1. SECTION 113(A)(3) OF THE CLEAN AIR ACT ( CAA ), 42 U.S.C. SECTION 7413(A)(3). 2. HOUSTON MANUFACTURING & SPECIALTY COMPANY, INC., A TEXAS CORP. 9909 WALLISVILLE ROAD HOUSTON, HARRIS COUNTY, TEXAS 77013 3. RESPONDENT WAS IN VIOLATION OF SECTION 112 OF THE CAA BY (1) FAILING TO CONDUCT AN INITIAL PERFORMANCE TEST TO DE- MONSTRATE COMPLIANCE OF THE TANKS, (2) FAILING TO MAIN- TAIN RECORDS, (3) FAILING TO CONDUCT MONITORING TO DEMON- STRATE COMPLIANCE, (4) FAILING TO NOTIFY EPA SOURCE IS SUBJECT TO SUBPART N, (5) FAILING TO SUBMIT NOTIFCATION OF COMPLIANCE STAUS, (6) FAILING TO SUBMIT A REPORT OF THE PERFORMANCE TEST RESULTS, AND (7) FAILING TO MAINTAIN ON-SITE, A SUMMARY REPORT DOCUMENTING ONGOING COMPLIANCE STATUS. 4. RELIEF SOUGHT PURSUANT TO SECTION 113(A)(3) OF THE CAA, EPA ISSUED AN ADMINISTRATIVE COMPLIANCE ORDER (ACO) TO THE RESPONDENT. THE ACO REQUIRES THE RESPONDENT TO: (A) DEMONSTRATE THAT ITS FACILITY IS IN COMPLIANCE WITH THE REQUIREMENTS OF 40 CFR SECTION 63.342, NO LATER THAN 45 DAYS, (B) PREPARE AN OPERATION AND MAINTENANCE PLAN TO BE IMPLEMENTED NO LATER THAN 45 DAYS FROM THE EFFECTIVE DATE OF THE ACO, (C) IMMEDIATELY BEGIN MONITORING TO DEMON- STRATE CONTINUOUS COMPLIANCE, AND