EPA alleges that Respondents violated the requirements of their NPDES Permit (Permit # NER910191) and discharged pollutants into the waters of the United States, in violation of Sections 301 and 402 of the Clean Water Act, 33 U.S.C. ?? 1311 and 1342. The EPA alleges that Respondents failed to include the facility?s material storage area in their NPDES Permit and Stormwater Pollution Prevention Plan and the lack of stormwater controls in that area resulted in unauthorized discharges. Respondents also failed to implement the SWPPP and adequate controls in the material storage area and the ready-mix plant, failed to adequately perform and document routine facility inspections, failed to perform and adequately perform and document quarterly visual assessments, and failed to perform benchmark monitoring.