No Records, No Labels, No Plan
A company built to handle some of America’s most dangerous industrial waste ran its PCB storage facility in Plainwell, Michigan with unmarked containers, no spill plan, and years of missing paperwork. The EPA found out. The fine was $10,245.
TL;DR
- The Company DLD Environmental Services, Inc., based in Plainwell, Michigan, is a federally approved commercial storage facility for PCBs (polychlorinated biphenyls), one of the most toxic and persistent industrial chemicals ever manufactured.
- The Violations A September 2023 EPA inspection uncovered 7 separate violations: unmarked PCB containers, missing worker training records, three years of absent annual document logs, and no Spill Prevention Control and Countermeasure Plan on site.
- The Timeline DLD had been operating under a federal storage approval since at least September 2020, meaning these documentation failures may have persisted for three or more years before anyone checked.
- The Penalty The EPA settled for $10,245 (roughly the cost of one month’s rent for two families in a mid-size American city), a sum that functions more as a rounding error than a deterrent for a commercial hazardous waste operation.
- The Resolution DLD neither admitted nor denied the factual allegations, waived its right to a hearing or appeal, and signed the consent agreement on May 20, 2025.
A federally licensed toxic waste storage company in Michigan spent at least three years without completing a single annual document log, let alone training its workers to handle one of the most dangerous chemicals ever banned by the U.S. government, and the EPA’s response was a fine smaller than the average American’s monthly car payment.
What PCBs Are and Why This Facility Exists
Background Polychlorinated biphenyls, PCBs, are synthetic chemicals that were used for decades in electrical equipment, industrial oils, and manufacturing processes. The U.S. effectively banned their production in 1979 because of their severe toxicity, their tendency to accumulate in living tissue, and their near-indestructibility in the environment. They do not break down. They build up.
Because PCBs are still present in aging infrastructure, old transformers, and contaminated soil across the country, there exists an entire industry dedicated to collecting, transporting, storing, and ultimately destroying this legacy waste. DLD Environmental Services, Inc., operating out of 331 Broad Street in Plainwell, Michigan, is one of those businesses. The federal government, through the EPA, formally approved the facility to commercially store PCB waste in September 2020.
That approval came with legal obligations. Specific, detailed, non-negotiable obligations. Worker training documentation. Annual activity logs. Properly marked containers. A written plan for what to do when something spills. These are the bare minimum requirements for operating a facility that holds one of the most hazardous classes of chemicals in existence. When the EPA walked through the door on September 7, 2023, it found that DLD had failed all of them.
A Company That Inherited a Problem
The facility’s EPA approval was originally issued to DLD’s predecessor entity, Drug and Laboratory Disposal, Inc., and DLD Environmental Services took over ownership and operation of the site. The approval transferred with the facility. So did the legal obligations. Whatever happened inside that building between September 2020 and September 2023 falls squarely on DLD.
The company’s president, Brent W. Walter, signed the consent agreement on May 20, 2025. The EPA’s Division Director for Enforcement and Compliance Assurance, Michael D. Harris, signed two days later. A Regional Judicial Officer entered the final order the same day. The case is closed. The fine is paid or being paid. And the facility is, according to DLD’s own certification in the agreement, currently in compliance.
Three consecutive years. Gone. No log for the year the facility received its federal approval. No log for the year after. No log for the year after that. This is not a paperwork technicality. Annual document logs for PCB storage facilities are the primary paper trail that tells regulators what came in, what went out, and whether the people handling it knew what they were doing.
Timeline constructed from factual allegations in the EPA Consent Agreement and Final Order, TSCA-05-2025-0003, filed May 30, 2025.
Seven Counts. Zero Excuses.
The EPA did not find one problem on one bad day. Inspectors documented seven separate, distinct violations during their September 2023 walkthrough. Each one represents a specific legal requirement that DLD had an affirmative duty to satisfy, and each one had been neglected.
The Labeling Failures: A Quiet Danger
Federal law has required PCB containers to be marked since July 1, 1978. That is nearly five decades of legal clarity on this point. The warning labels on PCB containers are not bureaucratic decoration. They communicate to every worker, emergency responder, and inspector exactly what they are dealing with. Six unmarked containers in two separate storage areas means six times that a worker could have moved, opened, or disturbed a PCB container without the immediate knowledge that the contents require specific handling protocols.
The labeling requirements exist specifically because PCBs are invisible to the naked eye and carry no immediate, obvious warning signs. You cannot smell imminent danger. You cannot see contamination occurring. The label is the only warning system in the room.
The Training Records: Nobody Could Prove They Knew What They Were Doing
DLD’s EPA approval required the company to maintain records proving that staff who handle PCBs received proper training: names, titles, training dates, and signed certifications. When the inspector asked for those records, the company could not produce them. This does not necessarily mean training never happened. It means there is no way to know whether it happened, and in hazardous waste management, “no way to know” is functionally identical to “it didn’t happen.”
The training requirements in DLD’s approval were not vague. Approval Conditions E.4. and E.5. spelled out exactly what needed to be recorded and kept. The failure to maintain those records is not a filing mistake. It is an operational breakdown in a facility handling chemicals that cause cancer, disrupt hormones, and persist in human tissue for years after exposure.
No Spill Plan: Hoping for the Best in a Chemical Storage Facility
The Spill Prevention Control and Countermeasure Plan is the document that tells workers what to do when something goes wrong. Where is the containment equipment? Who do you call? How do you stop a PCB spill from reaching a drain, a floor crack, the soil beneath the building? DLD was required under federal law and its own approval conditions to maintain a current, accessible SPCC Plan at the facility at all times. When the inspector arrived, the company could not produce one.
