'VIOLATION: 1) Respondent conducted the relevant activities and operated the facility without NPDES permit coverage. RELIEF SOUGHT: a) Within 30 days, take corrective action; b) Within 30 days, report on the corrective action taken; c) If not possible to correct the violations in 30 days, within 30 days, submit a comprehensive plan to do so; and d) Within 45 days, arrange to meet with EPA and show cause.'