EPA v. MULLINS, SCOTT / ARNCO OIL & GAS, LLC / BRUCE ARNOLD

Case summary

3/16/2010 - ADMINISTRATIVE ORDER ON CONSENT. ORDER ALLEGES: THE SUBJECT WELL IS PRESENTLY PERMITTED IN THE NAME OF YOUNG OIL CORPORATION, AND EPA HAS NOT RECEIVED THE REQUIRED DOCUMENTAIION FOR THE TRANSFER OF PERMIT AND FINANCIAL RESPONSIBILITY, COVERAGE, AND LIABILITY FROM YOUNG OIL CORPORATION TO SCOTT MULLINS. THEREFORE, RESPONDENT IS IN VIOLATION OF 40 CFR SECTION 144.51(a), ITS PERMIT, AND THE SDWA FOR OPERATING WITHOUT NOTICE TO AND APPROVAL OF EPA REGARDING THE TRANSFER OF THE PERMIT. PART II, SECTION G, PARAGRAPH OF THE PERMIT REQUIRES A DEMONSTRATION OF MECHANICAL INTEGRITY AT LEAST ONCE EVERY FIVE YEARS. THE LAST SUCH DEMONSTRATION OF THE SUBJECT WELL WAS ON MAY 31, 2002, AND SHOULD HAVE BEEN REPEATED NO LATER THAN MAY 13. 2007. NO SUBSEQUENT MECHANICAL INTEGRITY TEST WAS PERFORMED. THEREFORE, RESPONDENT VIOLATED 40 CFR SECTION 144.51(a), THE PERMIT, AND THE SDWA BY FAILING TO DEMONSTRATE THE MECHANICAL INTEGRITY OF THE SUBJECT WELL BY MAY 31, 2007. PART I, SECTION C, PARAGRAPH 2, REQUIRES THE PERMITTEE TO WEEKLY MONITOR THE INJECTION PRESSURE AT THE WELLHEAD, ANNULUS PRESSURE AT THE WELLHEAD, AND FLOW RATE OF THE INJECTED FLUID. IN ADDITION, THE CUMULATIVE VOLUME OF THE INJECTED FLUID MUST BE RECORDED EACH MONTH. PART I, SECTION 3, PARAGRAPH 2, CONTAINS THE REQUIREMENT TO SUBMIT THE RESULT OF ALL MONITORING BY JANUARY 30TH OF THE FOLLOWING YEAR. MONITORING REPORTS WERE NEVER SUBMITTED TO EPA FOR THE SUBJECT WELL. THEREFORE, RESPONDENT VIOLATED 40 CFR SECTION 144.51(a), THE PERMIT, AND THE SDWA BY FAILING TO SUBMIT MONITORING REPORTS TO EPA. PART I, SECTION C, PARAGRAPH 3, REQUIRES THE PERMITTEE TO CONDUCT INJECTION FLUID ANALYSIS AT LEAST ONCE EVERY 12 MONTHS. PART I, SECTION D, PARAGRAPH 2, OF THE PERMIT, REQUIRES THE RESULTS OF ALL MONITORING TO BE SUBMITTED ONCE EVERY 12 MONTHS. THERE ARE NO INJECTION FLUID ANALYSIS REPORTS ON FILE FOR THE SUBJECT WELL. THEREFORE, RESPONDENT VIOLATED 40 CFR SECTION 144.519a), THE PERMIT, AND THE SDWQ BY FAILING TO SUBMIT THE REQUIRED FLUID ANALYSIS REPORTS TO EPA.

Defendants (3)

• MULLINS, SCOTT (SB)Named in settlement
• ARNOLD, BOB
• ARNCO OIL & GAS, LLC

Facilities (1)

• T. MULLINS-PERRY #2

  36.46684, -85.29527, LIVINGSTON, KY, 38570

  Registry ID: 110041217402

Statutes cited

• SDWA 1422/1423 — UIC Regulations Classes I - V

Enforcement conclusions (1)

• MULLINS, SCOTT / ARNCO OIL & GAS, LLC / BRUCE ARNOLDentered 2010-03-16

  Primary law: SDWA

Timeline (2 milestones)

• 2010-03-16Final Order Issued
• 2010-03-24Enforcement Action Data Entered