Who They Are and What They Did

California Resources Corporation (CRC) is an oil and gas company headquartered at 1 World Trade Center, Suite 1500, Long Beach, California. It operates the Elk Hills Power Plant in Tupman, California through a wholly-owned subsidiary called Elk Hills Power, LLC. The plant burns natural gas and produces industrial wastewater as a byproduct of its operations.

To dispose of that wastewater, CRC holds federal permits under the Safe Drinking Water Act’s Underground Injection Control (UIC) program. The UIC program exists for one reason: to stop industrial waste from contaminating the underground water sources that communities drink from. Injection wells pump fluid deep into the earth, and if the pressure gets too high, the fluid can crack the surrounding rock and migrate toward protected aquifers.

The federal permit CRC operated under, designated Permit No. R9UIC-CA5-FY20-3 and issued on March 5, 2021, set a hard ceiling on how much pressure could be applied during injection: 200 pounds per square inch (psi). CRC’s own quarterly reports to the EPA showed that this limit was not just occasionally exceeded. It was shattered, repeatedly, across all three active injection wells at the facility.

The Numbers That Can’t Be Explained Away

According to the EPA’s consent agreement, the Maximum Allowable Injection Pressure (MAIP) of 200 psi was exceeded at well 25A-18G at least 335 times, at well 35A-18G at least 137 times, and at well 35-18G at least 382 times between July 1, 2018 and June 30, 2023. That is a five-year window. That is 854 documented pressure violations. And that is only what showed up in the quarterly reports CRC themselves submitted.

These are not rounding errors or sensor glitches. The permit required continuous monitoring of injection pressure. The violations were logged by CRC’s own systems, compiled into their own reports, and sent to the EPA. The company knew. The data existed. And the injections continued.

A Permit History That Shows They Knew the Rules

The 200 psi limit was established in 2003, when CRC’s predecessor entity actually requested a permit modification to raise the pressure ceiling to that level. They wanted 200 psi, they got 200 psi, and then they exceeded it 854 times. This was not an ambiguous rule. This was a limit they negotiated for themselves.

The original permit for these injection wells was issued on February 21, 2001. Over two decades, the facility operated under federal oversight that required continuous pressure monitoring, quarterly reporting, and full compliance with injection limits. CRC had access to lawyers, engineers, and compliance officers. They knew exactly what the limit was and exactly when they were breaking it.

$109,000: The Price of Poisoning a Community’s Water Supply

The EPA assessed a civil penalty of $109,000 (roughly enough to pay a mid-level marketing manager’s annual salary, or to cover about three months of rent for six families in Kern County). For five years and 854 violations of federal drinking water law, CRC will pay one hundred and nine thousand dollars. No admission of guilt. No criminal referral. No trial.

To understand how insulting that number is, consider this: the EPA’s own regulations allowed for penalties of up to $27,018 per day per violation, with a maximum administrative penalty of $337,725. CRC paid less than a third of the statutory maximum administrative penalty, despite having violated the law on at least 854 separate occasions across three wells over five years. The EPA’s own penalty ceiling was barely reached, let alone exceeded in any meaningful way relative to the scale of the violation.

CRC also agreed to a Supplemental Environmental Project (SEP) worth $282,000 (roughly what a Kern County schoolteacher earns over eight years). That money goes toward fixing up the Buttonwillow County Water District, the rural water utility serving the very community whose drinking water was at risk. The company gets credit for this in the settlement. It is framed as goodwill. In reality, it is the cost of making the problem go away quietly.

The Non-Financial Ledger: What Money Doesn’t Measure

Tupman, California is a small unincorporated community in Kern County. Kern County has one of the highest rates of environmental contamination exposure in the state of California. The people who live near the Elk Hills Power Plant are not Silicon Valley executives or Malibu homeowners. They are agricultural workers, refinery employees, and working-class families who have limited resources to relocate, limited political power to push back, and limited ability to test their own water for contamination. When CRC exceeded the injection pressure limit 854 times, those are the people whose drinking water was at risk.

