THIS IS A CIVIL ACTION UNDER THE UNDERGROUND INJECTION CONTROL ( UIC ) PROGRAM, SECTION 1423(B) OF THE SDWA, 42 USC 300H-2(B), FOR FAILURE OF DEFENDANT TO COMPLY WITH PART C OF THE SDWA, 40 CFR PART 144. ROBERT D. BENSON, SR., DEFENDANT, AN INDIVIDUAL DOING BUS- INESS AS BENSON OIL COMPANY, OWNS AND OPERATES 23 OIL PRO- DUCTION WELLS AND 29 ENHANCED RECOVERY UNDERGROUND INJEC- TION WELLS IN AN AREA OF APP. 415 ACRES DESIGNATED AS THE BENSON-ZINK LEASE . THESE WELLS ARE LOCATED IN ALLEGANY TOWNSHIP, CATTARAUGUS COUNTY, NY. THE VIOLATIONS UPON WHICH THE ACTION IS BASED: A. 40 CFR 144.26: FAILURE TO SUBMIT INVENTORY INFORMATION; B. 40 CFR 144.28(D): FAILURE TO DOCUMENT FINANCIAL RESPON- SIBILITY TO PLUG AND ABANDON WELLS; C. 40 CFR 144.28(C): FAILURE TO SUBMIT PLUGGING AND ABAN- DONMENT PLANS; D. 40 CFR 144.28(H): FAILURE TO SUBMIT ANNUAL MONITORING REPORTS; E. 40 CFR 144.11: UNAUTHORIZED INJECTION. THE PROPOSED RELIEF TO BE SOUGHT: INJUNCTIVE RELIEF REQUIRING DEFENDANT TO CEASE OPERATION UN- TIL HE OBTAINS A PERMIT; ADDITIONAL RELIEF REQUIRING DEFEN- DANT TO SUBMIT AN APPROVABLE PERMIT APPLICATION, EVIDENCE OF FINANCIAL RESPONSIBILITY, A PLUGGING AND ABANDONMENT PLAN AND ANNUAL MONITORING REPORTS; CIVIL P