CONOCOPHILLIPS -SAN JUAN 32-8 UNIT 221A

ConocoPhillips San Juan 32-8 Unit 221A is a single oil-and-gas production facility — EPA Registry ID 110042148761 — operating in the San Juan Basin of northwestern New Mexico under NAICS 211111 (crude petroleum extraction). EPA ECHO data as of May 4, 2026 records zero formal quarters of non-compliance across the trailing 24-month window. The site's derived 24-month penalty allocation totals $3,760,000, a figure EPA calculates by scaling a five-year penalty base to a 24-month interval using the formula penalty_24mo = total_5yr × (24/60) [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No active permits appear in the current ECHO exporter snapshot. The facility's EJ index average is reported as 0.0, which reflects either unpopulated tract-linkage data or the remote rural character of this Archuleta-adjacent well unit [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Parent ConocoPhillips Company (NYSE: COP) posted Q1 2026 net income of $2.18 billion on production of 2,309 MBOED. The company simultaneously trimmed annual production targets, citing Middle East geopolitical disruption [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/]. The San Juan asset sits within ConocoPhillips's Rocky Mountain Business Unit, a portfolio with a documented federal Clean Air Act history. On November 2, 2011, EPA Region 8 announced a settlement resolving alleged CAA violations at ConocoPhillips and Williams compressor and production infrastructure on the Southern Ute Indian Reservation [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/d19971f9fa2962be8525793c0065c7ef.html]. That settlement established the compliance architecture that still shapes how adjacent San Juan Basin units are monitored today. The 2023 Sustainability Report places emissions reduction and biodiversity management under board-level governance [source: https://static.conocophillips.com/files/resources/conocophillips-2023-sustainability-report.pdf].

San Juan 32-8 Unit 221A appears in EPA's Integrated Compliance Information System as a single wellpad-class site within NAICS 211111. ECHO's trailing 24-month window records no quarters of significant non-compliance for registry ID 110042148761, and no formal enforcement action has been docketed against the unit within that period [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3,760,000 penalty figure is a proportional allocation from a longer five-year penalty base — not a freshly adjudicated fine tied to 2024–2026 conduct. EPA discloses the methodology explicitly as penalty_24mo = total_5yr × (24/60) [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The San Juan asset's federal compliance history traces back to November 2, 2011, when EPA Region 8 announced a settlement resolving alleged Clean Air Act violations at ConocoPhillips and Williams operations on the Southern Ute Indian Reservation. That agreement required emission controls at compressor stations and condensate tanks across the basin [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/d19971f9fa2962be8525793c0065c7ef.html]. Five years later, in September 2016, ConocoPhillips's Rocky Mountain Business Unit — San Juan Asset filed an application to amend Synthetic Minor New Source Review permit SMNSR-SU-000054-2012.001 for the Ute Compressor Station. The 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]. That permit amendment establishes the baseline monitoring regime governing adjacent San Juan Basin units, including wellpad infrastructure of the class represented by Unit 221A.

Across the 24-month window running from mid-2024 through May 2026, no new consent decree entries, no new significant non-compliance quarters, and no active permits are recorded for registry ID 110042148761 in the ECHO exporter [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Parent-level disclosures in Q1 2026 focused on Qatar exposure and Iran-conflict operational risk rather than domestic air-quality enforcement [source: https://www.reuters.com/business/energy/conocophillips-posts-lower-first-quarter-profit-2026-04-30/]. Separately, the U.S. Forest Service's Carson National Forest project archive documents gas-well activity under the San Juan 30-5 Unit designations — 008A, 008M, 008N, and 008P — providing a federal-lands paper trail for adjacent ConocoPhillips assets in the same basin, though not for Unit 221A specifically [source: https://www.fs.usda.gov/r03/carson/projects/archive/39600].

No enforcement action is recorded against EPA Registry ID 110042148761 (San Juan 32-8 Unit 221A) within the ECHO trailing 24-month window ending May 4, 2026; violation_count_24mo = 0 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3,760,000 penalty_total_24mo field is a derived allocation from a five-year base — not a discrete 2024–2026 adjudication [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The nearest documented federal enforcement touching the broader San Juan asset is the November 2, 2011 Clean Air Act settlement between EPA, Williams, and ConocoPhillips covering operations on the Southern Ute Reservation, a matter resolved by agreement rather than contested litigation [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/d19971f9fa2962be8525793c0065c7ef.html].

At the corporate parent level, a separate enforcement instrument governs downstream operations. The Second Amendment to Consent Decree in United States et al. v. ConocoPhillips Company and WRB Refining, LLC — Case 4:05-cv-00258, S.D. Tex., filed August 11, 2008, before Judge Sim Lake — addresses refining obligations across facilities in Illinois, Louisiana, New Jersey, Pennsylvania, and Washington's Northwest Clean Air Agency jurisdiction [source: https://www.epa.gov/sites/default/files/documents/2ndamended-conocophillips-cd_0.pdf]. That instrument covers refining scope only. It has no bearing on upstream San Juan well units. No RCRA or CWA formal action against Unit 221A is indexed in the current ECHO extract [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

San Juan 32-8 Unit 221A, located in Archuleta, NM (EPA Registry ID 110042148761), is the sole facility keyed to this slug. ECHO records zero quarters of non-compliance in the trailing 24 months and zero active permits in the current exporter snapshot. The derived 24-month penalty allocation is $3,760,000, calculated via the five-year-to-24-month scaling formula [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The EJ index average is reported as 0.0. In EPA's EJScreen framework, that figure typically reflects either sparse demographic tract coverage or a rural population context. The San Juan Basin portion of northwestern New Mexico overlaps Navajo Nation and Southern Ute jurisdictions, where tribal sovereignty complicates EJScreen tract-mapping in ways that can suppress index values without reflecting actual community exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That distinction matters for any downstream ESG analysis drawing on this field.

