1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. SOUTHWEST SHIPYARD, L.P., A TEXAS LIMITED PARTNERSHIP BY SEATTLE SHIPYARD, L.L.C., A TEXAS LIMITED LIABILITY CO., GENERAL PARTNER 18310 MARKET STREET HIGHLAMDS, HARRIS COUNTY, TEXAS 77530 3. RESPONDENTS WERE IN VIOLATION OF SECTION 301 OF THE CWA BY 1) CONDUCTING THE RELEVANT ACTIVITIES AND OPERATING THE FACILITY WITHOUT NPDES PERMIT COVERAGE FROM NOV. 4, 1996, THRU JAN. 9, 1997, AND 2) DISCHARGING FROM THE SAN- ITARY SEWER TREATMENT PLANT AND THE STEAM DOCK WITHOUT AUTHORIZATION OF A PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) TO THE RESPONDENT. THE AO ORDERS THE RESPONDENT TO: A) WITHIN 30 DAYS OF THE EFFECTIVE DATE OF THE AO, TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO CORRECT THE DEFICIENCIES AND ELIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS CITED AND TO COME INTO COMPLIANCE WITH ALL OF THE APPLICABLE REQUIRE- MENTS OF THE PERMIT, B) WITHIN 30 DAYS OF THE AO, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC ACTIONS TAKEN TO CORRECT THE VIOLATIONS CITED AND EXPLAINING WHY SUCH AC- TIONS ARE ANTICIPATED TO BE SUFFICIENT TO PREVENT RECUR- RENCE OF THE VIOLATIONS, C) IF PE