EPA IDENTIFIED AN ADDITIONAL 13 INJECTION WELLS LOCATED ON LEASES IN RESPONDENT'S NIAGARA FIELD WHICH ARE NOT PERMITTED OR AUTHORIZED BY RULE. THESE WELLS WERE OBSERVED TO BE IN OPERATION DURING AN INSPECTION. EPA DISCOVERED AN UN-CASED WELL AND A CASED WELL THAT FLOWS OIL AND BRINE TO THE SURFACE DURING INJECTION ACTIVITY. THESE TWO WELL COULD ALLOW (AND MAY HAVE ALLOWED) CONTAMINANTS TO MOVED INTO A USDW; RESPONDENT NEVER DEMONSTRATED FINANCIAL RESPONSIBILITY FOR THE WELLS.