The EPA alleges that Respondent violated its General Permit authorization because it failed to implement adequate stormwater management controls; failed to have an adequate and accurate Storm Water Pollution Prevention Plan (?SWPPP?) and/or to amend the Facility?s SWPPP as required; failed to document spills, conduct required inspections, document the inspections and/or maintain records of such spills and inspections; and failed to perform training and maintain records of employee training.