Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards

Context Corner Edition 10

April 3, 2025

By Carrie Crumpton, CNX Vice President of Environmental Strategy

Hey Carrie, what’s up with the NOVs coming in on the wells CNX acquired in Westmoreland County?

CNX’s Standard of Accountability

First off, acquiring an oil and gas company generally means inheriting all liabilities, past and present, including notices of violation (NOVs). As the new owner, CNX is responsible for addressing these violations, which can range from minor paperwork/administrative issues to other environmental/regulatory-related non-compliances.

CNX is very proud of our high operational and compliance standards, and we are known for our transparency. Some of the issues we inherited were discovered and reported by the previous operator during the standard due diligence process prior to the acquisition, and some have been identified by our team post-acquisition.

Regardless of previous compliance status, CNX is taking responsibility for these non-compliance matters and is excited to bring these assets into our portfolio and incorporate our operational, safety, and environmental standards. We are also implementing our Radical Transparency program at these sites, which includes information on air quality and other monitoring above and beyond regulatory standards.

*CNX’s Herminie Pad in Sewickley Township, Westmoreland County, was recently inherited through the acquisition of Apex Energy.*

Differing Views of Responsible Operation

In addition to differing operations’ standards in an acquisition, another challenging aspect that comes into play is the differing views of what responsible operation entails. CNX believes that responsible operation includes following regulations, being very transparent, and self-reporting when conditions arise that may lead to a violation.

CNX also aims to adhere to the spirit of the regulations and/or seek guidance from the DEP in cases of uncertainty about permitting, reporting, and mitigation expectations. The key is to develop a plan to align the new assets and expectations with CNX’s standard of responsible operation. One of the first things we did was meet with the DEP to discuss the known issues related to the acquired sites. This ensures that everyone is on the same page with the next steps, including the implementation of process and safety improvements.

CNX’s Commitment to Compliance

CNX believes that a responsible operator prioritizes safety, environmental stewardship, and ethical practices in all aspects of their operations. Responsible operators adhere to stringent regulatory standards, invest in advanced technologies to minimize impact and maintain transparent communication (self-reporting) with stakeholders, including local communities and regulatory bodies. CNX is proud of being a leader on this front and attempts, in every aspect, to demonstrate responsible operatorship and follow the letter and spirit of the law.

As we identify potential compliance items, we report them to the regulatory agency. You might wonder why the operator who says they are conscientious and self-reports is also the operator who gets violations. We wonder that too sometimes, but it’s a bit like being the kid who raises their hand in class—you’re more likely to get called on. By actively reporting compliance issues, CNX is taking responsibility and showing transparency, which can sometimes mean more scrutiny. But it’s all part of being a responsible operator, instilling confidence in how we operate within our communities, and ensuring long-term success. CNX continues to actively call on our peers to do the same and encourage the agencies to focus their efforts on identifying and addressing operators who do not meet these calls.

CNX is actively managing and working with the Department to quickly resolve a number of violations recently identified through the acquisition while simultaneously bringing the assets into conformance with CNX’s operating standards. A summary of these and their current status is noted below.

Project Name	Permit Number	Reported to DEP Date	Violation Description
PF Eisaman South 43	129-28941	1/31/2025	Unreported release prior to acquisition. Reported by CNX on 1/31/25.
Norah Well Pad and Pipelines	ESX17-129-0016	1/20/2025	Failure to submit the NOT prior to expiration of ESCGP (NOV received 1/31/25).
Steel to Faulk Pipeline	ESG17-129-0017	1/14/2025	Failure to submit the NOT prior to expiration of ESCGP (NOV received 1/31/25).
McIlvaine to Spectra Pipeline	ESG16-129-0012	1/14/2025	Failure to submit the NOT prior to expiration of ESCGP (NOV received 1/31/25).
Stewart McIlvaine Pipeline	ESG16-129-0006	1/14/2025	Failure to submit the NOT prior to expiration of ESCGP (NOV received 1/31/25).
Faulk-Fetur Pipeline	ESG16-129-0018	1/14/2025	Failure to submit the NOT prior to expiration of ESCGP (NOV received 2/3/25).
Graham Well Pad	65-01139A	1/13/2025	Agency inspection finding related to performance test (NOV issued 2/3/25).
Weitz South 20 Compressor Station	65-01118	1/13/2025	Agency inspection finding related to performance tests (NOV issued 1/28/25).
Herminie Well Pad	129-29262	2/14/2025	Unreported release prior to acquisition. Discovered and reported by CNX on 2/14/25 (NOV issued 2/18/25).
Draftina Central Pad-31	ESG076522011-00	2/27/2025	Erosion and sediment control repairs in process at time of inspection (NOV received 3/5/25).
Marian Laskowski 6	129-27145	1/31/2025	Failure to P&A in 2024 (NOV received 3/14/25).
Marian Laskowski 7	129-27422	1/31/2025	Failure to P&A in 2024 (NOV received 3/14/25).