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DELISTING PETITION OF EXXONMOBIL REFINING & 

SUPPLY COMPANY 

PART 1: DELISTING ADMINISTRATIVE INFORMATION 

1. Name of Petitioner. 

a. Name of individual or firm sending petition: 

ExxonMobil Refining & Supply Company (Exxon Mobil) Baytown Refinery (BTRF) 

 

b. Mailing address of individual or firm: 

Street/P.O. Box: 5000 Bayway Drive 

City: Baytown 

State: Texas Zip Code: 77520 

Telephone No.: 281-834-3300 

Fax No.: 281-834-5788 

2. People to Contact for Additional Information Pertaining to this Petition. 

a. Name: 

Amy E. Climo 

b. Title: 

Baytown Refinery Waste and Water Section Supervisor 

c. Company: 

ExxonMobil Refining & Supply Company Baytown Refinery 

d. Telephone No.: 

281-834-0100 

e. Mailing address: 

Same as petitioner 
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f. Name: 

Peter J. Gagnon, P.E., BCEE 

g. Title: 

Associate 

h. Company: 

Environmental Resources Management (ERM) 

i. Telephone No.: 

(281) 600-1044 

j. Mailing address: 

Street/P.O. Box: 15810 Park Ten Place, Suite 300 

City: Houston 

State: Texas Zip Code: 77084 

3. Facility Responsible for Generating Petitioned Waste. 

a. Name of facility: 

ExxonMobil Refining & Supply Company, Baytown Refinery (BTRF) 

b. Location of facility: 

Street/P.O. Box: 5000 Bayway Drive 

City: Baytown 

State: Texas Zip Code: 77520 

c. RCRA ID/EPA ID number: 

RCRA ID: HW-50111-000 

EPA ID: TXD000782698 

4. Location of Petitioned Waste. 

Same as facility name and address given in item 3 

5. Describe the proposed delisting action. 

Exxon Mobil requests a conditional delisting for the underflow water generated at the North 

Landfarm (NLF) at the Baytown, Texas refinery, shown in Figure 1. Figure 2 is a plot plan of 

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PART 2: DELISTING WASTE AND WASTE MANAGEMENT INFORMATION 

BASIS FOR THE WASTE LISTING 

1. Scenario that best describes the petitioned waste. 

a. Petitioned waste is not a mixture of two or more listed hazardous wastes. 

b. Common name of petitioned waste: 

Underflow water 

c. EPA Hazardous Waste Number: 

F039 

d. Hazardous waste description: 

Per the definition provided in 40 CFR 261.31, an F039 listed hazardous waste is a liquid 

that has percolated through the soils contaminated with more than one listed hazardous 

waste listed in Subpart D of 40 CFR 261. The NLF receives various hazardous waste 

streams from the BTRF. The NLF underflow is an aqueous solution which seeps through 

the treatment zone (soils) of the NLF, making it an F039 waste stream by definition. The 

underflow is collected and removed by the underflow management system to reduce the 

potential for downward migration of underflow water through the base of the NLF. 

2. Describe the physical form of the petitioned waste (e.g., solid, liquid). 

Liquid 

3. If the physical form is sludge or liquid, estimate based on waste analysis the percentage 

of solids (e.g., provide a range). 

Total Suspended Solids: 1.3 mg/L – 30.0 mg/L based on sampling of the NLF underflow water as 

required by the Waste Analysis Plan of the ExxonMobil Resource Conservation and Recovery 

Act (RCRA) Permit (HW-50111-000). 

HISTORY OF WASTE GENERATION

4. Generation of the petitioned waste. 

a. Waste has been generated in the past. 

Provide the year when waste was first generated: 1989 

b. Waste is presently being generated. 

Provide the year when waste was first generated: 1989 
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c. Waste will be generated in the future. 

The waste will continue to be generated while the NLF is operational and during closure 

and post-closure of the NLF. 

VOLUME OF PETITIONED WASTE 

5. Is the petition for a waste of fixed quantity (e.g., a discrete volume of waste contained in 

a unit)? 

No 

a. Petitioned waste is/will be generated on a routine or continuous basis. 

 Average 

Quantity 

Maximum 

Quantity 

Unit of 

Measurement

Monthly Volume 53,200 125,000 gallons 

Annual Volume 638,800 1,500,000 gallons 

b. Describe the method of volume estimation. 

The volume estimation is based on historical generation (2002–2008) of waste and 

estimated future generation amounts.

HISTORY OF WASTE MANAGEMENT 

6. As appropriate, describe the present, past, and proposed waste management methods 

for the petitioned waste. 

a. Present waste management methods, and off-site facility or facilities used (name, 

address, and waste management method). 

Underflow is generated at the NLF by the downward migration of irrigation water, 

rainwater, and wastes applied to the NLF through the treatment zone. 

The amount of water which seeps through the treatment zone is a function of the 

transmissivity of the soils of the treatment zones and the amount of water applied to the 

NLF plots. During periods of relative dryness within the treatment zone, water exists in 

the soils tightly bound to the soil particles. During these dry periods seepage is minimal. 

When free water is available within the treatment zone, seepage proceeds at slow 

velocities. The base of the NLF is made up of clays that are compacted to produce a 

permeability of approximately 2 x 10-7 cm/s (1.7 in/day) in order to reduce seepage 

through the base layer.
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At the base of the sand layers of the NLF’s perched bed system is an underflow collection 

system. The underflow collection system collects liquids which seep through the 

treatment zone. A cross section of the NLF’s perched-bed system design feature is 

provided in Figure 3. The collection system consists of approximately 70 two-inch 

diameter perimeter lateral HDPE pipes, 50 feet apart, which slope at 1% grade into a six 

inch diameter collector system. The collector system is sloped at a 0.18% grade to carry 

fluids to the underflow collection sump which is located on the eastern side of the NLF’s 

perimeter berm. The lateral (two inch) pipes are perforated to accept the drainage and are 

wrapped with a geotextile designed to filter out fine soil particles from entering the pipes. 

The pipes are also fitted with a cleanout access. A cross-sectional view and plan view of 

the collection system are provided in Figures 4 and 5, respectively. 

The underflow collection sump is constructed of reinforced-concrete, approximately six 

feet in diameter and approximately 15 feet in height. The sump is equipped with a pump 

system that is activated by a level control switch to remove the underflow as it 

accumulates. The underflow is stored in frac tanks or Tank 102 (Figure 2) and reapplied 

to the NLF (while it remains active) via an irrigation system. Tank 102 can hold 

approximately 190,000 gallons of underflow water. In the rare event that the NLF is too 

wet for reapplication, the underflow can be transported off site for disposal. In the event 

of equipment failure at the underflow sump, the underflow would continue to accumulate 

in the underflow collection sump. To prevent overflow from the system, the walls of the 

sump extend well above the natural grade at the sump. The underflow would, therefore, 

back up in the collection system and drainage layer rather than overtop the sump. If 

needed, the collection system can be evacuated using temporary pumps or vacuum tanks. 

If needed, the collection system can be evacuated using temporary pumps or vacuum 

trucks and pumped to Tank 102 or frac tanks and then used as irrigation water or sent 

off-site for disposal. 

b. Past waste management methods, if different from present, and off-site facility or 

facilities used (name, address, and waste management method). 

Waste management methods have remained the same since operations began at the NLF. 

c. Proposed waste management methods if delisting petition is granted, and off-site 

facility or facilities to be used (name, address, and waste management method). 

The proposed waste management for the underflow water while the NLF is active is to 

collect the underflow water in the underflow sump and reapply it to the NLF as 

irrigation water as described above in Section 6.a.

In the future, ExxonMobil will pursue closure of the NLF. During the closure and postclosure periods, waste will no longer be applied to the NLF surface (including applying 

underflow as irrigation water). Therefore, the underflow water will need to be managed 

by another method. 

During the closure and post-closure periods of the NLF, ExxonMobil plans to treat and manage NLF 

underflow water by routing it through the BTRF waste water treatment system (WWTS). The underflow 

will continue to be collected by the underflow collection system and accumulated in Tank 102. When the 

water level in Tank 102 reaches a predetermined level, a sample of the water will be collected and 

analyzed for target constituents. Once analytical results indicate that target constituent concentrations 
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are less than target concentrations (established during the delisting process), the water in Tank 102 will 

be routed to a series of open drainage ditches to the underground BTRF East Sewer via a series of open

ditches and culverts where it is commingled with process unit wastewaters. This process of management

of water in Tank 102 will continue until the date of closure of the North Landfarm and for thirty-six 

months (three years) post closure. After that, the facility may either: (1) continue to accumulate the

underflow water in Tank 102, sample the water once each calendar year, analyze the annual sample for 

target constituents and submit the results to the EPA for review, or (2) route the underflow to the 

underflow collection system and then to the series of ditches to the underground BTRF East sewer. In the 

latter case, samples of the underflow water would be collected from the underflow sump once each 

calendar year, analyzed for target constituents and the results submitted to the EPA for review. 

Ultimately, the underflow will enter the WWTS where it is commingled with other wastewaters from the 

Baytown Chemical Plant and Baytown Olefins Plant. Figure 6 illustrates the route of underflow water 

through the BTRF to the WWTS. 

At the WWTS, the commingled wastewater is first sent through one of three oil-water preseparators that

operate in parallel. These separators skim off free oil for reprocessing and settled sludge is removed 

periodically for dewatering and processing at our delayed coker. After the preseparators, the wastewater 

travels through the stormwater diversion box, through a lift station, and then to API Separator 12. Oil 

skimming and removal of settled sludge also occurs in this unit. The effluent from the API Separator 

flows to the Wastewater Oxidation Unit (WOU) where biological treatment begins. The biologicallytreated effluent is piped to a 300+ acre series of stabilization lagoons for additional polishing prior to 

discharge to the Houston Ship Channel via permitted Outfall 001. Up to 4 million gallons per day 

(MGD) of the treated wastewater in the stabilization lagoons is recycled to the BTRF for firewater and

process unit cleaning. The effluent limitations for Outfall 001 from the TPDES permit are provided in 

Table 1.

 

 
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PART 3: DELISTING PROCESS INFORMATION 

GENERAL OPERATIONS AT THE REFINERY 

1. Describe facility business area(s) and operations. Include SIC code(s). 

The ExxonMobil Baytown Refinery (BTRF) processes crude oil in the production of a number of 

petroleum products, including fuels, solvents, and chemical feedstocks. The SIC for the BTRF is

2911-Petroleum Refining. 

 

2. List and describe products manufactured at the facility. 

The BTRF employs a number of petroleum processing steps to produce the following principle 

products: motor gasoline, jet fuel, kerosene, heating oil, diesel oil, regular and low-sulfur fuel oils, 

asphalt, coke, solvents, lubricating oils, and chemical feedstock (olefins and aromatics). 

 

3. List and describe all wastes (including all hazardous wastes) generated at the facility. 

See Table 2. 

4. Describe your manufacturing and waste treatment areas and waste management units. 

Attach schematics showing the layout of the facility. 

There are five permitted waste management units at the BTRF. As-generated hazardous and 

nonhazardous wastes are managed at the NLF and Tank 102. Remediation wastes that meet land 

disposal restriction (LDR) standards are managed at the NLF. Surface impoundments 

(Wastewater Oxidation Unit (WOU), Upper Outfall Canal (UOC), Retention Basin 1 (RB1), 

and the Lower Outfall Canal (LOC)) manage only nonhazardous wastewaters and sludges under 

delay-of-closure. The location of these waste management units is shown in Figure 1. Wastes are 

also transported to off-site facilities for disposal. 

 

5. Describe the regulatory status of all on-site waste treatment, storage, and disposal units. 

Include a list of all hazardous waste permits and other permits issued under Federal and 

State environmental statutes. Include the permit numbers in this list. 

See Table 3 for a summary of on-site permitted waste management units. 

See Table 4 for a summary Federal and State permits maintained by the BTRF. 
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CONTRIBUTING MANUFACTURING PROCESSES 

6. Describe and include schematics of all “pre-process” steps used to prepare materials for 

processing before primary manufacturing operations, including surface and equipment 

preparation operations. Identify all pre-process material inputs and outputs in your 

description and schematics. 

The NLF does not prepare or process materials. The NLF receives waste generated at the BTRF. 

These wastes are listed in Table 5.

7. Provide a step-by-step description and schematic of each manufacturing process 

contributing to the petitioned waste. Include each process step, reactions occurring, 

flow rates, and material inputs and outputs, as well as reaction intermediates and 

byproducts. Identify and describe waste inputs and outputs on the schematic(s) and 

show how each waste is managed. 

Downward migration of irrigation water and rain water and moisture from waste applied to the 

surface is the only process at the NLF that contributes to the generation of the underflow water. 

The amount of water which seeps through the treatment zone is a function of the transmissivity 

of the treatment zone soils and the amount of water and waste applied to the NLF plots. Water 

that seeps through the treatment zone is collected as underflow water in the underflow sump. 

This process is illustrated in Figure 3. 

A cross section of the NLF’s perched-bed system design feature is provided in Figure 3. The 

system consists of a three foot thick soil zone composed of clayey soils with a high cation exchange 

capacity and compacted to a permeability of approximately 5 x 10-5 cm/sec. The top foot of this 

three foot zone is tilled and receives the applied wastes. The bottom two feet of this zone controls 

vertical migration of water and provides a long residence time for water which may pass 

vertically through the treatment zone. Beneath the three foot thick soil zone is a drainage layer 

consisting of approximately one foot of relatively permeable sand, with 8 x 10-3 cm/sec average 

permeability. At the base of the sand is an underflow collection piping system (described in 

Section 6.a). Underlying the drainage layer is an imported compacted clay layer of 

approximately one foot thickness and a permeability of approximately 1 x 10-7 cm/sec. 

Underlying the imported clay is 11 feet or more of native clay soils with an average permeability 

of approximately 5 x 10-7 cm/sec. During construction of the NLF, these soils were exposed by 

removal of overlying topsoils or debris, and the top foot was carefully recompacted to compensate 

for any disruption. 

8. Describe, and identify on the schematic, exactly where the petitioned waste is generated 

(if generated by a manufacturing process). 

The petitioned waste is generated by downward vertical migration of liquid through the NLF. 

The underflow is transported by the collection system to the NLF underflow sump which is the 

point of waste generation. Figures 2 and 5 illustrate the location of the sump. 

 
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9. List and describe all process equipment, including the function of each unit and the 

ranges of the operating parameters. 

In addition to the NLF’s active plots, the underflow collection system, and underflow sump the 

NLF also includes ancillary equipment and structures (to the east of the land treatment area) as 

illustrated on Figures 2 and 5. The ancillary equipment and structures include a control 

building, holding pads for solids, roads, parking areas, the Tank 102 system, and the entry 

control gate. The land treatment surface, as well as these ancillary equipment and structures, are 

surrounded by a six foot high chain link fence. 

The control building provides a location for personnel to complete administrative functions and 

operations monitoring. Located outside and immediately west of the control building is a boot 

wash station. The truck wash rack is used to decontaminate vehicles prior to leaving the landfarm 

treatment area, and it consists of a concrete foundation and catch basin to collect wash waters. 

Above this catch basin is metal grating over structural steel supports. Trucks drive onto the 

wash rack for cleaning and rinse waters are collected in the concrete catch basin. The catch basin 

is constructed of 12-inch thick reinforced concrete and has inside dimensions of 40 feet x 12 feet 

wide x 4 feet deep. A collection sump is located outside the run-off control berms of the NLF near 

Tank 102 (Figure 2). This sump, which is prefabricated double-walled high-density polyethylene 

(HDPE) tank, is used to collect (via gravity) potentially contaminated water from the Tank 102 

containment area, the sludge transfer pump area, the truck unloading area catch basins, the truck 

wash rack, and the control building boot wash station and drains. The sump is automatically 

emptied, as needed, by pumping the water into Tank 102. 

