1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. SULLIVAN TRANSFER COMPANY 3817 IRVING BOULEVARD DALLAS, DALLAS COUNTY, TEXAS 75247 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY EACH DAY THAT RESPONDENT CONDUCTED THE RELEVANT ACTIVI- TIES AN 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 THE EPA; B) WITHIN 30 DAYS, TAKE CORRECTIVE ACTION TO CORRECT THE DIFICIENCIES 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 AND EXPLAIN HOW THE AC- TIONS WILL PREVENT RECURRENCE; 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: AND E) WITHIN 45 DAYS, ARRANGE TO MEET WITH EPA AND SHOW CAUSE.