1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. B & F CATTLE COMPANY, AN OKLAHOMA COMPANY 310 COLLEGE ROAD, P.O. BOX 841 ALVA, WOODS COUNTY, OKLAHOMA 73717 3. RESPONDENT WAS IN VIOLATION OF SECTIN 201 OF THE CWA BY FAILING TO DEVELOP AND FULLY IMPLEMENT AN APPROPRIATE POLLUTION PREVENTION PLAN (PPP) FOR ITS FACILITY BY MAR. 10, 1994. 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, TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO DEVELOP AND IMPLEMENT ITS PPP, CORRECT THE INSPECTION DEFICIENCIES, AND MAINTAIN THE PPP AT THE FACILITY, AND B) WITHIN 30 DAYS, SUBMIT A LETTER TO EPA CERTIFYING THAT THE INSPECT- ION DEFICIENCIES HAVE BEEN CORRECTED; OR, IF NOT POSSIBLE TO CORRECT THE DEFICIENCIES WITHIN 30 DAYS, WITHIN 30 DAYS, SUBMIT A WRITTEN PLAN FOR THE COMPLETION AND IMPLE- MENTATION OF AN APPROPRIATE PPP WITHIN THE SHORTEST REASONABLE TIME, INCLUDING A DETAILED DESCRIPTION OF THE SPECIFIC ACTIONS TO BE TAKEN AND A PROPOSED DATE OF COM- PLETION AND IMPLEMENTATION.