Six concrete solids holding pads, attached to the spine road of the NLF, are used to temporarily 

store solid waste during periods when the landfarm is unable to receive waste. These pads are 10 

feet x 20 feet and are located on either side of the spine road and indicated on Figures 2 and 5. 

 

10. Describe all of your operating cycles (batch cycles, versus continuous operation, startup, shut-down, maintenance, cleaning) on a daily, weekly, or other period basis, as 

appropriate. Identify periods when process wastes are not generated (e.g., plant 

shutdowns or routine equipment maintenance). 

See Table 6 for a description of the NLF underflow generation contributing process. 

 

11. Assess the extent that all contributing manufacturing processes, operations, process 

materials, or generated wastes have varied in the past or may vary in the future. 

The NLF contributing processes, operations, or process materials have not varied in the past. The 

wastes applied to the NLF are regulated by BTRF RCRA Permit (Table 5) and are not expected to 

vary in the foreseeable future. Closure of the NLF will be pursued at a later date. After closure of 

the NLF, waste will no longer be applied to the landfarm and the only contributing process to the 

generation of underflow water will be rain and fire water (as irrigation water) migrating 

vertically downward through the NLF soils. 
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12. Describe how the composition and generation rate of the petitioned waste may 

periodically vary due to any aspect of manufacturing process variability. 

The composition of the petitioned waste will not vary beyond the parameters specified in the 

attached sampling data. The generation rate is likely to vary with the amount of rainfall and 

waste from the BTRF received each month; however, the petitioned waste is not expected to exceed 

the volume specified in Part 2, Section 5.a. 

 

13. Does a waste treatment process contribute to the petitioned waste? 

No 

CONTRIBUTING WASTE TREATMENT PROCESSES 

14. Provide a step-by-step description and schematic of each waste treatment process 

contributing to the petitioned waste. Include process steps, reactions occurring, flow 

rates, material inputs, and waste inputs and outputs. 

Not Applicable. The NLF does not have a waste treatment process that contributes to the 

petitioned waste. The petitioned waste is generated by vertical migration of wastes applied, rain 

water, or irrigation water through the NLF. 

15. Describe, and identify on the schematic, exactly where the petitioned waste is generated 

(if applicable). 

The petitioned waste is generated by rain water or irrigation water migrating vertically through 

the treatment zone creating underflow water which collects in the underflow sump (see Figure 2 

and 5). Therefore the sump is considered the point of generation. 

16. Identify and describe waste inputs and outputs on the schematic(s) and show how each 

waste is managed. 

On average, 53,233 gallons of NLF petitioned waste is generated monthly by rain water, 

irrigation water, or application of wastes from the refinery. The petitioned waste can be stored in 

a holding tank (Tank 102), which can hold approximately 190,000 gallons. The petitioned waste 

is currently redistributed on the NLF as irrigation water to maintain a specified moisture level as 

required to promote microbial activity. 

17. Describe all non-process wastes entering the waste treatment processes, including 

composition, rate of inputs, and source. 

Not Applicable. See Table 5 for wastes applied to the NLF. 

 

18. List and describe all process equipment, including the function of each unit and the 

ranges of the operating parameters. 

Not Applicable. The NLF does not have any process equipment. 
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19. Describe all of your operating cycles (batch cycles versus continuous operation, start-up, 

shut-down, maintenance, cleaning) on a daily, weekly, or other period basis, as 

appropriate. Identify periods when treatment wastes are not generated (e.g., plant 

shutdowns or routine equipment maintenance). 

See Table 6 for a description of the NLF underflow generation contributing process. 

20. Assess the extent that all contributing treatment processes, operations, process materials, 

or generated wastes have varied in the past or may vary in the future. 

Not Applicable. The NLF does not have a contributing treatment process, operations, or process 

materials. 

21. Describe how the composition and generation rate of the petitioned waste may 

periodically vary due to any aspect of treatment process variability. 

The petitioned waste will not vary beyond the parameters specified in the attached sampling data. 

The generation rate varies with the amount of rainfall and waste applied per month, but will not 

exceed the volume specified in Part 2, Section 5.a. 

22. Has the petitioned waste been managed in a land-based unit? 

Yes, as irrigation water. 

PROCESS MATERIALS 

23. List all materials used in the operations that contribute to the petitioned waste. The list 

should include: 

a. The name of the material(s). 

Rain water, irrigation water (underflow water and fire water), and moisture from the 

waste applied to the NLF contribute to the petitioned waste. Wastes applied to the NLF 

also contribute to the composition of the underflow water. Table 5 provides a description 

of the wastes applied to the NLF. 

 

b. The process/operation in which it is used (i.e., manufacturing process, treatment 

process, waste management operations). 

Not Applicable. 

c. Function of each material in the process. 

The function of the waste applied to the NLF is for disposal. The rain water and 

underflow water functions to maintain a moisture content sufficient to promote an active 

microbial community. 
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d. Approximate annual quantities used. 

The annual quantities of waste used to create the underflow water is a function of the 

amount of rainfall, irrigation water, and waste received each month. 

 

24. Provide Material Safety Data Sheets (MSDS) and any other compositional information 

for trade name and non-elemental materials. Include raw materials, cleaners, oils, 

solvents, strippers and any by-products generated by the process. 

See Table 5. 

25. Specify the source, quality (i.e., recycled or virgin), and quantity of oil, grease, and 

hydraulic fluids entering the process. 

None 

SPECIAL INFORMATION 

26. Are you requesting an upfront exclusion for a waste that is not currently generated but 

will be in the future? 

No 

27. Are you requesting an exclusion for a waste generated by a multiple waste treatment 

facility (MWTF)? 

No 
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PART 4: DELISTING ANALYTICAL PLAN DEVELOPMENT 

1. Provide a complete list of the constituents and parameters of concern identified for your 

petitioned waste based on appropriate waste constituent analyses and the results of an 

engineering analysis. Identify those constituents quantitated by laboratory analysis and 

those quantitated using mass balance demonstrations. 

A review of historical analytical data of the petitioned waste, beginning in May 2002, was 

utilized to help determine which constituents have been of concern at the NLF. The constituents 

of concern (COCs) with historical concentrations greater than detection limits were used to help 

create the final list of COCs. 

An initial sample of the petitioned waste was collected on January 2009 and analyzed for total 

concentration of the full list of constituents for which F039 is a listed hazardous waste, provided 

in 40 CFR Part 261, Appendix VII. The final list of COCs for the petitioned waste was 

established to include those constituents reported at concentrations greater than the detection 

limit in this sampling event as well as historical detections at the NLF. This process was 

discussed in the sampling and analysis plan (SAP, included as Attachment 1). 

The final list of COCs is included in Table 7, as well as the reason the COC remained on the list. 

The analytical results from historical sampling events can be found in Attachment 8 of the SAP 

(included as Attachment 1). 

2. Provide mass balance demonstrations for those constituents of concern in your list for 

which analyses were not conducted. Provide all calculations and assumptions. 

Not applicable. Laboratory analyses were conducted to identify COCs. 

3. Explain why any other delisting constituent of concern is not on the constituent of 

concern list for your petitioned waste. 

Not Applicable. The final list of COCs for the petitioned waste was established to include those 

constituents reported at concentrations greater than the detection limit in current and historical 

sampling events historical detections at the NLF. 

4. Explain why your petitioned waste does not exhibit any hazardous waste characteristic 

for which analysis was not conducted. 

Laboratory analyses were conducted for hazardous waste characteristics and the petitioned waste 

did not exhibit any hazardous waste characteristics. 
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PART 5: DELISTING SAMPLE AND ANALYSIS INFORMATION 

1. Has a draft sampling and analysis plan been submitted to EPA for review before 

petition preparation? 

Yes The SAP and Quality Assurance Project Plan (QAPP) were submitted to the 

Environmental Protection Agency (EPA) on December 16, 2009 and approved 

on January 14, 2010. These documents have been included as Attachment 1 and 

2, respectively. 

a. Submittal date of sampling and analysis plan: 12/16/2009

b. Log number assigned by EPA to your draft submittal: Not Applicable. 

WASTE SAMPLING INFORMATION 

2. Were all sampling-related activities performed by in-house staff? 

Yes 

a. For each individual person (in-house and otherwise) who designed the sampling 

plan, the quality control plan, and/or participated in sample collection, please 

provide a resume of qualifications and the following information: 

Name: Peter J. Gagnon, P.E., BCEE 

Affiliation: Environmental Resources Management (consultant for ExxonMobil 

Refining & Supply Company) 

Title: Associate 

Name: Tracy L. Jackson P.E. 

Affiliation: Environmental Resources Management (consultant for ExxonMobil 

Refining and Supply Company) 

Title: Project Manager 

Name: Sassan Mouri 

Affiliation: Environmental Resources Management (consultant for ExxonMobil 

Refining & Supply Company) 

Title: Staff Geologist 
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SAMPLING STRATEGY 

3. Provide the following information (items 3a through 3f) on the sampling strategy you 

followed to make sure that the samples were representative. 

a. Identify which process point discharges, containment areas (e.g., lagoons), or 

other areas (e.g., soil) were sampled and why these areas were selected for 

sample collection. 

The petitioned waste is generated by downward vertical filtration of liquid through the 

NLF. This liquid is ultimately collected in the underflow sump. Samples were collected 

from the underflow sump. 

b. Describe the techniques and guidelines used to select waste sampling points 

(e.g., random sampling procedure or fixed transect and offset sampling 

procedure). 

Because the underflow water accumulates at the underflow sump, there is no spatial 

variability within the petitioned waste. All samples collected for this petition were 

collected at the underflow sump. 

c. Describe the sampling and subsampling (i.e., transferring of sample aliquots into 

containers specific to certain analyses) procedures used during the sample 

collection process, including the particular days and times selected for sample 

collection, the number of grab samples collected for each composite sample, and 

why these procedures were used. 

The potential temporal variability in the underflow water was addressed through a 

variation in sampling frequency, thus representing a range in possible constituent 

concentrations with time. The NLF operates continually, so temporal variability was 

characterized by collecting five samples of underflow water at a frequency of once every 

two weeks. 

The samples of underflow water were collected using a disposable plastic bailer. The 

disposable bailer was tied off to a rope that was lowered into the sump until the bailer was 

filled with underflow water. Once the bailer was full, it was raised to the surface where 

sample bottles were filled by pouring underflow water from the bailer into the sample 

bottles. This procedure was repeated until the necessary number of sample bottles were 

filled to analyze for constituents of concern COC. The samples bottles were placed in a 

cooler with sufficient ice to maintain a temperature of approximately 4°C and 

transported to the ALS Laboratory in Houston, Texas for analysis. Each sample bottle 

label included a unique sample identification, the time and date sampled, the parameters 

to be analyzed, the preservatives (if any), and the sampler’s initials. 

The sample identification numbers for each sampling effort were recorded on sample 

labels and chain-of-custody forms and the other applicable documentation used during 

the sampling activity. 
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These procedures were used because they provide objective and useable results for 

evaluation. 

d. Describe the sampling devices used for sample collection and the basis for 

selecting the devices. 

Samples were collected using a disposable plastic bailer. A disposable bailer was selected 

in order to protect the integrity of samples. 

e. Identify and discuss any deviations from your original sampling plan and 

strategy and the impact of these deviations on waste characterization. 

Not Applicable. There were no deviations from the SAP. 

f. Explain why you believe the samples collected are non-biased and sufficiently 

represent the petitioned waste. In this explanation, fully address the potential 

for waste uniformity or spatial and temporal variability and how the strategy 

ensured collection of representative samples. 

The SAP meets the requirements of non-biased representation of the underflow water due 

to the number of samples collected, temporal variability, quality assurance, and the 

comprehensive analytical analysis of the samples. 

The NLF operates continually and the petitioned underflow water is continuously 

collected at the underflow sump. The strategy to address temporal variability involved 

collecting five samples at two week intervals to encompass five time periods to address 

temporal variability. Spatial variability was not a factor since underflow water collects in 

one location at the NLF. The strategy was designed to address temporal variability by 

collecting and analyzing samples that represent a range of possible constituent 

concentrations with time. 

A review of the results shown on Table 8 indicates that a relatively consistent range of 

concentrations was reported. The quality control samples in the form of duplicate 

samples, matrix spikes and matrix spike duplicates meet the data useability requirements. 

SAMPLE SPECIFIC INFORMATION 

4. How many samples of the petitioned waste were collected? 

One initial characterization sample was collected in January 2009 followed by five additional 

samples beginning in February 2010. In addition to those samples, one duplicate sample, one 

matrix spike and one matrix spike duplicate were collected. 

An initial sample of the petitioned waste was collected in January 2009 and analyzed for total 

concentration of the full list of constituents for which F039 is a listed hazardous waste provided 

in 40 CFR Part 261, Appendix VII. The final list of COCs for the petitioned waste was 

established to include those constituents reported at concentrations greater than the detection 
Texas Registered Engineering Firm F-2393 18 G:\2010\0102974\15096H Delisting Petition.doc 

limit in previous sampling events at the NLF. The five samples collected for the purpose of this 

petition were analyzed for the COCs on the final list. 

Is the number of samples taken different from the number of samples agreed upon 

during the pre-petition scoping meeting? 

Explain the deviation. 

The number of samples collected is as agreed upon during the pre-petition scoping meeting 

between EPA, ERM, and ExxonMobil on October 8, 2009 and as presented and approved in the 

SAP. 

5. For each individual sample collected, please provide the following sample-specific 

information (items 5a through 5g). 

a. For each sample included in item 4, provide the sample identification number (as 

it appears in your field logbook and other records), the date that the sample was 

taken, an indication as to what type of sample it is (waste sample versus quality 

control sample and whether or not it is a composite sample). 

Type of Sample 

[Mark one box only] 

Sample 

Identification 

Number 

Date 

Sample 

Was Taken 

Waste 

Sample 

Quality 

Control 

Sample 

Composite Sample

 Yes No 

UF011409 01/14/2009   

Underflow Delisting - 01 02/02/2010   

Underflow Delisting – 02 03/22/2010   

Duplicate – 01 03/22/2010   

Underflow Delisting – 02 

(MS/MSD) 

03/22/2010   

Underflow Delisting – 03 04/20/2010   

Underflow Delisting – 04 05/03/2010   

Duplicate – 02 05/03/2010   

Underflow Delisting – 05 05/18/2010   

b. Describe how each sample was collected, and its point of collection from the 

petitioned waste. If a sample is a composite of grabs, provide the number of 

grab samples collected for the composite sample, the sampling location for each 

grab sample, the volume of each grab sample, and the volume of the composite 

sample. 

The petitioned waste was collected from the underflow sump at the NLF for each 

sampling event. Each sample was a grab sample of approximately six liters. 

 
Texas Registered Engineering Firm F-2393 19 G:\2010\0102974\15096H Delisting Petition.doc 

c. Describe the general sampling location (e.g., which quadrant of a surface 

impoundment) and the specific sampling points (e.g., specific location in the 

quadrant). You may refer to numbered sampling points shown in a diagram. 

The petitioned waste was collected from the underflow sump at the NLF. The underflow 

sump is approximately 14 ft. in depth by 4.5 ft. in diameter and has a total capacity of 

1,665 gal. The petitioned waste was sampled from the center of the sump each time.

d. Describe how each sample was composited (e.g., equipment used and manner of 

mixing). 

Each sample was a grab sample. Samples were collected by directly pouring the 

underflow water from the bailer into the sample bottles. 

e. Provide a physical description of each sample at time of collection (e.g., color, 

odor, whether phase separation occurred soon after collection). 

