EPA v. Devon Energy Production Co.

Case summary

On February 21, 2018, EPA Region 6 and Devon Energy Corporation (Devon) entered into an Administrative Order on Consent (AOC) under Clean Air Act (CAA) Authority for addressing potential violations at multiple energy extraction facilities owned/operated by Devon in the Eagle Ford Shale Formation (EFS) located in the state of Texas. The AOC was issued in response to the following types of violations: a. Devon Energy violated 30 T.A.C. 106.4(c) by failing to maintain in good condition and properly operate the emissions control equipment at certain Facilities; b. Devon Energy violated 30 T.A.C. 106.492(l)(B) by failing to equip certain Facilities with a continuously burning pilot or automatic ignition system that assures gas ignition; c. Devon Energy violated 30 T.A.C. 106.352(e)(11)(E) by failing to operate flares used for control of emissions from production units such that the flares are lit at all times when gas streams are present; d. Devon Energy violated 30 T.A.C. 106.352(m), Table 8, by failing to record the time, date, and duration of any loss of flame, pilot flame, or auto-ignition; e. Devon Energy violated 30 T.A.C. 106.352(e)(1) by failing to ensure that hatch seals were maintained in good working order and operated properly during facility operations; f. Devon Energy violated 30 T.A.C. 106.352(e)(5)(C) by failing to ensure that thief hatches, which are not designed to be completely sealed, were closed except during sampling, gauging, loading, unloading, or planned maintenance activities; g. Devon Energy violated 30 T.A.C. 116.615(9) by failing to ensure that equipment was maintained in good working order and operating properly during normal facility operations; h. Devon Energy violated 30 T.A.C. 116.620(a)(12) by failing to ensure adequate combustion in flares and failing to properly conduct pilot flame monitoring; and i. Devon Energy violated 30 T.A.C. 116.620(b)(1)(D) by failing to either (i) install a floating roof on storage tanks or (ii) route tank emissions to a destruction device such that a minimum VOC destruction efficiency of 98% is achieved or to a vapor recovery system such that a minimum VOC recovery efficiency of 95% is achieved.

Defendants (1)

• Devon Energy Production Co., L.P.Named in complaintNamed in settlement

Facilities (51)

• DEVON ENERGY HEIBEL A 1 PRODUCTION FACILITY

  SEE LAT/LON OR COMMENT, YOAKUM, TX, 77995

  Registry ID: 110069571546

• DEVON ENERGY MUSICK A 1H - 7H PRODUCTION FACILITY

  SEE LAT/LON AND COMMENT, NORDHEIM, TX, 78141

  Registry ID: 110069567873

• DEVON ENERGY ELDER B 1 PRODUCTION FACILITY

  SEE LAT/LON OR COMMENT, CUERO, TX, 77954

  Registry ID: 110069571029

• DEVON P FRISBIE B 2H 3H 4H

  SEE LAT/LON AND COMMENT, RUNGE, TX, 78151

  Registry ID: 110070107037

• DEVON ENERGY ULRICH A 1H AND ULRICH B 1H PRODUCTION FACILITY

  SEE LAT/ LONG, HOCHHEIM, TX, 77967

  Registry ID: 110069564590

• DEVON ENERGY WARWAS A 1H PRODUCTION FACILITY

  SEE LAT/ LONG, NORDHEIM, TX, 78141

  Registry ID: 110069570510

• DEVON ENERGY SCHENDEL A1 PRODUCTION FACILITY

  SEE LAT/ LONG, NORDHEIM, TX, 78141

  Registry ID: 110069566160

• DEVON ENERGY HEIBEL A 2H 8H PRODUCTION FACILITY

  SEE LAT/LON OR COMMENT, WESTHOFF, TX, 77995

  Registry ID: 110069565526

• DEVON ENERGY MIGURA B NO 1H PRODUCTION FACILITY

  SEE LAT/LON AND COMMENT, NORDHEIM, TX, 78141

  Registry ID: 110069570253

• DEVON ENERGY JORDAN A NO 1H JORDON B NO 1H PRODUCTION FACILITY

  SEE LAT/LON AND COMMENT, YORKTOWN, TX, 78164

  Registry ID: 110069566874

• DEVON ENERGY STEINMAN A 1H AND STEINMAN A NO. 2H PRODUCTION SITE

  SEE LAT/ LONG, YOAKUM, TX, 77995

  Registry ID: 110069571573

• DEVON ENERGY BUCKHORN B H1 PRODUCTION FACILITY

  SEE LAT/LON OR COMMENTS BELOW, CUERO, TX, 77954

  Registry ID: 110069567953

• DEVON ENERGY MUIR D NO. 1 & MUIR E NO. 1 PRODUCTION FACILITY

  SEE LAT/LON AND COMMENT, HOCHHEIM, TX, 77967

  Registry ID: 110069565919

• DEVON ENERGY NELSON A NOS 3H AND 4H PRODUCTION FACILITY

  SEE LAT/ LONG, NORDHEIM, TX, 78141

  Registry ID: 110069566008

• DEVON ENERGY PEEBLES A 1H, 2H, & 3H PF PRODUCTION FACILITY

  SEE LAT/ LONG, HOCHHEIM, TX, 77967

  Registry ID: 110069566758

• …and 36 more

Statutes cited

• CAA PARTD — New Source Review Permit Requirements
• CAA 173 — New Source Review Permit Requirements
• CAA 110 — Implementation Plan for National Primary and Secondary Ambient Air Quality Standards

Enforcement conclusions (1)

• Devon Energy Production Co.entered 2018-02-22

  Primary law: CAA

Timeline (4 milestones)

• 2018-02-22Final Order Issued
• 2018-03-22Enforcement Action Data Entered
• 2018-08-20Air Resolved
• 2019-06-28Enforcement Action Closed