In Building A, EPA inspectors said they found eleven PCB articles, three PCB transformers and a 55-gallon container outside the storage area approved for that waste. The items were estimated to contain 1,881 gallons of PCBs and PCB-contaminated oil. Most were sitting directly on the floor rather than within the containment arrangement identified in Hydrodec’s federal approval.

The inspection account did not stop there. EPA described another 15 articles containing an estimated 150 gallons in Building F, plus a 55-gallon container and a 10-gallon bucket containing an estimated 60 gallons in Building G. It alleged that none of these locations provided the approved storage conditions required for disposal-bound PCB items.

The approved system and the conditions EPA described

Hydrodec operates a mineral oil refining facility and held federal approval to store and treat PCB waste. EPA granted that approval in January 2018 and modified it twice in 2021. The approval identified specific storage areas, including Dike C and Building A, and imposed conditions governing containment, labels, inspections, container placement and access.

Building A’s designated PCB storage area was described in the approval application as a concrete containment structure, with PCB items supported on racks above it and protected by the building’s roof. The approval authorized storage of drums, totes and PCB articles containing up to 880 gallons in that designated area.

Twelve counts show how the safeguards allegedly failed

The PCB rules cited in the order do more than designate a room. They require physical containment, visible hazard markings, readable disposal dates, periodic leak checks, appropriate containers and enough aisle space for inspection and spill response. EPA’s allegations reached across each of those layers.

One alleged violation moved beyond the possibility of a release. Inspectors reported seeing less than one gallon leak from a bushing containing PCBs at concentrations of at least 50 parts per million. Under the cited regulation, an uncontrolled discharge at that concentration constitutes disposal. EPA therefore alleged improper disposal under federal PCB rules.

The order does not describe an injury, human exposure, contamination beyond the facility or a cleanup tied to that leak. It also does not provide environmental sampling results. The documented consequence is the regulatory violation alleged by EPA, not a demonstrated public health outcome.

• ContainmentCurbs, nonporous floors and controlled storage areas are intended to confine liquid and prevent it from leaving the storage unit.
• IdentificationWarning labels and disposal dates allow workers and inspectors to identify regulated items and track how long they have been out of service.
• MonitoringLeak checks at least every 30 days create a record of whether stored items and containment structures were inspected.
• AccessAisle requirements preserve room to inspect containers and respond to a leak instead of forcing responders around tightly packed pallets.

EPA’s account describes a control system weakened in several places at once: where the waste sat, how it was contained, whether it was labeled, whether checks were documented and whether responders could reach it.

The penalty stretches across three years

Hydrodec consented to a civil penalty of $144,484. EPA said it considered the nature and gravity of the alleged violations, culpability, compliance history, ability to continue doing business and other statutory factors. The agency also analyzed Hydrodec’s financial information and determined that the company had a limited ability to pay.

The resulting schedule allows payment in 36 installments. With $14,749.42 in scheduled interest, the order lists a total of $159,233.42. Hydrodec may instead pay the full $144,484 within 30 days of filing and avoid interest, or later pay the remaining principal and accrued charges early.

Late payments can trigger additional interest, handling charges and a six percent annual late penalty on debts delinquent for more than 90 days. The order also allows collection actions if Hydrodec does not follow the schedule.

Hydrodec accepted the order without admitting the allegations

The settlement was reached without a complaint being litigated and without adjudication of any factual or legal issue. Hydrodec admitted EPA’s jurisdiction but neither admitted nor denied the factual allegations. It waived a hearing, any right to contest the allegations and its right to appeal the final order.

That distinction matters. The final order conclusively establishes Hydrodec’s obligation to pay the agreed penalty. It does not convert every factual allegation into an admitted fact or a finding reached after a contested hearing.

Hydrodec also certified in the agreement that it was complying with the Toxic Substances Control Act and the federal PCB regulations. The document does not detail the physical changes, record reconstruction or operational measures behind that certification.

From permit approval to final order

1. June 16, 2017

   Hydrodec submitted its application for federal approval to treat and commercially store PCB waste.

2. January 8, 2018

   EPA granted the treatment and storage approval.

3. June and November 2021

   EPA modified the approval, including authorization tied to designated storage areas and capacity limits.

4. May 14, 2024

   EPA inspectors examined PCB waste handling, storage, disposal operations and records at the Canton facility.

5. September 21, 2026

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

What the settlement resolves, and what it leaves unanswered

The order resolves Hydrodec’s federal civil penalty liability for the violations alleged in this matter. It does not limit the company’s continuing duty to comply with environmental laws, and it preserves the government’s ability to pursue other forms of relief or sanctions for violations of law.

The significance of EPA’s case lies in the combination. A missing label can be treated as paperwork. A blocked aisle can look like housekeeping. A container beyond containment can appear temporary. In this order, however, EPA linked those conditions to a broader system for controlling disposal-bound PCB waste and alleged that multiple parts of that system failed during the same inspection.

The penalty creates a financial consequence. The public record remains less complete on the physical consequence: it documents a small observed leak, but no established injury or off-site contamination, and it gives little detail about how Hydrodec corrected the conditions inspectors described.