THE PRESENT CASE INVOLVES NUMEROUS VIOLATIONS OF THE CLEAN WATER ACT (CWA), THE CLEAN AIR ACT (CAA) AND THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) BY KETCHIKAN PULP COMPANY (KPC) AT ITS PULP MILL IN KETCHIKAN, ALASKA. CWA: THE CWA VIOLATIONS CONSIST OF VILATIONS OF KPC'S NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT, AS WELL AS UNPERMITTED DISCHARGES. THE PERMIT VIOLATIONS CONSIST OF SEVERAL HUNDRED VIOLATIONS OF THE PERMIT'S BOD, TSS AND PH EFFLUENT LIMITS AND THE ASSOCIATED REPORTING REQUIREMENTS, 170 VIOLATIONS OF THE PERMIT'S EFFLUENT MONITORING REQUIREMENTS, AND THE CONTINUING PRACTICE OF DISCHARGING SLUDGE IN VIOLATION OF THE PERMIT. THE REMAINING VIOLATIONS ARE BASED ON FIVE UNPERMITTED DISCHARGES OF RED LIQUOR, COOKING ACID, OR MAGNESIUM OXIDE. EACH VIOLATION CARRIES A MAXIMUM PENALTY OF $25,000 PER DAY. WHILE MANY OF THE CWA VIOLATIONS INDIVIDUALLY WERE NOT PARTICULARLY SEVERE, THE NUMBER OF VIOLATIONS THAT OCCURRED OVER THE PAST FEW YEARS IS ENORMOUS. THEIR CUMULATIVE EFFECT ON WARD COVE, WHICH HAS HAD SIGNIFICANT WATER QUALITY DETERIORATION, CERTAINLY WOULD BE SIGNIFICANT. FURTHERMORE, THEIR SHEER NUMBERS INDICATE A PATTERN OF VIRTUAL DISREGARD OF KPC'S NPDES PERMIT REQUIREMENTS, WHICH HAD PERSISTED UNABATED DESPITE THE PAYMENT OF A $179,800 PENALTY FOR SIMILAR (BUT FEWER) VIOLATIONS JUST OV