Need to return call by / at/between and

. Signature: Project No.: 

### 0317.00.005.522 Page 1 of 1

Project Name: 

### TRI20 11 

## CBI?

Yes

No TELEPHONE CALL RECOR D

Incoming

Outgoing Date: 

### 01/22 /13 Time: 

### 9:00 am

pm

Company Name: 

### ExxonMobile ERG Staff Name: 

### Elizabeth Sabol

Contact Name: 

### Stan Labat Contact Phone Number: 

### ( 225) 997

- 7226

General Subject: 

### 2011 TRI Mercury and PAC Discharges



## TOPICS DISCUSSED AND ACTION TAKEN

On January 14, 2013, at 2:45pm, I called Stephanie Cargile, ExxonMobile, and left a message asking her to

return my call. Ms. Cargile returned my ca ll later that day at 5:00pm. I explained I was calling about 2011 TRI

discharges . She took my email address and said that someone from the ExxonMobile environmental group

would contact me.

On January 17, 2013, Stan Labat called me to discuss the 2011 TRI discharges. I provided some background

information and explained that I was calling about two ExxonMobile facilities in Baton Rouge, LA. In order to

discuss the information, I sent Mr. Labat an email with the questions for each ExxonMobile facility

. Addit ionally, we set up a conference call on January 22, 2013 to discuss my questions.

On January 22, 2013, I participated in a call with Mr. Labat, Doug Vanpelt, Meredith Moe, Stephanie Cargile,

and Donna Rea with ExxonMobile. In preparation for the call, M r . Labat provided a handout with answers to

the questions I asked as part of my follow up email (see below for the email communication and the attached

handout).

During the call, we discussed the 2011 TRI mercury discharges from ExxonMobile Refining & Supp ly B at on

Rouge Refinery (70805XXNBT405 0S). The 2011 TRI mercury discharges were estimated from sampling data

(one mercury sample resulted in a detection of 0.022 ppm ). Previously, mercury samples at the facility were all

non

- detect; however, t he Louisiana Department of Environmental Quality (LDEQ) published new

, lower MQLs

for metals as part of the water quality standards

. Based on our discussion, there were no changes made to the

2011 TRI mercury data.

Additionally, we discussed 2011 TRI polycyclic aromatic compound (PAC) discharges from ExxonMobile

Baton Rouge Chemical Plant (70805XXNCH 4999S). The 2011 TRI PAC discharges were estimated from

monthly sampling results. The sampling results provided by ExxonMobile show that all results are nondetect

(se e attached)

. As a result, EPA zeroed the PACs load for ExxonMobile.From: "Labat, Stan N" <stan.n.labat@exxonmobil.com> [mailto:"Labat, Stan N"

<stan.n.labat@exxonmobil.com>]

Sent: Tuesday, January 22, 2013 10:02 AM

To: Elizabeth.Sabol@erg.com; donna.l.rea@exxonmobil.com; doug.j.vanpelt@exxonmobil.com;

jacob.l.talbot@exxonmobil.com; meredith.m.moe@exxonmobil.com;

stephanie.k.cargile@exxonmobil.com

Subject: RE: ExxonMobil

- ERG Call

Follow

- up as requested. Elizabeth re quested additional information on the Refinery Hg analysis.

• The 2011 TRI Hg reported was based on only one wastewater treatment plant effluent sample

• The new analysis method used fir Hg is a 2

- step analysis with EPA 1631E and EPA 16 38

Please let us know if we can be of further assistance.

Stan Labat

Protect Tomorrow. Today.

Baton Rouge SHE

Environmental MultiMedia for BRCP, BRRF & CHRF

4024 Refinery Main Office

Work (225) 977

- 7226

Mobile (225) 200

- 6138

Home (225) 926

- 3413

From: Labat, Stan N

Sent: Tuesday, January 22, 2013 7:36 AM

To: Moe, Meredith M; Talbot, Jacob L; 'Elizabeth Sabol'; Rea, Donna L; Cargile, Stephanie K; Vanpelt,

Doug J

Subject: ExxonMobil

- ERG Call

Attached is a one page handout for our 8 AM call.

