Hilcorp Energy Company (Pennsylvania) Settlement Summary

On November 21, 2024, the U.S. Environmental Protection Agency (EPA), Department of Justice, and Pennsylvania Department of the Environment reached a settlement agreement with Hilcorp Energy Company resolving Clean Air Act and Pennsylvania law violations at the company’s oil and gas production operations in western Pennsylvania.  

Under the settlement, Hilcorp agreed to pay a civil penalty of $1.275 million for violations resulting from the company’s failure to comply with federal and state clean air regulations. The agreement further requires Hilcorp to implement projects to comply with the law and offset past illegal emissions. The projects are expected to cost approximately $1.65 million.  

The settlement is part of the EPA’s National Enforcement and Compliance Initiative to mitigate climate change and the agency’s larger effort to hold oil and gas companies accountable for widespread violations throughout the country. Like all of the EPA’s national enforcement initiatives, this initiative prioritizes communities already overburdened by pollution and with other potential environmental justice concerns.  

On this page:

• Overview of Hilcorp Energy Company
• Summary of Violations
• Summary of Environmental Impacts
• Environmental Benefits
• Overview of Consent Decree
• Comment Period
• Contact Information

Overview of Hilcorp Energy Company

Hilcorp Energy Company (Hilcorp) is a privately-owned natural gas extraction and production company and is one of the nation’s largest oil and gas exploration and production companies. Hilcorp is registered to do business in Pennsylvania, headquartered in Houston, Texas, and engages in oil and gas exploration, development, and production across the United States.  

Summary of Violations

In the complaint, filed with the proposed consent decree, EPA alleges that the company violated Clean Air Act (CAA) regulations at six Hilcorp facilities in Lawrence and Mercer counties in western Pennsylvania. Specifically, Hilcorp violated Pennsylvania’s state implementation plan (SIP) at five of the facilities by failing to comply with the specifications in permit applications and the terms and conditions of its permits that require routing all vapors, including volatile organic compounds (VOCs) and methane, to a control device from the storage tanks at each of these facilities. The complaint also alleges that Hilcorp violated the SIP by failing to obtain a plan approval and operating permit at one additional facility.  

These violations resulted in unlawful emissions of VOCs to the atmosphere. VOCs are regulated under the CAA as precursors to the criteria pollutant ground-level ozone. 

Summary of Environmental Impacts

VOCs are a key component in the formation of ground-level ozone, a pollutant that irritates the lungs, exacerbates diseases such as asthma, and can increase susceptibility to respiratory illnesses, such as pneumonia and bronchitis.  

Methane, a climate super pollutant, is a hydrocarbon that is a primary component of natural gas and a potent greenhouse gas, approximately 25-28 times more powerful than carbon dioxide. It is the second most abundant greenhouse gas after carbon dioxide, accounting for about 16% of global emissions. Achieving significant reductions of methane would have a rapid and significant effect on atmospheric warming potential. 

Environmental Benefits

EPA projects that the Hilcorp agreement will result in the reduction of over 160 tons of VOC emissions annually and 5,200 tons of carbon dioxide equivalent emissions per year released as methane. The reductions in methane from the settlement are similar to the reductions that would be achieved by taking 1,100 cars off the road for one year.   

Overview of Consent Decree

Hilcorp will pay a civil penalty of $1.275 million, split evenly between the United States and the commonwealth of Pennsylvania. 

Hilcorp is required to achieve and maintain ongoing compliance with all applicable regulatory requirements at each of the six facilities and conduct a compliance program that includes:  

• Performing a field survey to identify and remedy any compromised equipment;  
• Performing a design analysis to ensure adequate design and sizing of the vapor control systems, followed by a requirement to implement any necessary modifications to correct systems that are under-designed;  
• Complying with extensive continuous monitoring requirements that include tank pressure monitoring, bypass monitoring, vapor recovery unit  inlet monitoring, and flare pilot monitoring;  
• Implementing an ongoing and robust directed inspection and preventative maintenance program to ensure that problems are identified and resolved promptly;  
• Performing pressure testing to determine a defined trigger point for the pressure relief devices on storage vessel pressure monitors and, if a pressure monitor records a measurement exceeding the defined trigger point, complying with a requirement to promptly initiate and complete all necessary corrective actions within 5 days or initiate a temporary “shut-in” of production operations until such time that corrective action is completed; and,  
• Implementing a third-party verification program to check and verify Hilcorp’s compliance with the consent decree.

Additionally, Hilcorp must submit a Pennsylvania General Permit registration to PADEP for its unpermitted oil and gas facility. Hilcorp will also mitigate past harm by retrofitting at least 164 intermittent bleed pneumatic controllers with non-emitting process controls earlier than required under law at eight of Hilcorp’s facilities located in Pennsylvania.

Comment Period

The proposed settlement, lodged in the U.S. District Court for the Western District of Pennsylvania, is subject to a 30-day public comment period and final court approval. Information on providing public comment, and the complaint and proposed consent decree are available on the DOJ's Proposed Consent Decree webpage. 

Contact Information

For additional information on this settlement, please contact: 

Christopher Williams, Chemical Engineer   
Air Enforcement Division  
Office of Civil Enforcement  
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
williams.christopher@epa.gov 

Daniel Hoyt, Environmental Engineer  
Air Enforcement Division   
EPA Office of Civil Enforcement
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460 
hoyt.daniel@epa.gov 

Robert Klepp, Attorney-Adviser  
Air Enforcement Division   
Office of Civil Enforcement
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460  
klepp.robert@epa.gov  

Kristin Terry, Attorney-Adviser  
Office of Civil Enforcement  
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460  
terry.kristin@epa.gov