1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. RICHARD HENSON HOMES, A TEXAS CORPORATION MIKE BRATTLOF HOMES, A TEXAS CORPORATION FACILITY: THE WOODS 3311 WOODS BOULEVARD TYLER, SMITH COUNTY, TEXAS 75707 3. RESPONDENTS WERE IN VIOLATION OF SECTION 301 OF THE CWA BY EACH DAY THAT RESPONDENTS CONDUCTED THE RELEVANT AC- TIVITIES 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 RESPONDENTS 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 AND HOW THE ACTIONS WILL PREVENT RECUR- RENCE; 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, ARRANGE TO MEET WITH EPA AND SHOW