ORION DIESEL LLC

Orion Diesel LLC is a privately held Waterford, Michigan entity classified under NAICS 811198 that became the subject of a federal Clean Air Act enforcement action culminating in an August 29, 2022 default judgment of $10 million in the U.S. District Court for the Eastern District of Michigan. The case, United States of America v. Diesel Ops LLC et al, 2:2021cv12928, was filed in December 2021 and named Orion Diesel LLC, DieselOps LLC, and sole owner Nicholas Piccolo of Waterford Township as defendants for the sale of aftermarket products that the United States alleged functioned as emissions defeat devices on motor vehicles [source: https://www.epa.gov/newsreleases/united-states-awarded-10-million-default-judgment-and-permanent-injunction-against-two] [source: https://dockets.justia.com/docket/michigan/miedce/2:2021cv12928/358784]. EPA ECHO lists one facility linked to the company (registry ID 110070386156) and allocates a prorated 24-month penalty total of approximately $4.18 million derived from the larger five-year judgment [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Two features make this case stand out. The court imposed an additional roughly $1.46 million civil penalty against Piccolo individually — separate from the corporate judgment — for failing to respond to federal information requests and for transferring approximately $979,818 in company assets after EPA issued Notices of Violation, conduct the government characterized in filings as asset concealment [source: https://www.mlive.com/public-interest/2022/09/michigan-companies-fined-10m-for-selling-diesel-defeat-devices.html] [source: https://www.emissions.co.uk/news/emissions-defeat-device-supplier-fined-10m-after-dieselgate/]. The matter also resolved by default judgment rather than negotiated consent decree, meaning the company did not contest liability on the merits [source: https://morelaw.com/verdicts/case.asp?s=MI&d=167539]. That procedural posture matters: the government's factual allegations were admitted by operation of Rule 55, not litigated to a finding. Orion Diesel LLC is private, carries no SEC filings, and has published no sustainability disclosure of record.

Orion Diesel LLC's compliance record is effectively defined by a single federal civil enforcement action under the Clean Air Act's mobile-source provisions, Section 203(a)(3), which prohibits the manufacture, sale, or installation of parts that bypass, defeat, or render inoperative vehicle emissions controls. EPA's December 2021 complaint, filed jointly by the Department of Justice in the Eastern District of Michigan, alleged that Orion Diesel and affiliated DieselOps LLC sold products designed to disable onboard diagnostic and emissions systems on diesel pickup trucks [source: https://www.epa.gov/newsreleases/united-states-awarded-10-million-default-judgment-and-permanent-injunction-against-two] [source: https://dockets.justia.com/docket/michigan/miedce/2:2021cv12928/358784].

The chronology is specific. During 2020 and 2021, EPA issued information requests and Notices of Violation to the two Piccolo-owned entities. The companies did not fully respond to those requests. Following NOV issuance, approximately $979,818 in company assets was transferred to the individual owner — a sequence EPA referenced directly in subsequent filings [source: https://www.emissions.co.uk/news/emissions-defeat-device-supplier-fined-10m-after-dieselgate/]. The government filed its civil complaint on December 15, 2021 [source: https://dockets.justia.com/docket/michigan/miedce/2:2021cv12928/358784]. Defendants failed to appear and defend. The court entered default, and on August 29, 2022, the district court awarded the United States a $10 million civil penalty against the two LLCs jointly, plus a permanent injunction barring further manufacture, sale, or installation of defeat devices, plus an additional approximately $1.46 million in civil penalties directly against Piccolo [source: https://www.epa.gov/newsreleases/united-states-awarded-10-million-default-judgment-and-permanent-injunction-against-two] [source: https://www.mlive.com/public-interest/2022/09/michigan-companies-fined-10m-for-selling-diesel-defeat-devices.html] [source: https://morelaw.com/verdicts/case.asp?s=MI&d=167539].

