EPA request that Department of Justice initiate a civil enforcement action against the Defendant for violations of the CWA, NPDES regulations at 40 CFR Part 21, and the 2003 NPDES Construction General Permit at the Condado Duo Hotel Complex. In carrying out construction activities at the Condado Duo Hotel Complex Defendants were negligent by failing to: (1)Timely apply for coverage under the Construction General Permit for the storm water discharges; (2)Apply for NPDES Permit coverage for the discharges of contaminated non storm water. After obtaining coverage under the Construction General Permit for the storm water discharges, Defendants continue to violate the CWA and the Construction General Permit by failing to comply with it requirements. EPA seeks a Judicial Order on Consent that places the Defendants on an enforceable schedule to immediately revise and implement all elements of the SWPPP as well as forces Defendants to remain in a compliance thru the duration of construction activities. EPA also seek to obtain an appropriate penalty for Defendants' non compliance.