EPA v. TRAVIS COOMER DRILLING COMPANY

Case summary

10/14/10- CONSENT AGMT AND FINAL ORDER ISSUED, ASSESSING A PENALTY OF $10,715 DUE IN INSTALLMENTS. THE FIRST $5,357.50 IS DUE WITHIN 30 DAYS. THE REMAINDER OF THE PENALTY PAYMENT IS DUE WITHIN 90 DAYS OF THE FIRST INSTALLMENT. ALLEGATIONS: THE PERMIT FOR THE JESSE SULLIVANT #7 REQUIRES A DEMONSTRATION OF MECHANICAL INTEGRITY AT LEAST ONCE EVERY 2 YRS. THE RESPONDENT FAILED TO DEMONSTRATE THE MECHANICAL INTEGRITY OF THIS WELL BY THE DATE INDICATED BELOW: JESSE SULLIVAN #7 - LAST MIT, 10/20/05 - MIT DUE, 10/20/07 THEREFORE, RESPONDENT VIOLATED 40 CFR 40 CFR 144.51(a), ITS PERMIT AND THE SDWA BY FAILING TO TIMELY DEMONSTRATE THE MECHANICAL INTEGRITY OF THE SUBJECT WELL. IN ACCORDANCE WITH THE PERMITS, EPA REQUIRES THAT AFTER A CESSATION OF INJECTION FOR TWO YEARS, THE PERMITTEE SHALL DEMONSTRATE THE MECHANICAL INTEGRITY OF THE INJECTION WELL, OR PLUG AND ABANDON ACCORDING TO AN EPA-APPROVED PLUGGING AND ABANDONMENT PLAN. THE RESPONDENT FAILED TO DEMONSTRATE THE MECHANICAL INTEGRITY, OR TO PLUG AND ABANDON THE FOLLOWING INACTIVE WELLS BY THE DATES INDICATED BELOW: BILLY WHITNEY #8 - LAST MIT, 11/29/05 - MIT DUE, 11/29/07. JOE IRWIN, #2 - LAST MIT, 11/25/05 - MIT DUE, 11/25/07. THEREFORE, RESPONDENT VIOLATED 40 CFR 144.51(a), ITS PERMIT, AND THE SDWA BY FAILING TO TIMELY DEMONSTRATE THE MECHANICAL INTEGRITY OF THE SUBJECT WELLS OR PLUG AND ABANDON THEM ACCORDING TO AN EPA-APPROVED PLUGGING AND ABANDONMENT PLAN. THE PERMIT REQUIRES THE PERMITTEE TO CONDUCT INJECTION FLUID ANALYSES AT LEAST ONCE EVERY 12 MONTHS AND WHENEVER CHANGES ARE MADE TO THE INJECTION FLUID. THE INITIAL FLUID ANALYSES ARE DUE WITHIN 12 MONTHS OF THE EFFECTIVE DATES FOR EACH PERMIT. THE RESULTS OF THESE INEJCTION FLUID ANALYSES ARE TO BE SUBMITTED ANNUALLY. THE RESPONDENT FAILED TO SUBMIT THE RESULTS OF THE INJECTION FLUID ANALYSES FOR THE SUBJECT WELLS AS SHOWN BELOW: JESSE SULLIVAN #7 - PERMIT EFFECTIVE DATES, 8/20/90 - ANALYSES, NONE. BILLY WHITNEY #8 - PERMIT EFFECTIVE DATES, 10/22/01 - ANALYSES, NONE. HAROLD ERVIN #5 - PERMIT EFFECTIVE DATES, 10/2/07 - ANALYSES, NONE. JOE IRWIN #2 - PERMIT EFFECTIVE DATES 12/4/92 - ANALYSES, NONE. THEREFORE, RESPONDENT VIOLATED 40 CFR 144.51(a), ITS PERMIT, AND THE SDWA BY FAILING TO SUBMIT THE REQUIRED INJECTION FLUID ANALYSES FOR THE SUBJECT PERMITTED WELLS. THE PERMITS REQUIRES THE PERMITTEE TO MONITOR THE INJECTION AND ANNULUS PRESSURES AT THE WELLHEAD, THE FLOW RATE, AND CUMULATIVE VOLUME OF THE INJECTED FLUID. THE RESULTS OF ALL MONITORING ARE REQUIRED TO BE SUBMITTED BY THE END OF JANUARY OF THE FOLLOWING YEAR. RESPONDENT FAILED TO ANNUALLY SUBMIT MONITORING REPORTS FOR THE SUBJECT WELLS AS INDICATED BELOW: JESSE SULLIVAN #7; BILLY WHITNEY #8; HAROLD ERVIN #5; AND JOE IRWIN #2. THEREFORE, RESPONDENT VIOLATED 40 CFR 144.51(a), ITS PERMIT AND THE SDWA BY FAILING TO ANNUALLY SUBMIT THE REQUIRED MONITORING REPORTS FOR THE SUBJECT WELLS. THE FOLLOWING WELL IS OVERDUE FOR MECHANICAL INTEGRITY DEMONSTRATION OR PLUGGING AND ABANDONMENT: LIZZIE GUPTON #13 - LAST MIT, 4/12/06 - MIT DUE, 4/12/08. THEREFORE, RESPONDENT VIOLATED 40 CFR 144.28(c)(2)(iv) AND THE SDWA BY FAILING TO TIMELY DEMONSTRATE THE MECHANICAL INTEGRITY OR CLOSE, PLUG AND ABANDON THE SUBJECT RULE-AUTHORIZED INACTIVE WELL. 40 CFR 144.28(g)(2)(ii)(B) REQUIRES THE OWNER OR OPERATOR OF A RULE-AUTHORIZED INJECTION WELL TO MONITOR THE INJECTION PRESSURE, FLOW RATE, AND CUMULATIVE VOLUME OF THE INJECTED FLUID ON A MONTHLY BASIS FOR ENHANCED RECOVERY OPERATIONS. BY THE REGULATION AT 40 CFR 144.28(h)(2)(i), ALL MONITORING RESULTS ARE REQUIRED TO BE REPORTED TO THE DIRECTOR ANNUALLY. MONITORING REPORTS WERE NOT SUBMITTED ANNUALLY FOR THE SUBJECT RULE-AUTHORIZED WELL AS INDICATED BELOW: LIZZIE GUPTON #13. THEREFORE, RESPONDENT VIOLATED 40 CFR 144.28(c)(2)(iv) AND THE SDWA BY FAILING TO ANNUALLY SUBMIT THE REQUIRED MONITORING REPORTS FOR THE SUBJECT RULE-AUTHORIZED WELL.

