1. SECTION 1423(C) OF THE SAFE DRINKING WATER ACT ( SDWA ), 42 U.S.C. SECTION 300H-2(C). 2. MCKEE ENERGY COMPANY, INC. P.O. BOX 501 PAWHUSKA, OSAGE COUNTY, OKLAHOMA 74056 FACILITIES: AVANT FIEDL, OSAGE COUNTY, OKLAHOMA OS2428 WELL NO. 119, NW/4, SEC. 5, T23N, R12E OS3792 WELL NO. 125, NE/4, SEC. 5, T23N, R12E OS3790 WELL NO. 11C, SW/4, SEC. 30, T24N, R12E OS2569 WELL NO. 817, NW/4, SEC. 31, T24N, R12E OS0789 WELL NO. 914, SE/4, SEC. 31, T24N, R12E OS2572 WELL NO. 913W, SE/4, SEC. 31, T24N, R12E OS2348 WELL NO. 918W, SW/4, SEC. 32, T24N, R12E OS2345 WELL NO. 454, NW/4, SEC. 32, T24N, R12E OS3789 WELL NO. 4C, NE/4, SEC. 35, T24N, R12E 3. RESPONDENT WAS IN VIOLATION OF SECTION 1421 OF THE SDWA BY MAINTAINING CLASS II INJECTION WELLS WITHOUT MECHANI- CAL INTEGRITY AND FAILING TO COMPLY WITH WELL CONSTRUCT- ION REQUIREMENTS. 4. RELIEF SOUGHT PURSUANT TO SECTION 1423(C) OF THE SDWA, EPA ISSUED A PROPOSED ADMINISTRATIVE ORDER (AO) ORDERING THE RESPONDENT TO PLUG THE WELLS ACCORDING TO REGULATIONS OR CONVERT THE WELLS TO GAS OR OIL PRODUCTION ON OR BE- FORE DEC. 31, 1997. THE ORDER BECOMES EFFECTIVE 30 DAYS AFTER THE ISSUANCE DATE UNLESS AN