1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. 1319(A). 2. KLAAS VELLENGA, D.B.A. VELLENGA DAIRY ROUTE 1, BOX 30 COMO, HOPKINS COUNTY, TEXAS 75431 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY FAILING TO DEVELOP AND IMPLEMENT AN APPROPRIATE POLLUTION PREVENTION PLAN (PPP) BY MAY 3, 1994. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) TO THE RESPONDENT. THE AO REQUIRES THE RESPONDENT TO, WITHIN 30 DAYS: A) TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO DEVELOP AND IMPLEMENT A PPP UTILIZING BEST MANAGEMENT PRACTICES FOR THE FACILITY, AND B) SUBMIT CERTIFICATION TO EPA THAT A PPP HAS BEEN COMPLETED AND IMPLEMENTED, OR, IF NOT POS- SIBLE WITHIN 30 DAYS, SUBMIT A PLAN TO DO SO IN THE SHORTEST TIME POSSIBLE.