The largest alleged storage failure sat inside Building A. EPA inspectors said they found 11 non-transformer PCB articles, three PCB transformers and one 55-gallon container outside the designated storage area. Together, the items held an estimated 1,881 gallons of PCBs and PCB-contaminated oil.

Most of those items were directly on the building floor, according to the order. The 55-gallon container was in secondary containment, but not containment identified in Hydrodec’s approved application. EPA alleged that the broader area lacked the continuous curbing and approved nonporous containment required for PCB waste designated for disposal.

That was not an isolated paperwork allegation. The order describes a chain of failures involving where waste was placed, how it was marked, whether inspections could be documented and whether workers could reach containers to inspect them or respond to a leak.

An approved PCB operator, and safeguards EPA says failed

Hydrodec of North America operates a mineral oil refining facility in Canton. EPA approved it in January 2018 as a commercial storer of PCB waste and as a disposer using an alternative treatment method. The approval was modified twice in 2021.

That authorization came with specific controls. The order describes them as a practical containment system, not a single permit form filed and forgotten.

On May 14, 2024, inspectors examined approved storage areas, other buildings and Hydrodec’s PCB handling operations. EPA later organized its allegations into 12 counts under the Toxic Substances Control Act and federal PCB regulations.

Where inspectors reported PCB items

Source: EPA consent order, paragraphs 58 to 88. The gallon estimates are EPA’s estimates for the cited items, not a total inventory for the facility.

The smaller details describe how control can break down

EPA said Hydrodec could not produce 10 inspection records from the previous 30 months. Those records mattered because the rules required PCB items in storage to be checked for leaks at least every 30 days.

Inspectors also reported no removal-from-service dates on three transformers, one PCB container and 13 other PCB items. They observed three open containers in the approved Building A storage area, four containers overhanging pallet edges in Buildings A and F, and pallets arranged two rows wide where the approval required access for inspection and spill response.

The order connects those controls to an actual release. Inspectors said less than one gallon leaked from a bushing containing PCBs at 50 parts per million or more. Under the cited rule, an uncontrolled PCB discharge at that concentration constitutes disposal. EPA framed the resulting count as improper disposal of less than five gallons of PCB oil.

What the record says about harm, and what it does not

The order documents the alleged leak and the failure of controls intended to contain waste, identify PCB items and preserve access for inspection and spill response. It does not document an injury, a person’s exposure, contamination beyond the facility or a cleanup total.

That distinction matters. The evidence supports an account of alleged regulatory and permit failures, including one observed release. It does not support a claim that the order established broader health or environmental damage.

The practical risk identified by the rules is nevertheless clear within the document. Continuous curbing and nonporous floors are intended to contain liquids and minimize PCB penetration. Closed containers reduce leakage risk. Adequate aisles let people inspect stored items and respond when a container leaks. Missing dates and records make it harder to verify how long an item has been awaiting disposal and whether recurring checks occurred.

The penalty, the payment plan and a discrepancy in the schedule

EPA set the civil penalty at $144,484. The agency said it considered the nature, circumstances, extent and gravity of the alleged violations, along with factors including culpability, prior violations and ability to pay. EPA also said a review of Hydrodec’s financial information found that the company had a limited ability to pay.

The payment plan calls for installments at 30-day intervals, generally listed as $4,423.15 each, with the final payment listed as $4,423.17. Hydrodec can instead pay the full $144,484 within 30 days of filing and avoid interest, or pay the remaining principal and accrued charges early after installments begin.

How the case moved from approval to settlement

1. June 16, 2017

   Hydrodec submitted its application for federal PCB alternative-treatment and commercial-storage approval.

2. Jan. 8, 2018

   EPA granted the approval.

3. June 22, 2021

   EPA modified the approval, including authorization involving the designated Building A and Dike C storage areas.

4. Nov. 11, 2021

   EPA issued another modification to the approval.

5. May 14, 2024

   EPA inspectors conducted the compliance inspection described in the order.

6. Sept. 21, 2026

   The consent agreement and final order was filed, making it effective and concluding the administrative proceeding.

What Hydrodec accepted, and what remains unresolved

Hydrodec consented to the penalty, waived its right to a hearing, waived its right to contest the allegations and gave up its right to appeal the order. It also certified that it was complying with the Toxic Substances Control Act and the federal PCB regulations when the agreement was signed.

That certification is the order’s stated compliance endpoint. The document does not provide a detailed account of when each storage, labeling, inspection or aisle issue was corrected. It also does not contain an admission that EPA’s factual allegations were true.

The settlement’s significance lies in the gap between authorization and execution. Hydrodec had federal approval to store and treat PCB waste. EPA alleged that basic conditions attached to that approval failed across several layers at once: location, containment, labeling, dating, inspection records, container closure, pallet placement and access for spill response.

The order does not prove a sweeping contamination event. It records something narrower and still consequential: an approved operator agreed to pay a six-figure penalty after inspectors reported that the controls meant to keep PCB waste identifiable, contained and reachable were repeatedly not in place.