Petroleum Management polluted Baltimore’s air with Volatile Organic Compounds and Hazardous Air Pollutants.

Petroleum Management Operated Without Permits for Years, EPA Says
Corporate Misconduct Accountability Project

Petroleum Management Operated Without Permits for Years, EPA Says

EPA alleges Petroleum Recovery and Remediation Management, Inc. released over 25 tons of toxic air pollutants annually from 2014 to 2022 without required permits or pollution controls, endangering workers and Baltimore communities near its Curtis Avenue facility.

CRITICAL SEVERITY
TL;DR

From 2014 through March 2022, Petroleum Management operated a Baltimore waste processing facility that the EPA says emitted over 25 tons per year of volatile organic compounds and hazardous air pollutants without obtaining mandatory federal permits or installing pollution controls. The company expanded operations multiple times without required reviews, failed to properly classify hazardous waste, and lacked adequate spill prevention measures despite storing 80,000 gallons of oil near navigable waters. In April 2024, the company agreed to pay $230,000 in civil penalties to settle 17 separate counts of Clean Air Act, Clean Water Act, and hazardous waste violations spanning eight years.

This case reveals how a single facility evaded environmental oversight for nearly a decade while communities bore the health costs.

8 years
Period facility operated without required Title V air permit
25+ tons/year
VOC emissions threshold exceeded without controls
$230,000
Total civil penalty agreed in settlement
80,000 gal
Oil storage capacity near Patapsco River tributaries
17 counts
Separate violations across three federal environmental statutes

