1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. FIDEL UDENZE AND JOHN EGBUNA, D.B.A. AB'S LIKE NEW AUTO PARTS 3416 EAST JEFFERSON STREET GRAND PRAIRIE, DALLAS COUNTY, TEXAS 75051 3. RESPONDENTS WERE IN VIOLATION OF SECTION 301 OF THE CWA BY CONDUCTING THE RELEVANT ACTIVITIES AND OPERATING THE FACILITY WITHOUT NPDES PERMIT COVERAGE SINCE SEPT. 9, 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, AP- PLY FOR PERMIT COVERAGE, SUBMITTING A COPY OF THE APPLI- CATION, CONFIRMATION OF COVERAGE AND THE ASSIGNED PERMIT NUMBER TO EPA, B) WITHIN 30 DAYS, TAKE WHATEVER CORRECT- IVE ACTION IS NECESSARY TO CORRECT THE DEFICIENCIES AND ELIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS CITED, AND TO COME INTO COMPLIANCE, C) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC ACTIONS TAKEN TO CORRECT THE VIOLATIONS AND EXPLAIN HOW THEY WILL PREVENT RECURRENCE, AND SUBMIT A COPY OF THE SWPPP FOR THE FACIL- ITY, D) IF NOT POSSIBLE TO CORRECT THE VIOLATIONS WITHIN 30 DAYS, WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORTEST REASONABLE