RESPONDENT FAILED TO OBTAIN CONDITIONAL EXCLUSION FROM NPDES STORM WATER PERMITTING, AND AS SUCH, DISCHARGED STORM WATER ASSOCIATED WITH INDUSTRIAL ACTIVITY WITHOUT A NPDES STORM WATER PERMIT. UPON THE INSPECTION, RESPONDENT OBTAINED THE EXCLUSION BY FILING AN ELECTRONIC NO EXPOSURE CERTIFICATION WITH INTERNAL RESOURCES. NO OTHER COMPLIANCE ACTIONS ARE REQUIRED AT THIS TIME. THIS PROCEEDING FOLLOWED 40 C.F.R. 22.18(B) -- SIMULTANEOUS COMMENCEMENT AND CONCLUSION OF THE ADMINISTRATIVE PENALTY.