6/9/09 - CONSENT AGMT WITH STIPULATED PENALTY ISSUED. RESPONDENT OWNS AND/OR OPERATES THE FOLLOWING CLASS II ENHANCED RECOVERY INJECTION WELLS ON THE PRESTON SLOAN LEASE:
PRESTON SLOAN NUMBERS 5, 8, 11, 17, 20, 21, 24, 25, W-1, W-2, W-3, W-4, AND W-5. RESPONDENT PURCHASED THE LEASE ON THE SUBJECT WELLS FROM CHARLIE PERDUE AND PERDUE DAVIDSON ON OR ABOUT OCT 6, 2008. AT THE TIME OF THE PURCHASE, NO DEMONSTRATION OF MECHANICAL INTEGRITY HAD EVER BEEN SUBMITTED TO EPA, IN VIOLATION OF 40 CFR 144.28(f)(2); NO MONITORING REPORT OR FLUID ANALYSIS REPORTS HAD EVER BEEN SUBMITTED TO EPA, IN VIOLATION OF 40 CFR 144.28(h)(2); AND NO DEMONSTRATION OF FINANCIAL RESPONSIBILITY FOR PLUGGING AND ABANDONMENT HAD EVER BEEN SUBMITTED TO EPA, IN VIOLATION OF 40 CFR 144.28(d).