Each bar represents the count of violations found in that category during the EPA’s September 7, 2023 inspection. Source: EPA CAFO, TSCA-05-2025-0003.
The Non-Financial Ledger
The settlement document measures DLD’s failures in dollars. $10,245 (roughly what a median American worker earns in six weeks of full-time labor). But no dollar figure in this agreement captures what it means to work inside a facility handling some of the most toxic legacy chemicals in American industrial history, without knowing whether the people next to you have been trained to handle a spill, without knowing whether the containers around you are clearly marked, without a spill plan on the wall telling anyone what to do when the worst-case scenario happens.
PCBs are not theoretical. They are carcinogens. The International Agency for Research on Cancer classifies them as Group 1 carcinogens, meaning the evidence that they cause cancer in humans is definitive. They disrupt the endocrine system. They accumulate in fatty tissue and do not leave. A person exposed to PCBs today carries them for years. The workers inside DLD’s Plainwell facility were entitled, under federal law, to documented proof that their employer had trained them to minimize that risk. That proof did not exist, or could not be produced, when the government came to check.
Consider what the absence of an SPCC Plan actually means in practice. A Spill Prevention Control and Countermeasure Plan is the facility’s emergency rulebook. It describes where containment equipment is stored. It outlines the steps workers must take in the first minutes of a spill to prevent PCBs from migrating into drains, groundwater, or soil. Without that plan posted and accessible, a worker facing a real spill at DLD’s facility in Plainwell was operating without a script in a situation where every second of delay increases the area of contamination. That is not a bureaucratic oversight. That is a failure of basic occupational duty of care.
The six unmarked containers compound this picture. Two in storage area DSL-1. Four in storage area DSL-5. A warehouse worker, a delivery driver, a maintenance contractor unfamiliar with the facility’s layout would have no way of knowing from the container itself that the contents required specific, legally mandated handling procedures. The labeling requirement has existed since 1978. That is almost half a century of settled law and settled science on why the label matters. DLD operated with unlabeled PCB containers anyway, and the consequence was a fine most small businesses spend on office supplies in a month.
Legal Receipts: Straight from the Document
These are direct quotations and findings from the EPA’s own Consent Agreement and Final Order. Read them slowly.
“During the September 7, 2023 inspection, Respondent was unable to produce a training records and files for its staff that handle PCBs.”
Count 3, Paragraph 33 — EPA Consent Agreement and Final Order, TSCA-05-2025-0003
“During the September 7, 2023 inspection, Respondent was unable to produce a written annual document log for 2020, 2021, and 2022.”
Counts 4 to 6, Paragraph 37 — EPA Consent Agreement and Final Order, TSCA-05-2025-0003
“At the time of inspection, Respondent was unable to produce a current SPCC Plan.”
Count 7, Paragraph 43 — EPA Consent Agreement and Final Order, TSCA-05-2025-0003
“Respondent neither admits nor denies the factual allegations in this CAFO.”
Paragraph 8 — EPA Consent Agreement and Final Order, TSCA-05-2025-0003
“Respondent certifies that it is complying fully with TSCA and the PCB Regulations.”
Paragraph 56 — EPA Consent Agreement and Final Order, TSCA-05-2025-0003
Societal Impact Mapping
Public Health: The Workers the Agreement Does Not Name
The federal PCB regulations exist in their current form because PCBs caused documented, measurable, irreversible harm to human populations. Studies of workers exposed to PCBs in industrial settings showed elevated rates of liver cancer, non-Hodgkin lymphoma, and skin conditions. PCBs cross the placental barrier, meaning they transfer from an exposed mother to a developing fetus. Children with elevated PCB exposure show measurable cognitive deficits. This is the scientific context inside which every single compliance requirement for a PCB storage facility was designed.
DLD’s missing training records mean there is no documented assurance that the workers handling PCBs at the Plainwell facility were informed of these risks in any standardized, verifiable way. The EPA’s approval conditions required records of worker names, training dates, and signed certifications. Those records did not exist at inspection. The gap between federal requirement and documented reality is the space where worker health risk lives, unnamed and unquantified in the settlement document.
The missing SPCC Plan reinforces this concern. In the event of a PCB spill at DLD’s facility, an inadequately trained worker without a clear emergency response protocol in hand is a public health risk as well as an occupational one. PCB spills that are not immediately and correctly contained can migrate. They can enter storm drains. They can reach soil. They can reach groundwater. Plainwell, Michigan sits within the Kalamazoo River watershed, a system that has its own documented PCB contamination history from upstream industrial activity. The stakes of a containment failure at a facility like DLD’s are not hypothetical.
Environmental Degradation: The Spill That Didn’t Happen, As Far As We Know
The settlement document does not report an active spill or environmental release. What it documents is the infrastructure failure that would have made a spill catastrophic: no current spill plan, no documented trained workforce, no properly identified containers. The regulatory framework for PCB storage exists precisely to prevent contamination events before they occur, because PCB contamination events are extraordinarily expensive and functionally permanent to remediate.
The PCB regulations at 40 C.F.R. Part 761 define “disposal” to include not just intentional discarding but also “spills, leaks, and other uncontrolled discharges.” The marking requirements, the training requirements, and the SPCC Plan requirement all exist upstream of disposal, as the prevention layer. DLD’s failures were concentrated in exactly that prevention layer. The environmental risk was not the result of a deliberate illegal dump. It was the result of chronic, years-long neglect of the systems designed to make an unintentional environmental disaster less likely.
Please visit this link from the EPA’s website to view the information displayed about: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/6EE1B92593439ED785258C9A006FEA51/$File/TSCA-05-2025-0003_CAFO_DLDEnvironmentalServicesInc_PlainwellMichigan_12PGS.pdf
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