ARCO HAS VIOLATED THE SDWA AND REGULATIONS PROMULGATED THEREUNDER, INCLUDING 40 CFR 144.11, BY CONTRUCTING AN INJECTION WELL WITHOUT AUTHORIZATION, I.E. WITHOUT HAVING RECEIVED A VALID UIC PERMIT. THE MAXIMUM STATUTORY CIVIL PENALTY IS $5,000 FOR EACH DAY OF SUCH VIOLATION. THE PROPOSED RELIEF TO BE SOUGHT, INCLUDING INJUNCTION, AND PROPOSED AMOUNT OF PENALTY TO BE SOUGHT AT SETTLEMENT, IF APPLICABLE. WE ARE REQUESTING A CIVIL PENALTY ONLY IN THIS CASE. WE CALCULATE A STATUTORY MAXIMUM OF $110,000.00 AND RECOMMEND SETTLEMENT FOR $55,000.00 SIGNIFICANT NATIONAL OR PRECEDENTIAL LEGAL OR FACTUAL ISSURE. THIS IS ONE OF THE FIRST CASES PROSECUTING THE UNAUTHOR- IZED CONSTRUCTION OF AN INJECTION WELL.