CONOCOPHILLIPS - SAN JUAN 31-6 UNIT 212

ConocoPhillips' San Juan 31-6 Unit 212 is a single-well natural gas extraction site in San Juan County, New Mexico, operating under NAICS 211130 and carried in EPA ECHO under facility identifier 110055587388 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The ECHO exporter snapshot dated May 4, 2026 records zero formal violations in the trailing 24 months at this specific wellsite. Zero active federal permits appear in that snapshot. The EJ index average is reported as 0.0 — a figure that reflects the absence of residential receptors within the immediate ECHO buffer, not a measured community-exposure finding [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That distinction matters. The derived 24-month penalty allocation of $3,760,000 is a pro-rata share — specifically 24/60 of five-year totals — attributable to the parent ConocoPhillips enforcement footprint, not a standalone penalty issued against Unit 212 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The parent entity, ConocoPhillips (NYSE: COP), reported Q1 2026 net income of $2.18 billion, earnings per share of $1.78, and production of 2,309 MBOED, while excluding Qatar from its Q2 guidance due to the Iran conflict [source: https://stocktitan.net/sec-filings/COP/10-q-conocophillips-quarterly-earnings-report-f52a142b2f14.html] [source: https://www.reuters.com/business/energy/conocophillips-posts-lower-first-quarter-profit-2026-04-30/]. Historical enforcement context traces back to a 2005 Clean Air Act consent decree filed in the Southern District of Texas as Case 4:05-cv-00258 before Judge Sim Lake, amended twice and finalized in its second form on August 11, 2008. A separate 2011 Clean Air Act settlement addressed operations on the Southern Ute Reservation, which sits adjacent to the San Juan Basin [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]. Neither docket touches Unit 212 directly, but both establish the compliance baseline against which the parent's current San Juan operations are read.

Unit 212 sits within ConocoPhillips' Rocky Mountain Business Unit San Juan Asset, historically headquartered at P.O. Box 4289, Farmington, NM, and regulated in part through EPA Region 8's Tribal Minor New Source Review program [source: https://19january2021snapshot.epa.gov/sites/static/files/2017-03/documents/conocophillips_utecs_smnsr_permit_smnsr-su-000054-2016_002_admin_record.pdf]. Air-permitting activity in the San Juan Basin has been sustained and specific. On September 30, 2016, ConocoPhillips filed an amendment application to Synthetic Minor NSR Permit SMNSR-SU-000054-2012.001 covering the Ute Compressor Station. That amendment added monthly auditory, visual, and olfactory — AVO — inspections for condensate storage tanks TK-5080 and TK-5081 [source: https://19january2021snapshot.epa.gov/sites/static/files/2017-03/documents/conocophillips_utecs_smnsr_permit_smnsr-su-000054-2016_002_admin_record.pdf]. Federal surface permitting for adjacent San Juan 30-5 gas wells has flowed through the U.S. Forest Service Carson National Forest unit under project number 39600 [source: https://www.fs.usda.gov/r03/carson/projects/archive/39600].

The ECHO exporter snapshot records no quarters of non-compliance flagged to facility 110055587388 across the review period, producing a derived violation_count_24mo of zero under the formula viol_24mo=min(qtrs_with_nc,8) [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3.76 million figure is a mechanical 24/60 allocation of five-year penalty totals attributed to the corporate parent. It should not be read as a standalone Unit 212 assessment [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No active federal permits appear against this specific wellsite in the current exporter data, and the latest_permit_date field is blank — indicating either delegation of operational permitting to the State of New Mexico or tribal authority, or coverage under a broader area-wide authorization [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The 24-month window running May 2024 through May 2026 spans several significant corporate events. ConocoPhillips completed its acquisition of Marathon Oil during this period. The company published its 2023 Sustainability Report in September 2024 [source: https://static.conocophillips.com/files/resources/conocophillips-2023-sustainability-report.pdf]. The Q1 2026 earnings cycle followed, with adjusted EPS of $1.89 [source: https://conocophillips.com/news-media/story/conocophillips-announces-first-quarter-2026-results-and-quarterly-dividend]. Year-over-year Q1 profit fell 21% to $2.2 billion, driven largely by Qatar exposure rather than any disruption to U.S. onshore production [source: https://finance.yahoo.com/sectors/energy/articles/conocophillips-q1-2026-earnings-fall-152507622.html]. No New Mexico Oil Conservation Division or NMED Air Quality Bureau enforcement action against Unit 212 appears in the news and SERP bundles reviewed for this period.

