9/16/14 - ADMINISTRATIVE ORDER ISSUED.
CONSTRUCTION REQUIREMENTS OF THE UIC PERMIT PROVIDE THAT INJECTION MAY NOT COMMENCE UNTIL THE PERMITTEE HAS FILED THE NOTICE OF COMPLETION FORM 7520-10; THE WELL HAS BEEN SHOWN TO HAVE MECHANICAL INTEGRITY; RESPONDENT HAS SUBMITTED LOGS, TESTS, AND REPORTS AS REQUIRED BY PERMIT -- NONE OF WHICH HAS BEEN COMPLETED.
ROUTINE INSPECTION BY THE EPA-AUTHORIZED INSPECTOR ON APR 14, 2011 AND NOV 19, 2012 FOUND THE WELL TO BE ACTIVE. RESPONDENT IS IN VIOLATION OF THE SDWA AND 40 CFR 144.51(a).
OPERATING REQUIREMENTS FOUND IN THE PERMIT STATE THAT THE MAX ALLOWABLE PRESSURE MEASURED AT THE WELLHEAD SHALL NOT EXCEED 450 POUND PER SQUARE INCH (psig). DURING THE ROUTINE INSPECTION CONDUCTED ON APR 14, 2011, IT WSA OBSERVED THAT THE GAUGE READING ON THE INJECTION TUBING WAS 980 psig. THE INSPECTOR ALSO NOTED THAT THE GAUGE READING ON THE INJECTION PUMP SHOWED THAT THE PUMP WAS SET AT 980 psig. RESPONDENT IS IN VIOLATION OF THE SDWA AND 40 CFR 144.51(a) AND 146.23(a)(1) AND THE UIC PERMIT FOR EXCEEDING THE MAXIMUM INJECTION PRESSURE LIMITATION ESTABLISHED FOR THE UIC PERMIT FOR THE SUBJECT WELL; THAT WAS INTENDED TO PREVENT FRACTURES INTO THE CONFINING ZONE AND TO PREVENT MOVEMENT OF INJECTION OR FORMATION FLUIDS INTO AN UNDERGROUND SOURCE OF DRINKING WATER.
MONITORING REQUIREMENTS IN THE PERMIT REQUIRE THE PERMITTEE TO WEEKLY MONITOR THE INJECTION AND ANNULUS PRESSURES AT THE WELLHEAD, THE FLOW RATE, AND TO MONTHLY MONITOR THE CUMULATIVE