'**VIOLATION: 1) Respondent conducted the relevant activities and operated the facility without NPDES permit coverage. **RELIEF SOUGHT: a) Within 30 days, obtain NPDES permit coverage; b) Within 30 days, take corrective action; c) Within 30 days, report on the actions taken; d) I f unable to correct the violation in 30 days, within 30 days, submit a comprehensive plan to do so; and e) Within 45 days, arrange to meet with epa and show cause.