1. SECTION 309 OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319. 2. WAL-MART STORES, INC., A DELAWARE CORPORATION VRATSINAS CONSTRUCTION COMPANY, AN ARKANSAS CORPORATION FACILITY: WAL-MART STORE 789 200 E. HIGHWAY 80 MESQUITE, DALLAS COUNTY, TEXAS 75149 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY FAILING TO COMPLY WITH THE CONDITIONS OF THE STORM WATER GENERAL PERMIT DURING CONSTRUCTION ACTIVITIES BY 1) FAIL- URE TO OBTAIN PERMIT COVERAGE, 2) FAILURE TO MAINTAIN RE- CORDS, 3) FAILURE TO IMPLEMENT AND MAINTAIN CONTROL MEA- SURES, 4) FAILURE TO OBTAIN REQUIRED SIGNED CERTIFICATION STATEMENTS FROM THE CONTRACTOR WORKING AT THE SITE, AND 5) FAILURE TO CONDUCT REQUIRED PERIODIC INSPECTIONS. 4. RELIEF SOUGHT PURSUANT TO SECTION 309 OF THE CWA, EPA RE- FERRED THIS DIRECT REFERRAL TO DOJ REQUESTING THE INITIA- TION OF A CIVIL ENFORCEMENT ACTION. EPA IS SEEKING CIVIL PENALTIES AND INJUNCTIVE RELIEF.