The AO alleges multiple violations of the construction NPDES permit for storm water discharges from the Estates at Huntingdon Valley, a residential development by Hovnanian in Montgomery County, Pennsylvania. Specifically, the AO alleges that Hovnanian did not follow its approved Erosion and Sedimentation Control Plan because: it did not install silt fencing in several areas of the site perimeter; it did not install filter fencing around stockpiles; it did not install an emergency spillway in one of the sedimentation basins and did not stabilize the banks of the basin; it did not install another sedimentation basin as required; it did not install a diversion berm required by the Plan; it did not have inlet protection at two intlets; and it did not install fencing around several tree protection areas. Inspectors from EPA and from the Montgomery County Conservation District witnessed the violations on several inspections from January 2003 through March 2004.