1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. THE CITY OF CACTUS, A TEXAS MUNICIPALITY P.O. BOX 365 CACTUS, MOORE COUNTY, TEXAS 79013 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS FROM ITS FACILITY WITHOUT AN AC- TIVE NPDES PERMIT. 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 AN NPDES PERMIT APPLICATION FOR DISCHARGES TO CACTUS PLAYA, WITHIN 30 DAYS, SUBMIT A REPORT DETAILING THE DATE, DURATION, ESTIMATED VOLUME, LOCATION, AND CAUSE OF ALL OVERFLOWS FROM THE COLLECTION SYSTEM THAT OCCURRED DURING THE TIME PERIOD JAN. 1, 1995 TO PRESENT, INCLUDING A DESCRIPTION OF ALL ACTIONS TAKEN TO MITIGATE THE EFFECTS OF THESE OVERFLOWS, C) WITHIN 30 DAYS, SUBMIT ALL ANALYTICAL DATA CHARACTERIZING THE QUALITY OF OVERFLOWS INCLUDING ANY ANALYTICAL DATA FROM SOIL OR SEDIMENT SAM- PLES TAKEN FROM AREAS AFFECTED BY THE OVERFLOWS, D) WITH- IN 30 DAYS, SUBMIT TO EPA COPIES OF ALL MONTHLY EFFLUENT REPORTS SUBMITTED TO THE TNRCC DURING THE PERIOD JAN. 1, 1995 TO PRESENT, AND E) UNTIL AN NPDES PERMIT HAS BEEN ISSUED, THE RESPONDENT WILL COMPL