1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. PIONEER PAPER STOCK COMPANY OF TEXAS, INC., A TX. CORP. 5000 SINGLETON BOULEVARD DALLAS, DALLAS COUNTY, TEXAS 75235 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY EACH DAY THAT RESPONDENT CONDUCTED THE RELEVANT ACTIVI- TIES, AND OPERATED THE FACILITY WITHOUT NPDES PERMIT COVERAGE FROM 1992 UNTIL THE PRESENT. 4. RELIEF SOUGHT PURSUANT TO SECTIONS 308(A) AND 309(A) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) THAT ORDERED THE RESPONDENT TO: A) WITHIN 30 DAYS, OBTAIN NPDES PERMIT COVERAGE, SUBMITTING A COPY OF THE PERMIT APPLICATION AND NUMBER TO EPA; B) WITHIN 30 DAYS, TAKE CORRECTIVE ACTION TO CORRECT, ELIMINATE AND PREVENT RE- CURRENCE OF THE VIOLATIONS CITED, AND TO COME INTO COM- PLIANCE; C) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DE- TAILING THE SPECIFIC ACTIONS TAKEN , EXPLAIN HOW THE AC- TIONS WILL PREVENT RECURRENCE, AND INCLUDE A COPY OF THE FACILITY'S SWPPP; D) IF NOT POSSIBLE TO CORRECT THE VIO- LATIONS IN 30 DAYS, WITHIN 30 DAYS, SUBMIT A COMPREHEN- SIVE PLAN TO DO SO IN THE SHORTEST POSSIBLE TIME; AND E) WITHIN 45 DAYS, ARRANGE TO MEET WITH EPA AND SHOW CAUSE.