H.E.L.P.E.R., Inc. (“Helper”) operates an electrical equipment reclamation and recycling facility in Madison, South Dakota. The company recovers copper, steel, and brass from transformers that have reached the ends of their useful lives. Helper also processes mineral oils, such as transformer oil and mineral oil dielectric fluid, used in electrical equipment. These mineral oils contain varying concentrations of polychlorinated biphenyls (“PCBs”).