1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. THE CITY OF MARSHALL, A TEXAS MUNICIPALITY 1800' SOUTHEAST OF THE INTERSECTION OF INTERSTATE 20 AND FIVE NOTCH ROAD MARSHALL, HARRISON COUNTY, TEXAS 75671 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS FROM POINTS NOT AUTHORIZED BY ITS PERMIT AND FAILING TO REPORT THOSE INSTANCES OF NONCOM- PLIANCE. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED THE RESPONDENT AN ADMINISTRATIVE ORDER (AO) THAT REQUIRED THE RESPONDENT TO: A) WITHIN 30 DAYS, TAKE WHAT- EVER CORRECTIVE ACTION IS NECESSARY TO ELIMINATE AND PRE- VENT RECURRENCE OF THE VIOLATIONS CITED; B) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC AC- TIONS TAKEN AND EXPLAIN HOW THESE ACTIONS WILL PREVENT RECURRENCE; C) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT WITH INFORMATION PERTAINING TO ALL BYPASSES OR OVERFLOW OCCURRING AT THE TREATMENT WORKS AND/OR THE COLLECTION SYSTEM SINCE JAN. 1, 1996; AND D) IF NOT POSSIBLE TO COR- RECT THE VIOLATIONS IN 30 DAYS, WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORTEST POSSIBLE TIME.