1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. WALTER KOEPP, D.B.A. WAW SAND CO. NOCKENUT ROAD SEGUIN, GUADALUPE COUNTY, TEXAS 78155 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY CONDUCTING THE RELEVANT ACTIVITIES AND OPERATING THE FA- CILITY WITHOUT NPDES PERMIT COVERAGE. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED THE RESPONDENT AN ADMINISTRATIVE ORDER (AO) THAT REQUIRED THE RESPONDENT TO: A) WITHIN 30 DAYS, MAKE A COMPLETE AND CORRECT APPLICATION FOR PERMIT COVERAGE, SUBMITTING A COPY OF THE APPLICATION, CONFIRMATION OF COVERAGE, AND THE PERMIT NUMBER TO EPA; B) WITHIN 30 DAYS TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO CORRECT THE DEFICIENCIES, ELIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS CITED, AND TO COME INTO COMPLIANCE; C) IF NOT POSSIBLE TO CORRECT THE VIOLATIONS IN 30 DAYS, WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORT- EST POSSIBLE TIME; D) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC ACTIONS TAKEN AND EXPLAIN HOW THESE ACTIONS WILL PREVENT RECURRENCE; AND E) WITHIN 45 DAYS, ARRANGE TO MEET WITH EPA AND SHOW CAUSE.