The Allegations: A Breakdown

⚠️
Core Allegations
What the company did · 8 points
01 EPA alleges the facility emitted more than 25 tons per year of volatile organic compounds from 2014 through March 2022, qualifying it as a major source that required a Title V operating permit, yet the company never applied for or obtained that permit during the entire eight-year period. high
02 The company failed to install any vapor control devices such as enclosed flares, condensers, or carbon adsorption units to capture or destroy toxic emissions, and in many cases left VOC-water separators uncovered or open to the atmosphere despite handling hundreds of gallons of volatile petroleum waste daily. high
03 Petroleum Management expanded and modified its facility in 2017, 2018, 2019, and 2020 without obtaining required New Source Review permits, even though these modifications increased the facility’s potential to emit regulated pollutants above significant thresholds in a region already designated as nonattainment for ozone pollution. high
04 The company discharged VOCs with vapor pressure greater than 0.002 psia from processing equipment in excess of 20 pounds per day without reducing the discharge by 85 percent or more, violating Maryland air quality standards designed to protect Baltimore residents from smog and toxic air contaminants. high
05 On February 6, 2019, the facility sent 6,000 gallons of material labeled as non-hazardous petroleum contaminated water to another facility, which upon testing determined the material was actually corrosive hazardous waste requiring a manifest that Petroleum Management never prepared. high
06 EPA inspections found the company operated VOC-water separators without vapor control devices even though these separators received liquid waste containing 200 gallons or more of VOC per day with true vapor pressure greater than 1.5 psi, directly violating Clean Air Act standards. high
07 Despite storing approximately 80,000 gallons of oil at a facility located 2,000 feet from Curtis Creek (a tributary to the Patapsco River), the company maintained an inadequate Spill Prevention Control and Countermeasure plan that was not properly certified by a licensed professional engineer and failed to describe secondary containment for multiple tanks and transfer areas. high
08 The facility failed to provide secondary containment for Tanks 7, 8, and 9, Wastewater Receiving Tank 1, a solidification pit, drums and totes, and two transfer areas, violating requirements to contain the entire capacity of the largest container plus precipitation for bulk storage installations. high
🏛️
Regulatory Failures
How oversight broke down · 6 points
01 EPA gave notice to Maryland Department of Environment in accordance with RCRA requirements, yet the facility operated from 2014 through 2022 without comprehensive compliance reviews despite multiple expansions that should have triggered permit applications and pollution control installations. high
02 The fragmented oversight structure across Clean Air Act, RCRA, and Clean Water Act programs allowed the company to slip through regulatory gaps, with each statute having distinct permit processes and delegated authorities that sometimes operate in silos. medium
03 EPA did not conduct its first comprehensive on-site inspection until September 2020, and mobile air monitoring around the facility perimeter did not occur until September 2020, nearly six years after the company began operating as a major source without required permits. high
04 The company failed to submit annual emissions statements to Maryland Department of Environment for at least calendar years 2016 through 2020, depriving regulators of basic data needed to track pollution and enforce compliance. medium
05 EPA issued its first Notice of Violation for Clean Air Act violations in May 2021, more than seven years after the alleged violations began, illustrating the substantial delay between noncompliance and enforcement action. medium
06 The SPCC plan dated July 26, 2021 was not properly certified by a licensed professional engineer at the time of EPA’s August 2021 inspection, and multiple technical amendments made in December 2018, December 2020, and July 2021 were never certified as required by federal regulations. medium
💰
Profit Over People
Cost cutting at public expense · 6 points
01 Installing vapor recovery or combustion controls to capture 85 percent or more of VOC emissions typically requires multi-million-dollar capital investments, which the company avoided for eight years by operating without required permits or pollution control equipment. high
02 By treating and disposing of petroleum-contaminated waste at rates exceeding 25 tons per year of VOCs without vapor controls, the facility gained a competitive cost advantage over compliant companies that invested in required pollution prevention technology. high
03 The company processed tens of thousands of gallons of contaminated material daily, generating substantial revenue from rapid low-cost waste treatment services while externalizing pollution costs onto Baltimore communities through uncontrolled toxic emissions. high
04 Petroleum Management used incompatible containers including a deteriorating solidification pit, corroded strainer boxes, and Wastewater Receiving Tank 1 for oil storage, cutting maintenance costs while increasing the risk of spills and releases into nearby waterways. medium
05 The facility failed to perform integrity testing on bulk storage tanks 1 through 9, avoiding inspection and maintenance expenses while risking catastrophic tank failures that could discharge thousands of gallons of oil or contaminated waste. medium
06 By not preparing proper hazardous waste manifests and determinations, the company avoided the stricter and more costly RCRA management requirements including specialized containment, tracking systems, and disposal at permitted hazardous waste facilities. high
🏥
Public Health and Safety
Risks to workers and communities · 7 points
01 The facility’s uncontrolled emissions included hazardous air pollutants such as benzene (a known carcinogen), acrolein, acrylonitrile, toluene, and xylene, exposing workers and nearby residents to substances that cause respiratory problems and long-term health effects including elevated cancer risk. critical
02 Volatile organic compounds released from the facility are precursors to ground-level ozone formation and smog, contributing to respiratory illnesses particularly affecting children, elderly residents, and individuals with asthma in surrounding Baltimore neighborhoods. high
03 EPA conducted mobile air monitoring at perimeter locations adjacent to the facility in September 2020, detecting VOCs and hazardous air pollutants that confirmed emissions were escaping beyond the facility fence line into the surrounding community. high
04 Workers at the facility faced exposure to high concentrations of airborne toxins from uncovered VOC-water separators, wastewater receiving tanks, and processing equipment that lacked vapor controls, potentially without adequate protective equipment or awareness of the health dangers. high
05 The facility’s location 2,000 feet from Curtis Creek, a tributary to Curtis Bay and the Patapsco River, meant that any oil spills or hazardous waste releases could contaminate traditional navigable waters affecting aquatic life, fishing, and recreational activities. high
06 In March 2022, the facility experienced a major fire event that halted operations, underscoring the inherent risks of handling volatile combustible materials without adequate safety controls and vapor management systems. critical
07 The facility’s SPCC plan failed to describe containment measures for heating fuel tanks and an oil-water separator, and did not adequately describe secondary containment for wastewater settlement tanks, wastewater processing tanks, and multiple strainer boxes, increasing spill risks. medium
