1. SECTION 1423(C) OF THE SAFE DRINKING WATER ACT ( SDWA ), 42 U.S.C. SEC. 300H-2(C). 2. PHILLIPS PETROLEUM COMPANY ROUTE 1, BOX 427 SHIDLER, OKLAHOMA 74652 LOCATION OF WELLS: NE/4, SEC. 11, T27N, R05E SW/4, SEC. 11, T27N, R05E SW/4, SEC. 23, T27N, R05E SW/4, SEC. 23, T27N, R05E NW/4, SEC. 26, T27N, R05E NE/4, SEC. 35, T27N, R05E NE/4, SEC. 01, T26N, R05E NE/4, SEC. 01, T26N, RO5E NW/4, SEC. 28, T26N, R05E SE/4, SEC. 11, T27N, R05E 3. RESPONDENT VIOLATED REGULATIONS AT 40 C.F.R. SECS. 147. 2909, 147.2911, AND 147.2912(A)(2) BY MAINTAINING THE WELLS, WHICH LACK MECHANICAL INTEGRITY IN THAT CONSTRUCT- ION IS INADEQUATE TO PREVENT SIGNIFICANT FLUID MOVEMENT INTO USDWS THROUGH VERTICAL CHANNELS ADJACENT TO THE WELL BORES. 4. RELIEF SOUGHT PURSUANT TO SECTION 1423(C) OF THE SDWA, A PROPOSED ADMINISTRATIVE ORDER WOULD REQUIRE THE RESPOND- ENT TO PLUG THE WELLS ACCORDING T