As part of an ongoing brownfield site development and remediation project, ESI was retained to assist in the removal of a 150,000 gallon above ground storage tank and its contents. The tank was previously used in a recycling operation during the early 1980s and received waste materials from unknown sources.

The tank was reported to contain over 50,000 gallons of sludge and liquid waste, which was listed as a Toxic Substances Control Act (TSCA) waste due to the addition of a waste stream containing high concentrations of PCBs.

Prior to our assignment to remove the tank and it’s contents, the estimated cost for removal was $1.2 million. Since there were no TSCA waste facilities near the site, a considerable portion of the cost would be incurred in transportation of the sludge to the nearest TSCA facility.

Our regulatory team reviewed all USEPA regulations associated with PCB disposal in order to eliminate the TSCA classification of the sludge. Negotiations with the USEPA resulted in an agreement to evaluate the current concentration of PCBs in the sludge. If the PCB concentration was found to be lower than two parts per million, the sludge would be reclassified as non-TSCA waste.

Tests were performed and the status of the sludge was reclassified. The project was completed on schedule and significantly below the original estimate, resulting in a substantial saving for the client.