A storm water compliance inspection was conducted by EPA on January 23, 2003, at the construction site for Devry University in Houston, TX. Although Devry had made timely application for coverage under the General Permit for Storm Water Discharges From Construction Activities, and had developed a Storm Water Pollution Prevention Plan (SWPPP), the Plan was not being implemented or updated, nor was it certified in accordance with permit requirements. An administrtive order was drafted to address these violations.