EPA issued this Administrative Order as a result of a remote desk audit conducted from March 9 to March 10, 2021. At the time of the remote desktop audit, EPA found several potential noncompliance items including: failure to developed an adequate SWMP Plan; failure to properly conduct Reconnaissance Outfall Inventories; failure to develop numerous required procedures; failure to maintain an inventory of post-construction practices; and failure to perform self assessments of municipal operations.