On April 26, 2022, Region III filed its first Expedited Administrative Order for Compliance ( AO or XAO ) issued to Top Drawer, LLC ( Respondent ) for violations of its National Pollutant Discharge Elimination System ( NPDES ) Permit for its home development project known as Cypress Pointe A, in Laurel, DE ( Site ). NPDES General Permit No. DE0051268 (and site-specific Permit No. DEC006311) ( Permit ) were issued by DNREC pursuant to its authority under the CWA NPDES program approval. On May 26, 2021, EPA conducted an NPDES construction stormwater inspection of the Site. Top Drawer, as permittee, is responsible for erosion and sediment controls at the 108.6 acre Site. At the time of the inspection, EPA inspectors observed multiple violations at the Site including: 1) failure to post permit coverage; 2) failure to maintain silt fence; 3) failure to maintain inlet protection; 4) a construction entrance not designed to specifications and trackout present; 5) debris and uncovered/unlidded dumpsters; 6) improper containment at concrete washout areas; 7) a partially excavated and unstabilized sediment pond; and 8) failure to provide all self-inspection reports for the time period requested. The AO requires Top Drawer to correct all site deficiencies and provide proof of corrections to EPA within 14 days. An EJSCREEN was run for the Site and the area was flagged for a potential EJ concern. EPA has consulted with DNREC during the development of this action, and EPA has mailed