12 construction sites in NJ, where the Defendant has conducted grading, grubbing, and/or other land-disturbing construction activity. The Defendant discharged pollutants in stormwater at some of these sites without obtaining an NPDES permit and failed to provide information necessary for coverage under the applicable NPDES permits at some sites. Finally, the Defendant routinely violated the condiitons of the permits it has obtained, including failing to fully implement and maintain stormwater pollution prevention erosion controls. EPA requests compliance with the applicable laws as well as a substantial penalty.