HOWELL C 200S/HOWELL C 1A

HOWELL C 200S/HOWELL C 1A is a single-facility crude petroleum extraction operation classified under NAICS 211111, tied to a Navajo City, New Mexico address and carrying EPA registry ID 110040828263 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The EPA ECHO exporter dataset, refreshed on 2026-05-04, records zero quarters with non-compliance across the trailing 24-month window. At the same time, it reports an imputed penalty total of $3,760,000, derived by scaling a 5-year penalty figure to the 24-month window using the formula penalty_24mo = total_5yr × 24/60 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That combination — a seven-figure penalty alongside a clean quarterly compliance record — is the central analytical tension this briefing addresses.

No active NPDES, Title V, or RCRA permits appear in the ECHO snapshot. No top pollutants are enumerated. The EJScreen index average is reported as 0.0, which for a rural San Juan Basin site more likely reflects sparse block-group overlay data than an affirmative low-exposure finding [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The operator is privately held. No SEC CIK applies, and no 10-K or 10-Q filings were available for this record. The only SEC filing in the research bundle referencing a similarly named entity is a 2001 Form 10-K/A from Howell Corporation of Houston, Texas — a distinct legal entity headquartered at 1111 Fannin Street — and no chain-of-title evidence connects it to the New Mexico site [source: https://www.sec.gov/Archives/edgar/data/745113/000074511302000019/k01a.txt]. Peer benchmarking against three upstream oil-and-gas sites drawn from the same ECHO export places this facility's $3.76M imputed 24-month penalty well below the leading peer: Greka Bell Compressor Plant at $26.16M, Red Hills Gas Processing Plant at $19.13M, and HP Gas Pad at $16.13M [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The facility's monetary-penalty signature without a corresponding recorded violation count is discussed at length in the enforcement section below.

EPA ECHO records for facility registry ID 110040828263 show zero quarters with non-compliance flags across the 24-month window ending at the 2026-05-04 export date [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The dataset's derivation formula caps the 24-month violation count at min(qtrs_with_nc, 8); the observed value is zero. Yet the same snapshot reports a penalty total of $3,760,000 allocated to those same trailing 24 months via linear apportionment of a 5-year penalty figure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Three explanations are consistent with this pattern. Enforcement activity may predate the 24-month rolling window entirely. The penalty may stem from a prior consent decree or administrative order being amortized across the 5-year horizon used in ECHO's formula. Alternatively, the quarterly non-compliance flag may be suppressed by program-specific reporting cadence at this site. The underlying data does not disambiguate among these possibilities, and the ECHO exporter does not provide transaction-level case docketing for registry ID 110040828263 in the snapshot. That uncertainty is stated explicitly here rather than papered over.

Searching the 365-day trailing window for facility-specific enforcement news against either the company name or the New Mexico surface returned nothing [source: https://www.tributearchive.com/obituaries/48180038/norvil-earl-howell]. Queries targeting sustainability disclosure, NGO litigation, and state-level violation records likewise returned no matches for this facility. The only New Mexico environmental-justice-adjacent material surfaced in the research bundle concerns two entirely separate matters: the Homestake Mining Mill Site in Milan, Cibola County — a uranium-legacy site with no connection to this operator — and a March 2024 community rally in Corrales against emissions from an Intel facility [source: https://www.atsdr.cdc.gov/hac/pha/homestake/homestakemcojun091.pdf] [source: https://corralescomment.com/2024/03/22/corrales-environmental-advocacy-group-rallies-against-intel-plant-pollution/].

Historical federal and state records surface several unrelated 'Howell'-named matters worth documenting. A 1989 Ohio Attorney General consent judgment ran against Ira Crouch d/b/a Howell Dry Cleaners for air pollution statute violations in Butler County [source: https://www.ohioattorneygeneral.gov/Files/About/Departments-and-Offices/Environmental-Enforcement-Section/Consent-Orders/Crouch-Ira-dba-Howell-Dry-Cleaners-Consent-Judgmen]. An Illinois Pollution Control Board matter from 1974, docketed as PCB 73-344, named The Howell Company furniture plant in St. Charles [source: https://pcb.illinois.gov/documents/dsweb/Get/Rendition-143353/unknown]. A 2010 West Virginia PSC motor-carrier docket involved Howell Sanitation [source: http://www.psc.state.wv.us/scripts/WebDocket/ViewDocument.cfm?CaseActivityID=287736&NotType=%27WebDocket%27]. None of these matters attach to New Mexico upstream oil-and-gas registry ID 110040828263. They appear here solely to document that no co-branded enforcement history was identified against this specific facility in the research bundle.

The ECHO dataset reports zero violation quarters for EPA registry 110040828263 over the trailing 24 months and does not enumerate case-level entries — no docket numbers, program codes, or settlement dates appear in the exporter snapshot [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3,760,000 24-month penalty figure is, per the dataset's stated derivation, a pro-rata allocation: total_5yr × (24/60). Reverse-engineering that formula implies a 5-year penalty total of approximately $9,400,000 attributable to this facility across the CWA, CAA, and RCRA programs collectively, though the program-level decomposition is not exposed in the snapshot [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

No adjudicated enforcement action against the HOWELL C 200S/HOWELL C 1A site appears in the news, web-search, or neural-search results returned for this query. The court-record surface returned three unrelated 'Howell'-named dockets — the Ohio dry-cleaning matter, the Illinois furniture-manufacturing matter, and the West Virginia sanitation docket — plus a 1992 District of New Mexico case, Howell v. US Army Corps of Engineers, which was a Clean Water Act §404 permit dispute brought by an individual plaintiff surnamed Howell, not by the operator of this facility [source: https://case-law.vlex.com/vid/howell-v-us-army-885405654]. That case is noted only to confirm it does not represent an enforcement action against registry ID 110040828263.

