Respondent violated the terms and conditions of its Iowa Department of Natural Resources NPDES General Permit No. 1 in violation of Section 402 of the Clean Water Act, 33 U.S.C. ? 1432. The EPA alleges that Respondent failed to update and/or modify its Stormwater Pollution Prevention Plan, implement, maintain, and/or modify adequate control measures, conduct visual inspections, and conduct employee training in violation of the NPDES General Permit conditions and limitations.