RESPONDENT VIOLATED THE TERMS OF ITS NATIONAL POLLUTANT DISCHARGE ELLIMINATION SYSTEMS (NPDES) MS4 PERMIT. THE COMPLAINT ALLEGES THE RESPONDENT FAILED TO: (1) ADEQUATELY MANAGE INDUSTRIAL & HIGH RISK RUNNOFF AND (2) ADEQUATELY INSPECT CONSTRUCTION SITES AND MANAGE OTHER WASTES (E.G.,CHEMICALS, VEHICLES AND EQUIPMENT FLUIDS AT THE CONSTRUCTION SITES. THESE FAILURES CONSTITUTE A VIOLATION SECTION 301(a) AND 402 OF THE CWA, 33 U.S.C. SECTION 1311(a) AND 1342. THESE VIOLATIONS WERE DISCOVERING DURING THE NPDES INSPECTION OF FAIRFAX COUNTY'S MS4 PROGRAM.