SAN JUAN 32-7 UNIT 238

San Juan 32-7 Unit 238 is a single-facility natural gas extraction operation in Turley, New Mexico, within San Juan County, operating under NAICS 211130. EPA ECHO exporter data as of May 4, 2026 records one regulated facility (FRS ID 110043218924), zero quarters-with-noncompliance in the 24-month lookback window, and a derived penalty total of $3,760,000 calculated from the five-year total pro-rated across 24 of 60 months [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No active permits appear on file. No top pollutants are recorded in the ECHO summary extract — an outcome consistent with a small upstream gas unit whose reporting footprint sits primarily with state-level oversight by the New Mexico Environment Department rather than federal NPDES or Title V programs.

San Juan County lease records associate the lease historically with Phillips Petroleum Co NW as operator [source: https://www.drillingedge.com/new-mexico/san-juan-county/leases/san-juan-32-7-unit/9260]. The unit is private, carries no CIK, and has filed no 10-K or 10-Q documents against which EPA data could be reconciled. That absence of public filings narrows the analytical lens to the ECHO record alone. Within the NAICS 211xxx peer set, Unit 238 is a comparatively low-penalty, zero-violation outlier. Greka Bell Compressor Plant carries a derived 24-month penalty of $26.16M; Red Hills Gas Processing Plant follows at $19.13M with eight recorded violation quarters; HP Gas Pad registers $16.13M with eight violation quarters as well [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. All three figures emerge from the same ECHO exporter methodology applied uniformly across the peer set. The $3.76M figure for Unit 238 — a zero-violation facility — reflects ECHO's pro-rating formula applied to a longer five-year history rather than any recent adjudicated enforcement action.

The compliance record for San Juan 32-7 Unit 238 rests on a narrow federal footprint. ECHO's exporter file records facility ID 110043218924 with zero quarters of noncompliance in the eight-quarter lookback through Q1 2026, zero active federal permits, and an environmental justice index average of 0.0 in the summary extract. That EJ figure reflects either a non-populated field or the rural, low-population-density character of the Turley, NM service area — not a substantive absence of EJ exposure in the broader basin [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. ECHO's derivation note explicitly states penalty_24mo is computed as total_5yr multiplied by (24/60), meaning the $3,760,000 figure implies a prior five-year total in the range of $9.4M that has since rolled off the violation-count window.

The 24-month chronology is clean. No federal enforcement docket entries appear. No news coverage ties Unit 238 to a spill, release, or consent-decree proceeding. No NGO or state-violation results surfaced in the research bundle. The San Juan Basin context adds texture here: the New Mexico Environment Department Ground Water Quality Bureau maintains a Public Involvement Plan effective January 31, 2025 for the San Juan Generating Station in Waterflow, NM — with Public Service Company of New Mexico as responsible party — covering Environmental Site Assessment and Remediation Plan Development [source: https://service.web.env.nm.gov/urls/NURGpWdn]. That site and the related EPA Superfund profile for NM San Juan Generating Station (EPA ID NMD069424323, NFRAP status, not on the NPL) [source: https://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0600839] are separate assets from Unit 238. They share the San Juan County airshed and groundwater context, which is why analysts running county-level screens will encounter them alongside Unit 238 data.

Historical federal Clean Air Act enforcement in facilities bearing the "San Juan" name includes a 1996 consent decree in United States v. San Juan Cement Company, Inc., Civ. Action No. 96-1381 DRD (D.P.R.), lodged July 12, 1996 — an unrelated Puerto Rico cement operation, not the New Mexico gas unit, flagged here solely because name-collision search returns conflate the two [source: https://www.govinfo.gov/content/pkg/FR-1996-07-30/html/96-19284.htm]. Similarly, a 1997 EPA Region 2 action fining four waste-oil handlers in Puerto Rico and the U.S. Virgin Islands a combined $92,500 [source: https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/6a022a6bc9fe4a8e8525726d00632d8c.html] and a 2005 Title V petition regarding the Puerto Rico Electric Power Authority Central San Juan plant [source: https://19january2021snapshot.epa.gov/sites/static/files/2015-08/documents/prepa_san_juan_petition2005.pdf] are Caribbean matters entirely. Neither touches New Mexico upstream gas operations. Both are flagged for analysts running name-based compliance screens who may otherwise pull them into Unit 238's dossier.

Per-action breakdown for the 24-month window ending Q1 2026: ECHO records zero formal enforcement actions, zero informal actions, and zero quarters of noncompliance against facility ID 110043218924 (San Juan 32-7 Unit 238, Turley, NM) under the Clean Water Act, Clean Air Act, or Resource Conservation and Recovery Act [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $3,760,000 penalty_total_24mo figure is not an adjudicated recent penalty. ECHO's own derivation documentation states the value is computed as total_5yr × (24/60) — a pro-rata apportionment of the full five-year history [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Analysts should read the figure as a historical-weighted estimator, not a recent cash outflow.

No CWA NPDES effluent violations, CAA Title V deviation reports, or RCRA corrective-action milestones are indexed against this facility in the ECHO exporter. No active permits are on file, and latest_permit_date is null in the extract [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No consent decrees, administrative orders, or civil complaints naming San Juan 32-7 Unit 238 appear in court-records searches. Those searches instead surfaced the unrelated 1996 San Juan Cement Company consent decree in D.P.R. [source: https://www.govinfo.gov/content/pkg/FR-1996-07-30/html/96-19284.htm] and the 2005 PREPA Central San Juan Title V petition [source: https://19january2021snapshot.epa.gov/sites/static/files/2015-08/documents/prepa_san_juan_petition2005.pdf]. Neither implicates the New Mexico gas unit. The distinction matters: an analyst pulling "San Juan" enforcement records without filtering by FRS ID or state will encounter both Caribbean items and should exclude them before drawing any conclusions about Unit 238's enforcement exposure.

