“The repairs required to fix the leaks identified by Gulfport and listed in Attachment A were not technically infeasible, would not have required a vent blowdown, a compressor station shutdown, a well shutdown or well shut-in, or would have been unsafe to repair during operation of the unit.”

💡 EPA explicitly found Gulfport had no legitimate reason to delay any of the 115 documented repairs, proving the violations were deliberate business decisions.

“The EPA and Respondent agree that settling this action is in the public interest and consent to the entry of this Consent Agreement and Final Order (CAFO) pursuant to 40 C.F.R. § 22.18(b)(2) and (3) without the adjudication of any issues of law or fact.”

💡 This standard language allows Gulfport to pay the penalty without ever admitting wrongdoing, preserving the company’s reputation while avoiding legal accountability.

“On May 14, May 15, and July 2, 2024, Gulfport provided EPA with documentation of leaks detected at 33 of its well pads and dates of first attempts and final repair. The documentation showed that Gulfport had not repaired leaks in the time frames required by NSPS Subpart OOOOa, at 40 C.F.R. § 60.5397a(h), and its GP 12.1 or 12.2 PTIOs, at provision C.5.(c)(3).”

💡 Gulfport tracked its own violations for years before EPA enforcement, showing the company knowingly operated out of compliance while documenting its own lawbreaking.

“Subpart OOOOa establishes emission standards for the control of emissions of volatile organic compounds (VOCs), sulfur dioxide, and greenhouse gases in the form of methane from various types of equipment at oil and natural gas facilities constructed, modified, or reconstructed after September 18, 2015, including fugitive emissions components at compressor stations.”

💡 Federal regulations specifically target methane because of its extreme potency as a greenhouse gas, making Gulfport’s prolonged leaks directly harmful to climate stability.

“40 C.F.R. § 60.5397a(h)(1) requires that ‘a first attempt at repair shall be made no later than 30 calendar days after detection of the fugitive emissions.’ 40 C.F.R. § 60.5397a(h)(2) requires that ‘repair shall be completed as soon as practicable, but no later than 30 calendar days after the first attempt at repair as required in paragraph (h)(1) of this section.'”

💡 Federal law gives clear, specific deadlines that Gulfport violated dozens of times, leaving no ambiguity about the company’s legal obligations.

“Provision C.5.(c)(3) of the Ohio GP 12.1 and 12.2 PTIOs applicable to the facilities listed in Attachment A states, ‘in the event that a leak or defect is detected in the cover, closed vent system, process equipment, or control device, the permittee shall make a first attempt at repair no later than 5 calendar days after the leak is detected.'”

💡 Ohio’s permits required even faster action than federal standards, yet Gulfport routinely missed these tighter five-day deadlines at multiple facilities.

“At the Schumacher facility, a T-handle on the right side of the Senior Daniel was detected leaking on November 27, 2023. The first attempt at repair was made the same day, but successful repair was not completed until April 17, 2024, a delay of 142 days between first attempt and successful repair.”

💡 This five-month delay for a single component shows how routine and systematic Gulfport’s noncompliance had become across its operations.

“At the Stout facility, four separate level controller leaks in GPU 1 and GPU 2 were all detected on December 23, 2020. None were successfully repaired until March 25, 2021, representing 92 days of delay for each component at a single site.”

💡 When multiple leaks at one facility all go unrepaired for months, it demonstrates management-level neglect rather than isolated maintenance problems.

“Based on analysis of the factors specified in Section 113(e) of the CAA, 42 U.S.C. § 7413(e), the facts of this case, and Respondent’s cooperation, the EPA has determined that an appropriate civil penalty to settle this action is $454,403.”

💡 This penalty averages less than $4,000 per violation and represents a fraction of the costs Gulfport avoided by delaying repairs for years.

“In accordance with 40 C.F.R. § 22.18(c), completion of the terms of this CAFO resolves only Respondent’s liability for federal civil penalties for the violations specifically alleged in this CAFO.”

💡 The settlement changes nothing about how Gulfport operates its facilities and requires no improvements to prevent future violations.

“EPA issued to Respondent Notices of Violation/Findings of Violation (NOV/FOVs) and provided copies of the NOV/FOVs to the Ohio Environmental Protection Agency (OEPA), providing notice to Respondent and OEPA that the EPA found Respondent committed the alleged violations.”

💡 Notice went only to the company and state regulators, with no mechanism for affected community members to participate in or even learn about the enforcement process.

“Fugitive emissions component means any component that has the potential to emit fugitive emissions of VOC at a well site or compressor station, including valves, connectors, pressure relief devices, open-ended lines, flanges, covers and closed vent systems not subject to § 60.5411 or § 60.5411a, thief hatches or other openings on a controlled storage vessel not subject to § 60.5395 or § 60.5395a, compressors, instruments, and meters.”

💡 This technical definition shows the wide range of equipment that leaked volatile organic compounds at Gulfport facilities for months or years.

“The EPA and the United States Department of Justice have jointly determined that this matter, although it involves alleged violations that occurred more than one year before the initiation of this proceeding, is appropriate for an administrative penalty assessment.”

💡 The earliest violations occurred in December 2020, but EPA did not file enforcement action until September 2025, allowing nearly five years of noncompliance before final resolution.

“EPA has approved various provisions of the Ohio Administrative Code (Ohio Admin. Code) as part of the Ohio SIP, including Ohio Admin. Code § 3745-31-29. Upon EPA’s approval of a SIP, the plans become independently enforceable by the federal government, as stated under Section 113(a)(1) of the CAA, 42 U.S.C. § 7413(a)(1).”

💡 This explains how violations of Ohio state permits simultaneously violated federally enforceable Clean Air Act requirements, giving EPA authority to intervene.

“Penalties, interest, and other charges paid pursuant to this CAFO shall not be deductible for purposes of federal taxes.”

💡 While Gulfport cannot write off the penalty as a business expense, the modest amount ensures minimal financial impact on corporate operations.