🏘️
Community Impact
Environmental justice concerns · 5 points
01 Residents living near the Curtis Avenue facility in Baltimore faced increased medical expenses from respiratory illnesses potentially triggered by high VOC and hazardous air pollutant levels, while property values likely declined in areas adjacent to the heavily polluting industrial operation. high
02 The Baltimore community bore the environmental burden of toxic emissions for eight years while the company reaped profits, exemplifying environmental injustice where economically disadvantaged neighborhoods host polluting facilities that would face immediate opposition if sited in affluent areas. high
03 Local residents likely experienced persistent foul odors, visible plumes, and anxiety about unknown chemical exposures throughout the period of noncompliance, yet lacked the technical knowledge or resources to understand that unpermitted facility expansions were behind their health concerns. medium
04 The facility’s violations imposed indirect costs on local government, including potential emergency response expenses, public health costs, and lost tax revenues if property values stagnated due to proximity to industrial pollution. medium
05 Communities near the facility faced chronic stress and anxiety about children’s health, constant worry about contamination, and suspicion about unreported spills or discharges, psychological burdens that persisted throughout the eight-year violation period. medium
⚖️
Corporate Accountability Failures
System weaknesses exploited · 6 points
01 The $230,000 settlement represents the total penalty for eight years of violations affecting air, water, and hazardous waste across 17 separate counts, an amount that may be modest compared to the millions of dollars saved by not installing required pollution controls and obtaining proper permits. high
02 The company certified to EPA that it is currently in compliance only after entering into an Administrative Order on Consent that addresses the Clean Air Act violations, meaning compliance came through legal compulsion rather than voluntary corporate responsibility. high
03 Respondent neither admits nor denies the specific factual allegations in the consent agreement, a standard settlement provision that allows the company to resolve penalties without acknowledging wrongdoing or accepting full accountability for eight years of alleged violations. medium
04 The consent agreement resolves only civil penalty claims for the specific violations alleged, while EPA reserves the right to commence action for any imminent and substantial endangerment and any violations not specifically resolved, leaving open the possibility of future enforcement. medium
05 The settlement occurred only after EPA conducted multiple inspections, issued information requests in November 2020 and April 2021, held opportunity to confer meetings in July 2021 and November 2022, and issued formal violation notices in May 2021 and August 2022, demonstrating the lengthy process required to achieve even basic compliance. medium
06 The final order does not require Petroleum Management to publicly disclose the violations to affected community members, implement long-term independent monitoring, or fund community health studies to assess the impact of eight years of uncontrolled toxic emissions. medium
📊
Wealth Disparity
Who pays the real price · 4 points
01 The cost savings from avoiding multi-million-dollar pollution controls and permit compliance flowed upward to company executives and owners, while frontline workers earning lower wages and economically disadvantaged Baltimore residents bore the health burdens of uncontrolled toxic emissions. high
02 Environmental justice principles suggest that if the facility were located in an affluent suburb rather than an industrial Baltimore neighborhood, residents would have mobilized legal challenges and political pressure long before the facility could emit 25 tons per year of VOCs for eight consecutive years. high
03 Communities adjacent to the Curtis Avenue facility lacked the political influence and financial resources to demand early enforcement action, forcing them to endure years of toxic exposure while awaiting regulatory intervention that arrived only after extensive EPA investigation. high
04 The $230,000 penalty amount is divided among violations of three separate federal statutes, resulting in relatively modest financial consequences for each count of noncompliance, while affected community members cannot be compensated for health impacts or diminished quality of life. medium
Exploiting Delay
Years of avoided compliance · 5 points
01 The facility began operations in 2011 and made major modifications in 2013, yet did not face comprehensive EPA inspection until September 2020, allowing nearly a decade of operation with inadequate oversight and no requirement to install pollution controls during this formative period. high
02 EPA issued its Notice of Violation in May 2021, held opportunity to confer meetings in July 2021 and November 2022, and did not file the final consent agreement until April 2024, meaning nearly three additional years elapsed between initial violation notice and final settlement. medium
03 The company expanded operations in 2017, 2018, 2019, and 2020 without triggering immediate permit reviews or enforcement, suggesting that incremental growth allowed the facility to avoid scrutiny that a single large expansion might have attracted. medium
04 Between EPA’s 2020 inspection and the 2024 settlement, the facility continued operating under various interim measures, demonstrating how protracted enforcement timelines allow companies to maintain operations for years even after violations are discovered. medium
05 The consent agreement allows 30 days for payment after the effective date, and interest on penalties does not accrue if payment is made within 30 days, providing additional grace periods even after an eight-year violation period and multi-year investigation. low
🎯
The Bottom Line
What this case reveals · 6 points
01 Petroleum Management’s case demonstrates how a mid-sized industrial facility can evade core environmental protections for eight years by exploiting fragmented oversight, under-resourced enforcement, and the complexity of overlapping federal and state regulations. high
02 The settlement provides a roadmap of 17 specific violations across air emissions, hazardous waste handling, and spill prevention that regulators failed to detect or address for nearly a decade, exposing systemic weaknesses in environmental enforcement. high
03 This enforcement action came only after EPA deployed specialized mobile air monitoring, conducted multiple site visits, issued formal information requests, and invested substantial investigative resources, suggesting that less-scrutinized facilities may continue operating in violation without detection. high
04 The $230,000 penalty for eight years of violations affecting tens of thousands of people raises questions about whether financial consequences are sufficient to deter future noncompliance or whether penalties simply become a cost of doing business for companies that save millions by avoiding required controls. high
05 Baltimore residents who endured eight years of toxic emissions, health risks, and environmental degradation receive no direct compensation, community health monitoring, or enhanced protections beyond the company’s agreement to achieve compliance it should have maintained from the beginning. high
06 The case illustrates how profit-maximization incentives under deregulated capitalism can override public health protections when enforcement is delayed, penalties are modest, and companies face limited reputational or financial consequences for years of environmental violations. high