Without transaction-level ECHO data or a state-agency docket, the composition of the $3.76M penalty figure cannot be attributed to a specific violation vintage, pollutant, or media program from the available materials alone. The penalty exists in the record; its origins do not. Readers requiring case-level detail should query the ECHO enforcement case search directly against registry ID 110040828263 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

HOWELL C 200S/HOWELL C 1A, located in Navajo City, New Mexico and carrying EPA registry ID 110040828263, is the only facility linked to this operator in the ECHO export. The snapshot indicates a single-facility footprint with no active permits enumerated and an EJScreen index average of 0.0 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That zero value, in ECHO's aggregation methodology, signals either absent EJScreen overlay data or a true low-exposure classification. The Navajo City locator places the site in the San Juan Basin, where block-group population density is low — making sparse overlay data the more plausible reading, though the dataset does not confirm either interpretation.

The $3.76M 24-month imputed penalty is concentrated entirely at this single site by construction of the formula. No sibling facilities, parent-entity co-located sites, or operator-wide facility tables appeared in the research bundle, so the standard 'top 5 facilities by EJ exposure' comparison cannot be populated here. For regional context on environmental-justice methodology in New Mexico extractive corridors, the ATSDR Health Consultation on the Homestake Mining Company Mill Site in Milan, Cibola County, documents demographic and exposure-pathway analysis applicable to rural New Mexico sites [source: https://www.atsdr.cdc.gov/hac/pha/homestake/homestakemcojun091.pdf]. The March 2024 Corrales Comment coverage of community advocacy against the Intel facility in the Rio Grande corridor illustrates how organized environmental mobilization takes shape in New Mexico [source: https://corralescomment.com/2024/03/22/corrales-environmental-advocacy-group-rallies-against-intel-plant-pollution/]. Neither source is attributable to the HOWELL C 200S/HOWELL C 1A site; both are offered as regional analytical context only.

The ECHO exporter returns an empty top_pollutants array for registry ID 110040828263. No TRI, DMR, or AQS-linked pollutant inventory is associated with this facility in the snapshot [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That absence forecloses any facility-specific emissions analysis from the available data.

For NAICS 211111 crude petroleum extraction sites operating in the San Juan Basin, the generic pollutant profile typically includes three categories. First, volatile organic compounds and methane from well venting, flaring, and fugitive tank emissions. Second, hydrogen sulfide where sour gas is present in the formation. Third, produced-water constituents — chlorides, benzene, and naturally occurring radioactive material — from impoundments or injection operations. None of these categories can be attributed to this specific site absent a facility-level emissions inventory. They are noted here as sector context, not as findings.

Regional precedent for exposure-pathway analysis in New Mexico is documented in the ATSDR Homestake Mill Site Health Consultation, which frames groundwater and airborne exposure methodology for rural New Mexico populations living near extractive and legacy-industrial sites [source: https://www.atsdr.cdc.gov/hac/pha/homestake/homestakemcojun091.pdf]. The Corrales community advocacy coverage describes VOC and particulate concerns raised by residents adjacent to industrial facilities in New Mexico's Rio Grande corridor [source: https://corralescomment.com/2024/03/22/corrales-environmental-advocacy-group-rallies-against-intel-plant-pollution/]. Again, both sources serve as methodological and regional templates rather than attributions to the Howell site.

Within the NAICS 211xxx upstream peer set drawn from the ECHO exporter, HOWELL C 200S/HOWELL C 1A's $3.76M 24-month imputed penalty is roughly one-seventh of Greka Bell Compressor Plant's $26.16M. It sits at approximately one-fifth of Red Hills Gas Processing Plant's $19.13M and one-quarter of HP Gas Pad's $16.13M [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The penalty gap is large. Two of the three peers — Red Hills and HP Gas Pad — carry the maximum-cap 8 quarters of non-compliance over the 24-month window, while the Howell site and Greka Bell both report zero quarters of non-compliance against nonzero penalty totals. That shared pattern, zero violation quarters alongside a substantial penalty figure, is consistent with penalties tied to pre-window consent decrees being amortized forward through ECHO's 5-year formula. All four entities show an EJScreen index average of 0.0 in the exporter, reflecting either sparse EJScreen overlay data for remote extraction sites or genuinely low-density population exposure in the surrounding block groups [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

No SEC Item 1A risk-factor disclosure is available for this operator. The entity is privately held, no CIK applies, and no 10-K or 10-Q filings were returned in the research bundle. The only 'Howell'-branded SEC artifact in the bundle is the 2001 Howell Corporation Form 10-K/A — neither current nor confirmed as a corporate predecessor to the New Mexico site — and it cannot be used to characterize forward-looking environmental risk at registry ID 110040828263 [source: https://www.sec.gov/Archives/edgar/data/745113/000074511302000019/k01a.txt]. Readers modeling forward environmental risk for this facility should rely on ECHO enforcement-case queries and New Mexico Oil Conservation Division and New Mexico Environment Department air-quality docket searches rather than SEC disclosure.