1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. PC & M CONSTRUCTION COMPANY, A NEW MEXICO CORPORATION EAST SIDE OF THE CITY, ON U.S. HIGHWAY 66, 1 BLOCK SOUTH ON PATTON DRIVE, OFFICE ON BORTOT STREET GALLUP, MCKINLEY COUNTY, NEW MEXICO 87301 3. RESPONDENT WAS IN VIOLATION OF SECTIONS 301 OF THE CWA BY EACH DAY THAT RESPONDENT CONDUCTED THE RELEVANT ACTIVI- TIES AND OPERATED THE FACILITY WITHOUT NPDES PERMIT COV- ERAGE. 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 APPLICA- TION, CONFIRMATION OF COVERAGE AND THE PERMIT NUMBER TO EPA, ALONG WITH A COPY OF ITS SWPPP WITH ALL INCORPORATED DOCUMENTS; B) 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 C) WITHIN 45 DAYS, ARRANGE TO MEET WITH EPA AND SHOW CAUSE.