On September 22, 2021, Region III entered into an Administrative Order on Consent ( AOC with the LKQ Corporation subsidiaries, Potomac German Auto, Inc. and LKQ Northeast, Inc. ( Respondents ) which requires them to correct industrial stormwater violations at seven automotive salvage yards in Maryland and Pennsylvania in order to comply with the requirements of the facilities applicable state General Permit for Stormwater Discharges Associated with Industrial Discharges (collectively, General Permits ). In the AOC, EPA alleged the following violations of the Respondents' NPDES General Permits: (1) failure to comply with permit requirements concerning the Storm Water Pollution Prevention Plan ( SWPPP ) at one facility; (2) failure to comply with permit requirements concerning the Preparedness, Prevention and Contingency ( PPC ) Plan at one facility; (3) failure to implement adequate control measures or take corrective action at three facilities; (4) failure to provide adequate erosion and sediment controls at three facilities; (5) failure to adequately conduct or report compliance - quarterly visual inspection at five facilities; (6) failure to adequately conduct or report compliance - benchmark monitoring at one facility; and (7) failure to conduct or adequately document routine inspections at six facilities. As a result of these failures to comply with the terms and conditions of the General Permit, the Respondents violated Section 301 of the CWA, 33 U.S.C. 1311. To cor