This Complaint and Notice of Opportunity for Hearing is issued to Jerry Byrkeland and Dennis Mines for owning/operating a Class V disposal facility which, through injection activity allows the movement of fluids containing any contaminant into underground sources of drinking water; failure to close or retrofit the Class V disposal system in a manner that would prevent contaminants from entering a USDW; and for operating a motor vehicle waste disposal facility after the 1/1/07 ban of all motor vehicle disposal wells.