A Well, A Permit, And Years Of Silence

Stevens and Soldwisch Oil and Gas Properties I, LLC is a Colorado corporation doing business in Michigan. On August 23, 2019, the EPA issued Permit No. MI-147-2D-0012 to the company, authorizing it to operate the Chudy #2 underground injection well in St. Clair County, Michigan. The permit did not grant the company a blank check; it came with a detailed list of monitoring, recordkeeping, and reporting requirements designed specifically to protect underground drinking water sources.

The Chudy #2 well is a Class II injection well. Under federal law, Class II wells inject fluids brought to the surface during oil and gas production, including salt water. The Safe Drinking Water Act gives the EPA authority to regulate these wells because poorly monitored injection wells can contaminate the underground water supplies that communities depend on for drinking water. The law defines “endangerment” as any injection that “may result in the presence in underground water which supplies or can reasonably be expected to supply any public water system of any contaminant.”

This is not abstract regulatory language. It is the legal architecture built after decades of contamination events that poisoned real water supplies used by real people. The permit conditions exist precisely because injection wells left unsupervised have a documented history of failure.

The Company Claimed It Was Watching. It Wasn’t.

The EPA inspected the Chudy #2 facility on October 23, 2019, just two months after the permit took effect. What the inspection revealed set the stage for everything that followed. When the EPA asked the company to produce gauge calibration records, the company could not furnish them. According to the consent agreement, Respondent “does not have such records.” The company had been operating monitoring equipment it could not prove was accurate, for a well designed to protect drinking water sources.

The permit required calibration records to be kept for at least three years. The permit required the company to furnish copies of those records to the EPA on request. The company claims it calibrated its gauges. Without records, that claim is simply a story.

The Non-Financial Ledger

What Nobody Paid For

There is a cost to this case that no penalty captures. An oil and gas company operated an underground injection well near Michigan’s drinking water supply for years. It did not keep the records its permit required. It did not log who took measurements, when they were taken, or where. When it could not produce calibration records at the very first EPA inspection, it still continued operating.

Injection wells that malfunction or are improperly monitored can allow salt water, hydrocarbons, and other production fluids to migrate into underground water tables. St. Clair County, Michigan is not an abstraction. It is a community. The people living near the Chudy #2 well site did not consent to have an oil and gas company skip safety monitoring in their backyard. They were not notified. They had no say. The system that was supposed to protect them depended entirely on a company that chose convenience over compliance.

For nearly two full years, from March 2020 through February 2022, the company did not take a single calibrated measurement of annulus or injection pressure at the Chudy #2 well. The permit required weekly measurements. That means over 100 separate weeks during which this company had a legal obligation to verify the well’s safety, and instead filed reports that contained no real data. During those same months, the company continued submitting monthly monitoring reports to the EPA. Those reports did not include the required flow rate data or cumulative volume measurements for the entire period from August 2019 through February 2022, nearly three years.

The Paperwork Is the Point

Some people hear “recordkeeping violation” and picture a bureaucratic technicality. It is the opposite. The requirement to log the date, exact place, time, and individual responsible for each measurement exists specifically so that when something goes wrong, investigators can trace it. Without those records, there is no accountability. Without those records, a contamination event can unfold for months before anyone with authority knows it happened.

Stevens and Soldwisch did not misplace a few forms. The company operated an injection well touching Michigan groundwater for years without generating the paper trail that would allow regulators to detect a problem. The monitoring records that do exist are missing the individual names of who performed the sampling. If something had gone wrong in one of those 100-plus unmonitored weeks, nobody could have been held responsible because nobody was officially there.

The communities near St. Clair County depend on groundwater the same way any community does. They fill glasses at kitchen sinks. They fill bathtubs for their kids. They do not think about injection wells when they do it. The legal infrastructure of the Safe Drinking Water Act, the permit conditions, the weekly monitoring requirements, exists so they do not have to think about it. When a company dismantles that infrastructure through negligence and paperwork fraud, the people who trusted the system absorb all the risk, with zero compensation, zero apology, and zero acknowledgment in the final settlement.

The consent agreement states plainly that the company “neither admits nor denies the factual allegations.” Nobody from Stevens and Soldwisch went on record to say they failed the community. No individual was named. No executive was held personally responsible. The company paid a penalty equivalent to roughly what a single average American worker earns in six months, spread across 24 comfortable installment payments, and the matter was concluded.

