State database lists 1,000-plus Citation entries in pollution reports and rule violations
The Bayou is a mile-wide oil field about 30 miles north of the Texas border outside Ardmore, Oklahoma. In June 2023, agency staff had spent more than a year building a case to punish Citation Oil & Gas, one of the nation’s largest privately owned oil companies. Toxic wastewater was gushing from the ground, leaving oily sheens on creeks and long streaks of salt across the land. The purges bubbled up among stands of oak and walnut trees, threatened drinking-water sources and drew attention from the Environmental Protection Agency, according to a federal report. State investigators attributed the pollution to Citation’s high-pressure injection wells, which pump oil-production wastewater underground to produce more oil.
After the Oklahoma Corporation Commission asked Citation to halve injection pressures, the company refused. Oil-division staff recommended punishment through the commission’s administrative law court. Agency manager Danny Ray wrote that “This will be an important case to get some of these purges stopped and particularly concerning Citation’s operations,” then called the situation “an emergency situation that needs to be addressed promptly” three days later. The commission temporarily shut all 22 Bayou injection wells, 19 owned by Citation, beginning a yearlong fight over the terms for restarting them. Citation repeatedly sought permission and challenged the state through the commission’s court to prove the connection between the Bayou purges and its operations.
Commission leadership did not follow that recommendation. In April 2024, officials including Robyn Strickland, then director of the Oil and Gas Conservation Division, approved a plan to bring seven of Citation’s 19 Bayou injection wells back online at pressures higher than Halff recommended, though lower than Citation requested. By the end of 2024, six more wells had been authorized, bringing the total to 13. Current and former employees said the decision came from senior leaders, including Strickland and deputy director Mike McGinnis, and bypassed objecting staff. One agency manager said, “They wore us out.” McGinnis did not respond to requests for comment.
The Frontier and ProPublica’s yearlong investigation found that agency leaders’ reluctance to punish Citation reflected a longstanding pattern in which Oklahoma regulators allowed oil companies to contaminate drinking water, farmland and people’s homes with scant consequences. The commission has no record of ever fining Citation or completing an enforcement case against it. Citation, one of the nation’s largest privately owned oil companies, was the most frequently named company in the agency’s database of pollution reports and other rule violations. Its more than 1,000 listings over the past decade represented hundreds more incidents than any other operator, including comparably sized companies. In recent years, purges linked to Citation included some of Oklahoma’s longest, most damaging oil field pollution events.
Citation has become Oklahoma’s second-largest well owner after taking over collections of aging, low-producing wells from major operators that had largely left the state for more lucrative fields in Texas and elsewhere; the company acquired its Bayou wells in 2010. Current and former employees described top agency officials as wary of going after habitual violators like Citation. They said regulators treated the company gently because it held onto aging, low-producing wells worth little; those wells could become a financial liability for Oklahoma if Citation sold or walked away from them. One current manager, speaking on condition of anonymity to protect their job, said, “Citation has been the thorn in my side for a long time.” The manager added, “They just operate however they want. They’ve had major pollution issues, and you can’t really touch them.”
Spokesperson Jack Damrill declined to answer questions about the commission’s handling of Citation’s record, noting the possibility of future enforcement or litigation. He said, “The OCC Oil and Gas Conservation Division must remain mindful of its regulatory and adjudicatory responsibilities and avoid making public statements that could potentially affect future proceedings or legal considerations.” Strickland had left the agency to become chief projects officer for the Interstate Oil and Gas Compact Commission, a quasi-governmental organization that often advocates for industry interests, and did not respond to comment requests. A Citation executive declined to comment in response to written questions. Neither the commission nor Halff responded to questions about whether the consulting firm still had a role at the state agency.
At a November 2023 meeting in the Oklahoma Corporation Commission’s Oklahoma City headquarters, five months into the shutdown, regulators and company officials packed a small conference room to discuss how injection might restart; more than a dozen others joined by video. State consultants presented a report with evidence tying Citation’s injection to wastewater surfacing in the Bayou. The state had hired environmental engineering firm Halff earlier that year under a $550,000 contract to investigate the fast-growing number of oil-field wastewater eruptions around Oklahoma. According to a video recording of the meeting obtained by The Frontier and ProPublica, consultants and agency staff presented a unified front in identifying the problem: Citation’s nearly two dozen Bayou injection wells were operating at unsafely high pressures. Over the years, injected wastewater had shattered underground rock layers, allowing toxic fluid to spread uncontrollably.