The underflow water is clear with a low turbidity. Odors emanating from the underflow 

were not noted during sampling. 

f. For each composite sample, specify the time and date when the grab samples 

were collected and the time and date when the sample was composited, as 

applicable. 

Not Applicable. 

g. Describe the handling and preparation techniques used for each sample 

(including types of containers used and techniques employed for container 

preparation) and types and amounts of preservatives used. 

New laboratory supplied glass and plastic containers were used to collect the samples. 

Various preservatives were used provided in the bottles by the laboratory, as appropriate 

for the analytical method. The table below describes the preservatives used in each of the 

analyses. 

Preservatives used in Analytical Methods 

Method Preservative 

Volatile Organics Hydrochloric Acid 

Total Cyanide Sodium Hydroxide 

Sulfide Zinc Acetate and Sodium 

Hydroxide 

Phosphorus Sulfuric Acid 

Total Metals Nitric Acid 

Herbicides, Pesticides, Semivolatiles, 

Dioxins, Furans, Hexavalent Chromium, 

and Misc Analysis 

Neat (i.e., no preservative) 

 
Texas Registered Engineering Firm F-2393 20 G:\2010\0102974\15096H Delisting Petition.doc 

OTHER GENERAL INFORMATION 

6. Describe the weather conditions during sampling (if conducted outdoors). 

February 2, 2010: Sunny, 57 degrees F 

March 22, 2010: Sunny, 68 degrees F 

April 20, 2010: Sunny, 77 degrees F 

May 3, 2010: Sunny, 91 degrees F 

May 18, 2010: Sunny, 88 degrees F 

. 

7. Describe any facility activities separate from sampling that occurred at the same time 

and might have affected sample representativeness. 

None 

8. Describe sampling device decontamination; and note when disposable devices were 

used for sample collection. 

New, disposable sampling devices were used in each sampling event. 

9. Were the chain-of-custody procedures specified in SW-846 followed? 

 Yes [Skip to item 11]

 No [Continue with item 10] 

10. Provide a description of the quality control procedures and documentation system used 

to track sample location and maintain sample integrity during transportation to the 

laboratory. Copies of the chain-of-custody forms may be provided, but are not needed. 

Not Applicable. 

LOCALIZED AREA OF CONTAMINATION 

11. Have you collected samples to characterize a localized area of contamination (a “hot 

spot”) within the petitioned waste? 

 Yes [Continue with item 12] 

 No [Skip to item 16]

12. Discuss your basis for believing a hot spot may or does exist (e.g., records of a one-time 

discharge of a concentrated material at a specific location). 

Not Applicable. 
Texas Registered Engineering Firm F-2393 21 G:\2010\0102974\15096H Delisting Petition.doc 

13. Describe the known or predicted location (on a diagram) and the dimensions (e.g., 

depth, width and length) of the hot spot. 

Not Applicable. 

14. Identify the samples specifically collected to characterize the hot spot. 

Not Applicable. 

15. Explain why the samples sufficiently represent the hot spot. 

Not Applicable. 

MULTIPLE WASTE TREATMENT FACILITY 

16. Have you collected samples to characterize a waste generated by a multiple waste 

treatment facility (MWTF)? 

No 

WASTE ANALYSIS INFORMATION 

17. Was sample analyses done by in-house staff? 

No 

a. Name and address of the organization(s) or company(s) responsible for sample 

analyses. 

Name: ALS Laboratory Group 

Street: 10450 Stancliff Rd. Suite 120 

City: Houston State: Texas Zip Code: 77099 

Telephone: 281-530-5656 

b. For each individual person (in-house and otherwise) who conducted analyses or 

was responsible for data reduction, validation, and laboratory quality control, 

please provide a resume of qualifications and the following information: 

Name: 

Affiliation: 

Title: 
Texas Registered Engineering Firm F-2393 22 G:\2010\0102974\15096H Delisting Petition.doc 

Please refer to pages two through three of Attachment 3, ALS Laboratory Group, 

Company Profile, for the resumes of key personnel responsible for data reduction, 

validation and laboratory quality control. Attachment 2 (QAPP) includes the Analytical 

Laboratory Quality Assurance Plan for ALS Laboratory Group. 

18. Provide your signed laboratory data reporting forms from all analyses, including results 

from quality control analyses. 

Analytical reports are included in Attachment 4. 

19. Provide the following information on each sample and each analyses. 

a. Sample identification numbers as logged during collection and as assigned by 

the laboratory. 

The Work Order Sample Summary of each analytical report summarizes this 

information. Analytical reports are located in Attachment 4. 

b. Type of sample (e.g., waste sample, waste sample replicate, equipment blank, 

field blank). 

The Work Order Sample Summary of each analytical report summarizes the sample 

matrix. Samples with field identification of Underflow Delisting are underflow sump 

water samples. Those identified as Dup are duplicate samples. Samples with field 

identifications of TB are trip blanks. Analytical reports are located in Attachment 4. 

c. Date of sample receipt by the laboratory. 

The Work Order Sample Summary of each analytical report indicates the collection date 

and time of each sample, in addition to the date and time of receipt by the laboratory. 

Analytical reports are located in Attachment 4. 

d. The sample workup or preparation method and reference for the method (e.g., 

SW-846 Method 3500). 

The Analytical Results section of each analytical report summarizes this information. 

Analytical reports are located in Attachment 4. 

e. The date of sample workup or preparation. 

The Analytical Results section of each analytical report summarizes this information. 

Analytical reports are located in Attachment 4. 

f. The name of the person conducting the analysis. 

The Analytical Results section of each analytical report summarizes the initials of the 

analyst performing the analysis. Analytical reports are located in Attachment 4. 
Texas Registered Engineering Firm F-2393 23 G:\2010\0102974\15096H Delisting Petition.doc 

g. The date of extraction and analysis. 

The Analytical Results section of each analytical report summarizes this information. 

Analytical reports are located in Attachment 4. 

h. The test method used and the source of the test method (e.g., SW-846 Method 

8020). 

The Analytical Results section of each analytical report summarizes this information. 

Analytical reports are located in Attachment 4. 

i. The specific constituent, parameter, or hazard for which analysis was conducted. 

The Analytical Results section of each analytical report summarizes this information. 

Analytical reports are located in Attachment 4. 

j. The test results, expressed in appropriate units (e.g., mg/L, mg/kg). 

The analytical results are summarized in Table 8 and the results section of each 

analytical report, located in Attachment 4. 

k. The basis for the analysis (e.g., wet/dry weight). 

The analytical results are summarized in Table 8 and the results section of each 

analytical report, located in Attachment 4. 

l. The quantitation limits. 

The analytical results are summarized in Table 8 and the results section of each 

analytical report, located in Attachment 4. 

20. Provide the names and model numbers of all equipment used during analysis. 

The names and model numbers of all equipment used during the analysis are included in 

Attachment 5. 

21. Provide all other information necessary to fully interpret the test procedures or results. 

Not Applicable. 

22. For each quality control analysis that involved a matrix or a surrogate spike and spike 

duplicate analysis, provide the following information. 

Because of the volume of information requested, please refer to the laboratory reports provided in 

Attachment 4 for answers 22a-22h. 
Texas Registered Engineering Firm F-2393 24 G:\2010\0102974\15096H Delisting Petition.doc 

a. The name of the spike analyte added. 

b. The concentration of the spike analyte in the unspiked sample. 

c. The amount of the spike analyte added. 

d. The measured amount of the spike in both spiked samples. 

e. The calculated percent recovery of the spike and method of calculation. 

f. The acceptance criterion for recovery of each matrix spike. 

g. The relative percent difference (RPD) between the duplicate results. 

h. The acceptance criterion for the RPD. 

23. Identify whether the waste analytical data was corrected based on quality control results 

(e.g., blank analysis) and explain how the correction was made. 

Any corrections to the analytical data are indicated in the Case Narrative of the analytical report. 

Analytical reports are located in Attachment 4. No additional corrections were made. 

24. Explain any inconsistencies or deviations found in the reported analytical results. The 

discussion should include any observed analytical interferences and what actions were 

taken to resolve the problems. 

Not Applicable. 

25. If any calculations are necessary, (i.e., in use of the Oily Waste Extraction Procedure, for 

the Mobile Metal Concentration) please include all calculation sheets. 

Not Applicable. 
Texas Registered Engineering Firm F-2393 25 G:\2010\0102974\15096H Delisting Petition.doc 

PART 6: DELISTING GROUNDWATER MONITORING INFORMATION 

1. Show which of the following describes the management of the petitioned waste. 

a. The petitioned waste is currently managed in a land-based waste management 

unit (on-site or off-site), and ground-water monitoring is needed under 40 CFR 

Part 264 or 265 or authorized Sate equivalent, or other Federal, state, or local 

requirements; or if ground-water monitoring information is otherwise available 

for the unit. 

Yes. The ground water around the NLF is being monitored semiannually as part of the 

Ground Water Detection Monitoring Program for the Resource Conservation and 

Recovery Act (RCRA) permit and has been monitored since 1990. The constituents that 

are analyzed for include dissolved chromium and lead, benzene, toluene, total phenol, 1-

methylnahpthalene, naphthalene, total dissolve solids, and total organic carbon. Based on 

historical data readily available, there have been no statistically significant exceedances 

for these constituents of the permit concentration limits since 2003. (ERM has historical 

data from 2003 to the present that is readily available). 

b. The petitioned waste was once managed (but is no longer) in a land-based waste 

management unit (on-site or off-site) and ground-water monitoring was needed 

under 40 CFR Part 264 or 265 or authorized State equivalent, or other Federal, 

state, or local requirements; or if ground-water monitoring information is 

otherwise available for the unit. 

Not Applicable. 

c. The petitioned waste is currently managed, or was once managed, in a landbased waste management unit, but ground-water monitoring requirement has 

been waived. 

Not Applicable. 

d. The petitioned waste is currently managed, or was once managed, in one or more 

land-based waste management units containing also significant amounts of other 

wastes, and you consider ground-water data from these non-dedicated units are 

immaterial in evaluating the petitioned waste’s impact on ground-water quality.

Not Applicable. 

e. None of the above management scenarios apply. 

Not Applicable. 

2. Describe why ground-water monitoring is not needed for your petitioned waste. 

Not Applicable.
 G:\2010\0102974\15096H Delisting Petition.doc 

Tables 

August 12, 2010 

Project No. 0102974 

Environmental Resources Management Southwest, Inc. 

15810 Park Ten Place, Suite 300 

Houston, Texas 77084-5140 

(281) 600-1000
TABLE 1

Effluent Limitations for Outfall 001 at the Baytown Refinery

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Daily Average (lb/day) Daily Maximum (lb/day) Single Grab (mg/L) Measurement Frequency 

Carbonaceous Biochemical Oxygen Demand, 5-Day (CBOD5)

7,808 15,616 56 1/week 

Total Organic Carbon (TOC) 37,725 70,490 255 1/week Total Suspended Solids (TSS) 14,819 23,559 85 2/week Oil and Grease 5,346 10,097 36 1/ 2 weeks Phenolic Compounds 88.2 233 0.846 1/ 2 weeks Ammonia as Nitrogen (NH3-N) 2,000 4,000 15 1/week 

Nitrate (as N) (x2) Report (mg/L) Report (mg/L) N/A 1/week Sulfide 73.7 163 0.591 1/ 2 weeks Total Chromium 105 300 1.08 1/ 2 months Hexavalent Chromium 10.0 22.5 0.081 1/ 2 weeks Temperature 98 deg F 98 deg F 98 deg F FWAT * 3 pH N/A N/A 6-9 (standard units) 1/day NOTES:N/A = Not applicableFWAT = Flow-Weighted Average Temperature

Discharge Limitation Minimum Self Monitorin

Effluent Characteristic

Effluent Limitations per TPDES Permit 0000592

Texas Registered Engineering Firm F-2393 
TABLE 2

Wastes Currently Managed at the Baytown Refinery

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Waste Description

TCEQ Waste 

Code

EPA Hazard 

Code

EPA Hazardous Waste 

Code

Miscellaneous Trash & 

Debris From Offices/Control 

Centers

00029022 None None

Asphalt 00034091 None None

Wood Debris 00044882 None None

Wood Debris 00054881 None None

Oily Trash & Debris 00064891 None None

Empty Containers Less 

Than Five Gallons

00083082 None None

Empty Containers 00093081 None None

Pressurized Aerosol Cans 0010319H I, R D001, D003, D005

Debris & Solids 00113191 None None

Debris & Solids 0012319H T,I,E D001, D002, D003, 

D004, D006, D007, 

D008, D018, D032, 

D035, F002, F003, F005, 

F037, K049, K050, K051, 

K169, K170, K171, K172, 

U154

Rust Scale 00133071 None None

Rust Scale 0014307H R,E D018, D003, D008

Non-Asbestos Insulation 00153192 None None

Asbestos 00163111 None None

Concrete & Debris 00183902 None None

Debris & Solids 00193192 None None

Asphalt From Roads and 

Tanks

00204092 None None

Wax from Dewaxing Units 00214092 None None

Catalyst Inert Balls 00503931 None None

Catalyst Inert Balls & 

Molecular Sieves

00513932 None None

NOTES:

T = Toxic

I = Ignitable

C = Corrosive

R = Reactive

E = Toxicity Characteristic

Page 1 of 6

Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H Petition Table
TABLE 2 (Cont'd)

Wastes Currently Managed at the Baytown Refinery

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Waste Description

TCEQ Waste 

Code

EPA Hazard 

Code

EPA Hazardous Waste 

Code

Non-Precious Metal (NPM) 

Catalyst From Catalytic 

Reforming, Hydro-fining, 

Hydro-cracking, 

Hydrotreating

00523931 None None

NPM Catalyst From 

Catalytic Reforming, 

Hydro-fining, 

Hydro-cracking, 

Hydrotreating

0053393H T,E D001, D008, D011, 

D018, D004, K171

Precious Metal Catalyst 

From Hydrocracking

00543931 None None

Precious Metal Catalyst 

From Reforming

00553932 None None

Alumina Silica Catalyst 

From FCCU

00563932 None None

Alumina Silica Catalyst 

From SCU

00573932 None None

Sand Filter 0058489H E D018

Hydrorefining Catalyst 0059393H T,E D004, D008, D018, K172

NPM Catalyst From 

Refining Units

00603932 None None

PCB Liquids Containing 

<50 ppm

01002191 None None

PCB Liquids Containing 50 

ppm & <500 ppm

01012971 None None

PCB Liquids Containing 

>500 ppm

01022981 None None

Electrical Equipment Device 

With 50 ppm & <500 ppm 

PCB

01033961 None None

Electrical Equipment Device 

With >500 ppm PCB

01043971 None None

NOTES:

T = Toxic

I = Ignitable

C = Corrosive

R = Reactive

E = Toxicity Characteristic

Page 2 of 6

Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H Petition Table
TABLE 2 (Cont'd)

Wastes Currently Managed at the Baytown Refinery

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Waste Description

TCEQ Waste 

Code

EPA Hazard 

Code

EPA Hazardous Waste 

Code

PCB Solids Containing <50 

ppm

01053191 None None

PCB Solids & Debris 

Containing 50 ppm & <500 

ppm

01063941 None None

Soil Contaminated With 350 

ppm & <500 ppm PCB

01073981 None None

PCB Solids & Debris 01083951 None None

Wax 02006091 None None

Spent Activated Carbon 02014041 None None

Spent Activated Carbon 02024042 None None

Ion Exchange Resins 02033192 None None

Stretford Solids 02043191 None None

Elemental Sulfur 02053192 None None

Petroleum-Contaminated 

Soil

02063012 None None

Petroleum-Contaminated 

Soil

02073011 None None

Petroleum-Contaminated 

Soil (BTCP)

