1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. PROGRESSIVE, INC., A TEXAS CORPORATION 1030 COMMERCIAL BOULEVARD NORTH ARLINGTON, TARRANT COUNTY, TEXAS 76017 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY FAILING TO MAKE A TIMELY APPLICATION FOR PERMIT COVERAGE FOR ITS ACTIVITIES AT THE FACILITY, AND WAS NOT COVERED UNDER THE PERMIT AT THE RELEVANT TIMES FOR THE RELEVANT ACTIVITIES. 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 MAKE A COMPLETE AND CORRECT APPLICATION FOR PERMIT COVER- AGE, SUBMITTING A COPY OF THE APPLICATION, CONFIRMATION OF COVERAGE AND THE PERMIT NUMBER TO EPA, B) WITHIN 30 DAYS OF THE AO, TAKE WHATEVER CORRECTIVE ACTION IS NECES- SARY TO CORRECT THE DEFICIENCIES AND ELIMINATE AND PRE- VENT RECURRENCE OF THE VIOLATIONS CITED AND TO COME INTO COMPLIANCE WITH ALL OF THE APPLICABLE REQUIREMENTS OF THE PERMIT, C) WITHIN 30 DAYS OF 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, D) IF THE RESPONDENT