EPA v. L.A.W. OIL AND GAS, LLC

Case summary

10/23/14 - CONSENT AGMT AND FINAL ORDER ISSUED, ASSESSING A PENALTY OF $7,500 DUE WITHIN 60 DAYS. ALLEGATIONS: THE UIC PERMIT REQUEST THAT A DEMONSTRATION OF MECHANICAL INTEGRITY IN ACCORDANCE WITH 40 CFR 146.8 BE MADE NO LATER THAN 5 YEARS FROM THE LAST APPROVED DEMONSTRATION. THE INFO CONTAINED IN EPA'S RECORDS INDICATES THE MECHANICAL INTEGRITY DEMONSTRATIONS FOR THE FOLLOWING ACTIVE PERMITTED WELLS ARE OVERDUE OR WERE PERFORMED LATE, AS SHOWN BELOW: TRIPLETT #6 - MIT DUE, 3/14/11; MIT DONE, 11/29/11 OVERFIELD #22 - MIT DUE 10/24/11, MIT DONE, NOT YET. THEREFORE, RESPONDENT IS IN VIOLATION OF 40 CFR 146.8, THE UIC PERMIT AND THE SDWA FOR FAILURE TO TIMELY DEMONSTRATE THE MECHANICAL INTEGRITY OF THE ACTIVE PERMITTED WELLS AS SHOWN ABOVE. THE FOLLOWING WELLS WERE IN EXISTENCE ON JUNE 25, 2984, THE EFFECTIVE DATE OF THE UIC PROGRAM IN KY AS IMPLEMENTED BY EPA, THEREFORE, ARE AUTHORIZED BY RULE AS THAT TERM IS DEFINED IN 40 CFR 144.21(a) W.A. SAUER #2; C.E. SPRINGER #1W; WILSON #5; WILSON #10. THE SDWA AND 40 CFR 144.28(a) REQUIRE THE OWNER OR OPERATOR OF A RULE-AUTHORIZED INJECTION WELL TO COMPLY WITH ALL APPLICABLE STATUTORY AND REGULATORY REQUIREMENTS. THE REGULATION AT 40 CFR 144.28(g)(2)(iv) REQUIRES THE OWNER OR OPERATOR OF AN ACTIVE RULE-AUTHORIZED INJECTION WELL TO DEMONSTRATE MECHANICAL INTEGRITY AT LEAST ONE EVERY 5 YEARS. THE INFO CONTAINED IN EPA'S RECORDS INDICATES THE MECHANICAL INTEGRITY DEMONSTRATIONS FOR THE FOLLOWING WELLS WERE PERFORMED LATE: W.A. SAUER #2 - MIT DUE 11/1/06, MIT DONE 7/25/12; C.E. SPRINGER #1W - MIT DUE 8/15/07, MIT DONE 6/6/13; WILSON #5 - MIT DUE 3/14/11, MIT DONE 7/25/12; WILSON #10 - MIT DUE 3/14/12, MIT DONE 7/25/12. THEREFORE, RESPONDENT IS IN VIOLATION OF 40 CFR 146.8 AND THE SDWA FOR FAILING TO TIMELY DEMONSTRATE THE MECHANICAL INTEGRITY OF THE WELLS.

Defendants (1)

• L.A.W. OIL AND GAS, LLCNamed in complaintNamed in settlement

Facilities (8)

• OVERFIELD #7 UIC WELL

  LAT: 37.67049 / LONG: 87.47686, HENDERSON, KY, 42420

  Registry ID: 110063700561

• W.A. SAUER #2 UIC WELL

  LAT: 37.8652 / LONG: -87.73842, HENDERSON, KY, 42420

  Registry ID: 110063700419

• OVERFIELD #6 UIC WELL

  LAT: 37.67089 / LONG: 87.47405, HENDERSON, KY, 42420

  Registry ID: 110063700552

• C.E. SPRINGER #1 UIC WELL

  LAT: 37.66738 / LONG: -87.47595, HENDERSON, KY, 42420

  Registry ID: 110063700428

• WILSON #5 UIC WELL

  LAT: 37.64022 / LONG: -87.61118, HENDERSON, KY, 42420

  Registry ID: 110063701962

• OVERFIELD #2 UIC WELL

  LAT: 66738 / LONG: -87.47595, HENDERSON, KY, 42420

  Registry ID: 110063700543

• WILSON #10 UIC WELL

  LAT: 37.640474 / LONG: -87.615147, HENDERSON, KY, 42420

  Registry ID: 110063701971

• TRIPLETT #6 UIC WELL

  LAT/LONG: 37.72331 / -87.46009, HENDERSON, KY, 42420

  Registry ID: 110063216381

Statutes cited

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

Enforcement conclusions (1)

• L.A.W. OIL AND GAS, LLCentered 2014-10-23

  Primary law: SDWA

  Federal penalty: $7,500

Timeline (4 milestones)

• 2014-10-23Complaint Filed/Proposed Order
• 2014-10-23Final Order Issued
• 2015-01-05Enforcement Action Data Entered
• 2018-02-02Enforcement Action Closed