EPA v. EMERALD TRANSFORMER PPM LLC

Case summary

CONSENT AGREEMENT FINAL ORDER: 08/18/2026 This is an administrative penalty assessment proceeding brought under Section 16(a) of the Toxic Substances Control Act (TSCA or the Act), 15 U.S.C. 2615(a), and Sections 22.13(b) and 22.18 of the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties and the Revocation/Termination or Suspension of Permits, as codified at Title 40 of the Code of Federal Regulations (C.F.R.), Part 22. On March 13, 2025, authorized agents of the EPA conducted an inspection at Respondent's Facility pursuant to Section 11 of TSCA, 15 U.S.C. 2610, to evaluate Respondent's compliance with its Approval and the PCB regulations. At the time of the inspection, Respondent had failed to maintain an accurate inventory of PCB waste on-site that included the total quantity of PCB Items being stored. The inventory provided did not accurately identify seven (7) different totes of PCB wastewater as they were listed under one identification number indicating that there was only one (1) tote. At the time of the inspection, Respondent was storing three (3) partially empty totes with PCB waste in the Empty Container storage area. At the time of the inspection, Respondent had double stacked a partially empty tote with PCB waste, which was leaning over, in a manner that was not safely supported. At the time of the inspection, Respondent was storing one (1) flat-bed trailer with electrical equipment of unknown PCB concentration in the front parking lot, outside the fence of the Facility. At the time of the inspection, Respondent had twelve (12) open PCB pole top transformers stored on-site. The EPA alleges that Respondent failed to maintain an accurate inventory of PCB waste on-site at the time of the inspection, as required by Approval Condition 111.H.1, in violation of Section 15 of TSCA, 15 U.S.C. 2614. The EPA alleges that Respondent failed to store PCB waste in the approved PCB storage area, as required by Approval Condition IV.A.1, in violation of Section 15 of TSCA, 15 U.S.C. 2614. The EPA alleges that Respondent did not manage its PCB Containers in a safely supported manner, as required by Approval Condition IV.1.4, in violation of Section 15 of TSCA, 15 U.S.C. 2614. The EPA alleges that Respondent failed to manage all PCB waste in the Facility staging area until accepted for storage, as required by Approval Condition IV.1.1, in violation of Section 15 of TSCA, 15 U.S.C. 2614. The EPA alleges that Respondent failed to keep all PCB containers closed during storage, as required by Approval Condition IV.1.2, in violation of Section 15 of TSCA, 15 U.S.C. 2614. Respondent consents to the payment of a civil penalty, which was calculated in accordance with the Act, in the amount of THIRTY-THREE THOUSAND, EIGHT HUNDRED AND FORTY-FIVE DOLLARS ($33,845.00), which is to be paid within thirty (30) days of the Effective Date of this CAFO.

Defendants (1)

• EMERALD TRANSFORMER PPM LLCNamed in complaintNamed in settlement

Facilities (1)

• EMERALD TRANSFORMER PPM LLC

  4720-B STONE DRIVE, TUCKER, GA, 30084

  Registry ID: 110071339634

Statutes cited

• TSCA 6-PCBS — PCBS

Enforcement conclusions (1)

• EMERALD TRANSFORMER PPM LLCentered 2026-08-18

  Primary law: TSCA

  Federal penalty: $33,845

Timeline (3 milestones)

• 2026-08-18Final Order Issued
• 2026-08-18Complaint Filed/Proposed Order
• 2026-10-07Enforcement Action Data Entered