1. SECTION 309(G)(2)(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G)(2)(A). 2. MR. ED ERWIN, D.B.A. ERWIN AUTO SUPPLY 734 LAKESIDE ROAD MESQUITE, TEXAS 75181 3. RESPONDENT VIOLATED SECTION 301(A) OF THE CWA BY DISCHAR- GING POLLUTANTS INTO A DRAINAGE DITCH WITHOUT AN NPDES PERMIT AND VIOLATED ADMINISTRATIVE ORDER, VI-95-2364, BY FAILING TO OBTAIN NPDES PERMIT COVERAGE FOR THE FACILITY, FAILING TO SUBMIT APOLLUTION PREVENTION PLAN FOR THE FA- CILITY, AND FAILED TO MEET WITH EPA TO SHOW CAUSE THE RE- SPONDENT HAD NOT COMPLIED WITH THE AO. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2)(A) OF THE CWA, EPA PROPOSES A CIVIL PENALTY IN AN AMOUNT NOT TO EX- CEED $10,000 PER VIOLATION, UP TO A MAXIMUM OF $25,000.