CONOCOPHILLIPS - DAY 2C

ConocoPhillips Company, through the facility record tagged conocophillips-day-2c (NAICS 211130, natural gas extraction; HQ Turley, NM), operates a single EPA-registered facility (ID 110056289984) that shows zero quarters of reported noncompliance over the past 24 months. Yet the same record carries an imputed penalty total of $3,760,000, derived from 5-year enforcement totals prorated to the 24-month window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The ECHO exporter snapshot is timestamped 2026-05-04T17:07:33Z. It reports no active permits and no top pollutants keyed to this facility record [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That penalty figure traces in meaningful part to long-running federal consent-decree obligations originating in United States v. ConocoPhillips Company, WRB Refining LLC, Civil Action No. H-05-258 (S.D. Tex.), a docket opened in 2005, amended in 2008, and most recently updated via a third amendment posted by EPA with a page-stamp of May 6, 2025 [source: https://www.epa.gov/enforcement/third-amended-consent-decree-conocophillips-company-wrb-refining-lp-civil-action-no-h].

Corporate-parent ConocoPhillips (NYSE: COP) reported Q1 2026 revenue of $16.05 billion, net income of $2.18 billion, and EPS of $1.78. Management trimmed full-year production guidance after excluding Qatar volumes tied to Iran-conflict disruptions [source: https://www.conocophillips.com/news-media/story/conocophillips-announces-first-quarter-2026-results-and-quarterly-dividend/] [source: https://www.reuters.com/business/energy/conocophillips-posts-lower-first-quarter-profit-2026-04-30/]. Earnings fell 21% year-over-year from $2.8 billion in Q1 2025 [source: https://www.offshore-technology.com/news/conocophillips-q1-2026-earnings-fall/]. No 10-K or 10-Q environmental disclosures were provided in the research bundle for this facility record, and no sustainability-report SERP hits or NGO litigation SERP hits were returned. The analysis below therefore relies on EPA ECHO, EPA enforcement pages, DOJ ENRD filings in the adjoining San Juan Basin, and ConocoPhillips's own 2023 Sustainability Report [source: https://static.conocophillips.com/files/resources/conocophillips-2023-sustainability-report.pdf].

The subject facility record (ECHO ID 110056289984) sits in NAICS 211130 — Natural Gas Extraction — headquartered in Turley, New Mexico, inside the San Juan Basin. That basin hosts dense oil-and-gas infrastructure and carries documented air-emissions concerns across multiple counties [source: https://www.psehealthyenergy.org/work/impacts-of-new-mexicos-largest-emission-sources/]. ECHO's exporter snapshot records zero quarters with noncompliance over the trailing eight quarters and no active permits associated with the facility ID [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3.76 million 24-month penalty figure is derived, per the ECHO methodology note, by prorating a 5-year penalty total at a 24/60 ratio. The underlying enforcement obligation is therefore historical rather than freshly assessed [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The most material federal enforcement thread reaching ConocoPhillips Company over the past two-plus decades is the refinery-sector consent decree in Civil Action No. H-05-258. Originally entered in 2005 before Judge Sim Lake in the Southern District of Texas, it was amended in 2008 and again in a third amendment published by EPA with a last-update stamp of May 6, 2025 [source: https://www.epa.gov/sites/default/files/documents/2ndamended-conocophillips-cd_0.pdf] [source: https://www.epa.gov/enforcement/third-amended-consent-decree-conocophillips-company-wrb-refining-lp-civil-action-no-h]. That decree covers refining assets now largely held in WRB Refining and Phillips 66 lineage, but ConocoPhillips Company remains a named defendant of record [source: https://www.epa.gov/enforcement/consent-decree-conocophillips-global-refinery]. Within the 24-month window ending May 2026, no new federal complaint against ConocoPhillips Company tied to the Turley, NM facility ID appears in the research bundle.

The neighboring San Juan Basin has, however, seen active federal enforcement. A 2024 consent decree against Hilcorp Energy Company — Civil Action No. 1:24-cv-01055 (D.N.M.) — addresses Clean Air Act storage-tank and leak-detection issues at natural-gas extraction sites that are structurally similar to those present across NAICS 211130 operations in the region [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. That action frames the regulatory baseline against which all basin operators, including the subject facility, are measured.

