Our client, a custom home builder, came to us after discovering that the five-acre urban, residential lot he had purchased and subdivided was an abandoned tannery waste disposal site. Oregon DEQ had declared the tannery down the road an “orphan” site years earlier when the corporation’s Directors declared insolvency and abandoned the manufacturing site, and the Department had failed to include the forty-year old disposal site in its databases because staff considered the waste to be non-hazardous at the time. The tannery waste contains trivalent chromium, hexavalent chromium, mercury and lead in excess of applicable risk-based concentrations. Environmental Compliance devised an innovative site investigation strategy and obtained approval for an Interim Removal Action Measure (“IRAM”) that resulted in the property being completely cleaned up, allowing the client to sell the lots with new custom homes. At the same time, Environmental Compliance successfully pursued the plant manager who had overseen waste disposal activities, the administratively dissolved “zombie corporation” (represented by its insurer), and even the tannery’s banker (who had taken over management of the tannery when its owners decided to retire) to secure a full recovery of the client’s response costs.