1. SECTION 1431(A) OF THE SAFE DRINKING WATER ACT ( SDWA ), 42 U.S.C. SECTION 300I(A). 2. SEABORD FARMS, INC., A DELAWARE CORPORATION SHAWNEE FUNDING LIMITED PARTNERSHIP, A DELAWARE PARTNER- SHIP PIC INTERNATIONAL GROUP, INC., A DELAWARE OWNER/OPERATOR FACILITIES: LACEY 1; LACEY 3; LACEY 4; LACEY 6; AND FAIR- VIEW NURSERY COMPLEX KINGFISHER AND MAJOR COUNTIES, OKLAHOMA 3. RESPONDENTS WERE IN VIOLATION OF SECTION 1431 OF THE SDWA BY THE DISCHARGE OF POLLUTANTS INTO AN UNDERGROUND SOURCE OF DRINKING WATER WHICH PRESENTS AN IMMINENT AND SUBSTAN- IAL ENDANGERMENT TO THE HEALTH OF PERSONS DRINKING THE WATER. 4. RELIEF SOUGHT PURSUANT TO SECTION 1431(A) OF THE SDWA, EPA ISSUED THE RESPONDENTS AN EMERGENCY ADMINISTRATIVE ORDER (AO) THAT ORDERED THE RESPONDENTS TO: 1) WITHIN 24 HOURS, NOTIFY EPA OF INTENT OF COMPLY; 2) WITHIN 24 HOURS DELIVER AN EMERGENCY SUPPLY OF WATER TO RESIDENTS AND EM- PLOYEES; 3) EVERY 7 DAYS, DELIVERY WATER TO THE RESIDENTS AND EMPLOYEES; 4) WITHIN 14 DAYS, NOTIFY EPA OF THE DE- LIVERY OF WATER, QUANTITY AND DATES OF DELIVERY; 5) WITH- IN 15 DAYS, SUBMIT TO EPA FOR APPROVAL, AN INVESTIGATION PLAN; 6) WITHIN 14 DAYS, ISSUE WRITTEN PUBLIC NOTICE BY PUBLICATION OF THE EXCEEDANCES; A