No discrete 2024–2026 enforcement action against facility 110055587388 — San Juan 31-6 Unit 212 — appears in the ECHO exporter or in the news, SERP, or search result sets reviewed. Violation_count_24mo equals zero [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3,760,000 penalty figure is a derived 24-month allocation, calculated as 24/60 of the parent's five-year penalty total, and is not tied to any specific docket at this wellsite [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Three parent-level enforcement dockets are on record. First: United States et al. v. ConocoPhillips Company; WRB Refining, LLC, Case No. H-05-258, filed January 27, 2005, in the Southern District of Texas before Judge Sim Lake. Co-plaintiffs included Illinois, Louisiana, New Jersey, Pennsylvania, and the Northwest Clean Air Agency. The Second Amendment to that consent decree was filed August 11, 2008 [source: https://www.epa.gov/sites/default/files/documents/2ndamended-conocophillips-cd_0.pdf]. Second: the EPA settlement covering the ConocoPhillips Global Refinery consent decree, maintained by EPA's Office of Enforcement [source: https://www.epa.gov/enforcement/consent-decree-conocophillips-global-refinery]. Third: on November 2, 2011, EPA Region 8 announced a resolution of alleged Clean Air Act violations by Williams and ConocoPhillips on the Southern Ute Reservation. That settlement addressed compressor station and production equipment emissions on land geographically adjacent to the San Juan 31-6 asset [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/d19971f9fa2962be8525793c0065c7ef.html]. All three dockets predate the 24-month review window. They involve refining assets and tribal-land upstream infrastructure rather than Unit 212 itself.

San Juan 31-6 Unit 212 (NM, facility 110055587388): a single gas well operating under NAICS 211130, with ECHO reporting zero 24-month violations, zero active permits in the exporter, and an EJ index average of 0.0 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The wellsite sits in San Juan County, New Mexico, within a lease pattern operated by ConocoPhillips Company and tracked by commercial drilling databases [source: https://www.drillingedge.com/new-mexico/san-juan-county/leases/phillips/31595].

Ute Compressor Station (Southern Ute Reservation, CO/NM border, Region 8 tribal jurisdiction): covered by Synthetic Minor NSR Permit SMNSR-SU-000054, amended September 30, 2016, to add monthly AVO inspections on condensate tanks TK-5080 and TK-5081; administered under EPA Region 8's Federal Minor NSR Permit program [source: https://19january2021snapshot.epa.gov/sites/static/files/2017-03/documents/conocophillips_utecs_smnsr_permit_smnsr-su-000054-2016_002_admin_record.pdf].

San Juan 30-5 Unit 008A/008M/008N/008P Gas Wells (Carson National Forest, NM): surface-use permitting handled through USFS project number 39600, dated July 8, 2012. These wells sit within the same San Juan Basin operating envelope as Unit 212 [source: https://www.fs.usda.gov/r03/carson/projects/archive/39600].

ConocoPhillips Global Refinery (downstream asset, not upstream NM): subject of an EPA enforcement consent decree posted on EPA's enforcement site; a historical Clean Air Act matter distinct from the San Juan upstream portfolio [source: https://www.epa.gov/enforcement/consent-decree-conocophillips-global-refinery].

WRB Refining co-defendant assets (Illinois, Louisiana, New Jersey, Pennsylvania, per docket caption): covered under the 2005 consent decree as amended August 11, 2008. These refining facilities anchor the parent company's pre-2009 Clean Air Act compliance baseline and do not overlap geographically with Unit 212 [source: https://www.epa.gov/sites/default/files/documents/2ndamended-conocophillips-cd_0.pdf].

The ECHO top_pollutants field for facility 110055587388 is empty. In the exporter convention, that indicates no Toxics Release Inventory or Discharge Monitoring Report releases attached to this specific facility ID — not a certification of zero emissions from the operator [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The distinction is consequential for any reader drawing conclusions from that blank field.

