Beginning on or about September 15, 2016, Graham engaged in construction of the Site. The Site is within the external boundaries of the Fort Berthold Reservation. The Site encompasses approximately 7.5 acres. On August 25, 2017, inspectors from the EPA conducted a storm water inspection of the Site. At the time of the EPA?s inspection, Graham had neither sought nor obtained authorization from the EPA to discharge storm water from the Site under any CWA permit. During the EPA?s inspection, the inspectors observed evidence of previous storm water sediment discharges, such as sediment accumulation in drainage ways and the lack of installation and maintenance of best management practices (BMPs) for storm water flows to the storm water drain inlets. Storm water runoff, snow melt runoff and/or drainage water have left the Site and have flowed to Lake Sakakawea. On December 7, 2017, Graham submitted a Notice of Intent (NOI) for the Site to be covered under the EPA?s 2017 general permit authorizing discharges of storm water associated with construction activities in Indian country in North Dakota. Coverage became effective December 21, 2017. Therefore, Graham discharged storm water from the Site to Lake Sakakawea without authorization by any permit issued under the CWA from September 15, 2016 to December 21, 2017. Graham has agreed to pay a civil administrative penalty to resolve its civil penalty liability for these alleged violations.