THIS ADMINISTRATIVE COMPLAINT AND NOTICE OF OPPORTUNITY OF HEARING IS ISSUED TO CAROTHERS CONSTRUCTION INC FOR VIOLATIONS ON THE FORT CARSON ARMY AIR FORCE EXCHANGE CONSTRUCTION SITE. EPA ALLEGES THAT CAROTHERS CONSTRUCTION VIOLATED SEVERAL PROVISIONS OF THEIR STORM WATER CONSTRUCTION PERMIT SUCH AS; FAILING TO CONDUCT INSPECTIONS, INCOMPLETE STORM WATER POLLUTION PREVENTION PLAN (SWPPP), FAILING TO IMPLEMENT BEST MANAGEMENT PRACTICES.