The company converted 4 oil and gas wells in Michigan to UIC injection wells before it obtained Federal UIC permits. This is a violation of 40 CFR 144.31. Susan Prout is the ORC attorney. The company has agreed to pay the $16,000 penalty. Water Division approved CAFO on 8/28/2012. After 40-day comment period, Final Order signed 10/22/2012. Penalty paid in full in early November 2012. Termination letter sent 11/13/2012.