Respondent did not submit a Notice of Intent (ÂNOIÂ) for coverage under the Storm Water Industrial General Permit for its activities at the facility, and was not covered by a NPDES permit at the relevant times for the relevant activities. During the time period December 2010 through December 2011, there were three (3) rain events one-inch or greater at the facility. Respondent failed to develop and implement a Storm Water Pollution Prevention Plan (SWP3), and failed to install and properly maintain Best Management Practices (BMPs) to control off-site discharges