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ESG & Compliance Snapshot

CONOCOPHILLIPS - SAN JUAN 28-7 98N

· HQ BLANCO, NM

Last updated May 11, 2026

Located in Rio Arriba County · New Mexico

Executive Summary

ConocoPhillips operates the San Juan 28-7 98N facility (EPA Registry ID 110056289804) in Blanco, New Mexico, within the San Juan Basin natural gas extraction footprint under NAICS 211130. EPA ECHO exporter data as of May 4, 2026 records zero formal quarters of non-compliance over the trailing 24 months at this specific facility, yet carries a pro-rata penalty allocation of $3.76 million derived from the five-year total scaled to a 24-month window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That number is a methodological artifact, not a single assessed fine — a distinction that matters when reading the facility record in isolation. No active permits appear in the ECHO dataset for this site as of the pull date, and the environmental justice index average is reported as 0.0, reflecting either a low-population census block or absent overlay data rather than an affirmative finding that no community exposure exists [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The parent entity, ConocoPhillips (NYSE: COP), reported Q1 2026 revenue of $16.05 billion and net income of $2.18 billion, then lowered full-year production guidance citing Middle East conflict-driven disruptions to Qatar operations [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/]. Historical federal enforcement against the parent includes a multi-state Clean Air Act consent decree amended on August 11, 2008 in S.D. Tex. Case No. H-05-258, covering nine refineries, and a November 2, 2011 Clean Air Act settlement addressing operations on the Southern Ute Reservation [source: https://www.epa.gov/sites/default/files/documents/2ndamended-conocophillips-cd_0.pdf] [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/d19971f9fa2962be8525793c0065c7ef.html]. The San Juan 28-7 98N site is an upstream wellpad, not a refinery. The historical decrees apply to downstream assets under common corporate ownership, and conflating the two asset classes would misread the compliance record.

Penalty trajectory (recent 24 months)

$3.76M24mo

What they say vs what EPA shows

ConocoPhillips' 2023 Sustainability Report, published September 16, 2024, organizes disclosure around Climate, Nature, and Social pillars. The Climate section covers Scope 1, Scope 2, and Scope 3 emissions. Nature addresses biodiversity and water. Social encompasses human rights and supply-chain topics [source: https://static.conocophillips.com/files/resources/conocophillips-2023-sustainability-report.pdf]. The company's sustainability reporting hub also references a 2024 Sustainability Report, 2023 Performance Metrics, and a 2022 CDP submission [source: https://www.conocophillips.com/company-reports-resources/sustainability-report/]. The 2019 report likewise foregrounded managing sustainable development risks and climate-related risks as governance pillars [source: https://static.conocophillips.com/files/callouts/conocophillips-2019-sustainability-report-4.pdf].

Set that corporate-level disclosure against the facility-level record. ECHO shows zero formal quarters of non-compliance at San Juan 28-7 98N over the trailing 24 months and zero active permits on file, alongside a derived $3.76 million penalty allocation whose underlying case basis the ECHO exporter fields do not identify [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The gap worth noting is one of disclosure granularity, not a direct contradiction between stated and measured performance. The sustainability report addresses corporate-wide Scope 1 and Scope 2 emission trajectories and water-risk management at an aggregate level. The only site-specific EPA document in this bundle for a neighboring ConocoPhillips asset — the Ute Compressor Station — concerns monthly AVO inspection of condensate storage tanks TK-5080 and TK-5081, a narrow fugitive-emission control that does not appear to be quantified in the public-facing sustainability narrative [source: https://19january2021snapshot.epa.gov/sites/static/files/2017-03/documents/conocophillips_utecs_smnsr_permit_smnsr-su-000054-2016_002_admin_record.pdf].

A second gap concerns operational risk framing. The 2023 report presents an energy-transition plan. Q1 2026 reporting shows the company cutting annual output guidance because of geopolitical conflict affecting Qatar LNG operations — an exposure that is distinct from, and not explicitly modeled within, the transition-plan framing [source: https://static.conocophillips.com/files/resources/conocophillips-2023-sustainability-report.pdf] [source: https://www.reuters.com/business/energy/conocophillips-posts-lower-first-quarter-profit-2026-04-30/]. The September 8, 2025 Gulf Coast LNG sales and purchase agreement extends long-dated hydrocarbon sales commitments even as the sustainability report discusses Scope 3 reduction approaches [source: https://www.conocophillips.com/news-media/story/conocophillips-adds-gulf-coast-lng-supply-with-latest-long-term-agreement/]. Neither observation constitutes a finding of misrepresentation; both are observable tensions between corporate-level strategic framing and the operational decisions recorded in public filings.

