RESPONDENT FAILED TO OBTAIN NPDES PERMIT COVERAGE FOR ITS STORM WATER DISCHARGES FROM THE FACILITY INTO A WATER OF THE UNITED STATES. A COUPLE OF MONTHS AFTER THE INSPECTION, THE FACILITY WAS CLOSED, AND NO FURTHER ACTIONS ARE REQUIRED. THIS PROCEEDING FOLLOWED 40 C.F.R. 22.18(B) -- SIMULTANEOUS COMMENCEMENT AND CONCLUSION OF THE ADMINISTRATIVE PENALTY.