EPA v. Circle-S Energy LLC-Section 3 Central Production Facility-2024 Flyover-CAFO With Inj Relief_FY2026

Case summary

EPA contracted helicopter flyovers of the Permian Basin between July 22, 2024, and August 19, 2024, to assess energy extraction facility emissions using Optical Gas Imaging ( OGI ) technology. EPA has conducted a comprehensive review of the facility-specific information gathered based upon observations made from the OGI video captures, facility permitted operations, and information provided by Respondent. Based on this review, EPA alleges the following violations for the Facility: a. Respondent violated TCEQ Non-Rule Standard Permit for Oil and Gas Facilities (e)(l) 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. b. Respondent violated TCEQ Non-Rule Standard Permit for Oil and Gas Facilities (e)(ll)(E) by failing to ensure that the flares are lit at all times when waste gas streams are present. c. Respondent violated 30 Tex. Ad min. Code 116.615(2) by failing to operate equipment consistent with the operating procedures set forth in the applicable permit listed in Appendix A. d. Respondent violated 30 Tex. Adm in. Code 116.615(9) by failing to ensure that equipment was maintained in good working order and operating properly during normal facility operations.

Defendants (1)

• Circle-S Energy LLCNamed in complaintNamed in settlement

Facilities (1)

• CIRCLE S ENERGY - SECTION 3 CENTRAL PRODUCTION FACILITY

  SEE LAT/LONG, MENTONE, TX, 79754

  Registry ID: 110071468265

Statutes cited

• CAA 173 — New Source Review Permit Requirements

Enforcement conclusions (1)

• Circle-S Energy LLC-Section 3 Central Production Facility-2024 Flyover-CAFO With Inj Relief_FY2026entered 2026-08-11

  Primary law: CAA

  Federal penalty: $59,700

Timeline (2 milestones)

• 2026-08-11Final Order Issued
• 2026-09-02Enforcement Action Data Entered