The Well That Went Dark: Missing Data and Michigan’s Drinking Water

The EPA accused Stevens and Soldwisch Oil and Gas Properties I, LLC of basic monitoring and reporting failures at a Class II injection well in St. Clair County, Michigan… failures which undercut safeguards meant to keep drinking water sources protected.

The evil company agreed to pay a civil penalty and comply with strict recordkeeping, calibrated monitoring, and reporting requirements that should have been routine from day one.

Keep reading for the full picture of how missing logs, uncalibrated gauges, and paper-thin reporting erode public health protections and thrive inside a system that rewards cutting corners.

The Core Failure

This case centers on a single, preventable breakdown: a company ran an injection well which required careful, calibrated monitoring and accurate records, then promptly failed to produce the calibration proof and full monitoring data that regulators demanded.

The well, known as Chudy #2 in St. Clair County, operated under a federal permit which set out straightforward duties (calibrate gauges, check pressures weekly, keep complete records, and send accurate monthly reports) yet the company came up short on each of those basics.

The EPA’s enforcement action resolved with a civil penalty and a set of remedial steps that read like a back-to-the-basics checklist for a facility handling oilfield wastes!

Inside the Allegations: Corporate Misconduct

The EPA documented four counts which point to a fairly damning (imo at least) pattern: missing calibration records, incomplete monitoring records, failure to monitor during a lengthy period, and reporting that omitted required weekly measurements.

The company told EPA that gauges were calibrated and pressures were recorded, but it could not furnish calibration records and could not supply monitoring records with required details such as date, exact place, time, and the person who took the measurements.

The EPA determined an appropriate civil penalty of $23,406.53 and imposed compliance requirements to restore basic controls, including certified calibration, standard operating procedures, and monthly submission of all monitoring records for a year.

Timeline of Key Events (from the record)

Each entry above is drawn directly from the enforcement order and the counts it sets out. The dates, duties, and deficiencies align with the permit’s monitoring and reporting rules, which are designed to prevent underground injection that could threaten drinking water.

Regulatory Capture & Loopholes

The Safe Drinking Water Act’s underground injection control framework is clear: no injection unless authorized, and every authorization comes with tight monitoring, recordkeeping, and reporting duties. When a company cannot produce calibration certificates and required weekly data fields, the guardrails that keep contaminants away from drinking water sources weaken at the point of enforcement.

Under our modern day neoliberal capitalism, evil companies rely on a deregulatory drumbeat that treats enforcement as an occasional cost rather than a binding discipline. When reporting turns into check-the-box submissions without the required weekly measurements, agencies face more work to reconstruct what happened in the field while firms keep the savings from lighter paperwork and fewer technician hours.

The pattern does not require a sweeping statute change; it requires daily diligence, which a permissive environment can quietly erode.

Profit-Maximization at All Costs

The record reads like an accounting ledger of avoided effort: calibrations without proof, measurements without full entries, and months where monitoring was replaced with pressure assumptions. These are the kinds of choices that shrink operating costs in the short run; fewer calibrations to schedule, fewer details to capture, fewer site visits to log weekly readings. The outcome is a facility that claims oversight while failing to meet the basic terms that make oversight real.

Shareholder primacy rewards margin gains that come from trimming compliance to the thinnest possible layer. A system that ties executive success to near-term savings gives managers a direct incentive to de-scope the invisible work of monitoring and documentation. The order’s remedy (mandating SOPs, calibration documentation, and monthly submission of all monitoring records) is an explicit correction to a business model that treated compliance as an optional extra.

The Economic Fallout

The penalty is modest in headline terms, but it translates into a two-year payment plan across 24 installments, with interest and additional financial consequences if late. This structure turns a one-time fine into a persistent financial obligation that crowds a company’s cash flow and signals that missed basics have a price tag that lingers. The order also requires concrete spending on calibrated gauges, training, and record systems that add recurring costs to operations.

Public budgets absorb the other side of these failures. When regulators must spend time chasing records and reasserting baseline duties, taxpayers finance the overhead of bringing a facility up to the level the permit required from day one. That is the hidden subsidy when companies externalize compliance effort and turn basic monitoring into an afterthought.

Environmental & Public Health Risks

The law treats underground injection as a potential threat to sources of drinking water unless strict conditions are met every week, every month, and every year. The record shows missing calibration documentation, missing weekly monitoring, and reporting gaps over long stretches, all of which degrade confidence that injection safeguards functioned as intended. When weekly pressures, flow rates, and cumulative volumes are absent from monthly reports, regulators cannot verify whether the well stayed within safe limits.

