REPONDENT PLACED 3 WELLS ON TA STATUS FOR OVER 2 YEARS. RESPONDENT DID NOT PLUG AND ABANDON OR DEMOSTRATE MECHAN- CAL INTEGRITY, IN VIOLATION OF 40 CFR SECT 141.28(C2IV). RESPONDENT DID NOT SUBMIT ANNUAL MONITORING REPORTS, IN VIOLATION OF 40 CFR SECT 144.28(G) AND (H).