Air Enforcement: Alabama Department of Environmental Management and Conecuh County Gas/Oil Production Wellsite Enter into Consent Order

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The Alabama Department of Environmental Management (“ADEM”) and Fletcher Petroleum CO., LLC (“Fletcher”) entered into a March 26th Consent Order (“CO”) addressing an alleged violation of an air permit. See Consent Order No. XX-XXX-CAP.

The CO provides that Fletcher operates the Brooklyn Field Area No. 1 (“Facility”).

The Facility is described as a group of wellsites for oil and gas production in Conecuh County, Alabama.

Fletcher is stated to operate the Facility pursuant to the authority of a Major Source Operating Permit. Such Permit is stated to contain requirements for a 145 BHP generator engine located at the referenced oil and gas production well.

The CO provides that the periodic monitoring report for the reporting period of January 1 through June 30, 2023, was received late by ADEM. Further, ADEM is stated to have inspected the Facility and discovered during the onsite records review that GEN-01exceeded the 100 operating ours limit for using propane as a fuel on January 2023, and that therefore the engine should have been tested by January 2024.

Fletcher is stated to have attempted to conduct a stack test on GEN-01 on July 16, 2024, but the initial calibrations for the engine failed. Fletcher informed ADEM that the stack test had been aborted, and that the engine had been removed from service that same day.

ADEM is stated to have requested the data from the July 16, 2024 stack test and Fletcher provided calibration data. Fletcher further informed ADEM that while investigating the cause of the calibration failures, the catalyst on GEN-01 was found to have imploded.

Fletcher neither admits nor denies ADEM’s contentions.

A civil penalty of $20,000.00 is assessed.

A copy of the CO can be downloaded here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

© Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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