1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. CITY OF PORT ARTHUR, A TEXAS MUNICIPALITY 6300 PROCTOR STREET PORT ARTHUR, JEFFERSON COUNTY, TEXAS 77641 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY ALLOWING OVERFLOWS TO OCCUR FROM VARIOUS LOCATIONS WITH- OUT NPDES PERMIT AUTHORIZATION. 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) COMPLY WITH THE SCHEDULE SUBMITTED BY THE PERMITTEE AND AGREED UPON BY EPA: NO. 1 - DEVELOPMENT OF DETAILED WORK PLAN BY MAR. 15, 1998; NO. 2 - RETENTION OF ADDITIONAL PERSONNEL & E- QUIPMENT NECESSARY FOR IMPLEMENTATION OF WORK PLAN BY APR. 15, 1998; NO. 3 - CHARACTERIZATION, MONITORING, MODELING, AND PHYSICAL INSPECTION OF THE SANITARY SEWER SYSTEM BY MAY 15, 1999; NO. 4 - FINAL REPORT (INCLUDING RECOMMENDATIONS) BY JAN. 15, 2000, AND B) THE PERMITTEE WILL SUBMIT PROGRESS REPORTS FOR THOSE ACTIVITES BY THE FOLLOWING SCHEDULE: REPORT NO. 1 BY APR. 30, 1998; NO. 2 BY JUL. 31, 1998; NO. 3 BY OCT. 31, 1998; NO. 4 BY JAN. 31, 1998; NO. 5 BY APR. 30, 1999; NO. 6 BY JUL. 31, 1999; AND NO. 7 BY OCT. 31, 1999, AND C) CONTINUE TO REPORT IN- STANCES OF NONCOMPLIANCE AS REQUI