Oklahoma Never Punished an Oil Company Behind 1,000 Violations

No U.S. oil company has a worse pollution record in Oklahoma than Citation Oil & Gas, and none has felt the sting of a fine. The privately held operator is named more than 1,000 times in the Oklahoma Corporation Commission's database of pollution incidents and rule violations over the past decade - hundreds more than any other operator, including comparably sized firms. Yet the agency has no record of ever fining or completing an enforcement case against Citation, according to an investigation by ProPublica and The Frontier. For a state not known for cracking down on oil and gas polluters, that is still a striking outlier: the company that appears most often in the complaint ledger is the one regulators never touched.

The breaking point came in June 2023, when staff at the commission's oil division recommended an official punishment after toxic wastewater began gushing from the ground near Ardmore in the Bayou oil field, about 30 miles north of the Texas border. An oily sheen glistened on creeks, long streaks of salt scarred the land, and drinking water sources were threatened, drawing attention from the Environmental Protection Agency in a federal report. Staff had asked Citation to cut injection pressures in half; the company refused. The state responded by temporarily shutting down the Bayou's 22 injection wells, all but three of them owned by Citation, which kicked off a yearlong fight over how injection could restart. In the end, agency leadership did not follow staff guidance to punish Citation through the commission's administrative law court. Instead, in April 2024, state officials including then-oil division director Robyn Strickland allowed Citation to restart injection at higher-than-recommended pressures.

The reversal was not an accident. Current and former employees at the Oklahoma Corporation Commission describe top agency officials as wary of going after habitual violators like Citation, and the reason is financial. Citation has become Oklahoma's second-largest well owner by taking over collections of aging, low-producing wells from oil giants that have largely left the state for more lucrative fields in Texas and elsewhere. Regulators treat Citation gently, employees say, because the company holds onto wells that are worth little - wells that could easily become a financial liability for the state if Citation were to sell or walk away from them. The logic is understandable: force a marginal operator too hard, and the state could end up responsible for cleanup and plugging costs. But the consequence is that a company with more than 1,000 recorded violations faces no enforcement record at all.

The urgency felt by staff was acute, and it was documented. In June 2023, Danny Ray, an agency manager at the time, emailed colleagues: "This will be an important case to get some of these purges stopped and particularly concerning Citation's operations." Three days later, he emailed oil division leaders and Citation officials: "We consider this an emergency situation that needs to be addressed promptly." The purges, as they are called locally, were bubbling up among oak and walnut trees, and investigators blamed Citation's injection wells, which pump wastewater from oil production back underground at high pressures and volumes to produce more oil. Over years, that injected wastewater had shattered underground rock layers, allowing toxic fluid to spread uncontrollably.

A November 2023 meeting made the technical case plain. Regulators and company officials packed into a conference room at the commission's Oklahoma City headquarters, with more than a dozen joining by video. The state had hired environmental engineering firm Halff earlier that year on a $550,000 contract to investigate the growing number of oil field wastewater eruptions around Oklahoma. Consultants and agency staff presented a unified front. "You definitely have overpressurization," Carolyn May, Halff's director of environmental remediation, told Citation officials as she presented calculations based on well records, field data and a federal standard. "It's allowing that rock to fracture." The evidence, in other words, was not ambiguous.

Citation's record outside Oklahoma shows that regulators elsewhere have been willing to act. 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, though 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 Citation in recent years for violations. But in Oklahoma, the company has built a reputation as untouchable. As one current manager at the Oklahoma agency put it, speaking on condition of anonymity to protect their job: "Citation has been the thorn in my side for a long time. They just operate however they want. They've had major pollution issues, and you can't really touch them."

For executives and boards, the story is a case study in how enforcement gaps form. Regulators face a real tension between protecting the environment and preserving the financial viability of aging assets that could become public liabilities. When that tension is resolved in favor of forbearance, the message to operators is that pollution records carry little cost at the state level. But the same company can face real money penalties from federal authorities and other states. Citation's $2.25 million settlement and $700,000 spill settlement prove that jurisdiction matters enormously.

Strickland has since left the Oklahoma agency for a job as chief projects officer for the Interstate Oil and Gas Compact Commission, a quasi-governmental organization that often advocates for industry interests. The Oklahoma Corporation Commission declined to answer questions about its handling of Citation's record, citing possible future enforcement actions or litigation. A Citation executive declined to comment in response to written questions. For every operator working in states with aging well inventories, the lesson is simple: regulatory patience is not a permanent license, and the longer a company's pollution ledger grows, the more exposure it carries in other venues where regulators are less forgiving.