0010301H E D018

Petroleum-Contaminated 

Soil

0208301H T, E D002, D007, D008, 

D009, D018, U019, 

U154, U159, U188, U220

Tank & Still Bottoms 02096021 None

None

None

None

None

None

Tank & Still Bottoms 0210602H T, I, E D001, D002, D007, 

D008, D018, D019, 

D028, D029, D030, 

D032, D033, D034,

 D036, D037, D038, 

D039, D040, D042, 

D043, K169

Cooling Towers 

Sludge/Solids

02113191 None None

NOTES:

T = Toxic

I = Ignitable

C = Corrosive

R = Reactive

E = Toxicity Characteristic

Page 3 of 6

Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H Petition Table
TABLE 2 (Cont'd)

Wastes Currently Managed at the Baytown Refinery

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Waste Description

TCEQ Waste 

Code

EPA Hazard 

Code

EPA Hazardous Waste 

Code

Chromate Cooling Tower 

Sludge

0212319H E D007

Coke Fines 02134042 None None

Coke Fines 02144041 None None

Sandblast Grit 02153892 None None

Sandblast Grit 02163891 None None

Sandblast Grit 0217319H E D007, D008

MEA Reclaimer Sludge 02185191 None None

Caustic Sludge 0219519H I, C, E D001, D002, D018, 

D019, D030, D032

Hazardous Lab Packs 0222003H C,I,R,T,E D001, D002, D003, 

D004, D005, D006, 

D007, D008, D011, 

D018, D019, D021, 

D022, D023, D024, 

D025, D035, D038, 

D039, F001, F002, F003, 

F005, P022, P030, P098, 

P105, U002, U007, 

U012, U019, U031, 

U037, U044, U052, 

U056, U080, U117, 

U119, U122, U123, 

U140, U144, U154, 

U159, U160, U161, 

U165, U188, U196, 

U210, U211, U213, U220

Nonhazardous Lab Packs 02230031 None None

Miscellaneous Chemical 

Compounds

02241191 None None

Alumina Silica Catalyst 02253931 None None

Metal Contaminated Soil 0226302H None D004, D007, D008, D009

Waste Alcohol 0220206H I D001

Ethylene Glycol 02212961 None None

NOTES:

T = Toxic

I = Ignitable

C = Corrosive

R = Reactive

E = Toxicity Characteristic

Page 4 of 6

Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H Petition Table
TABLE 2 (Cont'd)

Wastes Currently Managed at the Baytown Refinery

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Waste Description

TCEQ Waste 

Code

EPA Hazard 

Code

EPA Hazardous Waste 

Code

Wastewater Stripper 

Influent

0300102H E D018

Industrial Wastewater 03011022 None None

Industrial Wastewater 03021021 None None

Contaminated Water 0303102H T,E D002, D003,D004, D007, 

D008, D018, F037, F039, 

K049, K050, K051, K169, 

K170, K171, K172

NLF Leachate 0304116H T F039

Sanitary Sewer Sludge 03056092 None None

WOU, RB-1, UOC, LOC 

Sludges

03066951 None None

Old Aeration Pond & 

Lagoon Sludges

03075121 None None

Water Clarification Solids 03085193 None None

Waste Paint 0500604H T, I, E D001, D018, D027, 

D035, F002, F003, F005

Spent Solvents 0501203H I,E D001, D006, D008, 

D018, D027, D035, 

D039, D040

Heat Exchanger 

Bundle Cleaning Sludge

0502695H T, I, E, R K050, D001, D003, D018

TCCR Oily Solids 0503489H I, E D001, D018, D040

Slop Oil Emulsion Solids 0504603H T, I, E K049, D001, D018

API Separator Sludge 0505603H T, I, E K051, D001, D018

Heat Exchanger 

Bundle Cleaning Sludge

0502695H T, I, E, R K050, D001, D003, D018

TCCR Oily Solids 0503489H I, E D001, D018, D040

Slop Oil Emulsion Solids 0504603H T, I, E K049, D001, D018

API Separator Sludge 0505603H T, I, E K051, D001, D018

Primary Sludge 0506503H T, E F037, D007, D008, 

D018, D040

Mercury-Contaminated 

Waste

0507319H E D009

Miscellaneous Chemical 

Compounds

0508119H I, C, E D001, D002, D003, 

D018, D030, D032, D033

NOTES:

T = Toxic

I = Ignitable

C = Corrosive

R = Reactive

E = Toxicity Characteristic

Page 5 of 6

Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H Petition Table
TABLE 2 (Cont'd)

Wastes Currently Managed at the Baytown Refinery

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Waste Description

TCEQ Waste 

Code

EPA Hazard 

Code

EPA Hazardous Waste 

Code

Waste or Spent 

Halogenated Solvent

0509204H None D001, D002, D018, 

D021, D022, D035, 

D039, D040, F001, F002, 

F003, F005

Waste or Spent NonHalogen Solvent0510203H None D001, D002, D018, 

D035, F003, F004, F005

Miscellaneous Chemical 

Compounds

02241191 None None

Cleaning Compounds 0566203H E D006, D007, D008, 

D018, D021, D027, 

D035, D039, D040

Used Oil Filters 14763101 None None

Used Lead Acid, Nickel 

Cadmium, Lithium, and 

Nickel Metal Hydride 

Batteries

1477309H None D002, D003, D004, 

D006, D008

Wood Pallets 14784882 None None

Organic Compressed Gas 

Cylinders

1479801H None D001, D003

Miscellaneous Electronic 

Equipment

1481319H None D006, D007, D008, D009

Plant Trash 06019992 None None

Spent Carbon Hazardous 0602404H T, I D001, D018

Remediation Wastes - 

Solids Contaminated with 

Organics and/or Inorganics

0250301H T, I, E D001, D007, D008, 

D018, F037, K049, K050, 

K051, K052, K169, K170

Remediation Wastes - 

Solids Contaminated with 

Organics and/or Inorganics

02503011 None None

HAFO Tank Bottoms 0227602H T,I, E D001, D007, D008, 

D018, K170

Untreated Sewage 06046082 None None

NOTES:

T = Toxic

I = Ignitable

C = Corrosive

R = Reactive

E = Toxicity Characteristic

Page 6 of 6

Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H Petition Table
Waste Management Unit Status Waste Received

North Landfarm (NLF) Active

API Separator Sludge, 

API/Sewer Sediment (BOP),

Contaminated Water, 

Heat Exchanger Bundle Cleaning Sludge, 

Industrial Wastewater,

MEA Reclaimer Sludge, 

NLF Leachate, 

Oily Sand and Silt (BTCP)

Petroleum-Contaminated Soil, 

Petroleum-Contaminated Soil (BTCP), 

Primary Sludge, 

Slop Oil Emulsion Solids, 

Soil Contaminated with Organics (BOP)

TCCR Oily Solids

Tank & Still Bottoms, 

Impoundment Sludges, 

Wastewater Sludges (BOP),

RRU Solids,

Remediation Wastes – Solids Contaminated with Organics and/or Inorganics, 

OAP and Lagoon Sludges,

HAFO Tank Bottoms

Wastewater Oxidation Unit (WOU) Active Industrial Wastewater, WOU Sludge

Upper Outfall Canal (UOC) Active Industrial Wastewater, UOC Sludge

Retention Basin 1 (RB1) Active Industrial Wastewater, SRB Sludge

Lower Outfall Canal (LOC) Active Industrial Wastewater, LOC Sludge

NOTES:

Waste streams listed are those that are currently managed at each unit. Waste that is no longer managed in the units is not 

included in this table.

Baytown, Texas

TABLE 3

Summary of On-Site Permitted Waste Management Units

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H Petition Table
Relevant Program and/or Law Permit No. Government Agency

Texas Solid Waste Disposal Act HW-50111-000 Texas Commission on Environmental 

Quality (TCEQ)

NSR-1827-TX-730M4

FOP-01229

Hazardous Waste Management 

program under the Resource 

Conservation and Recovery Act

HW-50111-000 TCEQ 

Texas Pollutant Discharge 

Elimination System (TPDES) 

Program under the Clean Water Act

TPDES0000592 TCEQ

Dredge or fill permits under section 

404 of the Clean Water Act

13613 U.S. Army Corps of Engineers 

(USACE)

137908 (this number is revised 

annually)

Harris-Galveston Coastal Subsidence 

District

L01134 Texas Department of State Health 

Services (TDSHS) (Bureau of 

Radiation Control)

Baytown, Texas

Texas Clean Air Act TCEQ/Environmental Protection 

Agency (EPA)

TABLE 4

Summary of Permits Maintained by the BTRF

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H Petition Table
North Landfarm Underflow Delisting Petition

Waste Associated EPA Hazardous Waste Codes

API Separator Sludge K051, D018, D001

API/Sewer Sediment (BOP)* D018

API/Sewer Sediment (BOP)* None

Contaminated Water K049, K050, K051, F037, F039, D018, K169, K170, K171, K172, 

D002, D004, D007, D008, D003

Heat Exchanger Bundle Cleaning Sludge K050, D018, D001, D003

Industrial Wastewater None

Industrial Wastewater None

MEA Reclaimer Sludge None

NLF Leachate F039

Oily Sand and Silt (BTCP)* None

Petroleum-Contaminated Soil D002, D007, D008, D009, D018, U019, U154, U159, U188, U220

Petroleum-Contaminated Soil (BTCP) D018

Petroleum-Contaminated Soil None

Petroleum-Contaminated Soil None

Petroleum-Contaminated Soil (BTCP)* None

Primary Sludge D007, D008, D018, F037, D040

Slop Oil Emulsion Solids K049, D018, D001

Soil Contaminated With Organics (BOP)* None

TCCR Oily Solids* D001, D018, D040

Tank & Still Bottoms D001, D002, D007, D008, D018, D019, D028, D029, D030, D032, 

D033, D034, D036, D037, D038, D039, D040, D042, D043, K169, 

Tank & Still Bottoms None

Impoundment Sludges None

Wastewater Sludges (BOP) None

RRU Solids* K051, K049, K050, F037

Remediation Wastes – Solids Contaminated 

with Organics and/or Inorganics

D001, D007, D008, D018, F037, K049, K050, K051, K052, K169, 

K170

Remediation Wastes – Solids Contaminated 

with Organics and/or Inorganics

None

OAP and Lagoon Sludges None

HAFO Tank Bottoms D007, D008, D018, K170, D001

NOTES:

 All wastes are analyzed prior to placement at the North Landfarm to verify that the wastes meet Universal Treatment

Standards and Land Disposal Restrictions

TABLE 5

Current and Historical Wastes Applied to North Landfarm

ExxonMobil Baytown Refinery

Baytown, Texas

Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H Petition Table
North Landfarm Underflow Delisting Petition

Contributory Processes Operating Time Operation Cycle Scheduled Sh

Rain Water Average annual rainfall for Baytown, Texas is 29.47 inchesContinuous throughput None

Irrigation Water (Underflow and Fire Water) Continuous Continuous throughput NoneMoisture from waste applied to NLF Continuous Continuous throughput NoneNOTE:Source for rainfall average: www.wunderground.com

TABLE 6

NLF Underflow Generation Contributing Processes

ExxonMobil Baytown Refinery

Baytown, Texas

Texas Registered Engineering Firm F-2393 
North Landfarm Underflow Delisting Petition

Constituent Reason

Metals

Arsenic Constituent in waste applied to NLF, 

Constituent in 40 CFR 261.24

Barium Detected in Delisting Sample, 

Constituent in 40 CFR 261.24

Cadmium Constituent in 40 CFR 261.24

Chromium Constituent in waste applied to NLF, 

Constituent in 40 CFR 261.24

Cobalt Detected in historical underflow samples

Copper Detected in historical underflow samples

Lead Constituent in waste applied to NLF, 

Constituent in 40 CFR 261.24

Lithium Detected in historical underflow samples

Mercury Constituent in 40 CFR 261.24

Manganese Detected in historical underflow samples

Molybdenum Detected in historical underflow samples

Selenium Constituent in 40 CFR 261.24

Silver Constituent in 40 CFR 261.24

Zinc Detected in historical underflow samples

Semivolatiles

2,4-Dinitrotoluene Constituent in 40 CFR 261.24

2,4,5-Trichlorophenol Constituent in 40 CFR 261.24

2,4,6-Trichlorophenol Constituent in 40 CFR 261.24

3-Methylcholanthrene Constituent in waste applied to NLF

Benzo(a)anthracene Constituent in waste applied to NLF

Benzo(b)fluoranthene Constituent in waste applied to NLF

Benzo(a)pyrene Constituent in waste applied to NLF

Benzo(k)fluoranthene Constituent in waste applied to NLF

Chrysene Constituent in waste applied to NLF

o-Cresol Constituent in 40 CFR 261.24

m-Cresol Constituent in 40 CFR 261.24

p-Cresol Constituent in 40 CFR 261.24

Cresol Constituent in 40 CFR 261.24

Hexachlorobenzene Constituent in 40 CFR 261.24

Hexachlorbutadiene Constituent in 40 CFR 261.24

Hexachloroethane Constituent in 40 CFR 261.24

Nitrobenzene Constituent in 40 CFR 261.24

Pentachlorophenol Constituent in 40 CFR 261.24

Pyridine Constituent in 40 CFR 261.24

Volatiles

1,1-Dichloroethylene Constituent in 40 CFR 261.24

1,2-Dichloroethane Constituent in 40 CFR 261.24

1,4-Dichlorobenzene Constituent in 40 CFR 261.24

Benzene Constituent in waste applied to NLF, 

Constituent in 40 CFR 261.24

Carbon tetrachloride Constituent in 40 CFR 261.24

Chlorobenzene Constituent in 40 CFR 261.24

Chloroform Constituent in 40 CFR 261.24

Methyl ethyl ketone Constituent in 40 CFR 261.24

Tetrachloroethylene Constituent in 40 CFR 261.24

Trichloroethylene Constituent in 40 CFR 261.24

Vinyl chloride Constituent in 40 CFR 261.24

Miscellaneous

Cyanide Detected in historical underflow samples

Fluoride Detected in January 2009 sample,

Detected in historical underflow samples

Phosphorous Detected in historical underflow samples

Dioxins/Furans Detected in January 2009 sample

Baytown, Texas

TABLE 7

Final North Landfarm Underflow Delisting Constituent List

ExxonMobil Baytown Refinery

Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H Petition Table
TABLE 8

Summary of North Landfarm Underflow Sampling Data

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Delisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicat

2-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May

Constituent Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (MetalsAntimony 1.9 ND NS NS NS NS NS Arsenic 1.4 ND ND ND ND ND ND Barium 1.2 0.0192 0.0202 0.0216 0.025 0.0224 0.02Beryllium 0.82 ND NS NS NS NS NS Cadmium 0.69 ND ND ND ND ND ND Chromium 2.77 ND ND ND ND ND ND Cobalt --- NS ND ND ND 0.000953 J 0.0009Copper --- NS ND ND ND 0.00223 J 0.002Lead 0.69 ND ND ND ND 0.000947 J 0.0001Lithium --- NS ND ND ND ND ND Manganese --- NS 0.0249 0.0218 0.0774 0.427 0.40Molybdenum --- NS 0.0157 0.0141 0.0130 0.0156 0.01Nickel 3.98 ND NS NS NS NS NS Selenium 0.82 ND ND ND 0.00516 ND ND Silver 0.43 ND ND ND ND ND ND Thallium 1.4 ND NS NS NS NS NS Vanadium 4.3 ND NS NS NS NS NS Zinc --- NS 0.0605 0.0378 0.0440 0.0317 0.03Mercury 0.15 ND ND ND ND ND ND 

