Respondent violated the requirements of its National Pollutant Discharge Elimination System general permit for stormwater discharges associated with industrial activities, General Permit #3 (IA-159-0955), in violation of Section 402(p) of the Clean Water Act, 33 U.S.C. ? 1342(p). The EPA alleges that Respondent failed to develop and update, as appropriate, an effective stormwater pollution prevention plan (SWPPP), failed to develop and implement appropriate stormwater controls, and failed to conduct required stormwater monitoring.