1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. ROYAL PROPERTIES, AN ILLINIOS CORPORATION TDK CONSTRUCTION CO., INC., A TENNESSEE CORPORATION FACILITY: ROYAL LUBBOCK APARTMENTS 4TH STREET AND INDIANA AVENUE LUBBOCK, LUBBOCK COUNTY, TEXAS 79404 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; B) WITHIN 30 DAYS TAKE CORRECTIVE ACTION TO CORRECT THE VIOLATIONS; C) WITHIN 30 DAYS, SUB- MIT A WRITTEN REPORT DETAILING THE ACTIONS TAKEN HOW THE ACTIONS WIL 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 TIME; AND E) WITHIN 45 DAYS, ARRANGE TO MEET WITH EPA AND SHOW CAUSE.