Defendants (1)

• TRAVIS COOMER DRILLING COMPANY (SB)Named in complaintNamed in settlement

Facilities (5)

• LIZZIE GUPTON #13 UIC WELL

  LAT/LONG: 37.20900 / -85.55848, GREENSBURG, KY, 42743

  Registry ID: 110043253733

• JOE IRWIN #2 UIC WELL

  LAT/LONG: 36.92581 / -85.20086, JAMESTOWN, KY, 42629

  Registry ID: 110043253742

• BILLY WHITNEY #8 UIC WELL

  LAT/LONG: 37.01265 / -85.33527, COLUMBIA, KY, 42728

  Registry ID: 110043253715

• JESSE SULLIVAN #7 UIC WELL

  LAT/LONG: 36.93933 / -85.26075, COLUMBIA, KY, 42728

  Registry ID: 110043253706

• HAROLD ERVIN #5 UIC WELL

  LAT/LONG: 37.13112 / -85.52776, GREENSBURG, KY, 42743

  Registry ID: 110043253724

Statutes cited

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

Enforcement conclusions (1)

• TRAVIS COOMER DRILLING COMPANYentered 2010-10-14

  Primary law: SDWA

  Federal penalty: $10,715

Timeline (4 milestones)

• 2010-10-14Complaint Filed/Proposed Order
• 2010-10-14Final Order Issued
• 2010-12-21Enforcement Action Data Entered
• 2011-03-15Enforcement Action Closed