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 INDUSTRIAL & HIGH RISK RUNOFF AND (2) ADEQUATELY INSPECT CONSTRUCTION SITES AND MANAGE OTHER WASTES (E.G., CHEMICALS, VEHICLE AND EQUIPMENT FLUIDS) AT CONSTRUCTION SITES. THESE FAILURES CONSTITUTE A VIOLATION SECTIONS 301(a) AND R402 OF THE CWA, 33 U.S.C. SECTION 1311(a)AND 1342. THESE VIOLATIONS WERE DISCOVEREED DURING THE NPDES INSPECTION OF FIARFAX COUNTY'S MS4 PROGRAM.