EPA v. CONOCOPHILLIPS-MULTI SITES-2020 TX O&G FLYOVER CAFO-FY2024

Case summary

EPA Region 6 issued a Consent Agreement and Final Order (CAFO) to ConocoPhillips Company (ConocoPhillips) located in Houston, Texas. This CAFO is entered into under Section 113(d) of the Clean Air Act, as amended, 42 U.S.C. 7413(d), and the Consolidated Rules, 40 C.F.R. Part 22. The CAFO was issued in response to violations of Texas's federally approved State Implementation Plan (SIP). EPA alleges the following violations for the Facilities: a. Respondent violated 30 Tex. Admin. Code 106.4(c) by failing to maintain the Facilities emissions control equipment in good condition and properly operate such equipment. b. Respondent violated 30 Tex. Admin. Code 106.6(b) by failing to operate equipment consistent with operating procedures in the Facilities certified registrations. c. Respondent violated 30 Tex. Admin. Code 106.6(c) by varying from representations in the Facilities certified registrations regarding emissions at the Facilities. d. Respondent violated 30 Tex. Admin. Code 106.352(l)(1) by failing to comply with the requirements of 30 Tex. Admin. Code 106.492. e. Respondent violated 30 Tex. Admin. Code 106.492(l)(B) by failing to equip certain facilities with a continuously burning pilot or automatic ignition system that assures gas ignition. f. Respondent violated TCEQ Non-Rule Standard Permit for Oil and Gas Facilities (e)(1) by failing to ensure that facilities that have the potential to emit air contaminants are maintained in good working order and are operating properly during facility operations. g. Respondent violated TCEQ Non-Rule Standard Permit for Oil and Gas Facilities (e)(5) by failing to ensure that emissions from tanks are captured and routed to a control device with a minimum design control efficiency as specified in Table 10. h. Respondent violated TCEQ Non-Rule Standard Permit for Oil and Gas Facilities (e)(6) by not properly maintaining seals and gaskets to prevent leaking and not ensuring that tank hatches remain closed except during sampling, gauging, loading, unloading, or planned maintenance activities. i. Respondent violated TCEQ Non-Rule Standard Permit for Oil and Gas Facilities (e)(11)(A) and (E) by failing to ensure that the flares are lit at all times when waste gas streams are present and that flare tips are monitored per the specifications in 40 C.F.R. 60.18. j. Respondent violated TCEQ Non-Rule Standard Permit for Oil and Gas Facilities (e)(11)(B) by not ensuring adequate combustion at the flares. The CAFO requires ConocoPhillips to pay a penalty as well as satisfy an injunctive relief package that includes permitting and operational reviews, site inspections, engineering assessments at the facility, monthly OGI surveys and reports to EPA, and installation of monitoring equipment such as tank pressure monitors. ConocoPhillips shall send a letter to EPA detailing the work completed within one (1) year from the effective date of the CAFO.

Defendants (1)

• ConocoPhillipsNamed in complaintNamed in settlement

Facilities (8)

• BATTLESHIP CENTRAL FACILITY

  FROM ORLA, NW ON US HWY 285 N 10.9 MI, TURN LEFT 1, ORLA, TX, 79770

  Registry ID: 110070824239

• CONOCOPHILLIPS - TB-CHERRY PIE-57-T1-20-A

  SEE LAT/LONG, ORLA, TX, 79770

  Registry ID: 110071084295

• CONOCOPHILLIPS - RUSTLER HILLS 7-1H AND 2H BATTERY

  SEE LAT/LONG, ORLA, TX, 79770

  Registry ID: 110071084295

• CONOCOPHILLIPS - EL JEFE TANK BATTERY

  SEE LAT/LONG, ORLA, TX, 79770

  Registry ID: 110071084295

• CONOCOPHILLIPS - RAMSEY 10-1H BATTERY

  SEE LAT/LONG, ORLA, TX, 79770

  Registry ID: 110061343942

• CONOCOPHILLIPS - NORTH WATER TRANSFER FACILITY

  SEE LAT/LONG, ORLA, TX, 79770

  Registry ID: 110071084295

• CONOCOPHILLIPS - TEXAS 6 WF1

  NW ON US 285N, TAKE CR 447 TO CR 449 AND CARLSBAD, ORLA, TX, 79770

  Registry ID: 110070824146

• CONOCOPHILLIPS - RAMSEY WC 22-1H BATTERY

  SEE LAT/LONG, ORLA, TX, 79770

  Registry ID: 110071084295

Statutes cited

• CAA PARTD — New Source Review Permit Requirements
• CAA 173 — New Source Review Permit Requirements

Enforcement conclusions (2)

• CONOCOPHILLIPS-MULTI SITES-2020 TX O&G FLYOVER CAFO-AMENDMENT-FY2025entered 2025-05-15

  Primary law: CAA

• CONOCOPHILLIPS-MULTI SITES-2020 TX O&G FLYOVER CAFO-FY2024entered 2024-08-21

  Primary law: CAA

  Federal penalty: $490,000

Timeline (3 milestones)

• 2024-08-21Complaint Filed/Proposed Order
• 2024-09-09Enforcement Action Data Entered
• 2025-05-15Final Order Issued