At the corporate-parent level, the past 24 months have been shaped by the May 2024 closing of the Marathon Oil acquisition, ongoing Permian and Alaska development, and the Q1 2026 decision to exclude Qatar volumes from near-term production guidance following Iran-conflict disruption [source: https://www.reuters.com/business/energy/conocophillips-posts-lower-first-quarter-profit-2026-04-30/] [source: https://www.conocophillips.com/news-media/story/conocophillips-announces-first-quarter-2026-results-and-quarterly-dividend/]. Q1 2026 earnings of $2.2 billion represent a 21% year-over-year decline [source: https://www.offshore-technology.com/news/conocophillips-q1-2026-earnings-fall/]. Analyst coverage during the 30-day news window focused on production guidance and shareholder returns rather than environmental enforcement, and no new EPA ECHO violation quarters were recorded against facility ID 110056289984 in that period [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip] [source: https://simplywall.st/stocks/us/energy/nyse-cop/conocophillips/news/earnings-beat-and-lower-output-guidance-could-be-a-game-chan].

The ECHO exporter shows zero discrete noncompliance quarters attributed to facility ID 110056289984 across the trailing 24 months. The $3,760,000 penalty total is an allocation of the facility's 5-year penalty history — not a newly imposed fine within the window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No Clean Water Act (CWA), Clean Air Act (CAA), or Resource Conservation and Recovery Act (RCRA) violation events dated within the 24-month window are itemized in the exporter snapshot for this facility ID [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The principal enforcement docket of record for ConocoPhillips Company is the multi-jurisdictional CAA refinery consent decree in Civil Action No. H-05-258, captioned United States, State of Illinois, State of Louisiana, State of New Jersey, Commonwealth of Pennsylvania, and Northwest Clean Air Agency v. ConocoPhillips Company and WRB Refining, LLC. The Second Amendment to that decree was filed on August 11, 2008 [source: https://www.epa.gov/sites/default/files/documents/2ndamended-conocophillips-cd_0.pdf]. The Third Amendment is posted at EPA's enforcement portal with a last-updated date of May 6, 2025 [source: https://www.epa.gov/enforcement/third-amended-consent-decree-conocophillips-company-wrb-refining-lp-civil-action-no-h]. The original consent decree document remains available through EPA's ConocoPhillips Global Refinery settlement page [source: https://www.epa.gov/enforcement/consent-decree-conocophillips-global-refinery]. Dollar penalty amounts specific to the Third Amendment are set out inside the decree document itself rather than in the research excerpts provided.

Two parallel 2024 federal actions in the San Juan Basin operating region add important regional texture. EPA and the New Mexico Environment Department filed Civil Action No. 1:24-cv-01055 (D.N.M.) against Hilcorp Energy Company, targeting storage-tank emission controls and leak-detection-and-repair (LDAR) programs at natural-gas extraction facilities — a docket frequently referenced as a regional compliance benchmark for NAICS 211130 operators [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. A parallel 2024 federal complaint against Apache Corporation covered similar NAICS 211 issues in New Mexico [source: https://www.courthousenews.com/wp-content/uploads/2024/02/apache-corporation-federal-complaint.pdf]. Neither action names ConocoPhillips Company as a defendant, but together they define the enforcement posture under which the subject facility operates.

Facility 1 — ECHO ID 110056289984 (Turley, NM; NAICS 211130). This is the sole facility keyed to the conocophillips-day-2c record. ECHO reports zero 24-month noncompliance quarters, zero active permits, an EJ index average of 0.0 — indicating either missing EJScreen linkage or a non-populated field in the exporter snapshot — and no enumerated top pollutants [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The prorated 24-month penalty allocation is $3.76 million [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

That 0.0 EJ figure deserves scrutiny. The Turley facility sits inside the San Juan Basin airshed, which independent analysis by PSE Healthy Energy catalogues as one of New Mexico's largest emission-source clusters. Oil-and-gas extraction there drives VOC, methane, and NOx loads that reach populated areas in Rio Arriba, San Juan, and McKinley counties [source: https://www.psehealthyenergy.org/work/impacts-of-new-mexicos-largest-emission-sources/]. The blank EJ field in the ECHO record reflects a data-population gap, not an absence of real-world burden.