What the post-judgment record shows is quieter. In the 24-month window reflected in EPA ECHO data as of May 4, 2026, ECHO records no new quarters of non-compliance and no new permits for the single associated facility [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The $4,182,370 penalty figure shown in ECHO's 24-month window is a prorated allocation of the five-year default judgment under ECHO's standard derivation formula — total_5yr × 24/60 — rather than a new enforcement event [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No new complaints, consent decrees, or state-level enforcement matters against Orion Diesel LLC have surfaced in the public record reviewed. The permanent injunction functionally prohibits the company from resuming the product line at the center of the 2021–2022 case, and available filings contain no indication that Orion Diesel LLC is currently operating an active commercial business at scale.

Action 1 — United States v. Diesel Ops LLC and Orion Diesel LLC, Case No. 2:21-cv-12928, U.S. District Court, Eastern District of Michigan. Program: Clean Air Act, Title II (Mobile Sources), 42 U.S.C. § 7522(a)(3). Complaint filed December 15, 2021 [source: https://dockets.justia.com/docket/michigan/miedce/2:2021cv12928/358784]. Default judgment entered August 29, 2022. Outcome: $10,000,000 civil penalty against Diesel Ops LLC and Orion Diesel LLC jointly, plus a permanent injunction against further manufacture, sale, or installation of emissions defeat devices [source: https://www.epa.gov/newsreleases/united-states-awarded-10-million-default-judgment-and-permanent-injunction-against-two] [source: https://morelaw.com/verdicts/case.asp?s=MI&d=167539]. The EPA news release identifies the products at issue as aftermarket components that disable emissions controls on diesel vehicles, contributing to excess NOx and particulate matter emissions on in-use fleets [source: https://www.epa.gov/newsreleases/united-states-awarded-10-million-default-judgment-and-permanent-injunction-against-two].

Action 2 — Related individual judgment against Nicholas Piccolo, owner of both LLCs. Program: Clean Air Act, asset-transfer and information-request provisions. Outcome: approximately $1.46 million additional civil penalty for failing to respond to EPA Section 208 information requests and for transferring approximately $979,818 in company assets after NOV issuance [source: https://www.mlive.com/public-interest/2022/09/michigan-companies-fined-10m-for-selling-diesel-defeat-devices.html] [source: https://www.emissions.co.uk/news/emissions-defeat-device-supplier-fined-10m-after-dieselgate/]. The individual penalty runs parallel to, and does not substitute for, the corporate judgment. Both obligations stand independently on the docket.

EPA ECHO 24-month aggregates as of May 4, 2026: facility count 1, violation count 0 new quarters of non-compliance, active permits 0, 24-month penalty allocation $4,182,370 (prorated from the five-year default judgment) [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. No CWA, RCRA, SDWA, EPCRA, or TSCA actions are associated with the entity in the reviewed record.

Facility 1 — Orion Diesel LLC, Waterford, Michigan (EPA registry ID 110070386156). This is the only facility ECHO associates with the company. ECHO records zero active permits and zero quarters of non-compliance in the current 24-month window; the $4.18 million penalty allocation reflects the prorated federal default judgment rather than ongoing violations [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The facility functioned as the commercial base for distribution of the aftermarket products at the center of the 2021 complaint [source: https://dockets.justia.com/docket/michigan/miedce/2:2021cv12928/358784].

Contextual note on geographic overlap — GM Orion Assembly, 4555 Giddings Rd, Lake Orion, MI 48359. This facility is unrelated to Orion Diesel LLC in ownership and operations; it is a General Motors automobile assembly plant. It is flagged here only to disambiguate search results referencing 'Orion' and Michigan. The GM Orion plant holds a separate Clean Air Act NSR/PSD permit covering VOC (467 tpy), NOx (75.3 tpy), CO (86.9 tpy), PM10 and PM2.5 (27.6 tpy each), SO2 (1.63 tpy), and CO2e (120,020 tpy), with VOC emissions routed to a recuperative thermal oxidizer [source: https://www.epa.gov/nsr/gm-orion]. No corporate or compliance linkage exists between GM Orion and Orion Diesel LLC.

