This case involves unauthorized discharges at numerous facilities for which ABF failed to obtain timely National Pollutant Discharge Elimination System (NPDES) permits for stormwater discharges, as well as failure to comply with permit requirements at other ABF facilities. ABF has 236 truck terminals of various sizes throughout the country. According to ABF, of the 236 facilities, 45 currently have NPDES permit coverage and 191 have filed no exposure certifications (NEC).