1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. COMMERCIAL STRUCTURES AND INTERIORS, INC., A TEXAS CORP. UNIVERSAL ACADEMY, A TEXAS CORP. FACILITY: UNIVERSAL ACADEMY CONSTRUCTION PROJECT 3000 WAKETON ROAD FLOWER MOUND, DENTON COUNTY, TEXAS 75028 3. RESPONDENTS WERE IN VIOLATION OF SECTION 301 OF THE CWA BY EACH DAY THAT RESPONDENTS CONDUCTED THE RELEVANT ACTIVITIES AND OPERATED THE FACILITY WITHOUT NPDES PERMIT COVERAGE. 4. RELIEF SOUGHT PURSUANT TO SECTIONS 308(A) AND 309(A) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) THAT ORDERED THE RESPONDENTS 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; B) WITHIN 30 DAYS, TACKE CORRECTIVE ACTION TO COR- RECT THE DEFICIENCIES AND ELIMINATE AND PREVENT RECUR- RENCE OF THE VIOLATIONS CITED AND TO COME INTO COMPLI- ANCE; C) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAIL- ING THE SPECIFIC AACTIONS AND HOW THE ACTIONS WILL PRE- VENT RECURRENCE; D) IF NOT POSSIBLE TO CORRECT THE VIOLA- TIONS IN 30 DAYS, WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORTEST POSSIBLE TIME; AND E) WITH- IN 45 DAYS, ARRANGE TO MEET WITH