1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. CITY OF LUFKIN FARM ROAD 324, 1.5 M SOUTH OF THE CITY LUFKIN, ANGELINA COUNTY, TEXAS 75902 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY 1) FAILING TO COMPLY WITH WET LIMITS FOR CHRONIC LETHAL- ITY TO PIMEPHALES PROMELAS, 2) UNAUTHORIZED DISCHARGES FROM THEIR COLLECTION SYSTEM, AND 3) FAILING TO COMPLY WITH THE CEILING CONCENTRATION FOR ARSENIC IN SLUDGE. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) ORDERING THE RESPOND- ENT TO: A) WITHIN 30 DAYS OF THE EFFECTIVE DATE OF THE AO SUBMIT A COMPLETE LISTING OF ALL COLLECTION SYSTEMS OVER- FLOWS THAT OCCURRED DURING THE TIME PERIOD JAN. 1, 1996 TO PRESENT, B) WITHIN 30 DAYS OF THE AO, TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO ELIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS CITED, C) WITHIN 30 DAYS OF THE AO, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC ACTIONS TAKEN TO CORRECT THE VIOLATIONS CITED AND EX- PLAINING WHY SUCH ACTIONS ARE ANTICIPATED TO BE SUFFICI- ENT TO PREVENT RECURRENCE OF THE VIOLATIONS, OR D) IF THE PERMITTEE BELIEVES COMPLETE CORRECTION OF THE VIOLATIONS IS NOT POSSIBLE WITHIN 30 DAYS, SUBMIT A SCHEDULE FOR E- LIMINATION OF THE VIOLATIONS IN T