RESPONDENT VIOLATED THE TERMS OF ITS NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) MS4 PERMIT. THE COMPLAINT ALLEGES THAT THE RESPONDENT FAILED TO: (1) ADEQUATELY MANAGE PRIVATE STORM WATER MANAGEMENT SYSTEMS; (2) ACCURATELY IMPLEMENT THE CHESAPEAKE BAY PRESERVATION ACT; (3) ADEQUATELY MONIOTR AND CONTROL POLLUTANTS IN STORM WATER DISCHARGES FROM HAZARDOUS WASTE TREATMENT, STORAGE AND DISPOSAL FACILIITES; AND INDUSTRIAL FACILITIES; (4) ADEQUATELY REDUCE THE DISCHARGE OF POLLUTANTS TRANSPORTED BY STORM WATER RUNOFF FROM THE MS4; (5) ADEQUATELY MANAGE STORM WATER DISCHARGES FROM MUNICIPAL MAINTENANCE YARDS; AND (6) ADEQUATELY MANAGE OTHER WASTES (E.G., CHEMICALS, VEHICLE AND EQUIPMENT FLUIDS) AT CONSTRUCTION SITE. THESE FAILURES CONSTITUTE A VIOLATION SECTIONS 301(a) AND 402 OF THE CWA, 33 U.S.C. SECTION 1311(a) AND 1342. THESE VIOLATIONS WERE DISCOVERED DURING THE NPDES INSPECTION OF CITY OF NEWPORT NEWS' MS4 PROGRAM.