Respondent has continuously failed to: a) submit the December 2018 and June 2019 Periodic Reports to EPA as required, and b) submit all information requested in the 2019 Order #2; c) submit the December 2019, June 2020, December 2020, June 2021, and December 2021 Periodic Reports to EPA as required; and d) sample the process wastewater discharged from its manufacturing facility for the period of July 2018 to the present.