The September 2016 permit amendment for the adjacent ConocoPhillips Ute Compressor Station establishes that synthetic-minor NSR permits in the San Juan Asset cluster carry monthly AVO inspection requirements for condensate tanks — specifically TK-5080 and TK-5081. That is the operative air-compliance regime for wellpad infrastructure of this class [source: https://19january2021snapshot.epa.gov/sites/static/files/2017-03/documents/conocophillips_utecs_smnsr_permit_smnsr-su-000054-2016_002_admin_record.pdf]. Because only one facility is linked to this slug, the remaining four per-facility slots in a typical top-5 ranking are unpopulated. Adjacent ConocoPhillips San Juan units — including the San Juan 30-5 Unit 008 series gas wells on Carson National Forest lands — are separately indexed in U.S. Forest Service project archives and are not part of this ECHO registry cluster [source: https://www.fs.usda.gov/r03/carson/projects/archive/39600]. The DrillingEdge commercial database traces the broader San Juan unit system's operator lineage to Phillips Petroleum Co NW, confirming long-tenured upstream activity in the basin predating the ConocoPhillips corporate consolidation [source: https://www.drillingedge.com/new-mexico/san-juan-county/leases/san-juan-32-7-unit/9260].

ECHO's top_pollutants field for Unit 221A is empty in the current exporter extract. No TRI, DMR, or ICIS-Air pollutant loadings are aggregated to this specific registry ID in the 24-month window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That data gap does not mean the site emits nothing — it means site-specific loadings are not populated in the public extract. What the broader regulatory record does show is a clear picture of the emission categories that matter for NAICS 211111 facilities in this basin.

Three pollutant classes dominate. First, volatile organic compounds (VOCs) and hazardous air pollutants (HAPs) from condensate storage tanks — the exact emission source class that drove the September 2016 Ute Compressor Station permit amendment requiring monthly AVO inspections of 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]. Second, methane (CH4), a potent short-lived climate forcer. ConocoPhillips addresses methane at the corporate level through Scope 1 emissions reduction programs disclosed in its 2023 Sustainability Report [source: https://static.conocophillips.com/files/resources/conocophillips-2023-sustainability-report.pdf]. Third, nitrogen oxides (NOx) from compressor-engine combustion — historically the central focus of the November 2, 2011 EPA CAA settlement on the Southern Ute Reservation [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/d19971f9fa2962be8525793c0065c7ef.html].

Exposure pathways for populations near San Juan Basin wellpads include inhalation of VOCs and NOx, as well as downwind secondary ozone formation. EJ implications are amplified by the proximity of tribal and rural Hispanic communities across San Juan, Rio Arriba, and Archuleta counties. The specific Unit 221A EJScreen index is reported as 0.0 in ECHO's current extract — a data-completeness signal, not a finding of low community exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Within the adjacent NAICS 211-series peer set, San Juan 32-8 Unit 221A's $3.76M derived 24-month penalty allocation sits materially below the top three peers. Greka Bell Compressor Plant carries $26.16M. Red Hills Gas Processing Plant shows $19.13M, and HP Gas Pad shows $16.13M [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. On the violation count, Unit 221A's zero non-compliance quarters matches Greka Bell's clean record while contrasting sharply with Red Hills and HP Gas Pad, each of which logged eight quarters of non-compliance across the same window. The peer comparison should be read with the ECHO derivation caveat in mind: every penalty figure here is a scaled allocation of a five-year total, not a fresh adjudication [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

No current ConocoPhillips 10-K Item 1A text is available in the research bundle for this briefing; the provided SEC payload is empty. Forward-looking environmental risk disclosure from the Q1 2026 cycle, as reported in secondary coverage, centers on geopolitical disruption to Middle East operations — specifically Qatar exclusion from near-term outlook and Iran-conflict operational impact — rather than domestic upstream environmental liability [source: https://www.reuters.com/business/energy/conocophillips-posts-lower-first-quarter-profit-2026-04-30/]. The Q1 2026 10-Q coverage confirms updated 2026 production and capital guidance without flagging new domestic environmental enforcement exposure [source: https://stocktitan.net/sec-filings/COP/10-q-conocophillips-quarterly-earnings-report-f52a142b2f14.html]. For Unit 221A specifically, the forward risk profile is shaped less by active enforcement than by the data-visibility gap: facility-level pollutant loadings remain unpopulated in ECHO, and the synthetic-minor permitting structure limits the public compliance record available to analysts and investors.