1. SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G). 2. MICHAEL GRAY STEAL-A-PART 13701 CULLEN BOULEVARD HOUSTON, HARRIS COUNTY, TEXAS 77047 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY CONDUCTING THE RELEVANT ACTIVITIES AND OPERATING THE FA- CILITY WITHOUT THE AUTHORIZATION OF AN NPDES PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G) OF THE CWA, EPA PROPOSED A CIVIL PENALTY OF UP TO $27,500 FOR THE VIOLA- TION CITED.