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The United States Environmental Protection Agency (“EPA”) and Dart Oil & Gas Corporation (“Dart”) entered into a November 29th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of certain underground injection control regulations promulgated pursuant to the Safe Drinking Water Act. See Docket No. SDWA-05-2019-0002.

Dart is described as being authorized to inject into two Class II injection wells located in Crawford County, Michigan, pursuant to a permit.

The permit is stated to authorize the underground injection for the purpose of enhanced recovery of oil from the wells – subject to the terms and conditions set forth in the permit.

The CAFO states that Section G(1)(iv) of the permit required Dart to maintain positive pressure on the annulus on all active wells included in the permit. It further states that from May 1, 2012 through June 1, 2017, the annulus pressure at the Helveston 4-25 and Rodden 3-25 wells was zero pounds per square inch gauge (psig). This is alleged to constitute a violation of the permit and Safe Drinking Water Act.

Section G(2)(c) of the permit is stated to have required Dart to monitor the nature of the injection fluids quarterly and to monitor the specific gravity of the injection fluid monthly. Further, the permit is stated to have required Dart to report quarterly on the nature of the injection fluid and monthly on the specific gravity of the injection fluid for each active well.

Dart is stated to have failed to submit the quarterly fluid analysis reports to EPA for the first, second, and third quarter of 2014. This failure is alleged to be a violation of the permit and Safe Drinking Water Act.

Dart is stated to have failed to submit a specific gravity report to EPA for the month of September, 2015, for the Helveston 4-25 and Rodden 3-25 wells. Such alleged failure is stated to constitute a violation of the permit and Safe Drinking Water Act.

The CAFO assesses a civil penalty of $68,472.

A copy of the CAFO can be found here.