1. SECTION 309(A)(3) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A)(3). 2. CHALLENGE INDUSTRIES, INC. ROUTE 10, BOX 185 GLENWOOD, CATRON COUNTY, NEW MEXICO 88039 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY DISCHARGING POLLUTANTS FROM THE FACILITY WITHOUT A PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A)(3) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) ORDERING THE RE- SPONDENT TO DETAIL NONCOMPLIANCE, APPLY FOR A PERMIT, SUBMIT A POLLUTION PREVENTION PLAN (PPP), MEET WITH EPA AND SHOW CAUSE.