1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. BLUE AMERICAN ICE COMPANY, INC., A TEXAS CORPORATION 2431 WEST COMMERCE STREET DALLAS, DALLAS COUNTY, TEXAS 75212 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY EACH DAY THAT RESPONDENT CONDUCTED THE RELEVANT ACTIVI- TIES AND OPERATED THE FACILITY WITHOUT NPDES PERMIT COVERAGE. 4. RELIEF SOUGHT PURSUANT TO SECTIONS 308(A) AND 309(A) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) THAT ORDERED THE RESPONDENT TO: A) WITHIN 30 DAYS, OBTAIN NPDES PERMIT COVERAGE, SUBMITTING A COPY OF THE APPLICA- TION, CONFIRMATION OF COVERAGE AND THE NPDES PERMIT NUM- BER TO EPA; B) WITHIN 30 DAYS, TAKE CORRECTIVE ACTION TO CORRECT THE DEFICIENCIES AND ELIMINATE AND PREVENT RECUR- RENCE OF THE VIOLATIONS CITED AND TO COME INTO COMPLI- ANCE; C) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAIL- ING THE SPECIFIC ACTIONS TAKEN TO CORRECT THE VIOLATIONS AND EXPLAIN HOW THE ACTIONS WILL PREVENT RECURRENCE; D) 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 E) WITHIN 45 DAYS, AR- RANGE TO MEET WITH EPA AND SHOW CAUSE.