A storm water compliance inspection was conducted by EPA on January 23, 2003, at a construction site for Devry University in Houston, TX. During the inspection it was determined that, while Devry University had permit coverage, their general contractor, Opus West Construction Corporaton, had not applied for permit coverage under the General Permit for Storm Water Discharges From Construction Activities. A Storm Water Pollution Prevention Plan (SWPPP) had been prepared, but the inspection revealed the SWPPP was not being implemented or updated, nor was it certified in accordance with permit requirements. An administrative order was drafted to address these violations.