1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. STAR ENTERPRISE, A JOINT VENTURE PARTNERSHIP BETWEEN SAUDI REFINING, INC. AND TEXACO REFINING, INC. 4747 GREENVILLE AVENUE DALLAS, DALLAS COUNTY, TEXAS 75206 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS FROM A POINT SOURCE TO WATERS OF THE U.S. WITHOUT AN NPDES PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) TO THE RESPONDENT. THE AO ORDERS THE RESPONDENT TO: (A) WITHIN 30 DAYS, TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO ELIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS; (B) WITHIN 30 DAYS, SUBMIT A WRIITEN REPORT DETAILING THE SPECIFIC ACTIONS TAKEN TO CORRECT THE VIOLATIONS AND HOW THEY WILL PREVENT RECURRENCE; (C) IF NOT POSSIBLE TO CORRECT THE VIOLATIONS IN 30 DAYS, SUBMIT A PLAN TO DO SO IN THE SHORTEST TIME POSSIBLE; AND (D) WITHIN 45 DAYS, ARRANGE TO MEET WITH EPA AND SHOW CAUSE.