JURCHARAN BIAN IS THE CURRENT OWNER AND OPERATOR OF GARCIA AUTO PARTS, AN AUTO SALVAGE AND/OR SCRAP AND WASTE MATERIAL OPERATION. ACCORDING TO MR. JURCHARAN, THE FACILITY HAS BEEN IN OPERATION SINCE MARCH, 1998. MR. BIAN IS CURRENTLY OPERATING WITHOUT A NPDES PERMIT AND HAS NOT DEVELOPED OR IMPLEMENTED A STORM WATER POLLUTION PREVENTION PLAN. GARCIA CONTINUES TO DISCHARGE POLLUTED STORM WATER TO HICKEY RUN WHICH IS A TRIBUTARY TO THE ANACOSTIA RIVER IN WASHINGTON, DC.. HISTORICALLY, THE STREAM HAS BEEN PLAGUED BY ILLEGAL OIL AND GREASE DUMPING DUE, IN PART, TO A NUMBER OF TRANSPORTATION-RELATED FACILITIES IN THE WATERSHED. FOR THIS REASON, THE DISTRICT HAS SET AN OIL AND GREASE TOTAL MAXIMUM DAIL LOAD (TMDL) FOR HICKEY RUN. THIS IS THE ONLY TMDL THAT HAS BEEN APPROVED IN THE DISTRICT OF COLUMBIA. EPA WILL ALLEGE THAT THE DEFENDANT VIOLATED THE CWA BY (1) DISCHARGING POLLUTANTS WITHOUT AN NPDES PERMIT, (2) FAILING TO COMPLY WITH AN ADMINISTRATIVE ORDER, (3) FAILING TO SUBMIT AN NPDES PERMIT APPLICATION AND (4) DISCHARGING OIL IN HARMFUL QUANTITIES.