A settling RCRA and CWA defendant that violated solid and hazardous waste management practices and failed to implement spill prevention control and countermeasure (SPCC) plans must close all unpermitted hazardous waste storage facilities; minimize generation and ensure proper tracking and management of solid and hazardous waste; build or retrofit a permitted hazardous waste storage facility; revise its SPCC plans; install adequate secondary containment around oil storage containers; develop an integrity testing program for oil storage containers; and pay a civil penalty of $6.5 million.