KIRK CORPORATION, A DEVELOPER, FILLED A PORTION OF WET- LAND WHILE WAITING FOR THE CORPORATION ENGINEERS TO ISSUE A PERMIT. U.S. EPA ISSUED A PROJECT 309(G) ORDER FOR PENALTIES ON 1/12/88 AND A 309(A) ORDER TO REQUIREMITI- GATION UNDER AN AFTER - THE - FACT PERMIT (OR REMOVAL IF THE PERMIT IS NOT ISSUED) ON 1/13/88.