1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. SIMPSON PASADENA PAPER COMPANY, A WASHINGTON CORPORATION NORTH SHAVER AND WASHBURN TUNNEL PASADENA, HARRIS COUNTY, TEXAS 77506 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY CONDUCTING THE RELEVANT ACTIVITIES AND OPERATING THE FACILITY WITHOUT NPDES PERMIT COVERAGE FROM SEPT. 9, 1997 UNTIL NOV. 19, 1997. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) TO THE RESPONDENT. THE AO ORDERED THE RESPONDENT TO: A) WITHIN 30 DAYS, SUB- MIT A WRITTEN REPORT DETAILING THE SPECIFIC ACTIONS TAKEN TO CORRECT THE VIOLATIONS, EXPLAIN WHY SUCH ACTIONS WILL PREVENT RECURRENCE, AND SUBMIT A COPY OF THE STORM WATER POLLUTION PREVENTION PLAN (SWPPP) FOR THE FACILITY, AND B) IF NOT POSSIBLE TO CORRECT THE VIOLATIONS WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORT- EST TIME POSSIBLE.