DEFENDANT IS A READY MIX CONCRETE COMPANY WHICH OWNS THE FOUR FACILITIES WHICH ARE THE SUBJECT OF THIS LITIGATION. ALL FOUR FACILITIES HAVE HAD DISCHARGES OF POLLUTANTS WITHOUT A NPDES PERMIT. ONE OF THE FOUR FACILITIES RECENTLY OBTAINED A NPDES PERMIT BUT IT HAS VIOLATED ITS EFFLUENT LIMITS UNDER THE PERMIT AND HAS FAILED TO SUBMIT DMRS AS REQUIRED. ANOTHER OF THE FOUR FACILITIES HAS FAILED TO APPLY FOR A STORMWATER PERMIT AS REQUIRED.