The Respondent failed to apply for a permit, or to modify its existing NPDES Permit to incorporate discrete conveyances of storm water associated with a regulated industrial activity. Respondent failed to fully develop and implement procedures required by its NPDES to effect Best Management Practices for the prevention or minimization of discharge of pollutants at its permitted outfalls. Relief requested includes an a) engineering evaluation of the management of storm water impacting the Facility, in light of structural changes that have occurred in the footprint of the Facility, and how such changes have affected the hydrology and hydraulic character of the Facility in its present developed state; b) design and construct an appropriate structure with roof covering, secondary containment for proper storage and adequate management of bulk quantities of oils, other lubricants, solvents, and chemicals associated with the manufacturing processes. The structure must feature appropriate drainage to manage roof catchment, storm runoff flows, and to address spilled materials; c) permanently remove and ship off-island within 90 days, through a contract entered into with an identified appropriate contractor, all spent transformer units and related wastes that were temporarily relocated to a suitable storage area.