During Fall 2005 a major oil release from a TSCA-regulated PCB transformer (>100,000 ppm PCBs) occurred within the concentrating area of an iron ore processing facility, impacting four (4) levels of interior conveyor lines, flooring, stairways, catwalks, walls, lighting fixtures, piping, cables, electrical components, etc ● ERG worked 24/7 for six (6) continuous months to achieve decontamination of the facility to below TSCA-regulated criteria ● Impacted structures and surfaces were decontaminated to TSCA levels or removed for off-site treatment/ disposal ● Work performance was complicated by winter weather conditions in Northern Michigan, challenging ERG to employ “outside-of-the-box” solutions to complete the complicated project tasks.
Demolition/removal of impacted structures which could not be successfully decontaminated, including conveyor lines, 3’ diameter piping, heavy concrete, and more than 1,000 cubic yards of highly PCB-contaminated soil ● These items, plus wastes generated by decon activities, were transported to Idaho for management as high level TSCA-regulated waste. Dredging of a one (1) mile long trench via drag line and long-reach excavator to facilitate conveyance of water (the portion not re-circulated through the plant) to a processing pond located one (1) mile from the facility. Installation and operation of an on-site 10,000 gpm water treatment system. Replacement (installation) of components that were could not be decontaminated and were removed throughout the four (4) impacted levels of the facility.
Throughout the process, ERG performed continuous confirmatory sampling and analysis in compliance with TSCA-regulated protocols and procedures, including the EPA “Field Manual for Grid Sampling of PCB Spill Sites to Verify Cleanup” ● A final report was compiled, outlining all phases of the work, from initial survey of the impact through disposal and completion of final grid sampling ● The work was performed under the direct supervision of ERG’s CEO, Executive VicePresident, Vice-President, and Health and Safety Officer to ensure the work was performed in strict compliance with NREPA, RCRA, TSCA, MSHA, DOT, and associated regulations and protocols.