On May 11, 2022, Region III filed its second Expedited Administrative Order for Compliance (?AO?) issued to Kokosing Construction Company, Inc. ( Respondent ) for violations of its National Pollutant Discharge Elimination System (?NPDES?) Permit for its highway development project known as Corridor H Highway Project, in Randolph and Tucker Counties. Pursuant to its authority under the CWA NPDES program approval, WVDEP issued the General National Pollutant Discharge Elimination System, Water Pollution Control Permit, No. WV 0115924 for Stormwater Associated with Construction Activities ( Permit ), with an effective date of February 9, 2019, and an expiration date of February 9, 2024. In November 2020, WVDEP approved Permit coverage for Kokosing's construction of the H1 Site and H2 Site (collectively, the Sites ), as portions of the highway project. On March 23, 2022, EPA conducted an NPDES construction stormwater inspection of the Sites. Kokosing, as permittee, is responsible for construction and maintenance of erosion and sediment controls at the Sites, as specified in its Permit and approved Erosion and Sediment Control Plans. At the time of the inspection, EPA inspectors observed multiple violations at the Sites including: 1) failure to maintain Pipe Slope Drains at the H1 and H2 Sites; 2) failure to maintain Fencing Controls at the H1 and H2 Sites; 3) failure to maintain Water Bars at the H2 Site; and 4) failure to maintain Coir Curtains at the H2 Site. The AO requ