1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. AUSTIN ENERGY, A TEXAS CORPORATION NATIONAL ENERGY PRODUCTION (NEPCO), A WASHINGTON CORP. FACILITY: SAND HILL ENERGY CENTER 13005 FALLWELL LANE DEL VALLE, TRAVIS COUNTY, TEXAS 78617 3. RESPONDENT NEPCO WAS IN VIOLATION OF SECTION 301 OF THE CWA BY EACH DAY THAT RESPONDENT CONDUCTED THE RELEVANT ACTIVITIES AND OPERATED THE FACILITY WITHOUT NPDES PERMIT COVERAGE AND RESPONDENT AUSTIN ENERGY WAS IN VIOLATION OF SECTION 402 OF THE CWA BY VIOLATING THE TERMS AND CONDI- TIONS OF THE PERMIT BY FAILING TO PREPARE A SWPPP AND FAILING TO CONDUCT INSPECTIONS. 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, NEPCO WILL OBTAIN NPDES PERMIT COVERAGE, SUBMITTING A COPY OF THE APPLICATION, CONFIRMATION OF COVERAGE AND THE PERMIT NUM- BER TO EPA; B) WITHIN 30 DAYS, AUSTIN ENERGY WILL TAKE CORRECTIVE ACTION TO CORRECT THE DEFICIENCIES AND ELIMI- NATE AND PREVENT RECURRENCE OF THE VIOLATIONS AND TO COME INTO COMPLIANCE; C) WITHIN 30 DAYS, SUBMIT A WRITTEN RE- PORT DETAILING THE SPECIFIC ACTIONS TAKEN TO CORRECT THE VIOLATIONS AND EXPLAIN HOW THE AC