The Non-Financial Ledger: What the Paperwork Doesn’t Price

There is a well in St. Clair County, Michigan. It sits in the southeast quarter of Section 22, Township 4 North, Range 15 East. Most people who live near it have no idea it exists. They don’t know that for years, a Colorado-based oil and gas company had a federal permit to pump salt water from production operations into the ground beneath them. They don’t know that the gauges meant to detect dangerous pressure buildups may have gone uncalibrated. They don’t know that for almost two years, nobody was checking anything at all.

The Safe Drinking Water Act exists because of what happens when industrial operators are trusted to police themselves. It exists because of communities that lost their water to contamination nobody caught until it was too late. The entire architecture of underground injection control, the permits, the weekly monitoring, the calibration records, the monthly reports, exists so that there is always a paper trail connecting a well operator to the safety of the water below ground. Strip away that paper trail, and you strip away accountability. What you are left with is a hole in the earth, a company with a financial interest in keeping that hole open, and the assumption that everything is fine.

The people of St. Clair County were not asked whether they trusted Stevens and Soldwisch to monitor their own compliance. The regulatory system made that decision for them. And the regulatory system, in this case, required weekly pressure readings, calibrated instruments, detailed records of who measured what and when, and monthly reports to EPA. When those requirements went unmet for months and years at a stretch, the community lost something that cannot be priced in a $23,000 settlement: the basic assurance that someone, somewhere, was actually watching.

Consider what it means for a well operator to “assume” that pressure is zero because injections have paused. A well does not exist in isolation. Underground formations shift. Casings degrade. Pressure migrates. The entire reason weekly monitoring is mandatory, even when a well is not actively injecting, is that a quiet well is not the same as a safe well. When the company stopped checking for 23 months, they were not making a conservative judgment call. They were eliminating the only mechanism that existed to detect a problem before it reached the aquifer.

The penalty is $23,406.53. Spread across 24 monthly installments, that is roughly $975 per month. For a company operating oil and gas properties, that is not a deterrent. That is an accounting line. The community near the Chudy #2 well received no compensation. There is no remediation fund. No independent monitor was appointed. The company signed a consent order, agreed to finally do what they were always required to do, and that was that.

The harm here is not dramatic in the way an oil spill is dramatic. There are no photographs. There is no plume visible from the road. The harm is the absence of oversight, the years-long gap between what regulators required and what this company delivered. Every week those gauges went unchecked was a week the people downstream in the water supply chain were protected by nothing more than the hope that nothing had gone wrong underground.

Legal Receipts: What the Government Documents Actually Say

These are direct quotes and findings from Docket No. SDWA-05-2024-0001, the Consent Agreement and Final Order filed with EPA Region 5 on January 18, 2024. The company neither admitted nor denied these facts, but agreed to pay a penalty and comply with remediation requirements.

“Respondent was not able to furnish to EPA calibration records for the annulus and injection pressure gauges, as Respondent does not have such records.”

— CAFO Paragraph 39, Count 1: Failure to Retain Annulus and Injection Gauge Calibration Records

• This quote proves that the company’s own claim, made in its March 2, 2022 response to EPA, that gauges “were calibrated,” was unverifiable. No records existed to support it. Claiming compliance without documentation is functionally the same as non-compliance under the permit’s terms.
• The permit, effective August 23, 2019, required calibration records to be retained for at least three years. The absence of records at the time of the October 23, 2019 inspection means violations were occurring within the first 60 days of the permit taking effect.

“Respondent did not include such information in its records… such as the date, exact place, and time of the sampling or measurement, and the individual who performed the sampling or measurement.”

— CAFO Paragraph 46, Count 2: Failure to Record All Required Monitoring Information

• This admission covers the entire active injection period, August 23, 2019 through February 2020. Every single week of that period, the company’s monitoring records were structurally incomplete. They were missing the who, the where, and the when of every measurement taken.
• Without those fields, a monitoring record cannot be audited, investigated, or used as evidence of anything. The records existed as a formality, not as a genuine accountability mechanism.

“Respondent presumed annulus and injection pressure to be… annulus and injection [pressure readings suggesting zero or no injection].”

— CAFO Paragraph 49, Count 3: Failure to Monitor (March 2020 through February 2022)

• The company stopped all calibrated gauge monitoring for 23 consecutive months and substituted assumption for measurement. The permit requires monitoring “at least weekly, using a calibrated gauge.” Presuming a value is explicitly not the same as measuring it.
• This 23-month monitoring gap is the single most dangerous failure in the record. A non-injecting well can still experience casing failures, pressure changes from adjacent formations, or migration of previously injected fluids. None of those conditions would have been detected under the company’s self-imposed monitoring blackout.

“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.”

— CAFO Paragraph 52, Count 4: Failure to Report

• This count covers 30 consecutive months of deficient monthly reports submitted to EPA. The reports looked like compliance. They were not. Key data fields required by the permit were absent the entire time.
• This means EPA’s own monitoring database for this well was incomplete for two and a half years. Any EPA analysis of this well’s safety record during that period would have been based on fundamentally flawed data.

Societal Impact Mapping: Who Actually Pays the Price

Public Health

The Safe Drinking Water Act’s Underground Injection Control program exists for one reason: to prevent industrial fluids from contaminating the aquifers that feed public water systems. Every lapse in this case was a lapse in that protection.

