1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. CITGO REFINING & CHEMICAL, INC., A TEXAS CORPORATION 1801 NUECES BAY BOULEVARD CORPUS CHRISTI, NUECES COUNTY, TEXAS 78469 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS FROM ITS FACILITY THAT EXCEEDED PERMITTED EFFLUENT LIMITATIONS, AS SHOWN IN THE CERTIFIED DMRS FILED WITH EPA. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED THE RESPONDENT AN ADMINISTRATIVE ORDER (AO) THAT ORDERED THE RESPONDENT TO: A) SUBMIT THE FOLLOWING TO EPA AND TNRCC: 1) COMPLIANCE SCHEDULE PROGRESS REPORTS, 2) NONCOMPLIANCE REPORTS, AND 3) DMRS WITH AN ORIGINAL SIG- NATURE; B) WITHIN 30 DAYS, TAKE CORRECTIVE ACTION TO E- LIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS; C) IF NOT POSSIBLE TO CORRECT THE VIOLATIONS IN 30 DAYS, WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORTEST POSSIBLE TIME; AND D) CONTINUE TO REPORT ALL IN- STANCES OF NONCOMPLIANCE WITH THE CWA ON A MONTHLY BASIS.