RESPONDENTS ARE OPERATING A CONSTRUCTION SITE IN RICHMOND, VA IN NON-COMPLIANCE WITH THEIR STORM WATER CONSTRUCTION PERMIT. THIS IS RESULTING IN SEDIMENT BEING DISCHARGED TO WATERS OF THE US. THE AO WILL REQUIRE RESPONDENTS TO COMPLY WITH THEIR VPDES STORM WATER GENERAL PERMIT FOR CONSTRUCTION ACTIVITIES. IN ADDITION, SHOW CAUSE LANGUAGE IS BEING INCLUDED TO OFFER THE RESPONDENTS A CHANCE TO INFORMALLY BEGIN PENALTY NEGOTIATIONS.