Timeline of Events

2011
Petroleum Management begins operations at Curtis Avenue facility; installs Tanks 5-9 without amending SPCC plan
2013
Company installs Tanks 1-4 and makes major modifications without amending SPCC plan or obtaining construction permits
2014
Facility begins operating as a major source emitting over 25 tons per year of VOCs without applying for required Title V permit
2017
First of four major facility expansions occurs without obtaining Non-Attainment New Source Review permits
2018
Company makes second major modification increasing emission potential; again fails to obtain NNSR permits
December 2018
Petroleum Management amends SPCC plan but fails to have technical amendments certified by professional engineer
February 2019
Facility ships 6,000 gallons labeled as non-hazardous waste without manifest; receiving facility determines it is corrosive hazardous waste
2019
Third major facility modification occurs without required permits
2020
Fourth major facility expansion proceeds without NNSR permits; December 2020 SPCC amendment lacks professional engineer certification
September 2020
EPA conducts mobile air monitoring around facility perimeter detecting VOCs and hazardous air pollutants; performs on-site inspection
October 2020
EPA sends site inspection report to Respondent
November 2020
EPA issues Information Request under CAA Section 114, RCRA Section 3007, and CWA Section 308
February 2021
Respondent provides response to EPA’s 2020 Information Request
April 2021
EPA sends follow-up Information Request seeking additional details about facility operations
May 2021
Respondent responds to follow-up Information Request; EPA issues Clean Air Act Notice of Violation
July 2021
Parties participate in Opportunity to Confer conference to discuss CAA violations; Respondent amends SPCC plan again without proper certification
August 2021
EPA conducts SPCC inspection finding multiple deficiencies in spill prevention measures
February 2022
EPA sends post-inspection letter regarding SPCC violations; receives Respondent’s revised SPCC plan dated February 11, 2022
March 2022
Major fire event occurs at facility, halting operations
August 2022
EPA issues RCRA and Clean Water Act Notice of Potential Violation and Opportunity to Confer Letter
November 2022
Parties hold conference to discuss CAA Notice of Violation and RCRA/CWA Notice of Potential Violation
April 12, 2024
Consent Agreement and Final Order filed with EPA Regional Hearing Clerk; company agrees to pay $230,000 in civil penalties

Direct Quotes from the Legal Record

QUOTE 1 Eight years without required major source permit allegations
“Based on information available to the EPA, from 2014 to March 7, 2022, Respondent’s Facility had the PTE more than 25 TPY VOCs, and therefore was a major stationary source and was a major source of HAPs.”

💡 The facility qualified as a major pollution source requiring comprehensive federal permits for eight consecutive years but never applied.

QUOTE 2 Complete absence of pollution controls allegations
“Based on information available to the EPA, from 2014 to March 7, 2022, Respondent caused the discharge of VOC with a vapor pressure greater than 0.002 psia from any installation in excess of 20 pounds per day and did not use a vapor control device to reduce the VOC discharged from its process equipment at the Facility.”

💡 For eight years, the company released toxic air pollution without even basic vapor controls that regulations require.

QUOTE 3 Separators left open to atmosphere profit
“The VOC-water separators were uncovered or partially open to the atmosphere.”

💡 The company did not even install basic lids on equipment handling hundreds of gallons of volatile toxic waste daily.

