# FIRST RESPONSE, A TRADEBE COMPANY dba FIRST RESPONSE ENVIRONMENTAL GROUP > **Administrative - Formal** · FY2018 · — · Final Order With Penalty ## Case - **Activity ID:** `3601477373` - **Case Number:** 04-2018-2901 - **Type:** Administrative - Formal - **Lead:** EPA - **Outcome:** Final Order With Penalty - **Penalty assessed:** — - **Cost recovery:** — - **Compliance action $:** — - **Multimedia (multi-env):** — ## Defendants - FIRST RESPONSE ENVIRONMENTAL GROUP (settlement) - FIRST RESPONSE, A TRADEBE COMPANY (complaint) (settlement) ## Summary 6/19/18 - CONSENT AGREEMENT AND FINAL ORDER ISSUED, ASSESSING A PENALTY OF $25,500, DUE WITHIN 30 DAYS. ALLEGATIONS: ON OR ABOUT SEPT 1, 2016, A CLARKSVILLE DEPT OF ELECTRICITY LIGHTBAND (CDEL) EMPLOYEE DISCOVERED A LEAK IN A WESTINGHOUSE PAD MOUNT TRANSFORMER AND A 541 GALLON CAPACITY AT 1420 PARADISE HILL ROAD, CLARKSVILLE, TN. THE NAME PLATE FOR THE WESTINGHOUSE TRANSFORMER DID NOT IDENTIFY THE DATE OF MANUFACTURE OR THE TYPE OF DIELECTRIC FLUID. 40 CFR 761.2(a)(3) REQUIRES ANY PERSON TO ASSUME THAT A TRANSFORMER IS A PCB TRANSFORMER IF THE DATE OF MANUFACTURE AND THE TYPE OF DIELECTRIC FLUID ARE UNKNOWN. ON OR ABOUT OCT 6, 2016, CDEL SAMPLED THE DIELECTRIC FLUID IN THE WESTINGHOUSE TRANSFORMER AND DETERMINED THE PCB CONCENTRATION OF 4,222 PPM.. CDEL ESTIMATED THAT APPROX 20 GALLONS OF PCB OIL HAD LEAKED FROM THE WESTINGHOUSE TRANSFORMER. ON OR ABOUT DEC 20, 2016, FREG, A CONTRACTOR FOR CDEL, BEGAN REMEDIATION BY REMOVING THE WESTINGHOUSE TRANSFORMER AND THE CORRESPONDING PCB OIL WITHIN THE TRANSFORMER. THE PCB OIL WAS TRANSFERRED INTO TWO 275-GALLON TOTES AND MANIFESTED TO LEI, INC., ON MARCH 17, 2017. ON OR ABOUT DEC 20, 2016, FREG TRIPLE RINSED THE WESTINGHOUSE TRANSFORMER WITH DIESEL FUEL. THE DIESEL AND PCB WASTE GENERATED FROM RINSING THE WESTINGHOUSE TRANSFORMER WERE PLACED INTO ONE OF THE TWO 275-GALLON TOTES. FREG RECYCLED THE EMPTY WESTINGHOUSE TRANSFORMER AT BORDEAU METALS ON DEC 20, 2016. FREG TRANSPORTED ONE 25-CUBIC YARD R --- *Source: [EPA ECHO](https://echo.epa.gov/) · AI Analytics · CC0 1.0*