SINCLAIR OIL CORPORATION IS THE OWNER AND OPERATOR OF LITTLE AMERICA REFINING COMPANY, LOCATED IN EVANSVILLE, WY. ON OR ABOUT APRIL 19, 1988, THE REGION ISSUED A UNILATERAL SECTION 7003(A) ADMINISTRATIVE ORDER REQUIRING SINCLAIR TO PERFORM CERTAIN TASKS. SINCLAIR OIL CORPORATION PERFORMED MOST OF THE TASKS REQUIRED BY THE ORDER BUT IN AN UNTIMELY MANNER. THE REGION SEEKS TO RECOVER PENALTIES FOR SINCLAIR'S FAILURE TO TIMELY PERFORM TASK 7.