QUOTE 4 Major expansions without permits allegations
“The modifications made to Respondent’s Facility in 2017, 2018 and 2019 were major modifications, as that term is defined in COMAR 26.11.17.01B(16).”

💡 Each expansion increased pollution potential but the company bypassed construction permit reviews designed to require modern controls.

QUOTE 5 Misclassified hazardous waste to cut costs profit
“On February 6, 2019, the Facility sent 6,000 gallons of material described as Petroleum Contaminated Water on a non-hazardous Bill of Lading to ERC in Baltimore and, upon receipt, ERC determined the material was hazardous waste corrosive material with EPA Waste Code D002 and filled out a hazardous waste manifest on behalf of PMI prior to sending the material on to Cycle Chem on February 7, 2019.”

💡 The company avoided costly hazardous waste handling requirements by mislabeling 6,000 gallons of corrosive material as non-hazardous.

QUOTE 6 Toxic air pollutants confirmed in community health
“On September 8, 14, 15, and 16, 2020, the EPA conducted mobile air monitoring for VOCs and certain hazardous air pollutants at perimeter locations adjacent to the Facility.”

💡 EPA had to deploy specialized monitoring equipment to confirm that toxic emissions were escaping the facility and reaching nearby neighborhoods.

QUOTE 7 Exposing workers to known carcinogens health
“At the time of the Inspection, Respondent allowed VOCs, including HAP and VOHAP, in the off-site material to emit directly to the atmosphere.”

💡 Workers and nearby residents faced direct exposure to hazardous air pollutants including benzene, a known carcinogen.

QUOTE 8 Fire underscores uncontrolled risks health
“In March of 2022, indeed, Petroleum Management experienced a major fire event at the facility, halting operations.”

💡 A major fire at a facility handling volatile petroleum waste demonstrates the dangers of operating without adequate safety controls.

QUOTE 9 Massive oil storage near waterways without safeguards community
“According to the Facility’s SPCC Plan, the oil storage capacity of the Facility is approximately 80,000 gallons, and the Facility is located 2,000 feet from Curtis Creek, a tributary to Curtis Bay and Patapsco River. Both Curtis Bay and the Patapsco River are traditional navigable waters.”

💡 The facility stored 80,000 gallons of oil close to major waterways without proper spill containment or prevention measures.

QUOTE 10 Multiple tanks lacked any secondary containment allegations
“At the time of the August 26, 2021 SPCC Inspection, Respondent failed to provide Tanks 7, 8, and 9, Wastewater Receiving Tank 1, the solidification pit, drums/totes or two transfer areas with secondary containment.”

💡 Federal law requires secondary containment to prevent spills from reaching waterways, but the company left multiple tanks completely unprotected.

QUOTE 11 Never tested tanks for integrity profit
“At the time of the August 26, 2021 SPCC Inspection, Respondent had failed to perform integrity testing for each bulk storage containers 1-9 at the Facility.”

💡 The company avoided inspection and maintenance costs by never testing whether storage tanks could safely hold thousands of gallons without leaking.

QUOTE 12 Used incompatible, deteriorating containers profit
“At the time of the August 26, 2021 SPCC Inspection, Respondent failed to use compatible containers at the Facility for the storage of oil, specifically the solidification pit, strainer boxes, and Wastewater Receiving Tank 1.”

💡 The company stored oil and contaminated waste in corroded or inappropriate containers that increased the risk of releases.

QUOTE 13 Company admits compliance only after legal action accountability
“Respondent certifies to EPA, upon personal investigation and to the best of its knowledge and belief, that it currently is in compliance with the Administrative Order on Consent between Respondent and EPA, Docket No. CAA-03-2024-0060DA, which addresses the CAA violations alleged herein.”

💡 The company achieved compliance only after EPA issued an enforcement order, not through voluntary corporate responsibility.

QUOTE 14 Modest penalty after eight years of violations accountability
“In settlement of EPA’s claims for civil penalties for the violations alleged in this Consent Agreement, Respondent consents to the assessment of a civil penalty in the amount of TWO HUNDRED AND THIRTY THOUSAND DOLLARS ($230,000).”

💡 A $230,000 penalty for 17 counts across eight years may be far less than the millions saved by not installing required pollution controls.

QUOTE 15 No admission of wrongdoing in settlement accountability
“Except as provided in Paragraph 6, above, Respondent neither admits nor denies the specific factual allegations set forth in this Consent Agreement.”