Legal Receipts

Their Words, On The Record

“Respondent was not able to furnish to EPA calibration records for the annulus and injection pressure gauges, as Respondent does not have such records.” EPA Consent Agreement and Final Order — Count 1, Paragraph 39

“During this period of time, Respondent did not monitor annulus and injection pressure readings at least weekly, using a calibrated gauge to obtain the pressure measurements. Rather, Respondent presumed annulus and injection pressure to be [within acceptable limits].” EPA Consent Agreement and Final Order — Count 3, Paragraph 49

“In monthly monitoring reports submitted to EPA for August 2019 through February 2022, Respondent did not include weekly measurements of flow rate and cumulative volume, and in monthly monitoring reports submitted to EPA for August 2019 through February 2020, Respondent did not include weekly measurements for injection pressure and annulus pressure.” EPA Consent Agreement and Final Order — Count 4, Paragraph 52

“Respondent was not able to furnish annulus and injection pressure monitoring records for August 23, 2019 through February 2020 that include all monitoring information required by Part II(E)(8)(c) of the Permit, such as the date, exact place, and time of the sampling or measurement, and the individual who performed the sampling or measurement, as Respondent did not include such information in its records.” EPA Consent Agreement and Final Order — Count 2, Paragraph 46

“Underground injection endangers drinking water sources if such injection may result in the presence in underground water which supplies or can reasonably be expected to supply any public water system of any contaminant, and if the presence of such contaminant may result in such system not complying with any national primary drinking water regulation or may otherwise adversely affect the health of persons.” EPA Consent Agreement and Final Order — Statutory Background, Paragraph 11, citing 42 U.S.C. § 300h(d)(2)

Societal Impact Mapping

Public Health

The Safe Drinking Water Act’s underground injection control program exists because underground water systems are interconnected in ways that surface-level monitoring cannot catch in real time. A well injecting salt water and production fluids into the earth near St. Clair County, Michigan sits within a geography that feeds aquifers, wells, and public water systems. The legal definition the EPA uses is deliberately broad: contamination endangers drinking water if it “may result” in harm. The word “may” does the heavy lifting. You do not have to wait for someone to get sick to trigger a violation.

For nearly two years, this company ran an injection well without measuring its own pressure readings. Elevated or dropping pressure in the annulus or injection zone are the primary signals that a well’s mechanical integrity may be compromised. Those signals exist so operators can catch problems before fluids migrate. Stevens and Soldwisch eliminated that early-warning system entirely, not through equipment failure, but through a deliberate decision to stop measuring. Communities near St. Clair County absorbed that risk without their knowledge.

There is no finding in this settlement that contamination actually occurred. But the monitoring system that would have detected contamination was dismantled. The absence of documented harm here is not proof of safety; it is proof that the safety system was not operating.

Economic Inequality

The penalty in this case was $23,406.53 (roughly the cost of a slightly above-average used car, or about what an average Michigan household spends on housing over six months). The EPA’s own regulations allow for penalties of up to $12,537 per day of violation, up to a maximum of $313,448 ($313,448 would cover a full year of groceries for roughly 87 average American families). The company received a penalty that represents less than 8 cents on every dollar of the maximum allowed.

That penalty gets paid in 24 monthly installments. The first payment was $975.27. That is a smaller monthly bill than most people in St. Clair County pay for car insurance. For an oil and gas company operating multiple production wells across Michigan, this is not a financial consequence. It is a rounding error. The structure of the penalty, stretched across two years and broken into small pieces, communicates a clear message: the cost of noncompliance is lower than the cost of compliance.

The communities living near injection wells are disproportionately working-class and rural. They do not have lawyers on retainer to scrutinize permit compliance. They do not have the resources to independently test their groundwater quarterly. They depend on regulatory enforcement to protect them. When the enforcement system delivers a two-year installment plan to a company that skipped safety monitoring for years, it tells those communities exactly where they stand.

The Cost of a Life Metric

What Now?

Who Is Responsible

The settlement names the corporate entity: Stevens and Soldwisch Oil and Gas Properties I, LLC, a Colorado corporation doing business in Michigan, based in Bow Mar, Colorado. No individual executives are named in the enforcement document. The company’s email contact on file with the EPA is fas@incss.net. No individual officer was held personally accountable.

Who Has Authority To Act

• U.S. EPA Region 5 (Chicago) — Water Enforcement and Compliance Assurance Branch — direct enforcement authority over this permit
• Michigan Department of Environment, Great Lakes, and Energy (EGLE) — administers the Class II UIC program under a federal-state MOU
• U.S. Department of Justice — authorized to pursue collection if penalties go unpaid
• EPA Office of Inspector General — oversees adequacy of penalty calculations and enforcement decisions
• U.S. EPA Office of Water — Safe Drinking Water Act oversight at the national level

The Compliance Order Is Still Active

The settlement does not close the book entirely. Stevens and Soldwisch must now submit calibrated monitoring records monthly for the first year, develop and implement a formal Standard Operating Procedure for monitoring within 90 days of the order’s effective date, and certify gauge calibration in its first annual report. The EPA retains the right to use any information submitted against the company in future administrative, civil, or criminal proceedings.