1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. THE CITY OF GALVESTON, A TEXAS MUNICIPALITY NORTHEASTERN CORNER OF THE INTERSECTION OF 52ND STREET AND PORT INDUSTRIAL BOULEVARD GALVESTON, GALVESTON COUNTY, TEXAS 75802 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY THE UNAUTHORIZED DISCHARGES OF POLLUTANTS FROM LOCATIONS OTHER THAN THOSE AUTHORIZED BY THE PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED THE RESPONDENT AN ADMINISTRATIVE ORDER (AO). THE AO ORDERED THE RESPONDENT TO: A) COMPLY WITH THE SCHEDULE TO ELIMINATE OVERFLOWS FROM THE COLLECTION SYSTEM CON- TAINED IN THE AO, B) ELIMINATE ALL OVERFLOWS AND BYPASSES WHICH HAVE THE POTENTIAL TO REACH WATERS OF THE U.S. BY JAN. 1, 2002, C) CONTINUE TO SUBMIT QUARTERLY PROGRESS REPORTS TO EPA, AND D) OPERATE AND MAINTAIN THE COLLECT- ION SYSTEM SO AS TO MINIMIZE THE FREQUENCY, DURATION AND MAGNITUDE OF OVERFLOWS THAT OCCUR FROM THE COLLECTION SYSTEMS.