1. SECTIONS 308 AND 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1318 AND 1319(A). 2. CYRIL PETROCHEMICALCORPORATION A/K/A OKLAHOMA ENERGY CORPORATION, AN OKLAHOMA CORPORATION EAST OF THE INTERSECTION OF FIRST STREET AND MAIN STREET CYRIL, CADDO COUNTY, OKLAHOMA 73029 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY OPERATING ITS FACILITY WITHOUT NPDES PERMIT COVERAGE. 4. RELIEF SOUGHT PURSUANT TO SECTIONS 308 AND 309(A) OF THE CWA, EPA ISSUED THE RESPONDENT AN ADMINISTRATIVE ORDER (AO). THE AO ORDERED THE RESPONDENT TO: WITHIN 30 DAYS, MAKE A COMPLETE AND CORRECT APPLICATION FOR PERMIT COVER- AGE, SUBMITTING A COPY OF THE CONFIRMATION OF COVERAGE, AND THE PERMIT NUMBER TO EPA, B) WITHIN 30 DAYS, TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO CORRECT THE DEFICIENCIES AND ELIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS CITED, AND TO COME INTO COMPLIANCE, C) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC ACTIONS TAKEN TO CORRECT THE VIOLATIONS AND EXPLAIN HOW THE ACTIONS WILL PREVENT RECURRENCE, D) WITHIN 30 DAYS, PREPARE AND IMPLEMENT A STORM WATER POLLUTION PREVENTION PLAN FOR THE FACILITY, SUBMITTING A COPY TO ODEQ AND EPA, AND E) IF NOT POSSIBLE TO CORRECT THE VIOLATIONS WITHIN 30 DAYS, WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORTEST POSSIBLE TI