1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. ESTACADO INDUSTRIES, A TEXAS CORPORATION HCR 1 BOX 99 DIMMIT, CASTRO COUNTY, TEXAS 79027 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY FAILING TO DEVELOP AND IMPLEMENT AN APPROPRIATE POLLUTION PREVENTION PLAN (PPP) BY JUN. 28, 1994. 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) WITHIN 30 DAYS, TAKE ACTION TO DEVELOP AND IMPLEMENT A PPP UTILIXZING BEST MANAGEMENT PRACTICES (BMPS) AS APPROPRIATE FOR THE FACILITY, MAIN- TAINING THE PPP AT THE FACILITY; AND B) WITHIN 30 DAYS, SUBMIT CERTIFICATION THAT THE PPP HAS BEEN DEVELOPED AND IMPLEMENTED, OR IF NOT POSSIBLE TO DO SO IN 30 DAYS, WITH IN 30 DAYS, SUBMIT A WRITTEN PLAN TO DO SO IN THE SHORT- EST POSSIBLE TIME, INCLUDING A DETAILED DESCRIPTION OF THE SPECIFIC ACTIONS TAKEN AND A PROPOSED DATE OF COMPLE- TION AND IMPLEMENTATION OF THE PPP.