RESPONDENT OWNS 10 DUAL PRODUCTION WELLS (BOTH PRODUCTION AND INJECTION). WHEN RESPONDENT DECIDED TO CHANGE THOSE WELLS TO PRODUCTION ONLY, HE FAILED TO PROVIDE WRITTEN NOTICE OF THE PLUGGING OF THE INJECTION PORTION. HE ALSO PLUGGED THE WELLS IN A MANNER DIFFERENT FROM THAT SPECIFIED IN THE PLUGGING AND ABANDONMENT PLAN WHICH WAS PART OF THE PERMIT FOR EACH WELL. EPA APPROVED THE CONVERSION OF 2 OF THE 10 WELLS, SO ONLY 8 WELLS ARE VIOLATING THE P&A PLAN.