1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. WALTER KOEP 8 MILES SOUTH OF SEGUIN ON NOCKNUT ROAD SEGUIN, GUADALUPE COUNTY, TEXAS 78155 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY CONDUCTING THE RELEVANT ACTIVITIES AND OPERATING THE FA- CILITY WITHOUT NPDES PERMIT COVERAGE. 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, MAKE AN APPLICATION FOR PERMIT COVERAGE, SUBMITTING A COPY OF THE APPLICATION, CONFORMATION OF COVERAGE, AND THE AS- SIGNED PERMIT NUMBER TO EPA, B) WITHIN 30 DAYS, TAKE WHAT EVER CORRECTIVE ACTION IS NECESSARY TO CORRECT THE DE- FICIENCIES, ELIMINATE AND PREVENT RECURRENCE OF THE VIO- LATIONS CITED, AND TO COME INTO COMPLIANCE, C) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORTDETAILING THE SPECIFIC AC- TIONS TAKEN TO CORRECT THE VIOLATIONS, EXPLAIN HOW THEY WILL PREVENT RECURRENCE, AND INCLUDE A COPY OF THE SWPPP FOR THE FACILITY, AND D) IF NOT POSSIBLE TO CORRECT AND ELIMINATE THE VIOLATIONS WITHIN 30 DAYS, WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORTEST REASONABLE TIME.