• The Chudy #2 well is authorized to inject salt water from oil production into underground formations in St. Clair County, Michigan. The SDWA defines underground injection as endangering drinking water sources when it “may result in the presence in underground water which supplies or can reasonably be expected to supply any public water system of any contaminant” that adversely affects public health. The monitoring gaps in this case mean any such contamination onset during that period would not have been recorded.
• For 23 consecutive months, no calibrated pressure measurements were taken at the well. Pressure anomalies, which can signal casing failures or fluid migration into protected aquifer zones, went undetected by design. The community served by the groundwater in this area had no effective early-warning system operating on their behalf during that window.
• The calibration gap compounds the monitoring gap. Even during the period when the company claimed to be taking measurements (August 2019 through February 2020), the gauges doing the measuring may not have been accurate. An uncalibrated pressure gauge reading “normal” is not evidence of a normal well. It is evidence of an unknown.
• The permit authorizes injection of salt water from production wells, a fluid that, if it reaches a drinking water aquifer, can render water supplies unusable. The entire regulatory framework assumes continuous monitoring to catch migration before it reaches a water source. That framework was not functioning for this well for the better part of three years.

Economic Inequality

Injection wells and the risks they carry are not distributed equally. They cluster in regions where land is cheap, political power is thin, and residents have less institutional capacity to push back against industrial operators.

• Stevens and Soldwisch is a Colorado corporation operating in Michigan. The decision-makers are not residents of St. Clair County. The risk is borne by the local community. The profits flow elsewhere. This is the standard spatial logic of extraction industries: costs are local, gains are distant.
• The $23,406.53 penalty is structured as 24 installments, allowing a company to spread the cost of its violations over two years. A working family facing a contaminated well does not get a payment plan. They face immediate costs for bottled water, filtration systems, medical testing, and potential relocation, none of which are compensated under this settlement.
• The maximum possible penalty under the SDWA for these violations was $313,448. EPA settled for 7.5% of that ceiling. The gap between maximum liability and actual penalty is the effective subsidy the regulatory system provides to companies that violate the law. For a going concern in oil and gas, a $23,000 fine spread over two years is a rounding error, not a deterrent.
• The consent order requires the company to develop and implement a Standard Operating Procedure within 90 days, covering how all monitoring will be performed going forward. That SOP should have existed before the permit was issued. The community absorbed the risk of its absence for three years, with no recourse and no compensation.
• Rural communities in Michigan’s oil patch lack the legal resources of corporate defendants. When EPA issues a Notice of Potential Violation, a company like Stevens and Soldwisch hires counsel, submits a formal NOPV Response, and negotiates a settlement. Residents of St. Clair County had no seat at that table. The settlement was determined entirely between the violator and the regulator.

The “Cost of a Life” Metric: Pricing the Unacceptable

What Now? Accountability, Oversight, and Organizing

The consent order requires future compliance but creates no independent verification, no community notification, and no compensation for the years the well operated outside regulatory requirements. These are the bodies and actions that matter now.

Watchlist: Regulatory Bodies with Jurisdiction

• EPA Region 5 (Chicago): Retains direct enforcement and permitting authority over this specific Class II well under the Michigan-EPA UIC Memorandum of Understanding. The enforcement officers of record are Monica Dix (Water Enforcement and Compliance Assurance Branch) and Hala Kuss (Office of Regional Counsel). Compliance submissions for the next 12 months go directly to Region 5. Monitor whether those submissions are being made and made on time.
• Michigan Department of Environment, Great Lakes, and Energy (EGLE): Administers the UIC program for Class II injection wells in Michigan under the state-level primacy arrangement. While EPA retained direct authority for this specific well, EGLE has broader oversight of the state’s injection well inventory and groundwater protection programs.
• EPA Office of Inspector General (OIG): Has authority to investigate whether EPA’s penalty calculation and settlement terms adequately served the public interest. The 7.5% penalty recovery rate is a legitimate subject of oversight inquiry.
• U.S. Department of Justice, Environment and Natural Resources Division: If Stevens and Soldwisch defaults on any of the 24 installment payments, EPA is explicitly authorized under this order to refer collection to DOJ. Track the payment schedule; default would trigger federal collection action.

Compliance Deadlines to Watch

• Within 14 days of the CAFO effective date: The company was required to begin using calibrated gauges for all monitoring. Verify this was done.
• Within 90 days of the CAFO effective date: The company was required to submit a Standard Operating Procedure for EPA review and approval covering all monitoring, recording, and reporting practices. That SOP must be approved before implementation.
• First annual report after CAFO effective date: Must include documentation of gauge calibration certification or replacement with pre-calibrated gauges.
• Monthly for 12 months post-CAFO: The company must submit copies of all monitoring records alongside monthly reports, postmarked no later than the 10th of each following month. These are public documents submitted to a federal agency. They can be requested under FOIA.

For Residents, Organizers, and Local Advocates

• File a FOIA request with EPA Region 5 for all monitoring reports submitted by Stevens and Soldwisch under Docket No. SDWA-05-2024-0001 following the CAFO effective date. These documents will show whether the company is now meeting its obligations or reverting to pattern. The request can be filed online through EPA’s FOIA portal at no cost.
• Contact your St. Clair County Commission representative and request that the county formally ask EGLE for a groundwater status assessment near the Chudy #2 well site. County commissioners have standing to make that request. Residents can attend commission meetings and raise this on public comment.
• Connect with Michigan-based environmental justice organizations, including the Michigan Environmental Justice Coalition and the Great Lakes Environmental Law Center, both of which track industrial permitting and enforcement in Michigan communities. They have legal staff who can assess whether additional regulatory action is warranted.
• Document your water: If you live in St. Clair County and receive water from a private well or small municipal system in the vicinity of Township 4 North, Range 15 East, Section 22, request a baseline water quality test from your county health department. Create a paper record now, before any potential future contamination event, so that any change is documentable.
• Attend EPA public comment periods: Future permit renewals or modifications for this well require public notice under the SDWA. Sign up for EPA Region 5 public notice alerts at epa.gov to be notified when the next opportunity to comment on this facility arises.