1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. CITY OF DETROIT 1.5 M SE OF INTERSECTION OF U.S. HWY. 82 AND FM 2573 DETROIT, RED RIVER COUNTY, TEXAS 75436 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS FROM THE FACILITY THAT EXCEEDED PERMITTED EFFLUENT LIMITATIONS AND BY FAILING TO SUBMIT REQUIRED NONCOMPLIANCE REPORTS WITH THEIR DMRS FOR PERMIT LIMITATIONS EXCEEDED DURING THE MONITORING PERIOD. 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 REVISED COPIES OF ALL DMRS FOR THE TIME PERIOD JAN. 1, 1995 TO PRESENT, B) WITHIN 30 DAYS OF THE AO, SUBMIT NONCOMPLIANCE REPORTS FOR ALL PERMIT EXCEEDENCES THAT OCCURRED DURING THE TIME PERIOD JAN. 1, 1995 TO PRE- SENT, C) WITHIN 30 DAYSOF THE AO, SUBMIT A WRITTEN RE- PORT DETAILING THE SPECIFIC ACTIONS TAKEN TO CORRECT THE VIOLATIONS CITED AND EXPLAINING WHY SUCH ACTIONS ARE AN- TICIPATED TO BE SUFFICIENT TO PREVENT RECURRENCE OF THE VIOLATIONS, OR D) IF THE PERMITTEE BELIEVES COMPLETE COR- RECTION OF THE VIOLATIONS IS NOT POSSIBLE WITHIN 30 DAYS, WITHIN 30 DAYS OF THE AO, SUBMIT A SCHEDULE FOR ELIMINA- TIONS OF THE VIOLATIONS IN THE SH