EPA v. TAYLOR EQUIPMENT SERVICE

Case summary

8/17/10 - CEASE INJECTION ORDER ISSUED. EPA RECEIVED DOCUMENTATION SHOWING THAT ON JUNE 30, 2010, ONE OF THE RESPONDENT'S COMPANIES, CIRCLE T WASTE OIL RECOVERY, ACCEPTED PETROLEUM CONTAMINATED WASTEWATER FROM UNDERGROUND STROAGE TANK FACILITY NO. 9115026, TANK 3, FOR DISPOSAL INTO THE SUBJECT WELL. DURING A ROUTINE INSPECTION ON AUG 5, 2010, THE INSPECTOR WITNESSED THE INJECTION OF USED COMPRESSOR OIL INTO THE ROBERT TAYLOR #2. OPERATING REQUIREMENTS FOUND IN PART I, SECTION B, PARA 1, OF THE PERMIT, STATE THAT THE SUBJECT INJECTION WELL IS TO BE USED ONLY FOR THE DISPOSAL OF CLASS FLUIDS BROUGHT TO THE SURFACE IN CONNECTION WITH CONVENTIONAL OIL AND NATURAL GAS PRODUCTION FROM THE PERMITTEE'S OPERATIONS IN THE CORBIN NORTH FIELD, AND CLASS II FLUIDS FROM NEARBY OIL FIELDS. PART II, SECTION A, OF THE PERMIT, PROHIBITS ANY UNDERGROUND INJECTION NOT SPECIFICALLY AUTHORIZED IN THE PERMIT. THE REGULATION AT 40 CFR 144.11 PROHIBITS ANY UNAUTHORIZED UNDERGROUND INJECTION ACTIVITY. THE DESCRIPTION OF THE TRANPORTED FLUID IN THE MANIFEST DOCUMENT MATCHES THE TYPE OF FLUID DESCRIBED AT 144.81(16), UNDER SUBPART G, FOR CLASS V WELLS, AS DOES THE USED COMPRESSOR OIL. THESE ARE TYPICALLY FROM VEHICULAR REPAIR OR MAINTENANCE ACTIVITIES INVOLVING VEHICULAR REPAIRS. THESE FLUIDS MAY CONTAIN ORGANIC AND INORGANIC CHEMICALS IN CONCENTRATIONS EXCEEDING MCLs, AND MAY INCLUDE WASTE PETROLEUM PRODUCTS, THAT MAY CONTAIN CONTAMINANTS SUCH AS HEAVY METALS AND VOLATILE ORGANIC COMPOUNDS WHICH POSE A RISK TO HUMAN HEALTH. THEREFORE, RESPONDENT VIOLATED THE SDWA, 40 CFR 144.51(a), AND OPERATING REQUIREMENTS IN PART I, SECTION B, PARA 1, OF THE PERMIT, BY DISPOSING OF NON-CLASS II FLUIDS, INCLUDING PETROLEUM CONTAMINATED WASTEWATER FROM UNDERGROUN STORAGE TANK FACILITY NO. 9115026, TANK 3, AND USED COMPRESSOR OIL, INTO THE SUBJECT WELL. THIS CONSTITUTES UNAUTHORIZED UNDERGROUND INJECTION AND IS PROHIBITED BY THE SDWA, 40 CFR 144.11, AND PART II, SECTION A, OF THE PERMIT. ORDER REQUIRES: RESPONDENT IS HEREBY ORDERED TO IMMEDIATELY CEASE INJECTION INTO THE SUBJECT WELL, AND DISCONNECT THE INJECTION LINE FROM THE WELL.

Defendants (1)

• TAYLOR EQUIPMENT SERVI CE, INC. (SB)Named in settlement

Facilities (1)

• TAYLOR #2 UIC WELL (TAYLOR EQUIPMENT SERVICE, INC.)

  LAT/LONG: 36.98770 / -87.08901, CORBIN, KY, 40701

  Registry ID: 110043252958

Statutes cited

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

Enforcement conclusions (1)

• TAYLOR EQUIPMENT SERVICEentered 2010-08-17

  Primary law: SDWA

Timeline (2 milestones)

• 2010-08-17Final Order Issued
• 2011-01-06Enforcement Action Data Entered