San Juan 32-7 Unit 238 (Turley, NM; San Juan County; FRS 110043218924): the sole facility in scope. ECHO reports zero 24-month violations, zero active permits, and an EJ index average of 0.0 in the summary extract [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. San Juan County lease records list Phillips Petroleum Co NW as the historical operator [source: https://www.drillingedge.com/new-mexico/san-juan-county/leases/san-juan-32-7-unit/9260].

San Juan Generating Station (Waterflow, NM; EPA ID NMD069424323): a coal-fired station in the adjacent airshed, not owned by Unit 238, but relevant because it shares San Juan County groundwater and is subject to an active NMED Ground Water Quality Bureau Public Involvement Plan effective January 31, 2025 covering site assessment and remediation [source: https://service.web.env.nm.gov/urls/NURGpWdn]. EPA's Superfund profile lists the site as NFRAP — No Further Remedial Action Planned — and confirms it is not on the NPL [source: https://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0600839]. County-level groundwater monitoring activity at the Generating Station is therefore ongoing even as Unit 238 carries a clean federal record.

Greka Bell Compressor Plant (NAICS 211120 peer): $26,155,942 derived 24-month penalty, zero recorded violations, zero active permits per ECHO exporter [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. This is the highest-penalty facility in the NAICS 211xxx comparison set, and its zero-violation status — like Unit 238's — underscores that the derived penalty figure reflects historical five-year activity rather than current adjudicated enforcement.

Red Hills Gas Processing Plant (NAICS 211130 direct peer): two facilities, eight quarters of noncompliance in the 24-month window, $19,133,219 derived penalty, zero active permits [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. As the closest direct NAICS 211130 comparator, Red Hills shows materially higher noncompliance frequency than Unit 238 across the same measurement window.

HP Gas Pad (NAICS 211120 peer): one facility, eight quarters of noncompliance, $16,134,727 derived penalty [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Together with Red Hills, HP Gas Pad establishes that upstream gas peers in the same size band carry substantially higher enforcement exposure than Unit 238 on federal metrics.

ECHO returns an empty top_pollutants array for San Juan 32-7 Unit 238 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Pollutant profiling here is therefore constructed from sector-typical emissions inventories for NAICS 211130 upstream gas operations rather than facility-specific releases. Three pollutant categories dominate the sector profile, and each carries a distinct exposure pathway.

Methane (CH4) is the principal climate-forcing pollutant from natural gas extraction. EPA documents methane's global warming potential at roughly 28–36 times that of CO2 over a 100-year horizon. The exposure pathway is atmospheric. EJ implications are indirect, operating via regional ozone formation when CH4 is co-emitted with volatile organic compounds. The New Mexico Environment Department's active groundwater oversight in San Juan County [source: https://service.web.env.nm.gov/urls/NURGpWdn] reflects the state's sustained focus on subsurface integrity around gas operations throughout the basin.

Volatile organic compounds — specifically benzene, toluene, ethylbenzene, and xylene, collectively BTEX — are co-produced with natural gas. The primary exposure pathway is inhalation at the fenceline. EJ context in San Juan County includes proximity to Navajo Nation communities, and the EPA Superfund profile for the nearby San Juan Generating Station confirms county-level regulatory attention on both air and groundwater quality [source: https://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0600839]. No BTEX exceedances are recorded against Unit 238 in the ECHO extract, but the sector-level profile makes fenceline inhalation exposure the most analytically relevant pathway for this geography.

Hydrogen sulfide (H2S) is a sour-gas-field risk in portions of the San Juan Basin. Acute inhalation toxicity is well-established in EPA technical references. No H2S exceedances are recorded against Unit 238 in the ECHO extract [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The absence of facility-specific pollutant data in ECHO does not eliminate sector-level exposure; it means analysts must rely on basin-wide and NAICS-level inventories until Unit 238 generates its own reportable release data.

Within the NAICS 211xxx peer set, San Juan 32-7 Unit 238 sits at the low end of both violation count and derived penalty. Its zero-violation, $3.76M profile compares against Greka Bell Compressor Plant at $26.16M with zero violations, Red Hills Gas Processing Plant at $19.13M with eight quarters of noncompliance across two facilities, and HP Gas Pad at $16.13M with eight quarters of noncompliance [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The direct NAICS 211130 comparator — Red Hills — carries roughly five times the derived 24-month penalty and eight recorded noncompliance quarters versus zero for Unit 238. On federal enforcement metrics alone, Unit 238 is a below-peer-median asset in this comparison set.

San Juan 32-7 Unit 238 is private with CIK N/A and has filed no 10-K. There is no Item 1A forward-looking environmental risk disclosure to cite. Forward environmental risk for the lease must therefore be inferred from state-level instruments. The most direct is the NMED Ground Water Quality Bureau Public Involvement Plan effective January 31, 2025, which governs site assessment and remediation activity in San Juan County [source: https://service.web.env.nm.gov/urls/NURGpWdn]. The EPA Superfund profile framework applicable to co-located infrastructure in the basin adds a second layer of county-level context [source: https://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0600839]. Neither instrument names Unit 238 directly. Both establish that the regulatory environment surrounding the lease is active at the state level even where the federal record is clean, and that dynamic is the primary forward risk factor for analysts assessing this asset.