The Buttonwillow County Water District, the entity named as the beneficiary of the $282,000 remediation project in this settlement, serves a community so under-resourced that the settlement specifically notes one of their drinking water wells had a deteriorating 40,000-gallon metal tank attached to it and no backup generator for power outages. These are the conditions under which people were drinking their water while CRC’s injection wells were repeatedly over-pressurized underground. The company that helped create the risk gets to take credit for paying to reduce the community’s vulnerability. That is what corporate accountability looks like in practice.

The five-year timeline of violations is worth sitting with. From July 2018 to June 2023, CRC submitted quarterly reports to the EPA that contained evidence of these violations. Every quarter, the data arrived. Every quarter, the violations were documented. The enforcement action was not filed until April 2024, which means communities near these wells lived with this risk for nearly six years before a public legal document confirmed what the data had been saying all along. There was no emergency order. There was no public health alert. There was paperwork, a penalty, and a settlement.

The consent agreement contains a clause requiring CRC to include a specific disclosure on any public statement they make about the $282,000 community water project. They must say it “was undertaken in connection with the settlement of an enforcement action taken by the U.S. Environmental Protection Agency for alleged violations of the Safe Drinking Water Act.” That disclosure requirement exists because without it, CRC would likely present this as voluntary philanthropic investment. That one sentence is the difference between the public knowing this was ordered remediation and thinking it was generosity. The fact that the EPA had to write that clause into the settlement tells you everything about how these corporations prefer to manage their public image.

Legal Receipts: Straight from the Document

“According to Quarterly Reports submitted by Respondents to the EPA pursuant to section II.E.5.b. of the 2021 Permit, the MAIP was exceeded at injection wells 25A-18G, 35A-18G, and 35-18G, at least 335, 137, and 382 times, respectively, between July 1, 2018 and June 30, 2023.” — EPA Consent Agreement and Final Order, Section IV, Paragraph 37

“Any permit noncompliance constitutes a violation of the SDWA and is grounds for enforcement action, permit termination, revocation and reissuance, or modification, or denial of a permit renewal application.” — EPA Consent Agreement and Final Order, Section IV, Paragraph 38, citing 40 C.F.R. § 144.51(a) and 2021 Permit Section III.E.1.

“Cease injection of any fluids into any injection well authorized under the Permit for at least twenty-four (24) hours if the applicable MAIP under the Permit has been exceeded for that well during injection for more than thirty (30) consecutive minutes.” — EPA Consent Agreement and Final Order, Section V.B., Paragraph 46.b. — This is a new rule CRC must now follow. It did not exist before because nobody thought they would have to write it down.

“Any public statement, oral or written, in print, film, or other media, made by Respondents or a representative of Respondents making reference to the SEP from the Effective Date of this CA/FO shall include the following language: ‘This project was undertaken in connection with the settlement of an enforcement action taken by the U.S. Environmental Protection Agency for alleged violations of the Safe Drinking Water Act.'” — EPA Consent Agreement and Final Order, Section V.C., Paragraph 58

“Respondents: admit the jurisdictional allegations of the CA/FO; neither admit nor deny specific factual allegations contained in the CA/FO; consent to the assessment of any stated civil penalty… and waive any right to contest the allegations and their right to appeal the proposed Final Order.” — EPA Consent Agreement and Final Order, Section II, Paragraph 7. Translation: They paid without fighting because fighting would have cost more and drawn more attention.

Societal Impact: Who Pays When Corporations Cut Corners

Public Health: A Well Under Pressure

The entire legal framework violated here, the Underground Injection Control program under the Safe Drinking Water Act, exists for one purpose: to prevent industrial fluid injection from contaminating underground sources of drinking water. The federal definition embedded in this case is unambiguous. Underground injection “endangers drinking water sources if such injection may result in the presence in underground water which supplies or can reasonably be expected to supply any public water system of any contaminant.” CRC exceeded the pressure limit set to prevent exactly that outcome 854 times.

The Maximum Allowable Injection Pressure is not arbitrary bureaucracy. Injection pressure limits exist because above certain thresholds, the mechanical integrity of the surrounding rock formation can be compromised. Cracks form. Fluids migrate. The boundary between industrial wastewater and a protected drinking water aquifer becomes porous. Each of CRC’s 854 violations was an instance where that threshold was crossed, where the margin of safety between industrial waste and drinking water was eroded. The EPA document does not say whether any contamination actually occurred, because the settlement resolves the matter without an adjudication of facts. The community does not get that answer.

