1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. PANNELL INDUSTRIES, INC., A TEXAS CORPORATION 4361 CEDAR LAKE DRIVE DALLAS, DALLAS COUNTY, TEXAS 75237 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 COV- ERAGE. 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 PERMIT NUMBER TO EPA; B) WITHIN 30 DAYS, TAKE CORRECTIVE ACTION TO CORRECT THE DEFICIENCIES AND ELIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS CITED AND TO COME INTO COMPLIANCE; C) WITH IN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECI- FIC ACTIONS TAKEN , EXPLAIN HOW THE ACTIONS WILL PREVENT RECUURENCE AND SUBMIT A COPY OF THE FACILITY'S SWPPP; D) IF NOT POSSIBLE TO CORRECT THE VIOLATIONS IN 30 DAYS, WITHIN DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORTEST POSSIBLE TIME; AND E) WITHIN 45 DAYS, ARRANGE TO MEET WITH EPA AND SHOW CAUSE.