ROQUETTE, OVER THE PAST FIVE YEARS, HAS VIOLATED THE EFFLUENT LIMITATIONS CONTAINED ON ITS NPDES PERMIT ON NUMBEROUS OCCASIONS, ILLEGALLY DISCHARGED THOUSANDS OF GALLONS OF UNTREATED INDUSTRIAL WASTE INTO THE MISSISSIPPI RIVER AND SOAP CREEK, AND ILLEGALLY DISCHARGED PARTIALLY TREATED INDUSTRIAL WASTE FROM ITS WWTP, IN VIOLATION OF ITS NPDES PERMIT.