ON SEPTEMBER 30, 1993, REGION IV REFERRED TO DOJ A PROPOSED ACTION TO ENFORCE THE TERMS OF AN ADMINISTRATIVE ORDER ISSUED PURSUANT TO THE SAFE DRINKING WATER ACT FOR VIOLATIONS OF THE UNDERGROUND INJECTION CONTROL (UIC) REGULATIONS. THE ORDER WAS ISSUED IN 1992 AGAINST JAF OIL COMPANY, INC., AN INDEPENDENT OIL PRODUCER BASED IN CALIFORNIA BUT DOING BUSINESS IN KENTUCKY. JAF OWNS AND OPERATES 89 INJECTION WELLS IN KENTUCKY, WHICH INJECT BRINE FOR THE ENHANCE RECOVERY OF OIL. THE ACTION SEEKS TO OBTAIN COMPLIANCE AND PENALTIES FROM JAF AND FROM ITS PRESIDENT AND PRINCIPAL OWNER, PETER E. JOLLY. THE AO WAS ISSUED JANUARY 9, 1992, AND BECAME EFFECTIVE FEBRUARY 8, 1992. BECAUSE JAF DID NOT REQUEST A HEARING OR APPEAL THE ISSUANCE OF THE AO WITHING THE STATUTORY PERIODS, THE TERMS OF THE AO SHOULD NOT BE OPEN TO QUESTIONS. JAF HAS NOT COMPLIED WITH ANY TERMS OF THE AO, WHICH REQUIRE: (1) MEETING FINANCIAL RESPONSIBILITY REQUIREMENTS; (2) PROPERLY TESTING WELLS FOR MECHANICAL INTEGRITY; (3) FILING REQUIRED REPORTS; (4) MONITORING CERTAIN WELLS; AND (5) PROVIDING EPA WITH THE FRACTURE PRESSURE DATA RELEVANT FOR ITS OPERATIONS. THE MAXIMUM STATUTORY PENALTY CALCULABLE FOR THE VIOLATIONS EXCEEDS SEVERAL BILLION DOLLARS. THE ACTION PROPOSES PURSUING JOLLY INDIVIDUALLY AS WELL AS THE CORPORATION. JOLLY IS THE PRESIDENT OF THE CORPORATION, AND RESPONSIBLE FOR ALL ACTIONS AND