Contextual note on name overlap — Orion Engineered Carbons, LLC (now Orion S.A., NYSE: OEC). This publicly traded specialty chemicals company entered a 2017 Clean Air Act consent decree with EPA and DOJ covering carbon black plants in Louisiana, Ohio, and Texas [source: https://www.epa.gov/enforcement/orion-engineered-carbons-llc-clean-air-act-settlement] [source: https://www.epa.gov/enforcement/consent-decree-orion-engineered-carbons-llc]. It is a separate legal entity from Orion Diesel LLC and its compliance history should not be conflated with that of the Waterford, Michigan aftermarket diesel company. Facilities 4 and 5 positions are not populated because ECHO records only one facility linked to Orion Diesel LLC.

The 2021 complaint targeted defeat devices affecting on-road diesel vehicles, so the implicated pollutants are those controlled by modern diesel aftertreatment systems: nitrogen oxides (NOx), particulate matter (PM2.5), and carbon monoxide (CO). EPA has documented that tampered diesel pickups can emit NOx at levels many multiples of certified values. The agency's National Compliance Initiative on stopping aftermarket defeat devices frames these products as a significant driver of in-use excess emissions across the on-road fleet [source: https://www.epa.gov/newsreleases/united-states-awarded-10-million-default-judgment-and-permanent-injunction-against-two].

NOx contributes to ground-level ozone formation and to secondary PM2.5. Exposure pathways are predominantly inhalation along roadways, with documented associations to asthma exacerbation and cardiovascular effects. PM2.5 is directly emitted from diesel engines operating without functioning diesel particulate filters. EPA and IARC classify it as a human carcinogen when considered as part of diesel exhaust. CO is a product of incomplete combustion and is acutely toxic at high exposures, though roadway dispersion typically limits chronic risk.

Defeat-device cases involve mobile sources. The environmental footprint is therefore not tied to a single stationary facility but distributed along the routes and communities where the modified vehicles operate — a meaningful distinction from stack-based enforcement. EPA has identified low-income and minority communities near major freight corridors as disproportionately exposed to diesel PM and NOx, a pattern also raised in contemporaneous petitions on stationary diesel generator siting [source: https://www.indybay.org/newsitems/2026/04/22/18885732.php]. ECHO records an EJ index average of 0.0 for the single Orion Diesel facility itself, reflecting the absence of a stack-based emissions profile rather than an absence of downstream exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

No NAICS 811198 peer benchmark data was returned in the research bundle, so a quantitative peer comparison is not supported by the record. Qualitatively, the federal defeat-device docket contains numerous parallel cases against small and mid-size Michigan and Midwestern aftermarket diesel retailers pursued under the same Clean Air Act Title II authority, with EPA's national enforcement initiative describing the Orion Diesel / Diesel Ops judgment as part of a broader crackdown [source: https://www.epa.gov/newsreleases/united-states-awarded-10-million-default-judgment-and-permanent-injunction-against-two]. A $10 million default judgment sits at the upper end of outcomes in that cohort because of the asset-transfer and non-response findings that generated the additional individual penalty against Piccolo [source: https://www.mlive.com/public-interest/2022/09/michigan-companies-fined-10m-for-selling-diesel-defeat-devices.html].

Orion Diesel LLC is privately held and files no SEC reports; there is no Item 1A risk factor disclosure to cite. Forward-looking legal exposure is instead defined by the permanent injunction entered August 29, 2022, which bars the company and its owner from the manufacture, sale, installation, or offering for sale of emissions defeat devices, with any breach subject to contempt proceedings and further civil penalties [source: https://www.epa.gov/newsreleases/united-states-awarded-10-million-default-judgment-and-permanent-injunction-against-two] [source: https://dockets.justia.com/docket/michigan/miedce/2:2021cv12928/358784].