This is why the compliance order demands calibrated gauges within 14 days, documented calibration or replacement in the next annual report, and submission of all monitoring records for a full year.

The remedy reestablishes a chain of evidence from instrument to spreadsheet to agency inbox, so that each reported number can be traced to a time, a place, a person, and a calibrated device. The point is clear: paperwork becomes protection only when it reflects real measurements gathered with verified tools.

Legal Minimalism: Doing Just Enough to Stay Plausibly Legal

The record illustrates how an operator can proceed under an enforceable permit and still allow the compliance core to fray; calibration records go missing, weekly monitoring lapses, and required data fields drop from reports. A system that prizes formal submission over verifiable measurement creates space for a version of compliance that satisfies the surface and leaves the substance undone. The remedy in this case responds by codifying the substance through calibrated equipment, full record sets, and SOP-driven training.

In many industries, this is the preferred equilibrium. Companies meet the letter of submission while the intent (continuous, traceable protection of shared resources) gets sidelined. The way back runs through measurable duties and documentary proof that stands on its own.

How Capitalism Exploits Delay: The Strategic Use of Time

Time softens accountability when monitoring gaps and missing records extend across months or years. Each delayed fix keeps operating costs low and transfers risk to the public during the period when measurements should have been occurring. Enforcement that arrives later must rebuild the missing history with penalties and future-facing controls rather than a live-time record of safe operation.

The order imposes deadlines (14 days for calibrated gauges, 90 days for a standard operating procedure, and monthly reporting with full records for 12 months) that reclaim the clock. These dates convert time from a shield into a tool for public protection. The lesson is straightforward: timetables enforce integrity when everyday diligence fails.

The Language of Legitimacy: How Courts Frame Harm

Administrative resolutions lean on careful phrases that bring formality without a narrative of wrongdoing. The respondent’s position appears in a simple clause: consent to the penalty and terms, with neither admission nor denial of factual allegations. This language ends disputes and standardizes outcomes, yet it also narrows what the public learns about decisions that led to missing records and monitoring lapses.

Documents of this kind are precise about duties and remedies. They describe what must happen next rather than relitigating what happened before. The focus on calibrated gauges, full records, and SOPs underlines the gap between the system as designed and the choices that unfolded on the ground.

Monetizing Harm: When Victimization Becomes a Revenue Model

A small penalty with interest spread over 24 payments becomes a predictable cost center. The company can schedule the outflows and adjust cash planning, which normalizes the breach of basic safeguards into a line item. The policy design aims to deter, yet the payments may blend into operations that already budget for compliance clean-ups.

When enforcement converts missing measurements into a fixed payment plan and a set of process improvements, firms learn to price the difference between diligence and delay. The public obtains stronger procedures going forward, while the past remains an administrative summary. Deterrence needs visibility into who decided to skip the core tasks that protect water.

Profiting from Complexity: When Obscurity Shields Misconduct

Complex regulatory frameworks require expertise, record systems, and calibrated tools. When operators allow those systems to thin, the opacity of underground injection work makes lapses hard for the public to spot. The order responds by insisting on traceable records, defined roles, and retained calibration and maintenance logs for at least three years.

Clarity is a brake on harm in complex systems. Entities that inject industrial fluids must show their work in durable, reviewable form. The document’s record-retention and reporting provisions give regulators the leverage to look under the hood when red flags appear.

This Is the System Working as Intended

A structure that prioritizes growth and cost control will generate periodic monitoring failures unless verification is constant. Administrative settlements with scheduled payments and procedural fixes fit cleanly into that world. The public receives incremental protection, and firms carry on with a revised checklist.

The file proves that basic guardrails require more than rules. They require calibrated instruments, complete logs, and monthly transparency that links each number to a person and a time. The case shows how quickly these elements slip when profit and convenience take precedence.

Conclusion

This enforcement action states a simple truth: drinking water protection depends on the unglamorous work of calibration and recordkeeping.

When those duties lapse, the risk shifts to communities, and regulators must pull operators back to the baseline through penalties and forced documentation. The solution is durable only if the habits of monitoring and transparent reporting become ingrained parts of daily operations.

The EPA has a link to this consent agreement: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/2899F7F6C4CA6CA385258AA8005DCF61/$File/SDWA-0~3.PDF