Compliance Snapshot (24 months)

EPA-reported violations0
Aggregate penalties$3.76M
Active permits0
Latest permit on file
Latest inspection

Compliance Overview

The facility-level picture from ECHO is narrow. San Juan 28-7 98N carries a facility count of one, a violation count of zero over the trailing 24 months measured as quarters-with-noncompliance, and an imputed penalty allocation of $3,760,000 derived by ECHO's exporter methodology of taking the five-year penalty total and multiplying by 24/60 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No active NPDES, Title V, or RCRA permits are flagged in the current exporter snapshot, and no top-pollutant vector is populated. That absence is consistent with a small upstream gas extraction pad covered under a general permit or a Tribal Minor NSR instrument rather than a facility-specific major-source permit [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The past 24 months at the corporate level tell a busier story than the site-level record suggests. On January 31, 2025, the New Mexico Environment Department Ground Water Quality Bureau issued a Public Involvement Plan covering the nearby San Juan Generating Station — a PNM coal plant, not a ConocoPhillips asset — in San Juan County, illustrating the active groundwater remediation posture of the basin in which the 28-7 98N wellpad sits [source: https://service.web.env.nm.gov/urls/NURGpWdn]. That distinction matters: the PIP addresses a separate operator's coal-fired facility, yet it signals the regulatory attention the basin draws. On September 8, 2025, ConocoPhillips announced a long-term Gulf Coast LNG sales and purchase agreement, expanding downstream takeaway capacity that indirectly underpins continued San Juan Basin gas production [source: https://www.conocophillips.com/news-media/story/conocophillips-adds-gulf-coast-lng-supply-with-latest-long-term-agreement/]. In February 2026 the company issued full-year 2025 results alongside 2026 guidance [source: https://conocophillips.com/news-media/story/conocophillips-reports-fourth-quarter-and-full-year-2025-results-announces-2026-guidance-and-quarterly-dividend], and on April 30, 2026 disclosed Q1 2026 earnings with a downward revision to full-year output, attributing the cut to Iran-conflict disruptions affecting Qatar operations [source: https://www.reuters.com/business/energy/conocophillips-posts-lower-first-quarter-profit-2026-04-30/].

The EPA enforcement record against the corporate parent reaches further back. The Second Amendment to the ConocoPhillips Global Refinery Consent Decree, filed August 11, 2008 before Judge Sim Lake in the U.S. District Court for the Southern District of Texas, bound ConocoPhillips Company and WRB Refining, LLC to multi-state Clean Air Act compliance obligations across nine refineries, with controls targeting NOx, SO2, and flaring [source: https://www.epa.gov/sites/default/files/documents/2ndamended-conocophillips-cd_0.pdf] [source: https://www.epa.gov/enforcement/consent-decree-conocophillips-global-refinery]. On November 2, 2011, EPA Region 8 announced settlements with Williams and ConocoPhillips resolving alleged Clean Air Act violations on the Southern Ute Indian Reservation — a jurisdiction adjacent to the San Juan Basin operating area where 28-7 98N sits [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/d19971f9fa2962be8525793c0065c7ef.html]. EPA Region 8 records also document a September 30, 2016 Synthetic Minor NSR permit amendment application for ConocoPhillips' Ute Compressor Station, adding monthly AVO — auditory, visual, olfactory — monitoring of condensate storage tanks TK-5080 and TK-5081, which establishes an ongoing Tribal Minor NSR compliance track in the same basin [source: https://19january2021snapshot.epa.gov/sites/static/files/2017-03/documents/conocophillips_utecs_smnsr_permit_smnsr-su-000054-2016_002_admin_record.pdf].

Enforcement Actions

At the San Juan 28-7 98N facility level, ECHO records zero quarters of non-compliance across the trailing 24-month window under CWA, CAA, and RCRA program flags [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3,760,000 penalty figure in the ECHO summary is a derivation, not a single assessed fine: the exporter methodology scales a five-year total by 24/60 to produce a 24-month estimate [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Without the underlying case docket, the allocation cannot be attributed to a specific CWA, CAA, or RCRA order at this wellpad.

