VOTC discharged stormwater from the Site without a permit in July 2007, and failed to implement and/or maintain best management practices at the Site and to have make stormwater inspection reports available to EPA at the time of an on-site inspection, as required by the Construction General Permit. EPA issued a Clean Water Act penalty action against the company on 7/1/09. The case was resolved on 11/30/09. The company agreed to pay a penalty of $2,000.