--- Semivolatiles --- 1,2,4,5-Tetrachlorobenzene 0.055 ND NS NS NS NS NS 

1,2,4-Trichlorobenzene 0.055 ND NS NS NS NS NS 1,2-Diphenylhydrazine 0.087 ND NS NS NS NS NS 1,3-Phenylenediamine --- ND NS NS NS NS NS 1,4-Dinitrobenzene 0.32 ND NS NS NS NS NS 

2,3,4,6-Tetrachlorophenol 0.03 ND NS NS NS NS NS 

2,4,5-Trichlorophenol 0.18 ND ND ND ND ND ND 2,4,6-Trichlorophenol 0.035 ND ND ND ND ND ND 2,4-Dichlorophenol 0.044 ND NS NS NS NS NS NOTES:B - (Inorganics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).J - (organics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).ND = Not detected at Reporting Limit (RL)NS = Not sampledTSS - Total Suspended Solids

F039 Threshold Value 

(mg/L) a

a Provided in "Treatment Standards for Hazardous Waste" in 40 

--- = Threshold Value not provided for constituent

Page 1 of 9Texas Registered Engineering Firm F-2393 
TABLE 8 (Cont'd)

Summary of North Landfarm Underflow Sampling Data

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Delisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicat

2-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May

Constituent Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (Semivolatiles (cont.)2,4-Dimethylaniline 0.01 ND NS NS NS NS NS 2,4-Dimethylphenol 0.036 ND NS NS NS NS NS 2,4-Dinitrophenol 0.12 ND NS NS NS NS NS 2,4-Dinitrotoluene 0.32 ND ND ND ND ND ND 2,6-Dichlorophenol 0.044 ND NS NS NS NS NS 2,6-Dinitrotoluene 0.55 ND NS NS NS NS NS 2-Acetylaminofluorene 0.059 ND NS NS NS NS NS 2-Chloronaphthalene 0.055 ND NS NS NS NS NS 2-Chlorophenol 0.044 ND NS NS NS NS NS 2-Methylphenol 0.11 ND ND ND ND ND ND 2-Naphthylamine 0.52 ND NS NS NS NS NS 3&4-Methylphenol 0.77 ND ND ND ND ND ND 3-Methylcholanthrene 0.0055 ND ND ND ND ND ND 3-Methylphenol 0.77 NS NS NS NS NS NS 

4,4 ́-Methylene-bis(2-chloroaniline) 0.5 ND NS NS NS NS NS 4,6-Dinitro-2-methylphenol 0.28 ND NS NS NS NS NS 4-Aminobiphenyl 0.13 ND NS NS NS NS NS 4-Bromophenyl phenyl ether 0.055 ND NS NS NS NS NS 

4-Chloro-3-methylphenol 0.018 ND NS NS NS NS NS 4-Chloroaniline 0.46 ND NS NS NS NS NS 4-Methylphenol 0.77 NS NS NS NS NS NS 4-Nitroaniline 0.028 ND NS NS NS NS NS 4-Nitrophenol 0.12 ND NS NS NS NS NS 5-Nitro-o-toluidine 0.32 ND NS NS NS NS NS Acenaphthene 0.059 ND NS NS NS NS NS Acenaphthylene 0.059 ND NS NS NS NS NS Acetophenone 0.01 ND NS NS NS NS NS Aniline 0.81 ND NS NS NS NS NS Anthracene 0.059 ND NS NS NS NS NS Aramite 0.36 ND NS NS NS NS NS Benzo(a)anthracene 0.059 ND ND ND ND ND ND Benzo(b)fluoranthene 0.11 ND ND ND ND ND ND NOTES:B - (Inorganics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).J - (organics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).ND = Not detected at Reporting Limit (RL)NS = Not sampledTSS - Total Suspended Solids

a Provided in "Treatment Standards for Hazardous Waste" in 40 

F039 Threshold Value 

(mg/L) a

--- = Threshold Value not provided for constituent

Page 2 of 9Texas Registered Engineering Firm F-2393 
TABLE 8 (Cont'd)

Summary of North Landfarm Underflow Sampling Data

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Delisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicat

2-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May

Constituent Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (Semivolatiles (cont.)Benzo(ghi)perylene 0.0055 ND NS NS NS NS NS Benzo(a)pyrene 0.061 ND ND ND ND ND ND Benzo(k)fluoranthene 0.11 ND ND ND ND ND ND Bis(2-chloroethoxy)methane 0.036 ND NS NS NS NS NS Bis(2-chloroethyl)ether 0.033 ND NS NS NS NS NS Bis(2-chloroisopropyl)ether 0.055 ND NS NS NS NS NS bis(2-ethylhexyl)pthalate 0.28 ND NS NS NS NS NS Butyl benzyl phthalate 0.017 ND NS NS NS NS NS Chlorobenzilate 0.1 ND NS NS NS NS NS Chrysene 0.059 ND ND ND ND ND ND Dibenzo(a,h)anthracene 0.055 ND NS NS NS NS NS Dibenzo(a,e)pyrene 0.061 ND NS NS NS NS NS Diethyl phthalate 0.2 ND NS NS NS NS NS Dimethyl phthalate 0.047 ND NS NS NS NS NS Di-n-butyl phthalate 0.057 ND NS NS NS NS NS Di-n-octyl phthalate 0.017 ND NS NS NS NS NS Diphenylamine 0.92 ND NS NS NS NS NS Disulfoton 0.017 ND NS NS NS NS NS Ethyl parathion 0.014 ND NS NS NS NS NS Famphur 0.017 ND NS NS NS NS NS Fluoranthene 0.068 ND NS NS NS NS NS Fluorene 0.059 ND NS NS NS NS NS Hexachlorobenzene 0.055 ND ND ND ND ND ND Hexachlorobutadiene 0.055 ND ND ND ND ND ND Hexachlorocyclopentadiene 0.057 ND NS NS NS NS NS Hexachloroethane 0.055 ND ND ND ND ND ND Hexachloropropene 0.035 ND NS NS NS NS NS Indeno(1,2,3-cd)pyrene 0.0055 ND NS NS NS NS NS Isodrin 0.021 ND NS NS NS NS NS Isosafrole 0.081 ND NS NS NS NS NS Kepone 0.0011 ND NS NS NS NS NS Methapyrilene 0.081 ND NS NS NS NS NS NOTES:B - (Inorganics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).J - (organics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).ND = Not detected at Reporting Limit (RL)NS = Not sampledTSS - Total Suspended Solids

a Provided in "Treatment Standards for Hazardous Waste" in 40 

F039 Threshold Value 

(mg/L) a

--- = Threshold Value not provided for constituent

Page 3 of 9Texas Registered Engineering Firm F-2393 
TABLE 8 (Cont'd)

Summary of North Landfarm Underflow Sampling Data

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Delisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicat

2-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May

Constituent Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (Semivolatiles (cont.)Methylchrysene --- NS NS NS NS NS NS Methyl methanesulfonate 0.018 ND NS NS NS NS NS Methyl parathion 0.014 ND NS NS NS NS NS N-Nitroso-di-n-butylamine 0.4 ND NS NS NS NS NS N-Nitrosodi-n-propylamine 0.4 ND NS NS NS NS NS N-Nitrosodimethylamine 0.4 ND NS NS NS NS NS N-Nitrosodiphenylamine 0.92 ND NS NS NS NS NS N-Nitrosomethylethylamine 0.4 ND NS NS NS NS NS N-Nitrosomorpholine 0.4 ND NS NS NS NS NS N-Nitrosopiperidine 0.013 ND NS NS NS NS NS N-Nitrosopyrrolidine 0.013 ND NS NS NS NS NS Naphthalene 0.059 ND NS NS NS NS NS Nitrobenzene 0.068 ND ND ND ND ND ND o-Anisidine 0.01 ND NS NS NS NS NS p-Cresidine 0.01 ND NS NS NS NS NS Pentachlorobenzene 0.055 ND NS NS NS NS NS Pentachloronitrobenzene 0.055 ND NS NS NS NS NS Pentachlorophenol 0.089 ND ND ND ND ND ND Phenacetin 0.081 ND NS NS NS NS NS Phenanthrene 0.059 ND NS NS NS NS NS Phenol 0.039 ND NS NS NS NS NS Phorate 0.021 ND NS NS NS NS NS Phthalic anhydride 0.055 ND NS NS NS NS NS Pronamide 0.093 ND NS NS NS NS NS Pyrene 0.067 ND NS NS NS NS NS Pyridine 0.014 ND ND ND ND ND ND Safrole 0.081 ND NS NS NS NS NS Tris(2,3-dibromopropyl) phosphate 0.11 ND NS NS NS NS NS Volatiles1,1,1,2-Tetrachloroethane ND NS NS NS NS NS 1,1,1-Trichloroethane ND NS NS NS NS NS NOTES:B - (Inorganics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).J - (organics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).ND = Not detected at Reporting Limit (RL)NS = Not sampledTSS - Total Suspended Solids--- = Threshold Value not provided for constituent

F039 Threshold Value 

(mg/L) a

a Provided in "Treatment Standards for Hazardous Waste" in 40 

Page 4 of 9Texas Registered Engineering Firm F-2393 
TABLE 8 (Cont'd)

Summary of North Landfarm Underflow Sampling Data

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Delisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicat

2-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May

Constituent Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (Volatiles (cont.)1,1,2,2-Tetrachloroethane 0.057 ND NS NS NS NS NS 1,1,2-Trichlor-1,2,2-trifluoroethane 0.057 ND NS NS NS NS NS 1,1,2-Trichloroethane 0.054 ND NS NS NS NS NS 1,1-Dichloroethane 0.059 ND NS NS NS NS NS 1,1-Dichloroethene 0.025 ND ND ND ND ND ND 1,2,3-Trichloropropane 0.85 ND NS NS NS NS NS 1,2-Dibromo-3-chloropropane 0.11 ND NS NS NS NS NS 1,2-Dibromoethane 0.028 ND NS NS NS NS NS 1,2-Dichlorobenzene 0.088 ND NS NS NS NS NS 1,2-Dichloroethane 0.21 ND ND ND ND ND ND 1,2-Dichloropropane 0.85 ND NS NS NS NS NS 1,3-Dichlorobenzene 0.036 ND NS NS NS NS NS 1,4-Dichlorobenzene 0.09 ND ND ND ND ND ND 1,4-Dioxane 12 ND NS NS NS NS NS 2-Butanone 0.28 ND ND ND ND ND ND 2-Chloro-1,3-butadiene 0.057 ND NS NS NS NS NS 4-Methyl-2-pentanone 0.14 ND NS NS NS NS NS Acetone 0.28 ND NS NS NS NS NS Acetonitrile 5.6 ND NS NS NS NS NS Acrolein 0.29 ND NS NS NS NS NS Acrylonitrile 0.24 ND NS NS NS NS NS Allyl Chloride 0.036 ND NS NS NS NS NS Benzene 0.14 ND ND ND ND ND ND Bromodichloromethane 0.35 ND NS NS NS NS NS Bromoform 0.63 ND NS NS NS NS NS Bromomethane 0.11 ND NS NS NS NS NS Carbon disulfide 3.8 ND NS NS NS NS NS Carbon tetrachloride 0.057 ND ND ND ND ND ND Chlorobenzene 0.057 ND ND ND ND ND ND Chloroethane 0.27 ND NS NS NS NS NS Chloroform 0.046 ND ND ND ND ND ND Chloromethane ND NS NS NS NS NS NOTES:B - (Inorganics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).J - (organics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).ND = Not detected at Reporting Limit (RL)NS = Not sampledTSS - Total Suspended Solids--- = Threshold Value not provided for constituent

a Provided in "Treatment Standards for Hazardous Waste" in 40 

F039 Threshold Value 

(mg/L) a

Page 5 of 9Texas Registered Engineering Firm F-2393 
TABLE 8 (Cont'd)

Summary of North Landfarm Underflow Sampling Data

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Delisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicat

2-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May

Constituent Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (Volatiles (cont.)cis-1,3-Dichloropropene 0.036 ND NS NS NS NS NS Cyclohexanone 0.36 ND NS NS NS NS NS Dibromochloromethane 0.057 ND NS NS NS NS NS Dibromomethane 0.11 ND NS NS NS NS NS Dichlorodifluoromethane 0.23 ND NS NS NS NS NS Diethyl Ether 0.12 ND NS NS NS NS NS Ethyl acetate 0.34 ND NS NS NS NS NS Ethyl methacrylate 0.14 ND NS NS NS NS NS Ethylbenzene 0.057 ND NS NS NS NS NS Ethylene oxide 0.12 ND NS NS NS NS NS Iodomethane 0.19 ND NS NS NS NS NS Isobutyl alcohol 5.6 ND NS NS NS NS NS Methacrylonitrile 0.24 ND NS NS NS NS NS Methyl methacrylate 0.14 ND NS NS NS NS NS Methylene chloride 0.089 ND NS NS NS NS NS n-Butyl alcohol 5.6 ND NS NS NS NS NS Propionitrile 0.24 ND NS NS NS NS NS Tetrachloroethene 0.056 ND ND ND ND ND ND Toluene 0.08 ND NS NS NS NS NS trans-1,2-Dichloroethene 0.054 ND NS NS NS NS NS trans-1,3-Dichloropropene 0.036 ND NS NS NS NS NS Trichloroethene 0.054 ND ND ND ND ND ND Trichlorofluoromethane 0.02 ND NS NS NS NS NS Vinyl chloride 0.27 ND ND ND ND ND ND Xylenes 0.32 ND NS NS NS NS NS NOTES:B - (Inorganics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).J - (organics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).ND = Not detected at Reporting Limit (RL)NS = Not sampledTSS - Total Suspended Solids--- = Threshold Value not provided for constituent

a Provided in "Treatment Standards for Hazardous Waste" in 40 

F039 Threshold Value 

(mg/L) a

Page 6 of 9Texas Registered Engineering Firm F-2393 
TABLE 8 (Cont'd)

Summary of North Landfarm Underflow Sampling Data

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Delisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicat

2-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May

Constituent Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (Metals TCLPArsenic --- NS NS NS NS NS NS Barium --- NS NS NS NS NS NS Cadmium --- NS NS NS NS NS NS Chromium --- NS NS NS NS NS NS Lead --- NS NS NS NS NS NS Selenium --- NS NS NS NS NS NS Silver --- NS NS NS NS NS NS Mercury --- NS NS NS NS NS NS Semivolatiles TCLP2,4-Dinitrotoluene --- NS NS NS NS NS NS Hexachlorobenzene --- NS NS NS NS NS NS Hexachlorobutadiene --- NS NS NS NS NS NS Hexachloroethane --- NS NS NS NS NS NS Nitrobenzene --- NS NS NS NS NS NS 2-Methylphenol --- NS NS NS NS NS NS 4-Methylphenol --- NS NS NS NS NS NS Pentachlorophenol --- NS NS NS NS NS NS 2,4,5-Trichlorophenol --- NS NS NS NS NS NS 2,4,6-Trichlorophenol --- NS NS NS NS NS NS Pyridine --- NS NS NS NS NS NS Volatiles TCLPBenzene --- NS NS NS NS NS NS Carbon Tetrachloride --- NS NS NS NS NS NS Chlorobenzene --- NS NS NS NS NS NS Chloroform --- NS NS NS NS NS NS 1,4-Dichlorobenzene --- NS NS NS NS NS NS 1,2-Dichloroethane --- NS NS NS NS NS NS NOTES:B - (Inorganics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).J - (organics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).ND = Not detected at Reporting Limit (RL)NS = Not sampledTSS - Total Suspended Solids--- = Threshold Value not provided for constituent

a Provided in "Treatment Standards for Hazardous Waste" in 40 

F039 Threshold Value 

(mg/L) a

Page 7 of 9Texas Registered Engineering Firm F-2393 
TABLE 8 (Cont'd)

Summary of North Landfarm Underflow Sampling Data

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Delisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicat

2-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May

Constituent Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (Volatiles TCLP (cont.)1,1-Dichloroethene --- NS NS NS NS NS NS Tetrachloroethene --- NS NS NS NS NS NS Trichloroethene --- NS NS NS NS NS NS Vinyl Chloride --- NS NS NS NS NS NS Methyl Ethyl Ketone --- NS NS NS NS NS NS Chlorinated Herbicides2,4,5-T 0.72 ND NS NS NS NS NS 2,4,5-TP (Silvex) 0.72 ND NS NS NS NS NS 2,4-D 0.72 ND NS NS NS NS NS Dinoseb 0.066 ND NS NS NS NS NS Pesticides4,4 ́-DDD 0.023 ND NS NS NS NS NS 4,4 ́-DDE 0.031 ND NS NS NS NS NS 4,4 ́-DDT 0.0039 ND NS NS NS NS NS Aldrin 0.021 ND NS NS NS NS NS alpha-BHC 0.00014 ND NS NS NS NS NS beta-BHC 0.00014 ND NS NS NS NS NS Chlordane 0.0033 ND NS NS NS NS NS delta-BHC 0.023 ND NS NS NS NS NS Dieldrin 0.017 ND NS NS NS NS NS Endosulfan I 0.023 ND NS NS NS NS NS Endosulfan II 0.029 ND NS NS NS NS NS Endosulfan sulfate 0.029 ND NS NS NS NS NS Endrin 0.0028 ND NS NS NS NS NS Endrin aldehyde 0.025 ND NS NS NS NS NS gamma-BHC 0.0017 ND NS NS NS NS NS Heptachlor 0.0012 ND NS NS NS NS NS Heptachlor epoxide 0.016 ND NS NS NS NS NS Methoxychlor 0.25 ND NS NS NS NS NS Toxaphene 0.0095 ND NS NS NS NS NS 2,4 ́-DDD 0.023 ND NS NS NS NS NS 2,4 ́-DDE 0.031 ND NS NS NS NS NS 2,4 ́-DDT 0.0039 ND NS NS NS NS NS NOTES:B - (Inorganics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).J - (organics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).ND = Not detected at Reporting Limit (RL)NS = Not sampledTSS - Total Suspended Solids

F039 Threshold Value 

(mg/L) a

a Provided in "Treatment Standards for Hazardous Waste" in 40 

--- = Threshold Value not provided for constituent

Page 8 of 9Texas Registered Engineering Firm F-2393 
TABLE 8 (Cont'd)

Summary of North Landfarm Underflow Sampling Data

North Landfarm Underflow Delisting Petition

ExxonMobil Baytown Refinery

Baytown, Texas

Delisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicat

2-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May

Constituent Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (PCBs 0.1Aroclor 1016 --- ND NS NS NS NS NS Aroclor 1221 --- ND NS NS NS NS NS Aroclor 1232 --- ND NS NS NS NS NS Aroclor 1242 --- ND NS NS NS NS NS Aroclor 1248 --- ND NS NS NS NS NS Aroclor 1254 --- ND NS NS NS NS NS Aroclor 1260 --- ND NS NS NS NS NS MiscellaneousOil and Grease --- NS NS NS NS NS NS Ignitability (deg F) --- NS NS NS NS NS NS pH (s.u.) --- NS NS NS NS NS NS TSS --- NS NS NS NS NS NS Fluoride 35 0.513 0.720 0.710 0.531 0.402 0.38Total Kjeldahl Nitrogen --- NS NS NS NS NS NS Phosporous, Total --- NS ND ND ND 0.0950 0.040Total Organic Carbon --- NS NS NS NS NS NS Cyanide, Total 1.2 ND ND ND ND ND ND Sulfide 14 ND NS NS NS NS NS Methanol 5.6 ND NS NS NS NS NS Dioxins and Furans2,3,7,8-TCDD --- ND ND ND ND ND 1,2,3,7,8-PeCDD --- ND ND ND ND ND 1,2,3,4,7,8-HxCDD --- ND ND ND ND ND 1,2,3,6,7,8-HxCDD --- ND ND ND ND ND 1,2,3,7,8,9-HxCDD --- ND ND ND ND ND 1,2,3,4,6,7,8-HpCDD 3.5E-05 ND ND ND ND ND OCDD 6.3E-05 ND ND ND 2.91E-09 ND 2,3,7,8-TCDF --- ND ND ND ND ND 1,2,3,7,8-PeCDF --- 3.39E-10 ND ND ND ND 2,3,4,7,8-PeCDF --- ND ND ND ND ND 1,2,3,4,7,8-HxCDF --- ND ND ND ND ND 1,2,3,6,7,8-HxCDF --- ND ND ND ND ND 2,3,4,6,7,8-HxCDF --- ND ND ND ND ND 1,2,3,7,8,9-HxCDF --- ND ND ND ND ND 1,2,3,4,6,7,8-HpCDF 3.5E-05 ND ND ND ND ND 1,2,3,4,7,8,9-HpCDF 3.5E-05 2.06E-09 ND ND ND ND OCDF 6.3E-05 ND ND ND ND ND Total-TCDD 6.3E-05 ND ND 2.14E-09 ND ND Total-PeCDD 6.3E-05 ND ND ND ND ND Total-HxCDD 6.3E-05 1.28E-09 ND ND 1.54E-09 ND Total-HpCDD --- ND ND ND ND ND Total-TCDF 6.3E-05 ND ND ND ND ND Total-PeCDF 3.5E-05 3.39E-10 ND ND ND ND Total-HxCDF 6.3E-05 ND ND ND ND ND Total-HpCDF --- 2.06E-09 ND ND ND ND NOTES:B - (Inorganics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).J - (organics) The analyte is and estimated value between the Reporting Limit (RL) and the Method Detection Limit (MDL).ND = Not detected at Reporting Limit (RL)NS = Not sampledTSS - Total Suspended Solids

F039 Threshold Value 

(mg/L) a

--- = Threshold Value not provided for constituent

a Provided in "Treatment Standards for Hazardous Waste" in 40 

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Figures 

August 12, 2010 

Project No. 0102974 

Environmental Resources Management Southwest, Inc. 

15810 Park Ten Place, Suite 300 

Houston, Texas 77084-5140 

(281) 600-1000 
DECKER DRIVE

WASTEWATER

OXIDATION UNIT

SOUTH

LANDF ARM

H o u s t o n S h i p

C h a n n e l

S c o t t

B a y

B l a c k D u c k

B a y

M i t c h e l l

B a y

RETENTION BASIN 1

UPPER OUTFALL CANAL

LOWER OUTFALL

CANAL

SOUTH LANDFARM

(CLOSED)

EXXONMOBIL

REFINERY

NORTH LANDFARM

BAYWAY DRIVE

SAN JACINTO RIVER CANAL

GOOSE CREEK

TANK

102

LEGEND

SURFACE WATER

NORTH LANDFARM (NLF)

RAILROAD TRACK

REFINERY BOUNDARY

0 2500 5000

SCALE FEET

CHKD.:

REV.:

DRAWN:

DATE: SCALE:

W.O. NO.:

DESIGN:

H:\DWG\F10\0102974a201.dwg , 6/25/2010 4:20:55 PM

6/4/2010

FIGURE 1

SITE LOCATION MAP

NLF UNDERFLOW DELISTING PETITION

ExxonMobil Baytown Refinery

Baytown, Texas CPA JMH CPA

AS SHOWN

g:\2010\0102974\15096H(figs).pdf
G

G

D

C

B

A

F E

E

NLF TRUCK

WASH RACK

& BOOT WASH

SPINE ROAD

F

LANDFARMED SURFACE

LANDFARMED SURFACE

Plant

North

1

PERIMETER RUN-OFF COLLECTION DITCH

PERIMETER BERM

1%1%

1%1%

1%

1%

SAN JACINTO

AVE.

2 4

3

7 6

5

SUPPORT

FACILITIES

ENTRY

CONTROL

GATE

EXISTING HEAVY HAUL ROAD

PERIMETER RUN-OFF COLLECTION DITCH

PERIMETER BERM

1% 1%

8

SOURCE: MODIFIED FROM RADIAN INTERNATIONAL LLC DWG. No. D2393X, MAY 12, 1998. NOT TO SCALE

LEGEND

NLF FRAC TANKS

TANK 102

SLUDGE TRUCK UNLOADING

SLUDGE TRANSFER PUMP

COLLECTION SUMP

CONTROL BUILDING

BOOT WASH AT CONTROL BUILDING

EXISTING NLF UNDERFLOW SUMP

IRRIGATION SPRINKLER

SOLIDS OFF-LOADING PAD

NLF PLOT

SLOPE

A

1.

2.

3.

4.

5.

6.

7.

8.

1%

TANK 102

CHKD.:

REV.:

DRAWN:

DATE: SCALE:

W.O. NO.:

DESIGN:

H:\DWG\F10\0102974a202.dwg , 6/25/2010 4:21:07 PM

6/9/2010

ERM-Southwest, Inc. TX PE Firm No. 2393

FIGURE 2

PLOT PLAN OF NLF AND

ANCILLARY EQUIPMENT AND STRUCTURES

NLF UNDERFLOW DELISTING PETITION

ExxonMobil Baytown Refinery

Baytown, Texas

PJG EFC/RLM PJG

AS SHOWN 4/14/2010

g:\2010\0102974\15096H(figs).pdf
ZONE OF INCORPORATION

(DISKED)

CLEAN SOIL

SAND

DRAINAGE LAYER

IMPORTED CLAY LAYER (COMPACTED)

1% SLOPE

THICKNESS

VARIES

2' 1' 1'

Tz BTz

PRECIPITATION & IRRIGATION WATER

PERFORATED PIPE

UNDERFLOW

UNDERFLOW

UNDERFLOW

UNDERFLOW

UNDERFLOW

UNDERFLOW

CHKD.:

REV.:

DRAWN:

DATE: SCALE:

W.O. NO.:

DESIGN:

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6/25/2010

ERM-Southwest, Inc. TX PE Firm No. 2393

FIGURE 3

SOIL COLUMN DETAIL

NLF UNDERFLOW DELISTING PETITION

ExxonMobil Baytown Refinery

Baytown, Texas AB RLM PJG

NTS 4/14/10

NOT TO SCALE

Tz = Treatment Zone

BTz = Below Treatment Zone

LEGEND

g:\2010\0102974\15096H(figs).pdf
SOURCE: MODIFIED FROM RADIAN INTERNATIONAL LLC DWG. No. D2393Z, APRIL 21, 1997.

2%

(TYP.)

TREATMENT ZONE

DRAINAGE LAYER

12" AVG.

DEPTH 3" 12"

TREATMENT SOIL

SURFACE

COMPACTED CLAY LAYER

ORIGINAL CLAY SOIL 25'

NOT TO SCALE

25'

UNDERFLOW LATERAL:

2" PERFORATED HDPE

PIPE WRAPPED IN A

GEOTEXTILE MATERIAL

. 5 - CAMU Engineering Report

SUBSURFACE "CROWN"

BETWEEN UNDERFLOW

LATERALS

CHKD.:

REV.:

DRAWN:

DATE: SCALE:

W.O. NO.:

DESIGN:

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6/4/2010

ERM-Southwest, Inc. TX PE Firm No. 2393

FIGURE 4

TYPICAL SECTION THROUGH UNDERFLOW COLLECTION SYSTEM

NLF UNDERFLOW DELISTING PETITION

ExxonMobil Baytown Refinery

Baytown, Texas

PJG RLM PJG

AS SHOWN 4/14/10

g:\2010\0102974\15096H(figs).pdf
SPINE ROAD

Plant

North

PERIMETER RUN-OFF COLLECTION DITCH

PERIMETER BERM

SOURCE: MODIFIED FROM RADIAN INTERNATIONAL LLC DWG. No. D2393X, MAY 12, 1998. NOT TO SCALE

SAN JACINTO

AVE.

ENTRY

CONTROL

GATE

EXISTING HEAVY HAUL ROAD

LEGEND

2" LATERAL PIPE WITH CLEAN-OUT

6" COLLECTOR PIPE

EXISTING NFL SUMP

SOLIDS OFF-LOADING PAD

CHKD.:

REV.:

DRAWN:

DATE: SCALE:

W.O. NO.:

DESIGN:

H:\DWG\F10\0102974a205.dwg , 6/25/2010 4:21:33 PM

6/9/2010

ERM-Southwest, Inc. TX PE Firm No. 2393

FIGURE 5

PLAN VIEW

UNDERFLOW COLLECTION SYSTEM

NLF UNDERFLOW DELISTING PETITION

ExxonMobil Baytown Refinery

Baytown, Texas

PJG EFC PJG

AS SHOWN 4/14/10

g:\2010\0102974\15096H(figs).pdf
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 G:\2010\0102974\15096H Delisting Petition.doc 

Sampling and Analysis Plan 

Attachment 1 

August 12, 2010 

Project No. 0102974 

Environmental Resources Management Southwest, Inc. 

15810 Park Ten Place, Suite 300 

Houston, Texas 77084-5140 

(281) 600-1000 
Sampling and Analysis Plan: 

F039 Waste Delisting 

ExxonMobil Refining and Supply Company 

Baytown, Texas 

December 16, 2009 

www.erm.com

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 Texas Registered Engineering Firm F-2393

TABLE OF CONTENTS 

1.0 INTRODUCTION 1

1.1 SITE AND PROCESS DESCRIPTION 1

1.2 SCOPE AND OBJECTIVES 2

2.0 FIELD PROCEDURES AND METHODS 3

2.1 UNDERFLOW SAMPLING PROCEDURES AND FREQUENCY 3

2.2 SAMPLE MANAGEMENT PROCEDURES 4

2.3 ANALYTICAL REQUIREMENTS 4

3.0 SAMPLE PRESERVATION AND SHIPMENT 6

4.0 CHAIN-OF-CUSTODY AND RECORDKEEPING 7

5.0 QUALITY ASSURANCE AND QUALITY CONTROL (QA/QC) 9

5.1 EQUIPMENT 9

5.2 SAMPLE COLLECTION 9

5.3 DUPLICATES 9

5.4 MATRIX SPIKES AND MATRIX SPIKE DUPLICATES 10

6.0 MANAGEMENT OF INVESTIGATION-DERIVED WASTE 11

REFERENCES 12

APPENDIX 

A FIELD DATA FORMS 
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TABLE OF CONTENTS (Cont’d) 

List of Tables 

1 Analytical Methods 

2 Final North Landfarm Underflow Delisting Constituent List 

List of Figures 

1 Site Location Map 

2 Underflow Collection System Section 

3 Plot Plan of NLF and Ancillary Equipment and Structures 
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1.0 INTRODUCTION 

Environmental Resources Management-Southwest, Inc. prepared this Sampling 

and Analysis Plan (SAP) behalf of ExxonMobil Refining and Supply Company 

(ExxonMobil). This SAP describes the field and laboratory procedures that will 

be implemented during underflow sampling at the North Landfarm (NLF) at the 

ExxonMobil Baytown Refinery (BTRF). Ultimately, this underflow sampling 

data will be incorporated into a F039 waste delisting petition to be submitted to 

the United States Environmental Protection Agency (EPA) Region 6. 

The SAP will be used as the framework around which the sampling, testing, and 

analysis activities will be conducted during the waste delisting process. This 

plan was prepared in accordance with general EPA guidance including: 

• EPA, SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical 

Methods; and 

• EPA RCRA Delisting Program Guidance Manual for the Petitioner (March 23, 

2000). 