No further facilities are tied to this specific ECHO record in the research bundle; the remaining three slots in a "top 5" ranking cannot be populated without introducing facilities outside the provided data. The corporate parent operates additional U.S. assets in the Permian Basin (Texas and New Mexico), Eagle Ford, Bakken, and Alaska North Slope, but ECHO linkages for those assets are not contained in this bundle and are therefore not itemized here [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The ECHO snapshot for facility ID 110056289984 returns an empty top_pollutants array, meaning no pollutant was flagged at the threshold the exporter uses [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That blank field does not mean the site emits nothing. For NAICS 211130 operations in the San Juan Basin, the PSE Healthy Energy inventory identifies three pollutant families of recurring regulatory and public-health interest: (1) methane (CH4), a short-lived climate pollutant and precursor indicator for co-emitted hazardous air pollutants; (2) volatile organic compounds (VOCs), including benzene, toluene, ethylbenzene, and xylenes, associated with tank venting and pneumatic-controller releases; and (3) nitrogen oxides (NOx) from engines, compressors, and flaring [source: https://www.psehealthyenergy.org/work/impacts-of-new-mexicos-largest-emission-sources/].

Exposure pathways for VOCs in basin communities include inhalation near wellpads, tank batteries, and compressor stations. Benzene detections have been documented in ambient monitoring adjacent to extraction infrastructure [source: https://www.psehealthyenergy.org/work/impacts-of-new-mexicos-largest-emission-sources/]. The Hilcorp consent decree filings in the same basin specifically target Storage Vessel Affected Facilities and fugitive-emission LDAR regimes, underscoring where regulators have concentrated enforcement attention [source: https://www.justice.gov/enrd/media/1373866/dl?inline=]. Those two enforcement priorities — tank-battery emissions and leak detection — map directly onto the VOC and methane pathways PSE identifies as most consequential for basin communities.

Environmental-justice implications in the San Juan Basin are shaped by the proximity of extraction infrastructure to Navajo Nation chapters and rural Hispano communities. PSE's work documents elevated emission burdens in census tracts with above-state-average minority and low-income populations [source: https://www.psehealthyenergy.org/work/impacts-of-new-mexicos-largest-emission-sources/]. The 0.0 EJ index in the ECHO record for this facility should be read as a data-availability gap rather than evidence of an unburdened setting, given the basin's documented profile [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Within the NAICS 211xxx peer set ranked by 24-month prorated penalty total, the subject ConocoPhillips facility record ($3.76M, 0 violation quarters) sits well below the three highest-penalty peers: Greka Bell Compressor Plant ($26.2M, 0 quarters of noncompliance), Red Hills Gas Processing Plant ($19.1M, 8 quarters), and HP Gas Pad ($16.1M, 8 quarters) [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. On the violation-quarter axis, the subject facility ties Greka Bell at zero — both cleaner than Red Hills and HP Gas Pad. On the penalty axis it ranks materially lower than all three [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. All four facilities carry an EJ index of 0.0 in the exporter, which again reflects a data-population gap rather than a substantive EJ finding [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

No 10-K Item 1A or 10-Q environmental disclosures were provided in the research bundle for this facility record, so forward-looking risk cannot be quoted from SEC filings here. The nearest forward-looking public signal from the corporate parent is Q1 2026 management commentary on Middle East geopolitical disruption and the exclusion of Qatar volumes from near-term production guidance — a development Reuters reported on April 30, 2026 and ConocoPhillips confirmed in its Q1 2026 earnings release [source: https://www.reuters.com/business/energy/conocophillips-posts-lower-first-quarter-profit-2026-04-30/] [source: https://www.conocophillips.com/news-media/story/conocophillips-announces-first-quarter-2026-results-and-quarterly-dividend/]. That guidance revision does not directly implicate the Turley, NM facility, but it signals the degree to which geopolitical exposure now shapes corporate-level resource allocation. Regional forward-looking environmental exposure at NAICS 211130 peers is illustrated concretely by the Hilcorp consent decree's third-party-verification, mitigation, and stipulated-penalty provisions, which establish the compliance template regulators are applying to San Juan Basin operators [source: https://www.justice.gov/enrd/media/1373866/dl?inline=].