1. SECTION 1423(C) OF THESAFE DRINKING WATER ACT ( SDWA ), 42 U.S.C. SECTION 300H-2(C). 2. FLAT ROCK ENERGY COMPANY, AN OKLAHOMA COMPANY 1122 SADDLE LANE SKIATOOK, OSAGE COUNTY, OKLAHOMA 74070 WELLS: OSAGE COUNTY, OKLAHOMA OS3774 WELL NO. W-69 SW/4, SEC. 33, T21 N, R12 E OS2137 WELL NO. W-74 SW/4, SEC. 04, T20 N, R12 E OS4268 WELL NO. W-72 NE/4, SEC. 04, T20 N, R12 E OS2132 WELL NO. W-22 NW/4, SEC. 04, T20 N, R12 E OS2182 WELL NO. W-65 NW/4, SEC. 08, T20 N, R12 E OS2497 WELL NO. W-68 SW/4, SEC. 33, T21 N, R12 E 3. RESPONDENT WAS IN VIOLATION OF SECTION 1421 OF THE SDWA BY 1) MAINTAINING THE WELLS WITHOUT MECHANICAL INTEGRITY, AND 2) FAILING TO COMPLY WITH CONSTRUCTION REQUIREMENTS. 4. RELIEF SOUGHT PURSUANT TO SECTION 1423(C) OF THE SDWA, EPA ISSUED A PROPOSED ADMINISTRATIVE ORDER (AO) TO THE RESPONDENT. THE PROPOSED AO WOULD REQUIRE THE RESPONDENT TO: 1) EITHER PLUG THE WELLS, ACCORDING TO REGULATIONS, OR COMPLETE OTHER APPROPRIATE CORRECTIVE ACTION, ACCORD- ING TO THE FOLLOWING SCHEDULE: WELL NO. W-69 BY DEC. 31, 1999; WELL NO. W-74 BY APR. 30, 2000; WELL NO. W-72 BY AUG. 31, 2000; WELL NO. W-22 BY DEC. 31, 2000;