1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. CITY OF GALVESTON, A TEXAS MUNICIPALITY 52ND STREET AND PORT INDUSTRIAL GALVESTON, GALVESTON COUNTY, TEXAS 77551 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY: 1) FAILING TO PROPERLY OPERATE AND MAINTAIN THE FACILITY AS TO MINIMIZE UPSETS AND DISCHARGES OF EXCESSIVE POLLU- TANTS; AND 2) FAILING TO CONDUCT MONITORING ACCORDING TO APPROVED TEST PROCEDURES. 4. RELIEF SOUGHT PURSUANT TO SECTION 1414 OF THE CWA, EPA ISSUED THE RESPONDENT AN ADMINISTRATIVE ORDER (AO) THAT 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; B) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC AC- TIONS TAKEN AND EXPLAIN HOW THE ACTIONS WILL PREVENT RE- CURRENCE; C) IF NOT POSSIBLE TO CORRECT THE VIOLATIONS IN 30 DAYS, WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORTEST POSSIBLE TIME; AND D) CONTINUE TO REPORT ALL INSTANCES OF NONCOMPLIANCE WITH THE CWA ON A MONTHLY BASIS.