Braun Intertec provided environmental and waste disposition support at one of North America’s largest petroleum bulk storage terminals, in the aftermath of a catastrophic fire at the facility which required creation of a Unified Command and, as a consequence, obligations under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Emergency responders used over 2,000 Intermediate Bulk Containers (IBC totes) and 55-gallon polymer drums of firefighting foam containing per- and polyfluoroalkyl substances (PFAS) to extinguish and continuously suppress reignition of the fire.
Wastes generated during response action were regulated under both CERCLA and the Resource Conservation and Recovery Act (RCRA). IBC totes and drums were triple rinsed and associated liquids were temporarily stored in frac tanks, pending disposal. RCRA waste determinations were performed before liquids were ultimately disposed of at a CERCLA-approved wastewater treatment plant (WWTP). Activities were performed under the direct oversight of the U.S. Environmental Protection Agency (EPA) and Texas Commission on Environmental Quality (TCEQ).
Braun Intertec was retained to perform waste determination, classification, negotiation, and disposal of incident-related waste from the fire which consumed an entire tank farm at the bulk storage terminal facility. As part of waste-related activities, 1,586 (275-gallon) IBC totes and 680 (55-gallon) polymer drums that contained different mixtures of PFAS firefighting foam required disposal. Though not regulated under RCRA, firefighting foam-related materials were deemed a CERCLA waste and required classification and determination under agreement with the Unified Command. Additionally, state and federal approval was required for final classification and disposition of all fire-related wastes. With regulatory approval, totes and drums were triple-rinsed and associated rinse water was contained on-site.
Waste was classified and characterized, transported under Uniform Waste Manifests, and disposed of as a non-hazardous waste at an off-Site WWTP. IBC totes and polymer drums were recycled and/or reclaimed at a national tote and drum recycler. Residues were carefully managed, as TCEQ regulates PFAS in potable-use groundwater. The EPA has not yet established federal regulatory limits for PFAS in drinking water. The final disposition was approved by EPA and TCEQ and completed by Braun Intertec on time and on budget.
