COUNT 1: EPA WAS NOT INFORMED IN ADVANCE OF RESPONDENT'S INTENT TO CONVERT THE MALONE #3 INJECTION WELL TO A PRODUCTION WELL. COUNT 2: EPA WAS NOT NOTIFIED IN ADVANCE OF RESPONDENT'S INTENT TO P&A THE OVERTON #7 INJECTION WELL. COUNT 3: EPA DID NOT RECEIVE A STATEMENT THAT THE OVERTON #7 INJECTION WELL WAS PLUGGED IN ACCORDANCE WITH AN EPA APPROVED P&A PLAN. COUNT 4: RESPONDENT HAS FAILED TO SUBMIT FLUID ANALYSES ON ALL OF ITS INJECTION WELLS FOR THE YEARS 1994, 1995, 1996, AND 1997.