DEFENDANT, JAMES CHAPLIN, HAS VIOLATED THE CWA BY DISCHARGING POLLUTANTS FROM SIX PACKAGE PLANTS HE OWNS AND OPERATES IN VIOLATION OF THE CWA AND NPDES PERMITS. MR CHAPLIN HAS FAILED TO SECURE A PERMIT FOR ANOTHER PACKAGE PLANT HE OWNS AND OPERATES DESPITE DISCHARGING POLLUTANTS FROM THAT FACILITY AS WELL.