EPA alleges that Respondents violated the terms and conditions of their National Pollutant Discharge Elimination System General Permit by releasing unauthorized discharges of stormwater from their construction site at 110th West Terrace in Olathe, KS, into the unnamed tributary to Mill Creek, failed to implement adequate control measures or take sufficient corrective actions to improve control measures, failed to conduct and/or adequately document routine facility inspections, and failed to develop an adequate Storm Water Pollution Prevention Plan.