Three corporate-parent enforcement actions provide context — none applies directly to this site. First, United States, Illinois, Louisiana, New Jersey, Pennsylvania, and Northwest Clean Air Agency v. ConocoPhillips Company and WRB Refining, LLC, Civil Action No. H-05-258, S.D. Tex., was originally lodged January 27, 2005 and amended a second time on August 11, 2008. That CAA consent decree covered nine refineries and imposed NOx, SO2, and flaring controls across multiple states [source: https://www.epa.gov/sites/default/files/documents/2ndamended-conocophillips-cd_0.pdf]. Second, on November 2, 2011, EPA Region 8 announced settlements with Williams and ConocoPhillips resolving alleged CAA violations on the Southern Ute Indian Reservation, a jurisdiction that borders the San Juan Basin operating area [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/d19971f9fa2962be8525793c0065c7ef.html]. Third, the September 30, 2016 SMNSR-SU-000054-2012.001 permit amendment application for the Ute Compressor Station added monthly AVO inspection obligations for condensate storage tanks TK-5080 and TK-5081; EPA Region 8 in Denver processed that record [source: https://19january2021snapshot.epa.gov/sites/static/files/2017-03/documents/conocophillips_utecs_smnsr_permit_smnsr-su-000054-2016_002_admin_record.pdf]. None of these actions constitutes a 24-month enforcement event against San Juan 28-7 98N. The research bundle contains no NGO complaints, state NMED notices of violation, or CourtListener dockets naming this specific wellpad within the 24-month window.

Active Permits

No active permits on record.

Recent Violations (24 months)

No EPA-reported violations in the past 24 months.

Per-Facility Breakdown

San Juan 28-7 98N (Blanco, NM; EPA Registry ID 110056289804) — The only facility in scope. ECHO reports one facility, zero 24-month violations, a derived $3.76 million penalty allocation, zero active permits on file, and an EJ index average of 0.0 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The 0.0 EJ index reflects either sparse census-block population overlay in rural San Juan County or a missing demographic join, and should be read with that caveat rather than as a substantive finding of no community exposure.

Ute Compressor Station (adjacent San Juan Basin asset, Southern Ute Reservation) — Outside the San Juan 28-7 98N scope but operated by ConocoPhillips in the same basin. EPA Region 8 processed a 2016 Tribal Minor NSR permit amendment that added monthly AVO inspections of condensate storage tanks TK-5080 and TK-5081, establishing a documented fugitive-emission control track at a neighboring facility [source: https://19january2021snapshot.epa.gov/sites/static/files/2017-03/documents/conocophillips_utecs_smnsr_permit_smnsr-su-000054-2016_002_admin_record.pdf].

Phillips Lease, San Juan County, NM — Public well-data aggregator DrillingEdge lists a Phillips lease in San Juan County operated by ConocoPhillips Company, indicating the broader operated well inventory within which 28-7 98N sits [source: https://www.drillingedge.com/new-mexico/san-juan-county/leases/phillips/31595].

San Juan Generating Station (Waterflow, NM) — Not a ConocoPhillips asset. Owned by Public Service Company of New Mexico. It appears here solely for disambiguation: NMED's January 31, 2025 Ground Water Quality Bureau Public Involvement Plan addresses environmental site assessment at this PNM coal plant, and should not be conflated with ConocoPhillips wellpad operations in the same county [source: https://service.web.env.nm.gov/urls/NURGpWdn].

ConocoPhillips Global Refinery system (multi-state) — The nine-refinery footprint bound by the S.D. Tex. consent decree is a downstream asset class entirely separate from the upstream 28-7 98N wellpad, though both sit under the same corporate parent [source: https://www.epa.gov/enforcement/consent-decree-conocophillips-global-refinery].

Pollutant Context

ECHO returns an empty top-pollutants vector for San Juan 28-7 98N, so any pollutant profile must be inferred from the NAICS 211130 activity class and from adjacent San Juan Basin permit records [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Three pollutant families dominate upstream natural gas extraction in this basin, and each carries a distinct exposure pathway.

Volatile organic compounds and methane come first. The 2016 Ute Compressor Station SMNSR amendment record expressly targets condensate storage tank emissions through AVO inspection — a control pathway for fugitive VOC and methane releases characteristic of wet-gas gathering systems [source: https://19january2021snapshot.epa.gov/sites/static/files/2017-03/documents/conocophillips_utecs_smnsr_permit_smnsr-su-000054-2016_002_admin_record.pdf]. Exposure runs through ambient air to nearby residences. The San Juan Basin has drawn sustained EPA tribal-lands CAA enforcement attention precisely because of those pathways [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/d19971f9fa2962be8525793c0065c7ef.html].