Pollutants typical of the San Juan 31-6 operating profile, inferred from the adjacent Ute Compressor Station permit, include volatile organic compounds and hazardous air pollutants associated with condensate storage tank flashing and working and breathing losses. Those emissions were the specific reason EPA Region 8 required increased AVO inspection frequency on tanks TK-5080 and TK-5081 when it processed the September 2016 permit amendment [source: https://19january2021snapshot.epa.gov/sites/static/files/2017-03/documents/conocophillips_utecs_smnsr_permit_smnsr-su-000054-2016_002_admin_record.pdf]. VOC and HAP control at condensate tanks is not a theoretical concern in this basin — it drove a concrete regulatory requirement.

Methane and associated natural-gas-extraction fugitive emissions form the second pollutant category of regulatory relevance. ConocoPhillips' 2023 Sustainability Report identifies Scope 1 and Scope 2 emissions reduction as a reporting pillar and addresses Scope 3 in a separate section [source: https://static.conocophillips.com/files/resources/conocophillips-2023-sustainability-report.pdf]. The November 2, 2011 EPA Region 8 Clean Air Act settlement with Williams and ConocoPhillips on the Southern Ute Reservation addressed alleged violations at gas production and compression infrastructure comparable in type to Unit 212's operating envelope [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/d19971f9fa2962be8525793c0065c7ef.html].

Nitrogen oxides from compressor-engine combustion form the third category. NOx is the standard driver for New Source Review synthetic-minor permitting across the San Juan Basin, as reflected in the SMNSR permit series applied to the Ute Compressor Station [source: https://19january2021snapshot.epa.gov/sites/static/files/2017-03/documents/conocophillips_utecs_smnsr_permit_smnsr-su-000054-2016_002_admin_record.pdf]. On environmental justice: ECHO lists an EJ index average of 0.0 for Unit 212, but the wellsite operates near tribal jurisdictional boundaries addressed by EPA Region 8's tribal NSR program. Community exposure analysis therefore belongs at the airshed level rather than the individual wellhead buffer [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip] [source: https://19january2021snapshot.epa.gov/sites/static/files/2017-03/documents/conocophillips_utecs_smnsr_permit_smnsr-su-000054-2016_002_admin_record.pdf].

Against its NAICS 211120/211130 peer set, Unit 212's derived 24-month penalty allocation of $3.76 million sits well below Greka Bell Compressor Plant at $26.16 million — itself carrying zero recorded violations — and below Red Hills Gas Processing Plant at $19.13 million and HP Gas Pad at $16.13 million, both of which logged 8 quarters of non-compliance [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Zero quarters of non-compliance at Unit 212 versus the 8-quarter maxima at Red Hills and HP Gas Pad places the wellsite in the lower-risk tranche of its peer group on both frequency and derived-penalty dimensions [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Greka Bell's penalty allocation — nearly seven times Unit 212's — despite a matching zero-violation count illustrates how parent-level enforcement history can dominate the derived figure independent of individual facility performance.

No current SEC 10-K Item 1A or 10-Q Item 7 excerpts were provided in the research bundle for ConocoPhillips' CIK, so forward-looking environmental risk language cannot be quoted directly from those filings. What the available record does show: Q1 2026 net income of $2.18 billion, production of 2,309 MBOED, operating cash flow of $4.3 billion, and capital expenditure of $2.95 billion, with updated 2026 production and capital guidance reflecting the Qatar exclusion [source: https://stocktitan.net/sec-filings/COP/10-q-conocophillips-quarterly-earnings-report-f52a142b2f14.html]. Management commentary on the Q1 2026 earnings call and in Reuters coverage identifies Middle East geopolitical disruption as the dominant near-term operational risk. Domestic U.S. onshore assets, including the San Juan Basin, are characterized as stable baseline production in that framing [source: https://www.reuters.com/business/energy/conocophillips-posts-lower-first-quarter-profit-2026-04-30/] [source: https://finance.yahoo.com/sectors/energy/articles/conocophillips-q1-earnings-call-highlights-102050847.html]. For Unit 212 specifically, the forward risk profile tracks to the parent's broader San Juan Basin regulatory posture — air-permitting requirements under EPA Region 8's tribal NSR program, any future tightening of VOC or methane rules applicable to existing production wells in New Mexico, and the ongoing integration of Marathon Oil assets into the compliance management structure.