'**VIOLATION: 1) Conducting the relevant activities and operating the facility without NPDES permit coverage. **RELIEF SOUGHT: A) Within 30 days, take corrective action; B) Within 30 days, report on the corrective actions taken; C) If not possible to correct the violations in 30 days, within 30 days, submit a comprehensive plan to do so; and D) Within 45 days, arrange to meet with EPA and show cause.