1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. SGI BEAUMONT-II, LTD., A TEXAS PARTNERSHIP EMJ CORPORATION, A TEXAS CORPORATION FACILITY: SHOPS AT DOWLEN 4100 DOWLEN ROAD BEAUMONT, JEFFERSON COUNTY, TEXAS 77726 3. RESPONDENTS WERE IN VIOLATION OF SECTIONS 301 AND 402 OF THE CWA BY EACH DAY THAT RESPONDENT CONDUCTED THE RELE- VANT ACTIVITIES AND OPERATED THE FACILITY WITHOUT NPDES PERMIT COVERAGE AND VIOLATING THE TERMS AND CONDITIONS OF THE PERMIT. 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 DECIFICIENCIES AND ELIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS CITED AND TO COME INTO COMPLIANCE; C) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC ACTIONS TAKEN AND EXPLAIN HOW THE ACTIONS WILL PREVENT RECURRENCE; D) IF NOT POSSIBLE TO CORRECT THE VIOLATIONS IN 30 DAYS, WITHIN 30 DAYS, SUBMIT A COMPRE- HENSIVE PLAN TO DO SO IN THE SHOR