The Buttonwillow County Water District was specifically selected as the beneficiary of the remediation project precisely because it serves the communities most proximate to the Elk Hills facility. The settlement funds plugging and abandonment of an aging standby drinking water well, demolition of a deteriorating 40,000-gallon metal tank, installation of a backup generator at an active well, and potentially a chlorination system. These are not luxury upgrades. These are basic infrastructure components that any functioning water system should already have. The fact that this rural, working-class water district lacked backup power and had a deteriorating metal tank holding tens of thousands of gallons of water tells you everything about how environmental investment is distributed in California.

Economic Inequality: The Geography of Who Gets Poisoned

Kern County, where Tupman and Buttonwillow sit, is one of the most economically distressed counties in California. It is also one of the most heavily industrialized, home to oil fields, refineries, agricultural operations, and power plants that would never be sited in wealthier zip codes. The people who live near the Elk Hills Power Plant are not in a position to hire environmental lawyers, commission independent water testing, or lobby state legislators for stronger enforcement. They rely on federal agencies like the EPA to enforce the law on their behalf.

CRC’s penalty of $109,000 (about the cost of a moderately loaded luxury SUV) for five years of documented violations illustrates the structural imbalance at the core of environmental enforcement. The maximum administrative fine under the law, $337,725, was not reached. The per-day penalty of up to $27,018 was never applied at scale. The economic deterrent that federal law theoretically provides did not function. Instead, the company was assessed a fine well below the statutory ceiling, required to fund a community water project as partial credit, and allowed to close the case without admitting any wrongdoing. In economic terms, the cost of compliance almost certainly exceeded the cost of violation. That is the message the settlement sends to the next corporation doing the same math.

The settlement document notes that CRC must not receive any reimbursement for SEP expenditures from any other party and cannot deduct the civil penalty for federal tax purposes. Those provisions acknowledge the obvious temptation to recover costs. But they do nothing to change the fundamental calculus: CRC operated for five years in violation of federal law, saved money by not addressing the pressure exceedances, and resolved the matter for less than the price of a modest home in the communities it put at risk.

The “Cost of a Life” Metric

What Now: Names, Roles, and Watchdogs

The People Who Signed This

The following individuals were named in the consent agreement and certificate of service. Their roles put them at the center of this settlement:

• Jonathan Hilton, Vice President, San Joaquin Valley/Santa Maria Operations, California Resources Corporation. His name appears on the official correspondence list as the company’s operational leadership contact for the facility.
• Brandon Myers, Plant Manager, Elk Hills Power, LLC. The on-site manager of the facility where 854 pressure violations occurred. Listed as a named recipient of the final order.
• Amy C. Miller-Bowen, Director, Enforcement and Compliance Assurance Division, EPA Region 9. The EPA official whose division brought and settled this action.

The Watchdogs Who Must Do Better

• EPA Region 9 (San Francisco): The agency that took nearly six years from the start of violations to a final settlement. They have the authority to enforce and the obligation to move faster. Contact: www.epa.gov/aboutepa/epa-region-9-pacific-southwest
• California State Water Resources Control Board: While California lacks primacy for Class V wells, the state has overlapping authority over groundwater protection and should be monitoring outcomes here.
• OSHA (Region 9): Worker safety at industrial injection facilities is a parallel concern when pressure systems are operating at or above their design limits.
• DOJ Environment and Natural Resources Division: If CRC violates this consent agreement, the EPA is authorized to refer the matter to the Department of Justice for civil or criminal enforcement.

What You Can Do Right Now

If you live in Kern County or the San Joaquin Valley, your local water board has a public comment process. Attend it. The Buttonwillow County Water District is a small, under-resourced utility that is now receiving remediation money because of this settlement. That money comes with EPA oversight. Show up at that oversight. Contact the Central Valley Regional Water Quality Control Board and demand they track the outcome of the injection well compliance plan CRC is required to submit. And if you are a renter or homeowner anywhere near oil and gas infrastructure in California, request a copy of the nearest UIC well permit from the EPA Region 9 office. You have a right to that document. Reading it is the first act of resistance.