RESPONDENT OWNS AND/OR OPERATES AT LEAST 15 ENHANCED RECOVERY INJECTION WELLS WHICH DO NOT HAVE CASING AND CEMENTING AS REQUIRED BY 40 CFR 144.28(E)(1). RESPONDENT OWNS AND/OR OPERATES AT LEAST 23 ENHANCED RECOVERY INJECTION WELLS WHICH HAVE NOT HAD DEMONSTRATIONS OF MECHANICAL INTEGRITY AT LEAST ONCE EVERY 5 YEARS AS REQUIRED BY 40 CFR 144.28(G)(2)(IV)(A). RESPONDENT OWNS AND/OR OPERATES AT LEAST 23 ENHANCED RECOVERY INJECTION WELLS WHICH HAVE BEEN INACTIVE FOR MORE THAN 2 YEARS AND HAVE NOT BEEN PLUGGED AND ABANDONED NOR TAKEN ACTIONS AND PROCEDURES AS REQUIRED BY 40 CFR 144.28(C)(2)(IV). RESPONDENT OWNS ANDOR OPERATES INJECTION WELLS FOR WHICH NO ANNUAL REPORTS HAVE BEEN SUBMITTED SINCE 1988. RESPONDENT OWNS AND/OR OPERATES UNDERGROUND INJECTION WELLS AND HAS NOT DEMONSTRATED FINANCIAL RESPONSIBILITY AND RESOURCES TO CLOSE, PLUG AND ABANDON THE UNDERGROUND INJECTION OPERATION IN A MANNER PRESCRIBED BY EPA.