1.1 SITE AND PROCESS DESCRIPTION 

The ExxonMobil Baytown Complex is located in Baytown, Texas, approximately 

25 miles east of Houston. The Baytown Complex is comprised of the BTRF, the 

ExxonMobil Baytown Chemical Plant (BTCP), the ExxonMobil Basic Chemicals 

and Intermediates Technology (BCIT) and the ExxonMobil Baytown Olefins 

Plant (BOP) and occupies approximately 3,386 acres, most of which is situated 

south of Decker Drive (Spur 330) about four miles south of the Interstate 

Highway 10 exit. The Complex Administration Building (CAB) is located at 

5000 Bayway Drive. 

The BTRF operates a land treatment unit known as the NLF. The NLF is situated 

in the northern portion of the BTRF, just west of San Jacinto Avenue (Figure 1). 

The unit encompasses 44 acres, although 15.85 acres are in actual waste service. 

The area which receives waste is generally rectangular in plan view, measuring 

approximately 780 ft. from north to south and 930 ft. from west to east (Figure 2). 

Internal access to the plots on the landfarm is the spine road which is located in 

the center of the North Landfarm. The landfarm surface slopes at a 1% grade to 

the north, south, and east. Drainage ditches collect run off at the base of each 

sloped portion of the NLF. The surface of the NLF and the run-off collection 

ditches are surrounded by a perimeter berm. 

Underflow is aqueous solution which seeps through the treatment zone and is 

collected and removed by the underflow management system to reduce the 

potential for downward migration. The amount of water which seeps through 

the treatment zone is a function of the transmissivity of the soils of the treatment 

zones and the amount of water applied to the NLF plots. During periods of 

relative dryness within the treatment zone, water exists in the soils tightly bound 

to the soil particles. During these dry periods seepage is minimal. When free 
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water is available within the treatment zone, seepage proceeds at slow velocities. 

Because the clays at the base of the NLF were selected and compacted to produce 

a permeability of approximately 2 x 10-7 cm/sec (1.7 in/day) seepage is 

effectively reduced. Currently, NLF underflow is managed as a listed hazardous 

waste with EPA waste code F039 and is reapplied to the NLF as irrigation water 

to maintain a moisture content appropriate to promote degradation of applied 

wastes by the indigenous microbial communities. 

The BTRF will follow closure plans for the NLF found in the BTRF Resource 

Conservation and Recovery Act (RCRA) permit (Permit Number 50111-000) once 

the NLF has reached the end of its operating life. ExxonMobil desires to delist 

the NLF underflow so that following NLF closure collected underflow can be 

treated and discharged to the BTRF industrial wastewater treatment plant. 

Details regarding this proposed disposal method will be included in the F039 

Delisting Petition to be submitted to the Environmental Protection Agency 

(EPA) at a later date. 

1.2 SCOPE AND OBJECTIVES 

This SAP describes the methods and procedures that will be utilized during field 

sampling activities and laboratory analysis. The primary objective of the SAP is 

to document the techniques that will be used sample NLF underflow at the BTRF 

and facilitate compliance with the data quality assurance objectives outlined in 

SW-846. 

Where not explicitly described herein, field sampling will be completed in 

accordance with applicable EPA guidance and conventional sampling and 

analytical approaches. 

Additional detail and refinement of Quality Assurance/Quality Control 

(QA/QC) procedures are provided in a Quality Assurance Project Plan (QAPP) 

that serves as a companion document to this SAP but which has been submitted 

as a separate document. 
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2.0 FIELD PROCEDURES AND METHODS 

2.1 UNDERFLOW SAMPLING PROCEDURES AND FREQUENCY 

The underflow collection system is located at the base of the sand layers of the 

NLF’s perched-bed system to collect waters which seep through the soil zone. 

The system consists of approximately 70 two-inch diameter lateral HDPE pipes, 

50 feet apart, which slope into a six-inch diameter collector system which is itself 

sloped at a 1% grade to carry waters to the underflow collection sump located on 

the eastern side of the NLF’s perimeter berm. The lateral (2-inch) pipes are 

perforated to accept the drainage and are wrapped with a geotextile designed to 

filter out fine soil particles from entering the pipes. The pipes are also fitted with 

a cleanout access (Figure 2). 

The reinforced-concrete underflow collection sump is approximately six feet in 

diameter and approximately 15 feet in deep. The sump is equipped with an 

automatically-controlled pump system to remove the underflow as it 

accumulates. The underflow is stored in the frac tanks or Tank 102 and 

reapplied to the NLF via an irrigation system. In the rare event that the NLF is 

too wet for reapplication, the underflow can be transported off site for disposal. 

In the event of equipment failure, the underflow would continue to accumulate 

in the underflow collection sump. To prevent overflow from the system, the 

walls of the sump extend above the natural grade at the sump. The underflow 

would, therefore, back up in the collection system and drainage layer rather than 

overtop the sump. If needed, the system can be pumped. 

The location of the underflow sump where the delisting samples will be 

collected is shown in Figure 3. A 1 1/2 inch diameter by three feet long 

disposable plastic bailer will be used to collect samples of underflow water. 

The disposable bailer will be tied off to a rope that will be lowered into the sump 

until the bailer has been filled with underflow water. Once the bailer is full, it 

will be raised to the surface where sample bottles will be filled by pouring 

underflow water from the bailer into the sample bottles. This procedure will be 

repeated until the necessary number of sample bottles are filled to analyze for 

constituents of concern (COC). The samples bottles will be placed on ice and 

analyzed by ALS Laboratory Group. 

A total of five delisting samples will be collected from the NLF underflow. 

Samples from the underflow sump will be collected once every two weeks 

(bimonthly). For the first sampling event, samples will be collected and 

analyzed for the full suite of F039 constituents listed in Table 1. The four 

following samples will be collected and analyzed for the final list of constituents 

listed in Table 2. 

The COCs included in Table 2 are considered the “final delisting constituents” 

for the NLF underflow. This list of COCs was generated after reviewing 

historical underflow analytical results and wastes applied to the NLF and 
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eliminating constituents that are not of concern for the NLF underflow. The 

“final delisting constituents” remain COCs for the following reasons: 

• The constituent was present in waste historically applied on NLF; 

• The constituent is listed in 40 CFR 261.24 and cannot be discarded per EPA 

delisting guidance; or 

• The constituent was detected in historic underflow sample analysis. 

If a COC is detected in the first sample that is not listed on Table 2 then the COC 

detected would be re-evaluated and be added to the final list of constituents. 

2.2 SAMPLE MANAGEMENT PROCEDURES 

The sample management procedures are an important aspect for collecting and 

tracking analytical samples for characterization of the underflow. The 

underflow samples will be placed immediately into new, laboratory-supplied 

containers and labeled. The label will have unique sample identification, the 

time and date sampled, the parameters to be analyzed, the preservatives (if any), 

and the sampler’s initials. The samples will be placed in a cooler and packed on 

ice (See Section 3.0). 

The sample identification numbers for each sampling effort will appear on 

sample labels, sample-tracking matrix forms, chain-of-custody forms and the 

other applicable documentation used during the sampling activity. The sample 

identification will change when the location changes, but will not change 

because different analyses are requested for the same sample location. For 

example, an underflow sample collected at the same location, date and time for 

total metals and for reactivity would have the same sample identification. 

Sample identification numbers will consist of two components, a sample type 

code and sample number. The following is an examples of completely 

numbered samples, with each component identified: 

Underflow Delisting-01 (MS) 

Underflow Delisting – Underflow sample 

01 – first sample of underflow 

MS – Matrix spike sample 

Underflow Delisting-01 

Underflow Delisting – Underflow sample 

01 – first sampling event of underflow 

2.3 ANALYTICAL REQUIREMENTS 

The underflow samples will be analyzed per standard SW-846 Methods or EPA 

methods as indicated in Table 2. The analytical procedures will be conducted in 

accordance with the QAPP. 

Each sample location will be assigned a two-part sample type code. The first 

part of the code identifies the type of sample, as follows: 

• Underflow Delisting for underflow sample; 
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• Dup for duplicate samples; 

• FB for field blank; 

• TB for trip blank; and 

• MS/MSD for matrix spike and matrix spike duplicate. 

The second part of the code identifies the sample number, as well as if it is a 

Matrix Spike (MS) or Matrix Spike Duplicate (MSD). The sample location 

number will start with 01 and increase consecutively. 

Duplicate samples will be identified as primary samples with fictional sample 

location codes. The sample identification for duplicate samples will be identical 

to that described above. Duplicates will be assigned sequential numbers 

separately from primary samples. They will be numbered consecutively starting 

with 01. 

A chain-of-custody form will be completed for each sample shipment. A copy of 

an example chain-of-custody form is provided in Appendix A. The time and 

date the cooler is relinquished to the courier for the local analytical laboratory 

will be indicated on the chain-of-custody form. 
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3.0 SAMPLE PRESERVATION AND SHIPMENT 

Samples are to be labeled, shipped, and preserved using the following 

procedures: 

• The appropriate amount of chemical preservatives, if any, is added to the 

sample bottles by the laboratory before the bottles are delivered to the site. 

• A sample label is affixed to each sample container. 

• The field sampler records the analytical parameters and required sampling 

information for that sample on the chain-of-custody form. 

• Upon collection, the bottles are placed in ice chests containing packs of 

frozen gel or ice to lower and maintain a sample temperature of 

approximately 4°C. Samples are packed with cushioning material sufficient 

to prevent breakage of glass sample containers during transport. After 

sampling is completed, the samples are transported to the laboratory and 

stored, if necessary, under refrigeration at approximately 4° C. 

• The ice chests containing samples to be analyzed are delivered or picked up 

by the laboratory and signed over to laboratory personnel in accordance with 

chain-of-custody procedures for storage or preparation for analysis. 
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4.0 CHAIN-OF-CUSTODY AND RECORDKEEPING 

These procedures, which conform to those listed in SW-846 or equivalent U.S. 

Environmental Protection Agency (EPA) methods, are intended to document 

sample possession from the time of collection to analysis. For the purpose of 

these procedures, a sample is considered in custody if it is: 

• In one’s actual possession; 

• In view, after being in physical possession; 

• Locked so that no one can tamper with it, after having been in physical 

custody; and 

• In a secured area, restricted to authorized personnel. 

Chain-of-custody procedures include the following: 

• A chain-of-custody similar to that shown in Appendix A is initiated in the 

field. This record is completed with pertinent information, including 

analytical parameters for each different group of sample bottles. The original 

accompanies the samples during transit to the laboratory. 

• Upon sample receipt, the laboratory sample custodian responsible for 

logging in samples completes the chain-of-custody, files a copy, and sends 

the original to the laboratory project manager for the sampling program. A 

copy of the chain-of-custody is included with the analytical results. 

• The following recordkeeping items will supplement the chain-of-custody 

records: 

- Sampling records; 

- Field logbook; and 

- Sample receipt checklist or acknowledgment form from the laboratory. 

Each sample, field measurement, or field decision will be documented in the 

field logbook. Field investigation documentation shall include thorough, 

accurate record keeping. Information pertinent to field measurements or a 

sampling event will be recorded in a bound logbook with consecutively 

numbered pages. Entries in the logbook and on sample documentation forms 

will be made in ballpoint or waterproof ink and corrections will consist of linedout deletions that are initialed and dated. Entries in the logbook will include the 

following, as applicable: 

• Name and title of author, date and time of entry and physical/environmental 

conditions during field activity; 

• Names and addresses of field contacts; 

• Names and responsibilities of field team members; 

• Names and titles of site visitors; 

• Details of the sampling locations (documentation sketches of sampling 

locations may be appropriate); 
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• Information concerning sampling changes, scheduling modification and 

change orders; 

• Date and time of sample collection; 

• Field observations; 

• Sample identification number(s); 

• Sample distribution and transportation (e.g., name of the laboratory and 

overnight delivery service, if used); 

• Decontamination procedures; 

• Summary of daily tasks and documentation on any scope of work changes 

required by field conditions; and 

• Signature of the personnel responsible for observations and date. 

The field logbook will contain sufficient information so that a reviewer can 

reconstruct the sampling activity without relying on the collector's memory. The 

logbooks will be kept in the central project file following completion of the field 

activities. 
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5.0 QUALITY ASSURANCE AND QUALITY CONTROL (QA/QC) 

5.1 EQUIPMENT 

Dedicated sampling equipment is used whenever possible, or equipment is 

decontaminated between uses to reduce the potential for cross-contamination. 

Equipment used for measurement of field parameters is calibrated at the 

beginning and end of each sampling day and, as needed, between sampling 

events. 

5.2 SAMPLE COLLECTION 

The following procedures are used to identify and minimize sources of error in 

sampling and analysis: 

• Trip or field blanks are used to assess for potential cross-contamination at a 

rate of at least one/sampling event. 

• Blind field duplicate samples or split samples are used to assess for 

laboratory accuracy and precision at rates equivalent to standard industry 

practice. 

• Sufficient volume is provided to allow matrix spike and matrix spike 

duplicate analyses, as required by the laboratory. 

5.3 DUPLICATES 

Duplicates of the underflow samples will be submitted for analysis of the 

parameters specified for those samples. Unless otherwise indicated by analytical 

results or other factors, one duplicate sample will be collected every other 

sampling event starting with the second sampling event for a total of 2 duplicate 

samples. These duplicates will be assigned separate sample identification 

numbers from the actual field sample such that the laboratory will not be able to 

identify that it is the same as one of the other samples. 

Duplicate samples are collected in addition to, and at the same time, as an 

investigative sample. Field replication provides information on the precision 

and homogeneity of sampling, handling, shipping, storage, preparation, and 

analysis techniques because duplicate samples ideally are equally representative 

of the sample matrix at that point in time and are similarly influenced by 

conditions at the time of sampling, handling, shipping, storage, preparation and 

analysis. Duplicate samples will be submitted to the laboratory “blind” with 

fictional identities. 
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5.4 MATRIX SPIKES AND MATRIX SPIKE DUPLICATES 

As part of the laboratory’s internal QA/QC procedures, MS/MSD samples will 

be analyzed to provide a measurement of matrix effects on analytical 

procedures. An MS/MSD sample will be collected during one sampling event in 

addition to, and at the same time as, one of the investigative samples. One 

MS/MSD sample will be collected during the course of the assessment. 
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6.0 MANAGEMENT OF INVESTIGATION-DERIVED WASTE 

The primary types of investigation-derived waste that will be produced during 

the field sampling activities include: 

• disposable personal protective equipment (PPE) and disposable sampling 

equipment 

Used PPE and disposable sampling equipment will be properly managed per 

state and federal regulatory requirements. 
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REFERENCES 

EPA, SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. 

EPA 2000. EPA RCRA Delisting Program Guidance Manual for the Petitioner, 

United States Environmental Protection Agency, March 2000. 
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Tables 

December 16, 2009 

Project No. 0102974 

Environmental Resources Management Southwest, Inc. 

