1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. ROSE INDUSTRIES, INC. 2902 CENTER STREET HOUSTON, HARRIS COUNTY, TEXAS 77007 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY FAILING TO MAKE AN APPLICATION FOR PERMIT COVERAGE FOR ITS ACTIVITIES AT THE FACILITY, AND WAS NOT COVERED BY AN NPDES PERMIT AT THE RELEVANT TIMES FOR THE RELEVANT AC- TIVITIES, AS OF JUL. 11, 1997. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) ORDERING THE RESPON- DENT TO: A) WITHIN 30 DAYS OF THE EFFECTIVE DATE OF THE AO, MAKE A COMPLETE AND CORRECT APPLICATION FOR PERMIT COVERAGE AND SUBMIT TO EPA A COPY OF THE APPLICATION AND PERMIT ALONG WITH THE PERMIT NUMBER, B) WITHIN 30 DAYS OF THE AO, TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO CORRECT THE DEFICIENCIES AND ELIMINATE AND PREVENT RECUR- RENCE OF THE VIOLATIONS CITED AND COME INTO COMPLIANCE WITH ALL OF THE APPLICABLE REQUIREMENTS OF THE PERMIT, C) WITHIN 30 DAYS OF THE AO, SUBMIT A WRITTEN REPORT DETAIL- ING THE SPECIFIC ACTIONS TAKEN TO CORRECT THE VIOLATIONS CITED AND EXPLAINING WHY SUCH ACTIONS ARE ANTICIPATED TO BE SUFFICIENT TO PREVENT RECURRENCE OF THE VIOLATIONS, AND D) WITHIN 45 DAYS OF THEAO, A