1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. ACE ALUMINUM BRASS CASTING COMPANY, INC., A TEXAS CORP. 1203 SOUTH INDUSTRIAL BOULEVARD DALLAS, DALLAS COUNTY, TEXAS 75217 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 APR. 1, 1999 THROUGH JUL. 21, 1999. 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 AN NPDES PERMIT, SUBMITTING A COPY OF THE APPLICATION, CON- FIRMATION OF COVERAGE, AND THE NPDES PERMIT NUMBER TO EPA; B) WITHIN 30 DAYS, TAKE ACTION TO CORRECT THE DE- FICIENCIES, ELIMINATE AND PREVENT RECURRENCE OF THE VIO- LATION CITED, AND TO COME INTO COMPLIANCE; C) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC AC- TIONS TAKEN TO CORRECT THE VIOLATIONS AND EXPLAI HOW THE ACTIONS WILL PREVENT RECURRENCE; D) IF NOT POSSIBLE TO CORRECT THE VIOLATIONS IN 30 DAYS, WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORTEST POSSIBLE AND E) WITHIN 45 DAYS, ARRANGE TO MEET WITH EPA AND SHOW CAUSE.