'6/12/02 - Complaint/CAFO issued. Based on an April 1997 EPA inspection, on March 19, 1998, EPA determined that stormwater discharges from the product storage practices in teh Allapattah Product Market area were a significant contributor of pollutants to Wagner Creek. Therefore, the discharges were subject to NPDES permitting requirements. Respondent did not make application for an NPDES permit for this facility. On April 26, 1999 and April 29, 1999, EPA issued Info Request Letters, notifiying Respondent of EPA's determination that Respondent's point source discharge of stormwater at the facility contributes to a violation of a water quality standard or is a significant contributor of pollutants to waters of the U.S. The 308 letters requested Respondent to submit a Notice of Intent (NOI) for NPDES permit coverage under the MSGP and a Storm Water Pollution Prevention Plan (SWPPP) as required by the MSGP. Respondent did not respond to the 308 letters. On July 27, 1999, EPA issued Administrative Order, Docket Number 99-047 (See Enforcement Idenfier 04-1999-0355) pursuant to Section 309(a) of the CWA. Respondent did not respond to the A.O. On November 12, 1999, EPA sent Respondent a Notice of Violation for failure to respond to EPA's 308 Letters and for failure to respond to EPA's AO. Respondent did not respond to EPA's NOV. On August 4, 2000, EPA sent Respondent a Notice of Opportunity to Show Cause requesting that representatives of Respondent be present in EPA'