Dial

- in information:

1

- 888

- 272

- 5498 Access code

- 9703731

Stan Labat

Protect Tomorrow. Today.

Baton Rouge SHE

Environmental MultiMedia for BRCP, BRRF & CHRF

4024 Refinery Main Office

Work (225) 977

- 7226

Mobile (225) 200

- 6138

Home (225) 926

- 3413----- Original Message

----- From: Elizabeth Sabol<Elizabeth.Sabol@erg.com> [mailto:Elizabeth Sabol<Elizabeth.Sabol@erg.com>]

Sent: Thursday, January 17, 2013 2:51 PM

To: stan.n.labat@exxonmobil.com

Subject: Re: email and phone contacts

Hi Stan,

Thank yo u for your time on the phone earlier today. In preparation for our call next week, I wanted to

clarify about the data verification we are doing. We hope to learn the following:

1. ExxonMobil Refining & Supply Baton Rouge Refinery

- Baton Rouge, LA (7080 5XXNBT4050S):

How did you estimate the 897 pounds of mercury reported in the 2011 TRI? Why is this more than the

2007 through 2011 (2007 = 4 pounds released, 2008

- 2010 = 0 pounds released)? Do you use emission

factors or measured data (or other means) to e stimate releases? Are releases based on any measured

values that were below detection or near the detection limit?

2. ExxonMobil Chemical Baton Rouge Chemical Plant

- Baton Rouge, LA (70805XXNCH4999S): How

did you estimate the 856 pounds of PACs reported in the 2011 TRI? Do you use measured data (or other

means) to estimate releases? What PACs specifically did you detect/measure? Are releases based on any

measured values that were below detection or near the detection limit?

Here are some times that I'm available starting Tuesday, January 22.

(1) Tuesday, January 22 (8 AM EST

- 12:00 PM EST);

(2) Monday, January 28 (All Day until 4:00 PM EST)

(3) Tuesday, January 29 (All Day)

Please let me know if you have any additional questions. I look forward to speaking with you.

Thanks,

Elizabeth

Elizabeth A. Sabol

Environmental Engineer

Eastern Research Group, Inc.

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

elizabeth.sabol@erg.com

Phone:610

- 344

- 0829

## ExxonMobil

- EPA/ERG call to discuss additional requested TRI detail

January 22, 2013

ExxonMobil Refining & Supply Baton Rouge Refinery

– Baton Rouge, LA

(70805XXNBT4050S):

1. How did you estimate the 897 pounds of mercury reported in the 2011 TRI?

LDEQ published new lower MQLs for metals as part of the water quality

standards. To achieve the new MQLs, BRRF had to use a new lab and

analytical method which resulted in a Mercur y detection of 0.022 ppm from

Outfall 001 multiplied by the 001 2011 flow

. Historically, BRRF has shown non

detect for Mercury in all outfalls.

2. Why is this more than the 2007 through 2011 (2007 = 4 pounds released, 2008

- 2010 = 0 pounds released)?

2007 and prior, BRRF found Mercury to be non

- detect in Outfall 001 and used

half the detection limit (0.0002 ppm) to calculate 4 pounds of Mercury.

2008

– 2010, based on sample data and new guidance, BRRF believed Mercury

to be absent from the outfalls an d therefore reported 0 lbs.

3. Do you use emission factors or measured data (or othe r means) to estimate

releases?

Measured data (Outfall 001 gets sampled every 5 years for the NPDES permit

renewal.)

4. Are releases based on any measured values that were below detection or near

the detection limit?

The 897 pounds of Mercury was based on a sample result of 0.022 ppm

mercury from Outfall 001 and the annual discharge from Outfall 001.

ExxonMobil Chemical Baton Rouge Chemical Plant

– Baton Rouge, L A

(70805XXNCH4999S):

1. How did you estimate the 856 pounds of PACs reported in the 2011 TRI?

2. Do you use measured data (or other means) to estimate releases?

3. What PACs specifically did you detect/measure?

4. Are releases based on any measured values that we re below detection or near

the detection limit?