COMPLAINT FILED 5/4/99 PROPOSING A PENALTY OF $137,500. COMPLAINT ALLEGES: VIOLATION 1 RESPONDENT DID NOT PERFORM A MECHANICAL INTEGRITY TEST ON JULIE SALYERS #16 WELL UNTIL MARCH 7, 1996. THE REQUIRED TEST WAS DUE BY MAY 31, 1994. IN VIOLATION OF SDWA 40 C.F.R SECTION 144.51(A). VIOLATION 2 RESPONDENT HAS NOT SUBMITTED TO EPA ANNUAL MONITORING REPORTS FOR THE YEARS 1994 THROUGH 1998 AND INJECTION FLUID ANALYSIS REPORTS FOR THE PERIOD OF JANUARY 1993 THROUGH DECEMBER 1998. IN VIOLATION OF SDWA 40 C.F.R. SECTION 144.51(A).