1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C SECTION 1319(A). 2. REICHHOLD CHEMICALS INC., A DELAWARE CORPORATION 1503 HADEN ROAD HOUSTON, HARRIS COUNTY, TEXAS 77015 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS THAT EXCEEDED PERMITTED EFFLUENT LIMITATIONS AT THE DESIGNATED OUTFALL 001, AS SHOWN IN THE CERTIFIED DMRS FILED WITH EPA. 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) WITHIN 30 DAYS, TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO ELIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS CITED, B) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC AC- TIONS TAKEN TO CORRECT THE VIOLATIONS AND EXPLAIN HOW THEY WILL PREVENT RECURRENCE, AND C) IF NOT POSSIBLE TO CORRECT THE VIOLATIONS WITHIN 30 DAYS, WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE WRITTEN PLAN TO DO SO IN THE SHORTEST POSSIBLE TIME.