1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. KOPPERS INDUSTRIES, INC., A PENNSYLVANIA CORPORATION FACILITY: ATCHISON, TOPEKA, AND SANTA FE RAILWAY COMPANY SOMMERVILLE (TEXAS AT STATE HIGHWAY 36, .7 MILES NORTHWEST OF THE INTERSECTION OF STATE HIGHWAY 36 AND FM 1361 SOMERVILLE, BURLESON COUNTY, TEXAS 77879 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY FAILING TO SUBMIT CERTIFIED DMRS TO EPA FOR MAT 1998, AUG. 1998, AND OCT. 1998. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED THE RESPONDENT AN ADMINISTRATIVE ORDER (AO). THE AO ORDERED THE RESPONDENT TO: A) WITHIN 30 DAYS,TAKE WHAT EVER CORRECTIVE ACTION IS NECESSARY TO ELIMINATE AND PRE- VENT RECURRENCE OF THE VIOLATIONS CITED, WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC ACTIONS 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 COM- PREHENSIVE PLAN TO DO SO IN THE SHORTEST POSSIBLE TIME.