Core Allegations: What They Did

• HIGH Hilcorp failed to capture 100 percent of VOC emissions from its storage tanks.
• HIGH The company operated its Mahoning-Buckner facility without the required permit authorization.
• HIGH Hilcorp used an open flare at one facility instead of the required enclosed combustion device.
• MEDIUM The company failed to design and size its vapor control systems to route all tank vapors correctly.
• HIGH Hilcorp’s facilities released unlawful VOCs and other air pollutants into the atmosphere.

Regulatory Failures: How Oversight Broke Down

• HIGH Hilcorp violated the Clean Air Act.
• HIGH The company breached the Pennsylvania Air Pollution Control Act.
• HIGH Hilcorp failed to follow the specific terms and conditions of its GP-5 permits.
• MEDIUM The company ignored federally approved state implementation plan provisions.

Public Health and Safety: Unsafe Emissions

• HIGH Hilcorp released volatile organic compounds (VOCs) into the air.
• HIGH These emissions contribute to the formation of ground-level ozone.
• HIGH The company’s facilities emit hazardous air pollutants (HAPs) and methane.
• MEDIUM Uncontrolled vapors create smog through chemical reactions in heat and sunlight.

Corporate Accountability Failures

• HIGH Hilcorp lied in permit applications by claiming it captured 100 percent of VOC emissions.
• HIGH The company attempted to claim an exemption for a facility that did not qualify.
• HIGH Hilcorp operated industrial facilities without proper plan approval.

Profiting from Complexity

• MEDIUM Hilcorp used an open flare to bypass the requirement for an enclosed combustion device.
• MEDIUM The company used the technicality of an exemption to avoid mandatory permitting.

Evidence from the Case

“unlawful emissions of volatile organic compounds (“VOC”) and other air pollutants”

“Hilcorp represented that 100 percent of VOC emissions from storage tanks at each facility was captured and routed to a control device”

“Hilcorp used an open flare at this facility, rather than an enclosed combustion device”

“the facility does not qualify for exemption from the Pennsylvania SIP’s plan approval or permitting requirements”

“Hilcorp had failed to ensure that each of its vapor control systems was adequately designed and sized”

“the condensate and produced water (which still contains some condensate, even after initial separation) continue to emit vapors due to liquid level changes and temperature fluctuations”

“Hilcorp’s failure to comply with GP-5 requirements at these facilities is a violation of federally approved SIP provisions”

The Bottom Line: Accountability Questions

Is it legal for a company to claim total compliance while leaking toxins? No, it is a blatant violation of the law and a betrayal of public trust. Hilcorp lied about its capture rates to obtain permits, which is a direct attack on the integrity of our environmental protections.

How much air pollution did Hilcorp dump into our atmosphere? They dumped massive amounts of uncaptured VOCs and methane into the air. This is not just a technical error; it is a continuous release of harmful pollutants that residents had to breathe.

Why did regulators allow Hilcorp to operate under these false pretenses for so long? Corporate giants often exploit gaps in oversight to maximize profit. We must demand more frequent, unannounced inspections to catch these lies in real time.

What can I do to prevent this from happening again? You can take action by supporting local environmental monitoring groups and demanding that your representatives fund robust enforcement for the EPA and state agencies. Real accountability requires constant, public pressure.

Is this just a minor fine for a massive environmental crime? The government is seeking maximum civil penalties for a reason. We must ensure these fines are high enough to actually hurt the company’s bottom line, otherwise, they will just treat these penalties as the cost of doing business.

Can we trust any energy company’s permit application if they lie about capture rates? Not without strict, third-party verification. Hilcorp’s deception proves that self-reporting is a failed system that favors corporate greed over human health.

Does Hilcorp prioritize its bottom line over the air we breathe? Everything about this case suggests yes. By using cheaper, illegal equipment like open flares, they chose to save money while poisoning the community.

Will this lawsuit actually force real changes in how they manage vapors? Only if the court imposes strict injunctive relief. We need more than just money; we need mandatory, proven upgrades to every single one of their vapor control systems.

How many other facilities are hiding similar emission leaks? The scale of this violation suggests a systemic pattern. If they lied about these six facilities, we must assume their entire operation is under suspicion.

Are the penalties high enough to stop this behavior? The current pursuit of statutory maximums is a start, but true deterrence requires holding the executives themselves responsible for these environmental crimes.