1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. THE CITY OF WACO, A TEXAS MUNICIPALITY P.O. BOX 2570 WACO, MCLENNAN COUNTY, TEXAS 76702 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY FAILING TO APPLY FOR OR OBTAIN NPDES PERMIT COVERAGE AND TO BE COVERED BY AN NPDES PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) TO THE RESPONDENT. THE AO ORDERED THE RESPONDENT TO: A) ACCOMPLISH THE FOL- LOWING TASKS AND COMPLY WITH THE FOLLOWING SCHEDULE OF ACTIVITIES: 1) REVIEW ALL PAST SSO STUDIES AND DOCUMENTS AS REQUIRED BY DEC. 1998; 2) DESIGN REQUIRED IMPROVEMENTS (INCLUDING ALL AREAS LISTED IN THE CONSENT JUDGMENT) BY DEC. 1999; C) CONSTRUCT IMPROVEMENTS (NECESSARY TO COMPLY WITH THE CWA AND THE ONES LISTED IN THE CONSENT JUDGMENT) BY DEC. 2001; AND 4) OBTAIN COMPLIANCE WITH THE CWA BY DEC. 2001, B) REPORT COMPLIANCE OR NONCOMPLIANCE WITH SECTION A WITHIN 14 DAYS, C) SUBMIT PROGRESS REPORTS, AND D) REPORT INSTANCES OF NONCOMPLIANCES WITH THE CWA ON A MONTHLY BASIS.