1. SECTION 309(A)(3) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A)(3). 2. VICTOR AND JACKIE RICKER SCRAPPERS DEN NO. 61 9804 AIRLINE HIGHWAY GONZALES, LOUISIANA 70737 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS FORM THE FACILITY WITHOUT NPDES PERMIT COVERAGE. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A)(3) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) ORDERING THE RE- SPONDENT TO EXPLAIN THE FACILITY'S NON-COMPLIANCE, OBTAIN AN NPDES PERMIT, SUBMIT POLLUTION PREVENTION PLANS (PPP), AND MEET WITH EPA AND SHOW CAUSE.