An inspection conducted in June 2011, revealed the Defendant's MS4 program was not implemented as it should have been beginning in 2008. Therefore, EPA issued an administrative compliance order on July 25, 2011 with specific dates to implement the program. The Defendant tried to comply with the compliance dates, but continually submitted incomplete submissions. The Defendant was continually late with deadline submissions even after the Order on Consent was issued on June 28, 2012 and an information request and compliance order was issued on June 17, 2013. The EPA is seeking full implementation of the remainder of the Defendant's MS4 program.