💡 Settlement terms allow the company to pay a fine without admitting it harmed workers or communities for nearly a decade.

Frequently Asked Questions

What is Petroleum Management accused of doing?
EPA alleges that from 2014 through March 2022, Petroleum Management operated a waste processing facility in Baltimore that emitted over 25 tons per year of toxic air pollutants without obtaining required federal permits or installing pollution control equipment. The company also allegedly mishandled hazardous waste, failed to maintain spill prevention measures for 80,000 gallons of oil storage near waterways, and expanded operations multiple times without required environmental reviews.
How long did these violations go on?
The alleged violations span eight years from 2014 to March 2022. EPA did not conduct its first comprehensive inspection until September 2020, meaning the facility operated without required permits and controls for at least six years before regulators detected the full scope of noncompliance. The settlement was not finalized until April 2024, nearly ten years after violations allegedly began.
What toxic chemicals were released?
The complaint identifies volatile organic compounds and hazardous air pollutants including benzene (a known carcinogen), toluene, xylene, acrolein, and acrylonitrile. These substances can cause respiratory problems, long-term health effects, and contribute to ground-level ozone and smog formation. EPA deployed mobile air monitoring equipment in September 2020 that detected these pollutants at the facility’s perimeter.
Who was harmed by these violations?
Workers at the facility faced direct exposure to high concentrations of airborne toxins from uncovered processing equipment. Residents in surrounding Baltimore neighborhoods near Curtis Avenue were exposed to toxic air pollution for eight years. The nearby Patapsco River and its tributaries faced contamination risk from inadequate oil spill prevention at a facility storing 80,000 gallons. Children, elderly residents, and people with respiratory conditions in the community were particularly vulnerable.
Why did it take so long for EPA to act?
The complaint reveals systematic regulatory gaps including fragmented oversight across multiple environmental statutes, limited inspection frequency, and the complexity of detecting violations at facilities that expand incrementally rather than through single large projects. EPA did not conduct comprehensive mobile air monitoring or detailed inspections until 2020, six years after major violations allegedly began. The enforcement process from inspection to settlement took an additional four years.
How much is the company paying in penalties?
Petroleum Management agreed to pay $230,000 in civil penalties, divided as $187,243 for Clean Air Act violations, $29,463 for hazardous waste violations, and $13,294 for Clean Water Act violations. This total covers 17 separate violation counts spanning eight years. The settlement does not require the company to compensate affected community members or fund health studies.
Did the company admit wrongdoing?
No. The consent agreement explicitly states that except for jurisdictional matters, the company neither admits nor denies the specific factual allegations. This is a standard settlement provision that allows companies to resolve enforcement actions without acknowledging wrongdoing or accepting full accountability for alleged harms.
What pollution controls should have been installed?
Federal regulations required the company to install vapor control devices such as enclosed flares, condensers, or carbon adsorption units capable of capturing or destroying at least 85 percent of volatile organic compound emissions. The complaint alleges the facility operated for eight years without any of these controls, and in many cases left VOC-water separators completely uncovered.
What permits did the company fail to obtain?
EPA alleges the facility operated without a Title V operating permit required for major sources of air pollution, without Non-Attainment New Source Review construction permits required before making major modifications in a polluted air region, and without proper professional engineer certification of its Spill Prevention Control and Countermeasure plan. The company also failed to submit required annual emissions statements for multiple years.
What can residents do if they were affected?
Affected residents can document health problems and property impacts, contact local environmental justice organizations for support, request public records from EPA and Maryland Department of Environment about ongoing monitoring, attend public meetings about the facility’s compliance status, and consult with environmental attorneys about potential citizen suit provisions under federal environmental laws. Residents can also demand that local officials require independent air monitoring and community health assessments.
Post ID: 2507  ·  Slug: epa-voc-hazardous-waste-allegations-against-petroleum-management  ·  Original: 2025-03-15  ·  Rebuilt: 2026-03-20

You can find the consent agreement with this evil corporation by visiting the EPA’s website: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/08E13B8ABFCE797085258B09005808BA/$File/Petroleum%20Recovery%20and%20Remediation%20Management%20Inc%20dba%20Petroleum%20Management%20Inc_MM%20CAFO_April%2012%202024.pdf

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