1. SECTION 309(A)(3) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A)(3). 2. TROY ELLIS GABRIEL PAPER COMPANY 29325 SHORT CUT HIGHWAY SLIDELL, LOUISIANA 70461 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS FROM THE FACILITY WITHOUT NPDES PERMIT COVERAGE. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A)(3) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) ORDERING THE RE- SPONDENT TO EXPLAIN THE FACILITY'S NON-COMPLIANCE, OBTAIN AN NPDES PERMIT, SUBMIT POLLUTION PREVENTION PLANS (PPP), AND MEET WITH EPA AND SHOW CAUSE.