Braun Intertec provided comprehensive on-Scene support for an emergency Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) response at a petroleum bulk storage terminal following a catastrophic fire. Fire suppression and response activities generated an unprecedented volume of CERCLA- and Resource Conservation and Recovery Act (RCRA)-regulated waste, including 170 hazardous and non-hazardous solid waste roll-off boxes; 8.8 million pounds of scrap metal; 25 million gallons of hazardous aqueous liquids; 20 million gallons of hazardous non-aqueous liquids; 1,568 intermediate bulk containers (IBCs); 680 polymer drums; 3,300 cubic yards of impacted hard containment boom deployed in the adjacent marine waterway; and 100,000+ cubic yards of affected soil removed as part of remediation activities. These materials were impacted by per- and polyfluoroalkyl substances (PFAS), volatile organic compounds (VOCs), total petroleum hydrocarbons (TPH), and RCRA metals. Aqueous film forming foam (AFFF) containing PFAS was necessarily applied to extinguish the fire and prevent re-ignition. When the containment berm surrounding the tank farm was breached, a release of product (bulk chemical/fuel) and fire-suppression liquids entered a nearby waterway, triggering a CERCLA response and requiring waste management actions beyond standard RCRA requirements.

Braun Intertec developed, negotiated, and implemented the waste sampling and analysis plan with the Unified Command, which included the U.S. Environmental Protection Agency (EPA; federal on-scene coordinator), Texas Commission on Environmental Quality (TCEQ; state on-scene coordinator), and the facility representative. Braun Intertec provided waste sampling, characterization, staging, classification, determination, transportation, and disposal for all incident-related materials. More than 50 RCRA waste determinations were completed, and the facility’s Notice of Registration was updated to reflect applicable RCRA classifications. Non-RCRA regulated contaminants, including PFAS, were managed as CERCLA wastes and required Unified Command approval for characterization and disposal. Braun Intertec successfully negotiated sampling protocols, waste classifications, and secured state and federal approval for disposal/recycling outlets for both hazardous and non-hazardous materials, including recycling of rinsed scrap metal, IBCs, drums, and disposal of firefighting-impacted waters, organic liquids, and contaminated hard boom at approved RCRA- and CERCLA-regulated facilities. Associated wastes were transported by truck, rail, barge, and pipeline. Despite regulatory uncertainty surrounding PFAS and the scale of the response, Braun Intertec effectively coordinated regulatory approvals, disposal logistics, and pricing, supporting compliant and timely waste management for one of the largest emergency response cleanups in the region, all of which was documented in the associated report produced by Braun Intertec for the EPA.