Carolyn May, Halff’s director of environmental remediation, said, “You definitely have overpressurization,” and then, “It’s allowing that rock to fracture.” May said the calculations used well records, field data collected by agency staff and a federal standard. Current and former commission officials said the consultants were meant to serve as independent experts and mediate disagreements within the agency over how to address the wastewater eruptions. Agency imaging showed a plume of highly polluted wastewater rising from the injection zone, posing a threat to freshwater that some residents use for drinking and cooking. May added, “That’s our primary concern here.”
May and agency staff also raised problems with Citation’s wells that regulators had overlooked for years, including more than a dozen exemptions from testing and well-construction standards that endangered groundwater. Several wells had checkered compliance records. Agency documents noted that one had been in “perpetual violation” of its permit for “nine years running” and injecting tens of millions of gallons beyond the legal limit. Nearby were dozens of abandoned, unplugged wells that could provide pathways for pressurized wastewater to reach shallow freshwater and the surface. May singled out a handful that especially troubled her team, and oil-division deputy director Mike McGinnis suggested permanently plugging them. Nearby groundwater tests showed oil-field wastewater pollution, including high levels of salt, bromide and the carcinogen benzene, which exceeded the EPA drinking-water standard by five times. Earlier in 2023, the Environmental Protection Agency had warned of “potential endangerment to underground sources of drinking water” in the Bayou.
Citation disputed that its wells caused the purges. Its consultants attributed the pollution to historic drilling that began in the 1920s, wastewater dumped into large, unlined pits and recent rainfall. To bolster that position, the company’s consultants produced detailed reports citing the area’s history and Citation’s own water-testing data. The reports said old pollution that saturated the land was being flushed to the surface by rainfall, and each concluded there was no link between Citation’s injection and the Bayou pollution.
Engineering manager Jeff Lewis said the company’s data showed its wells were not responsible and that it could safely inject at pressures above Halff’s recommendation. He proposed restarting Citation’s deeper wells because rock layers separated them from abandoned wells Halff had identified as likely pathways for wastewater to surface. Agency staff and Halff rejected that conclusion, criticizing the company’s sampling practices as biased toward the rainfall explanation. They acknowledged old pollution across the Bayou but said recent purges had pushed significant volumes to the surface, covering creek beds in layers of snow-white salt. Old pollution would not have been that forceful, according to internal documents written by agency staff. In an internal memo, Ray wrote, “A purge is created by pressure and is not due to old pits.” May said the state’s evidence pointed to an injection problem and concluded that Citation had to change its Bayou injection practices. “If y’all want to start injecting again,” she told company representatives, “I think we’re going to have to look at those pressures and the volumes very carefully.” The meeting ended without a resolution.
Over the next four months, Citation and state regulators continued to debate the terms for restarting the Bayou; neither side budged. By the time they gathered for another face-off in March 2024, oil-division leaders appeared weary of fighting. Halff’s geologists again urged substantial pressure reductions to restart a handful of wells, but Citation representatives, including Lewis and vice president Bob Redweik, repeatedly spoke over them. Redweik and Citation’s attorney ended the meeting after more than two hours; Redweik said, “We’re not going anywhere.” Strickland, McGinnis and commission attorney Tyler Trout attended and remained largely silent. The following week, Trout tried to end the impasse by passing along a memo from Citation and asking whether the agency could meet the company in the middle on recommended injection pressures. May responded that Halff’s recommendations would not change and that the ultimate decision belonged to agency leaders.
