1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. HARRIS COUNTY SPORTS AND CONVENTION CORP., A TEXAS CORP. HARRIS COUNTY, A TEXAS COUNTY RAY FERGUSON INTERESTS, A TEXAS CORP. FACILITY: COMMERCIAL CONSTRUCTION SITE 8445 LANTERN POINT DRIVE HOUSTON, HARRIS COUNTY, TEXAS 77054 3. RESPONDENTS WERE IN VIOLATION OF SECTION 301 OF THE CWA BY CONDUCTING THE RELEVANT ACTIVITIES AND OPERATING THE FACILITY 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 PERMIT NUMBER TO EPA; B) WITHIN 30 DAYS, TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO CORRECT THE DEFICIENCIES, ELIMINATE AND PREVENT RECURRENCE, AND COME INTO COMPLIANCE; C) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC ACTIONS TAKEN AND EXPLAIN HOW THESE ACTIONS WILL PREVENT RECURRENCE AND INCLUDE A COPY OF THE FACILITY STORM WATER POLLUTION PREVENTION PLAN (SWPPP); D) IF NOT POSSIBLE TO CORRECT THE VIOLA- TIONS IN 30 DAYS, WITHIN 30 DAYS,