THE WEST UNION POTW VIOLATED ITS NPDES PERMIT BY DISCHARGING POLLUTANTS IN EXCESS OF PERMITTED LIMITS APPROXIMATELY 60 TIMES BETWEEN DECEMBER 2011 AND MARCH 2015 AND ILLEGALLY DISCHARGED UNTREATED SEWAGE ON AT LEAST SEVEN OCCASIONS BETWEEN MAY 2013 AND JUNE 2014 FROM UNPERMITTED LOCATIONS.