'VIOLATION: 1) Failure to obtain NPDES permit coverage for discharges of pollutants to waters of the United States.
**RELIEF: 1) Within thirty days, the Respondent shall take corrective action for all violations and submit a written report detailing the actions taken; 2) Respondent shall provide information in a report about unpermitted facilities; 3) If complete correction of violations is not possible within thirty days, submit a comprehensive plan to do so; 4) If Respondent did have permit coverage, submit a report with a copy of the NOI application and proof of delivery; and 5) Within forty-five days, arrange a Show Cause meeting with EPA.