***** RESPONDENT FAILED TO SUBMIT NOI SEEKING NPDES PERMIT COVERAGE FOR STORM WATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY FROM SEPTEMBER 14, 1995 UNTIL SEPTEMBER 14, 2000, WHEN IT FILED THE NOI; IT FAILED TO DEVELOP AND IMPLEMENT A SWPP AND IT FAILED TO MONITOR AND SAMPLE ITS STORM WATER DISCHARGES. THE COMPLAINANT IS PROPOSING THE MAXIMUM ALLOWED CALSS II PENALTY $137,500.