1. SECTION 1423(C) OF THE SAFE DRINKING WATER ACT ( SDWA ), 42 U.S.C. SECTION 300H-2(C). 2. LBG OPERATING COMPANY, AN OKLAHOMA COMPANY P.O. BOX 552 FAIRFAX, OSAGE COUNTY, OKLAHOMA 74637 WELLS: NO. 1, OS1206, SE/4, SEC. 10, T20 N, R11 E NO. 1, OS4030, NW/4, SEC. 24, T26 N, R4 E NO. 5, OS3736, NW/4, SEC. 24, T26 N, R4 E NO. 6, OS5468, NW/4, SEC. 8, T25 N, R4 E NO. 2, OS5460, SW/4, SEC. 12, T25 N, R6 E NO. 8, OS5181, NE/4, SEC. 28, T25 N, R6 E 3. RESPONDENT WAS IN VIOLATION OF SECTION 1421 OF THE SDWA BY: 1) FAILURE TO PLUG AND ABANDON WITHIN ONE YEAR AFTER TERMINATION OF INJECTION OPERATIONS; 2) MAINTAINING IN- JECTION WELLS IN A MANNER THAT COULD ALLOW FLUID MOVEMENT INTO UNDERGROUND SOURCES OF DRINKING WATER; AND 3) FAIL- URE TO SUBMIT ANNUAL OPERATION REPORTS. 4. RELIEF SOUGHT PURSUANT TO SECTION 1423(C) OF THE SDWA, EPA ISSUED A PROPOSED ADMINISTRATIVE ORDER (AO) THAT WOULD REQUIRE THE RESPONDENT TO: A) PLUG THE EXISTING WELLS ACCORDING TO REGULATIONS BY JUN. 1, 2002; B) COM- PLETE CORRECTIVE ACTIONS ON WELL NO. 6 NECESSARY TO PRO- TECT USDWS FROM CONTAMINATION DUE TO FLUID MOVEMENT THRU THE WELL BORE WITHIN 30 DAYS AFTE