AN EPA INSPECTION OF THE FACILITY THAT OCCURRED IN DECEMBER 2011 IDENTIFIED VIOLATIONS. THESE VIOLATIONS INCLUDED THE DISCHARGE OF POLLUTANTS TO WATERS OF THE UNITED STATES IN OCTOBER 2010 IN VIOLATION OF SECTION 301 OF THE CWA; (2) FAILURE TO COMPLY WITH ITS PERMIT ISSUED PURSUANT TO THE AUTHORITY OF SECTION 402 OF THE CWA FOR DISCHARGES OF STORMWATER FROM INDUSTRIAL FACILITIES BY FAILING TO DEVELOP AN ADEQUATE STORMWATER POLLUTION PREVENTION PLAN (SWPPP) FAILURE TO CONDUCT EMPLOYEE TRAINING ON THE SWPPP, FAILURE TO INSPECT STORMWATER CONTROLS; AND (3) FAILURE TO PREPARE AND IMPLEMENT AN ADEQUATE SPILL PREVENTION, CONTROL AND COUNTERMEASURES (SPCC) PLAN AND FAILURE TO CONDUCT EMPLOYEE TRAINING REGARDING THE SPCC PLAN IN VIOLATIONS OF SECTION 311 OF THE CWA.