1. SECTION 1423(C) OF THE SFAE DRINKING WATER ACT ( SDWA ), 42 U.S.C. SECTION 300H-2(C). 2. NADEL AND GUSSMAN, AN OKLAHOMA COMPANY 3232 FIRST NATIONAL TOWER TULSA, TULSA COUNTY, OKLAHOMA 74103 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; AND 2) MAINTAINING INJECTION WELLS IN A MANNER THAT COULD ALLOW FLUID MOVE- MENT INTO UNDERGROUND SOURCES OF DRINKING WATER. 4. RELIEF SOUGHT PURSUANT TO SECTION 1423(C) OF THE SDWA, EPA ISSUED A PROPOSED ADMINISTRATIVE ORDER (AO) THAT WOULD ORDER THE RESPONDENT TO: A) PLUG AND ABANDON WELL NO. 7 AND WELL NO. 6 ACCORDING TO REGULATIONS; B) COM- PLETE APPROPRIATE ACTIONS TO PREVENT FLUID MOVEMENT INTO USDWS THROUGH WELL NO. 2, WELL NO. 3, WELL NO. 40-A, AND WELL NO. 19-A; AND C) SUBMIT A REPORT OF THE COMPLETED WORKS TO THE BIA AND TO THE EPA.