NOx and SO2 are the second family. The ConocoPhillips Global Refinery consent decree is built around NOx, SO2, and flaring controls at downstream refineries [source: https://www.epa.gov/sites/default/files/documents/2ndamended-conocophillips-cd_0.pdf]. At an upstream wellpad, the analogous combustion-source NOx pathway runs through compressor engines and dehydrator reboilers rather than refinery process units — a different asset type, but the same chemical family.

Produced-water constituents form the third family: chlorides, BTEX compounds, and naturally occurring radioactive material. The NMED Ground Water Quality Bureau Public Involvement Plan for San Juan County documents the basin-level posture toward groundwater remediation, albeit for the PNM-owned San Juan Generating Station rather than a ConocoPhillips asset [source: https://service.web.env.nm.gov/urls/NURGpWdn]. That regulatory framework — groundwater monitoring, public involvement requirements, site assessment — applies broadly to produced-water handling across the basin, with exposure pathways running through shallow aquifers used for domestic and stock wells.

Environmental Justice Context

EJScreen national percentile across tracked facilities. Higher values indicate higher environmental and demographic exposure.

Average EJScreen index

0

Facility-level EJ data unavailable.

Peer Comparison

PeerViolations (24mo)Penalties (24mo)

Within the NAICS 211120/211130 peer set ranked by penalty_total_24mo, San Juan 28-7 98N's $3.76 million derived penalty figure sits well below Greka Bell Compressor Plant at $26.2 million, Red Hills Gas Processing Plant at $19.1 million, and HP Gas Pad at $16.1 million. Its zero-quarter violation count matches Greka Bell's clean record, while Red Hills and HP Gas Pad each register eight quarters of non-compliance across the 24-month window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. All four sites report an EJ index average of 0.0. That uniformity points to sparse census-overlay data common to rural upstream acreage rather than a substantive no-exposure finding across the peer group [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Forward-Looking Risk Factors

The research bundle contains no SEC 10-K Item 1A or 10-Q environmental risk-factor excerpts for ConocoPhillips; the SEC fields returned empty objects, so a direct forward-looking risk quotation cannot be sourced here. The closest forward-looking disclosure available in this bundle is the April 30, 2026 Q1 2026 earnings release, which lowered full-year production guidance and excluded Qatar from the near-term output outlook on account of Iran-conflict operational disruption. That revision carries direct near-term cash-flow implications and represents a geopolitical risk vector that sits outside the environmental compliance framework typically captured in ECHO data [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/].

Frequently Asked Questions

Does EPA ECHO show any formal violations at San Juan 28-7 98N in the last 24 months?

No. ECHO's exporter snapshot as of May 4, 2026 reports zero quarters of non-compliance for this facility over the trailing 24 months [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

What is the $3.76 million penalty figure and how was it calculated?

It is a derivation, not a single assessed fine. ECHO's exporter methodology scales the five-year penalty total by 24/60 to produce a 24-month allocation [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Is the 2008 ConocoPhillips refinery consent decree relevant to this wellpad?

The decree in S.D. Tex. Case No. H-05-258 covers nine refineries operated by ConocoPhillips Company and WRB Refining, LLC — downstream assets, not the upstream San Juan 28-7 98N wellpad [source: https://www.epa.gov/sites/default/files/documents/2ndamended-conocophillips-cd_0.pdf]. The November 2, 2011 Southern Ute Reservation CAA settlement is geographically closer to this asset [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/d19971f9fa2962be8525793c0065c7ef.html].

Why is the EJ index reported as 0.0?

The ECHO exporter returns 0.0 for this facility and for all three NAICS peers in the benchmark. That result is consistent with rural census-block overlays or missing demographic joins rather than a substantive no-exposure finding [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

What does ConocoPhillips' own sustainability report disclose?

The 2023 Sustainability Report, dated September 16, 2024, covers Scope 1, 2, and 3 emissions, biodiversity, water, human rights, and supply-chain topics at the corporate level. Site-specific disclosures for San Juan 28-7 98N are not itemized in the publicly available summary [source: https://static.conocophillips.com/files/resources/conocophillips-2023-sustainability-report.pdf] [source: https://www.conocophillips.com/company-reports-resources/sustainability-report/].

Sources

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