U.S. EPA Region 5 (“Region”) appeals from two nearly identical sets of decisions issued in two separate enforcement matters, each involving a single violation of the Resource Conservation and Recovery Act (“RCRA”) as amended, 42 U.S.C. §§ 6901 to 6992k. The alleged violation involved the failure to comply with closure requirements governing drip pads at each of two wood treatment facilities. Each matter involved the same parent company, John A. Biewer Company, Inc. (“JAB Inc.”), and a closely-held subsidiary who was the owner of the respective facility: John A.