EPA ALLEGES THAT RESPONDENT FAILED TO CONDUCT SITE INSPECTIONS AT THE REQUIRED FREQUENCY AND FAILED TO MAINTAIN BEST MANAGEMENT PRACTICES REQUIRED BY THE COMPANY'S STORM WATER POLLUTION PREVENTION PLAN, WHICH ARE VIOLATIONS OF THE COMPANY'S SWPPP AND ITS NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM PERMIT, AND AS SUCH VIOLATE SECTIONS 301(A) AND 402(P) OF THE CLEAN WATER ACT, 33 USC SECTIONS 1311(A) AND 1342(P).