1. SECTION 309(A)(3) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A)(3). 2. PETE BENAVIDAS DBA LAREDO AUTO & TRUCK PARTS 9645 NEW LAREDO HIGHWAY SAN ANTONIO, BEXAR COUNTY, TEXAS 78211 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS TO WATERS OF THE U.S. WITHOUT AN NPDES PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A)(3) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) ORDERING THE RE- SPONDENT TO 1) WITHIN 45 DAYS OF THE EFFECTIVE DATE OF THE AO, SUBMIT ANY INFORMATION DETAILING WHY THE FACILITY HAS NOT COMPLIED WITH SECTION 301 OF THE CWA, 2) WITHIN 45 DAYS OF THE AO, OBTAIN AN NPDES PERMIT, 3) SUBMIT ANY POLLUTION PREVENTION PLAN, AND 40 WITHIN 45 DAYS OF THE AO, APPEAR AT EPA AND SHOW CAUSE.