WITCO GOLDEN BEAR REFINERY OWNS AND OPERATES AN OIL REFINERY IN OILDALE, CALIFORNIA. WITCO HAS DISPOSED OF VARIOUS WASTES INTO THREE SHALLOW (14 TO 22 FEET DEEP) AND TWO DEEP (2600 TO 2900 FEET DEEP) INJECTION WELLS. WITCO USES THE SHALLOW WELLS TO DISPOSE OF WASTE OIL THAT SPILLS FROM STORAGE TANKS. WITCO USES THE DEEP WELLS TO DISPOSE OF A LARGE VOLUME OF REFINERY WASTES AND A RELATIVELY SMALL AMOUNT OF SPENT SOLVENTS (E.G. TOULUENE) USED TO CLEAN LAB EQUIPMENT. WITCO'S DISPOSAL OF OIL WASTE INTO THE SHALLOW WELLS IS ENDANGERING AN UNDERGROUND SOURCE OF DRINKING WATER ( USDW ) IN VIOLATION OF THE SAFE DRINKING WATER ACT (SDWA) AND THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA). THERE IS A SHALLOW ACQUIFER LOCATED ABOUT 40 FEET BENEATH THE SURFACE UNDERLYING WITCO'S REFINERY AND EXTENDING THROUGHOUT THE REGION. NOTABLY, FOUR DRINKING WATER WELLS LOCATED WITHIN ONE MILE OF THE REFINERY THAT TAP INTO THIS ACQUIFER HAVE BEEN ABANDONED DUE TO OIL CONTAMINATION. WITCO MIGHT BE CONTRIBUTING TO THE CONTAMINATION OF THESE WELLS. EVEN IF WITCO'S OPERATIONS HAVE NOT ACTUALLY CONTAMINATED THESE WELLS, THEY HAVE RISKED CONTAMINATION OF THE ACQUIFER UNDERLYING THE REFINERY. WITCO'S DISPOSAL OF SPENT SOLVENTS AND REFINERY WASTES INTO THE DEEP WELLS VIOLATES THE SDWA'S BAN ON OPERATION OF CLASS IV WELLS. A CLASS IV WELL IS