gas production operations in western Pennsylvania without naming a single-pad respondent [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary].

Third-party production reference — Sunray field (San Juan County). A public well-data aggregator lists Sunray as an active oil and gas production area in San Juan County, consistent with the Hilcorp-operated twinned pad described in the ECHO record [source: https://www.shalexp.com/new-mexico/san-juan-county/sunray/446891].

Pollutant 1 — Volatile organic compounds (VOCs) from well-completion flowback. The October 2024 New Mexico settlement is framed by EPA around emissions escaping during the completion phase, when gas and associated hydrocarbons are first brought to surface. VOCs in this stream include benzene, toluene, ethylbenzene, and xylenes — a suite of compounds with well-documented inhalation exposure pathways for residents near well pads. EPA's action description emphasizes that completion-stage emissions had not previously been the subject of a federal CAA enforcement case against a producer, making the $9.4 million Hilcorp penalty a definitional first [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. The exposure pathway for nearby residents is primarily inhalation of fugitive and vented emissions during the flowback window.

Pollutant 2 — Methane. Hilcorp's own 2025 San Juan disclosure highlights an 81% reduction in methane emissions from 2023 to 2024 in the region [source: https://www.hilcorp.com/wp-content/uploads/2025/05/SJ-2025.pdf]. Methane is both a short-lived climate forcer and a co-emitted tracer for the VOC stream targeted by the EPA completion-stage settlement. Reductions claimed by the operator and emissions targeted by EPA concern overlapping source categories, though the time windows and measurement methodologies differ [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement].

Pollutant 3 — Hazardous air pollutants and criteria co-pollutants (NOx, CO, PM) from engines, compressors, and flaring at production pads. The Pennsylvania settlement describes CAA violations at production operations and requires mitigation work to offset past illegal emissions — language that in EPA practice encompasses both VOC and hazardous air pollutant overages alongside criteria-pollutant exceedances at stationary sources [source: https://www.epa.gov/enforcement/hilcorp-energy-company-pennsylvania-settlement-summary]. EJ implications at the facility level: ECHO's EJ index average for Sunray G 2A / G250 is recorded as 0.0 in the current pull, indicating either sparse surrounding block-group population in the San Juan Basin or a reporting gap, rather than an affirmative finding of low environmental-justice exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Within the NAICS 211120/211130 natural-gas extraction and processing peer set pulled from ECHO, Sunray G 2A and G250's allocated 24-month penalty total of $3.76 million ranks below all three comparison facilities. Greka Bell Compressor Plant carries $26.16 million in allocated penalties despite also recording zero noncompliance quarters. Red Hills Gas Processing Plant shows $19.13 million and 8 NC quarters; HP Gas Pad shows $16.13 million and 8 NC quarters [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Unlike Red Hills and HP Gas Pad, the Sunray node shows zero quarters of formal noncompliance in the window, meaning its penalty allocation derives entirely from upstream operator-level enforcement — specifically the October 2024 New Mexico CAA settlement — rather than from facility-specific violations [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. On both metrics, allocated penalty and noncompliance quarter count, Sunray sits at the lower end of this peer group.

No SEC 10-K or 10-Q filings are available because Hilcorp Energy Company is privately held with no CIK of record. In lieu of SEC Item 1A disclosure, the operator's own Corporate Responsibility framing identifies the energy transition and declining long-run oil and gas demand as strategic context, stating that "oil and gas demand will plateau and eventually enter a long, slow decline" and positioning continued operation of legacy assets as the company's primary response [source: https://www.hilcorp.com/corporate-responsibility/]. That framing matters for assessing forward regulatory exposure. The compliance and mitigation project obligations embedded in the October 17, 2024 New Mexico CAA consent decree require Hilcorp to implement ongoing measures to bring well-completion operations into compliance with federal and state air rules, creating a defined set of near-term regulatory commitments across the New Mexico operating footprint [source: https://www.epa.gov/enforcement/hilcorp-energy-company-new-mexico-clean-air-act-stationary-source-settlement]. The Sunray G 2A / G250 pad, as one node within that footprint, sits within the scope of those obligations even though no facility-specific penalty was assessed against it.