Before injection restarted, three oil-division officials chosen by Strickland conducted a walkthrough of the Bayou with Halff and Citation, according to an email from Strickland. The rest of the division was left in the dark. That same day, a pollution-abatement manager told the commission’s general counsel in an email that agency critics of the plan had not been invited. Around the same time, staff were drafting an extensive contempt case against Citation for rule violations elsewhere in Oklahoma, according to public records obtained by The Frontier and ProPublica. Field staff and consultants were still turning up considerable problems related to Citation’s injection, including excessive pressures at destructive wastewater eruptions. The staff complaint called for the agency to issue fines and terminate well permits. But senior oil-division leaders never signed the paperwork. Under state rules, companies must not pollute, and the commission can revoke injection permits and issue fines.
Weeks after the restart, field staff found a “severely contaminated” private water well polluted by oil-field waste, with high salt levels and the “highest levels of bromide that we have ever sampled,” according to internal emails. The bromide finding referred to another chemical constituent of oil and gas waste that poses a public health risk. The landowners declined to comment because of an ongoing lawsuit against Citation, but court records say they do not drink from the well. Citation has fought the family’s claims and said in a court filing that it spent hundreds of thousands of dollars addressing the pollution on their land under a commission-approved plan. The next spring, the agency closed the Bayou investigation and several other Citation investigations without further action.
In the year and a half since the Bayou case closed, several of the oil-division staff who had pressed for enforcement had left the agency, as had a handful of senior leaders. Staffers said they grew frustrated with the division’s unwillingness to crack down on repeat corporate offenders that agency staff had spent months, at times years, investigating.
The Frontier and ProPublica also reviewed roughly 750 enforcement cases filed by the oil division in its administrative law courts since 2023. Fewer than one-third had resulted in punishment. The average fine was about $1,700, and the most common punishment was a $500 fine combined with company insurance money to plug unused wells. At a May national conference for oil regulators in Oklahoma City, oil and gas division attorney Tracy Case said, according to a recording of the meeting obtained by The Frontier and ProPublica, “I’ve been there 11 years doing this and we’ve never pursued what we call our ‘bad actors.’” She said the division was extremely short-staffed while handling hundreds of potential enforcement cases at any one time; an agency spokesperson declined to comment on her behalf.
Other jurisdictions have imposed penalties on Citation, which owns wells in 11 other states. In 2017, the company settled with the U.S. Department of Justice for $2.25 million over allegations of underpaid royalties from drilling on federal land in Wyoming, although the settlement did not rule that the company was liable. In 2025, Utah reached a $700,000 settlement with Citation after a crude-oil and wastewater spill. Texas and Colorado have also fined the company for violations in recent years.
By October, nearly all of Citation’s wastewater injection wells in the Bayou were operating again, many at pressures beyond Halff’s recommendations. Industry data indicated that the company had ramped oil production back to pre-shutdown levels even as evidence of new purges continued to emerge. In September, fresh layers of salt residue covered the dirt near yellowish puddles of standing water, and streaks of oil shone on the ground despite weeks of hot, dry weather with hardly any rain. In early October, an agency field worker asked Citation to install a specialized well in the Bayou to pump out polluted groundwater.
State records list more than 60 spills and leaks at Citation well sites over the past year. Separately, the records listed three purge blowouts in southern Oklahoma during the previous three months, and all three investigations remained active. About 10 miles east of the Bayou, rancher Mike Faulkner noticed salty water surfacing and flowing down a creek on his land in April, near dozens of Citation injection wells that pumped wastewater underground. Citation again blamed old drilling practices, and the agency temporarily shut down some nearby wells; Faulkner said the purge on his land then dried up for the first time in years. “That tells me that they know the why and the how of that saltwater purging,” he said in July.
The agency required monitoring wells, a pit with a rock dam and fencing to keep cattle out. It granted Citation multiple extensions and, in September, set a new deadline in December, seven months after Faulkner’s initial report. As of October, Faulkner said the wells where the state had asked Citation to pause operations were injecting at reduced pressure. Faulkner said he was fed up with Citation’s yearslong pattern of degrading his pastures. He blamed state officials for failing to rein in the company. “They’re like a spoiled kid,” he said. “They’ve just gotten away with it for a long time.” A reporting grant from the Fund for Investigative Journalism helped fund The Frontier and ProPublica’s reporting.