THIS COMBINED COMPLAINT AND CONSENT AGREEMENT IS ISSUED TO HOLCIM (US) INC FOR UNLAWFUL STORMWATER INSDUSTRIAL DISCHARGES TO BEAR CREEK. On January 21, 2009, EPA performed an inspection of HolcimÂs Florence, Colorado limestone/silica quarry and Portland cement plant and observed numerous violations of HolcimÂs individual NPDES permit, including unauthorized non-storm water discharges, failure to comply with sampling and analysis requirements, failure to comply with inspection and reporting requirements, and failure to develop an adequate storm water management plan (SWMP) for its operations. The inspection was part of a national initiative to inspect storm water activities at quarries throughout the United States.