1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. DAVID A WATERS, AN OKLAHOMA COMPANY ROUTE 2, BOX 387 PAWNEE, PAENEE COUNTY, OKLAHOMA 74058 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY FAILING TH DEVELOP AND FULLY IMPLEMENTING AN APPROPRIATE POLLUTION PREVENTION PLAN (PPP) BY MAR. 10, 1994 AS RE- QUIRED. 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 ACTION IS NECESSARY TO DEVELOP AND IMPLEMENT ITS PPP, CORRECT THE INSPECTION DEFICIENCIES, AND MAINTAIN ITS PPP AT ITS FACILITY, AND B) WITHIN 30 DAYS, SUBMIT A LETTER TO EPA CERTIFYING THAT THE INSPECTION DEFICIENCIES HAVE BEEN CORRECTED; OR, IF NOT POSSIBLE TO CORRECT THE VIOLATIONS WITHIN 30 DAYS, WITHIN 30 DAYS, SUBMIT A WRIT- TEN PLAN FOR THE COMPLETION AND IMPLEMENTATION OF AN AP- PROPRIATE PPP WITHIN THE SHORTEST REASONABLE TIME, IN- CLUDING A DETAILED DESCRIPTION OF THE SPECIFIC ACTIONS TO BE TAKEN AND A PROPOSED DATE OF COMPLETION AND IMPLEMENT- ATION.