Oil & Gas Producer Agrees to $1 Million Air Pollution Fine

2020 Environmental Real Estate IssuesTo settle a civil suit brought by the United States and the State of Colorado alleging unauthorized air emissions, K. P. Kaufmann Company, Inc. (“KPK”) agreed to pay a $1 million civil penalty, install additional pollution controls at 67 oil and gas production facilities in Colorado, and implement three mitigation projects to reduce emissions beyond regulatory requirements, according to US Department of Justice (“DOJ”) and US Environmental Protection Agency (“EPA”) information released January 21, 2020.

Condensate Tank Emissions
EPA and the State of Colorado filed suit based on an investigation of KPK from 2013 to 2018, which found unauthorized emissions of volatile organic compounds from many condensate storage tanks.  Among the problems were undersized vapor control systems and inadequate maintenance.

Required Additional Pollution Controls
The required additional controls, estimated to cost $2.5 million, include:

  1. upgrading KPK’s vapor control systems;
  2. evaluating its pressure relief valves and other equipment that may contribute to unauthorized emissions, followed by repairing, replacing, or upgrading as needed;
  3. implementing a directed inspection and preventative maintenance program, including regular use of infrared cameras, to ensure proper upkeep of control systems and identification of repairs needed to stop or prevent leaks; and
  4. installing pressure monitors with continuous data reporting to minimize tank over pressurization.

Mitigation Projects
In addition to the required controls, the settlement requires KPK to implement three mitigation projects: 1) installation of rod lifts to reduce the need to unload wells, 2) scanning for emissions at production facilities with a Boreal Laser, and 3) increasing inspections at four production facilities not covered by air pollution regulations due to their size.
For a copy of the DOJ press release https://www.justice.gov/opa/pr/justice-department-epa-and-state-colorado-announce-settlement-kp-kauffman-co-reduce-emissions

EPA’s information on the settlement is at https://www.epa.gov/enforcement/kp-kauffman-company-settlement