1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. UNIVERSITY OF TEXAS SYSTEMS, AN AGENCY OF THE STATE OF TEXAS SILVERTON CONSTRUCTION CO., INC., A TEXAS CORPORATION MARTIN K. EBY CONSTRUCTION CO., A KANSAS CORPORATION HENSEL PHELPS CONSTRUCTION CO., A COLORADO CORPORATION FACILITY: MEMORIAL STADIUM, ATHLETIC FACILITY AND SOCCER STADIUM CONSTRUCTION PROJECT 2110 E. CAMPUS DRIVE AUSTIN, TRAVIS COUNTY, TEXAS 78701 3. RESPONDENTS UNIVERSITY OF TEXAS SYSTEMS, SILVERTON, AND EBY WERE IN VIOLATION OF SECTION 301 OF THE CWA BY CON- DUCTING THE RELEVANT ACTIVITIES AND OPERATING THE FACILI- TIES WITHOUT NPDES PERMIT COVERAGE, AND RESPONDENT PHELPS WAS IN VIOLATION OF SECTION 301 OF THE CWA BY VIOLATING THE INTERIM STORM WATER POLLUTION PREVENTION PLAN (SWPPP) UNDER THE BASELINE PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED THE RESPONDENTS AN ADMINISTRATIVE ORDER (AO). THE AO ORDERED THE RESPONDENTS TO: A) WITHIN 30 DAYS, APPLY FOR AND OBTAIN NPDES PERMIT COVERAGE, SUBMITTING COPIES OF THE APPLICATIONS, CONFIRMATIONS OF COVERAGE, THE AS- SIGNED PERMIT NUMBERS TO EPA, B) TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO CORRECT TH