15810 Park Ten Place, Suite 300 

Houston, Texas 77084-5140 

(281) 600-1000
TABLE 1

Analytical Methods

F039 Waste Delisting

ExxonMobil Baytown Refinery

Baytown, Texas

Metals SW 846 Method

Mercury SW 7471A

Antimony SW 7471A

Arsenic SW 7471A

Barium SW 7471A

Beryllium SW 7471A

Cadmium SW 7471A

Chromium SW 7471A

Lead SW 7471A

Nickel SW 7471A

Selenium SW 7471A

Silver SW 7471A

Thallium SW 7471A

Vanadium SW 7471A

VOCs

1,1,1,2-Tetrachloroethane SW 8260

1,1,1-Trichloroethane SW 8260

1,1,2,2-Tetrachloroethane SW 8260

1,1,2-Trichloroethane SW 8260

1,1-Dichloroethane SW 8260

1,1-Dichloroethylene SW 8260

1,2,3-Trichloropropane SW 8260

1,2-Dibromoethane SW 8260

1,2-Dichloroethane SW 8260

1,2-Dichloropropane SW 8260

1,4-Dioxane SW 8260

Acetone SW 8260

Acetonitrile SW 8260

Acrolein SW 8260

Acrylonitrile SW 8260

Benzene SW 8260

Bromodichloromethane SW 8260

Bromoform SW 8260

Carbon disulfide SW 8260

Carbon tetrachloride SW 8260

Chlorobenzene SW 8260

Chlorodibrmomethane (Dibromochloromethane) SW 8260

Chloroethane SW 8260

Chloroform SW 8260

cis-1,3-Dichloropropene SW 8260

Dibromomethane (Methylene bromide) SW 8260

Dichlorodifluoromethane SW 8260

Ethyl methacrylate SW 8260

Ethylbenzene SW 8260

Iodomethane (Methyl iodide) SW 8260

Isobutyl alcohol SW 8260

Methyl methacrylate SW 8260

Methylene chloride SW 8260

Pentachlorobenzene SW 8260

Tetrachloroethylene SW 8260

trans-1,2-Dichloroethylene SW 8260

trans-1,3-Dichloropropene SW 8260

Trichloroethylene SW 8260

Trichloromonofluoromethane SW 8260

Vinyl chloride SW 8260

Xylene SW 8260

1,2-Dibromo-3-chloropropane SW 8260

Ethylene oxide SW 8260

Page 1 of 4

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TABLE 1 (Cont'd)

Analytical Methods

F039 Waste Delisting

ExxonMobil Baytown Refinery

Baytown, Texas

VOCs continued SW 846 Method

Methacrylonitrile SW 8260

Methanol SW 8260

Methyl bromide SW 8260

Methyl ethyl ketone SW 8260

Methyl isobutyl ketone (4-Methyl-2-pentanone) SW 8260

Toluene SW 8260

2-Chloro-1.3-butadiene (Chloroprene) SW 8260

Cyclohexanone SW 8260

3-Chloropropylene (Allyl chloride) SW 8260

Ethyl acetate SW 8260

Ethyl cyanide (Propanenitrile) SW 8260

Ethyl ether SW 8260

m-Dichlorobenzene SW 8260

o-Dichlorobenzene SW 8260

p-Dichlorobenzene SW 8260

Methyl chloride SW 8260

n-butyl alcohol SW 8260

SVOCs SW 846 Method

1,2,4,5-Tetrachlorobenzene SW 8260

1,2,4-Trichlorobenzene SW 8260

1,2-Diphenylhydrazine SW 8260

2,3,4,6-Tetrachlorophenol SW 8260

2,4,5-Trichlorophenol SW 8260

2,4,6-Trichlorophenol SW 8260

2,4-Dichlorophenol SW 8260

2,4-Dimethylphenol SW 8260

2,4-Dinitrophenol SW 8260

2,4-Dinitrotoluene SW 8260

2,6-Dichlorophenol SW 8260

2,6-Dinitrotoluene SW 8260

2-Acetylaminofluorene SW 8260

2-Chloronaphthalene SW 8260

2-Chlorophenol SW 8260

2-Naphthylamine SW 8260

3-Methylcholanthrene SW 8260

4-Aminobiphenyl SW 8260

4-Bromophenyl phenyl ether SW 8260

5-Nitro-o-toluidine SW 8260

Acenaphthene SW 8260

Acenaphthylene SW 8260

Acetophenone SW 8260

Aniline SW 8260

Anthracene SW 8260

Benzo(a)anthracene SW 8260

Benzo(a)pyrene SW 8260

Benzo(b)fluoranthene SW 8260

Benzo(ghi)perylene SW 8260

Benzo(k)fluoranthene SW 8260

Bis(2-chloroethoxy)methane SW 8260

Bis(2-chloroethyl)ether SW 8260

Bis(2-cloroisopropyl)ether SW 8260

Bis(2-ethylhexyl)phthalate SW 8260

Butyl benzyl phthalate SW 8260

Chlorobenzilate SW 8260

Chrysene SW 8260

Di-n-butyl phthalate SW 8260

Di-n-octyl phthalate SW 8260

Page 2 of 4

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TABLE 1 (Cont'd)

Analytical Methods

F039 Waste Delisting

ExxonMobil Baytown Refinery

Baytown, Texas

SVOCs continued SW 846 Method

Dibenz(a,h)anthracene SW 8260

Diethyl phthalate SW 8260

Dimethyl phthalate SW 8260

Diphenylamine SW 8260

Fluoranthene SW 8260

Fluorene SW 8260

Hexachlorobenzene SW 8260

Hexachlorobutadiene SW 8260

Hexachlorocyclopentadiene SW 8260

Hexachloroethane SW 8260

Hexachloropropene SW 8260

Indeno(1,2,3-cd)pyrene SW 8260

Isodrin SW 8260

Isosafrole SW 8260

Kepone SW 8260

Methapyrilene SW 8260

Methyl methanesulfonate SW 8260

Naphthalene SW 8260

Nitrobenzene SW 8260

N-Nitrosodi-n-butylamine SW 8260

N-Nitrosomethylethalamine SW 8260

N-Nitrosomorpholine SW 8260

N-Nitrosopiperidine SW 8260

N-Nitrosopyrrolidine SW 8260

Pentachloronitrobenzene SW 8260

Pentachlorophenol SW 8260

Phenacetin SW 8260

Phenanthrene SW 8260

Phenol SW 8260

Pronamide SW 8260

Pyrene SW 8260

Pyridine SW 8260

Safrole SW 8260

1,1,2-Trichloro-1,2,2-trifluoroethane SW 8260

1,3-Phenylenediamine SW 8260

1,4-Dinitrobenzene SW 8260

2-sec-Butyl-4,6-dinitrophenol (Dinoseb) SW 8260

4,4-methylene bis (2-chloroaniline) SW 8260

Aramite SW 8260

Chlorobenzilate SW 8260

Dieldrin SW 8260

Disulfoton SW 8260

Famphur SW 8260

m-Cresol SW 8260

methyl parathion SW 8260

o-Anisidine (2-methoxyaniline) SW 8260

o-Cresol SW 8260

Parathion SW 8260

p-cresidine SW 8260

p-Cresol SW 8260

4,6-Dinitro-o-cresol SW 8260

p-Nitroaniline SW 8260

p-Nitrophenol SW 8260

Di-n-propylnitrosamine (N-Nitrosodipropylamine) SW 8260

Diphenylnitrosamine (N-Nitrosodiphenylamine) SW 8260

Dibenz(a,e)pyrene SW 8260

p-Chloroaniline SW 8260

p-Chloro-m-cresol SW 8260

Phorate SW 8260

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TABLE 1 (Cont'd)

Analytical Methods

F039 Waste Delisting

ExxonMobil Baytown Refinery

Baytown, Texas

Organochlorine Pesticides SW 846 Method

4,4'-DDD SW 8081

4,4'-DDE SW 8081

4,4'-DDT SW 8081

Aldrin SW 8081

alpha-BHC SW 8081

beta-BHC SW 8081

Chlordane SW 8081

delta-BHC SW 8081

Dieldrin SW 8081

Endosulfan I SW 8081

Endosulfan II SW 8081

Endosulfan sulfate SW 8081

Endrin SW 8081

Endrin aldehyde SW 8081

Organochlorine Pesticides SW 846 Method

gamma-BHC SW 8081

Heptachlor SW 8081

Heptachlor epoxide SW 8081

Methoxychlor SW 8081

Toxaphene SW 8081

o,p'-DDD SW 8081

o,p'-DDE SW 8081

o,p'-DDT SW 8081

Chlorinated Herbicides SW 846 Method

2,4,5-T (Trichlorophenoxyacetic acid) SW 8151

Silvex SW 8151

Dioxins/Furans SW 846 Method

1,2,3,4,6,7,8,9-Octachlorodibenzofuran 8290

1,2,3,4,6,7,8,9-Octachlorodibenzo-p-dioxin 8290

1,2,3,4,6,7,8-Heptachlorodibenzofuran 8290

1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin 8290

1,2,3,4,7,8,9-Heptachlorodibenzofuran 8290

Hexachlorodibenzofurans 8290

Hexachlorodibenzo-p-dioxins 8290

Pentachlorodibenzofurans 8290

Pentachlorodibenzo-p-dioxins 8290

Tetrachlorodibenzofurans 8290

Tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) 8290

Polychlorinated dibenzofurans 8290

Polychlorinated dibenzo-p-dioxins 8290

Cyanide SW 846 Method

Cyanide (Total) (Amenable) 335.4C

Fluoride SW 846 Method

Fluoride 4500 FC

Sulfide SW 846 Method

Sulfide 4500 SE

PCB SW 846 Method

Polychlorinated biphenyls 8082

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Constituent Reason

Metals

Arsenic Constituent in waste applied to NLF, 

Constituent in 40 CFR 261.24

Barium Detected in Delisting Sample, 

Constituent in 40 CFR 261.24

Cadmium Constituent in 40 CFR 261.24

Chromium Constituent in waste applied to NLF, 

Constituent in 40 CFR 261.24

Cobalt Detected in historical underflow samples

Copper Detected in historical underflow samples

Lead Constituent in waste applied to NLF, 

Constituent in 40 CFR 261.24

Lithium Detected in historical underflow samples

Mercury Constituent in 40 CFR 261.24

Manganese Detected in historical underflow samples

Molybdenum Detected in historical underflow samples

Selenium Constituent in 40 CFR 261.24

Silver Constituent in 40 CFR 261.24

Zinc Detected in historical underflow samples

Semivolatiles

2,4-Dinitrotoluene Constituent in 40 CFR 261.24

2,4,5-Trichlorophenol Constituent in 40 CFR 261.24

2,4,6-Trichlorophenol Constituent in 40 CFR 261.24

3-Methylcholanthrene Constituent in waste applied to NLF

Benzo(a)anthracene Constituent in waste applied to NLF

Benzo(b)fluoranthene Constituent in waste applied to NLF

Benzo(a)pyrene Constituent in waste applied to NLF

Benzo(k)fluoranthene Constituent in waste applied to NLF

Chrysene Constituent in waste applied to NLF

o-Cresol Constituent in 40 CFR 261.24

m-Cresol Constituent in 40 CFR 261.24

p-Cresol Constituent in 40 CFR 261.24

Cresol Constituent in 40 CFR 261.24

Hexachlorobenzene Constituent in 40 CFR 261.24

Hexachlorbutadiene Constituent in 40 CFR 261.24

Hexachloroethane Constituent in 40 CFR 261.24

Nitrobenzene Constituent in 40 CFR 261.24

Pentachlorophenol Constituent in 40 CFR 261.24

Pyridine Constituent in 40 CFR 261.24

Volatiles

1,1-Dichloroethylene Constituent in 40 CFR 261.24

1,2-Dichloroethane Constituent in 40 CFR 261.24

1,4-Dichlorobenzene Constituent in 40 CFR 261.24

Benzene Constituent in waste applied to NLF, 

Constituent in 40 CFR 261.24

Carbon tetrachloride Constituent in 40 CFR 261.24

Chlorobenzene Constituent in 40 CFR 261.24

Chloroform Constituent in 40 CFR 261.24

Methyl ethyl ketone Constituent in 40 CFR 261.24

Tetrachloroethylene Constituent in 40 CFR 261.24

Trichloroethylene Constituent in 40 CFR 261.24

Vinyl chloride Constituent in 40 CFR 261.24

Miscellaneous

Cyanide Detected in historical underflow samples

Fluoride Detected in Pre-delisting sample,

Detected in historical underflow samples

Phosphorous Detected in historical underflow samples

Baytown, Texas

TABLE 2

Final North Landfarm Underflow Delisting Constituent List

ExxonMobil Baytown Refinery

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Texas Registered Engineering Firm F-2393

Figures 

December 16, 2009 

Project No. 0102974 

Environmental Resources Management Southwest, Inc. 

15810 Park Ten Place, Suite 300 

Houston, Texas 77084-5140 

(281) 600-1000
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Example Chain-of-Custody Form 

Appendix A 

December 16, 2009 

Project No. 0102974 

Environmental Resources Management Southwest, Inc. 

15810 Park Ten Place, Suite 300 

Houston, Texas 77084-5140 

(281) 600-1000 
g:\2010\0102974\15096H(Att1-AppA).pdf
 G:\2010\0102974\15096H Delisting Petition.doc 

Quality Assurance Project Plan 

Attachment 2 

August 12, 2010 

Project No. 0102974 

Environmental Resources Management Southwest, Inc. 

15810 Park Ten Place, Suite 300 

Houston, Texas 77084-5140 

(281) 600-1000 
Quality Assurance Project Plan: 

F039 Waste Delisting 

ExxonMobil Refining & Supply Company 

Baytown, Texas 

December 16, 2009 

www.erm.com

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TABLE OF CONTENTS 

1.0 INTRODUCTION 1

1.1 SITE AND PROCESS DESCRIPTION 1

1.2 SCOPE AND OBJECTIVES 2

2.0 PROJECT ORGANIZATION AND RESPONSIBILITY 3

2.1 PROJECT ORGANIZATION 3

2.2 RESPONSIBILITY FOR QUALITY ASSURANCE AND 

QUALITY CONTROL 3

2.2.1 ExxonMobil Refining & Supply Company 3

2.2.2 Environmental Resources Management 3

2.2.3 Laboratory Subcontractors 4

3.0 DATA QUALITY OBJECTIVES 5

3.1 INTENDED DATA USE 5

3.2 FIELD INVESTIGATION AND TESTING OBJECTIVES 5

3.3 DATA QUALITY/MEASUREMENT OBJECTIVES 5

3.3.1 Representativeness 6

3.3.2 Precision and Accuracy 6

3.3.3 Completeness 7

3.3.4 Comparability 7

3.4 ANALYTICAL METHODS AND DQOS 8

4.0 SAMPLING PROCEDURES 9

5.0 SAMPLE HANDLING, DOCUMENTATION, AND CUSTODY 10

6.0 QUALITY ASSURANCE PROCEDURES FOR ANALYTICAL 

LABORATORY ACTIVITIES 11

7.0 QUALITY ASSURANCE PROCEDURES FOR FIELD ACTIVITIES 12

7.1 INTERNAL QUALITY CONTROL 12

7.2 EQUIPMENT 13

7.2.1 Sampling Equipment Decontamination 13

7.2.2 Supplies and Consumables 13

7.3 FIELD DOCUMENTATION 13

7.4 PROCEDURES TO ASSESS PRECISION, ACCURACY, 

COMPLETENESS AND COMPARABILITY 13

7.5 CORRECTIVE ACTION 14
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TABLE OF CONTENTS (Cont'd) 

8.0 DATA REDUCTION, ASSESSMENT AND VALIDATION 15

8.1 LABORATORY DATA 15

8.2 DATA MANAGEMENT 15

8.3 DATA VALIDATION 16

9.0 AUDITS 17

9.1 FIELD SYSTEMS AUDIT 17

9.2 LABORATORY AUDIT 17

10.0 PREVENTIVE MAINTENANCE 18

11.0 CORRECTIVE ACTION 19

11.1 IMMEDIATE CORRECTIVE ACTION 19

11.2 LONG-TERM CORRECTIVE ACTION 19

REFERENCES 20

APPENDICES 

A ANALYTICAL LABORATORY QUALITY ASSURANCE PLAN 

(ALS Laboratory Group.) 
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TABLE OF CONTENTS (Cont'd) 

List of Tables 

1 Constituents of Concern and Analytical Methods 

List of Figures 

1 Site Location Map 

2 Project Organization Chart for Delisting Activities 
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1.0 INTRODUCTION 

Environmental Resources Management-Southwest, Inc. prepared this Quality 

Assurance Project Plan (QAPP) behalf of ExxonMobil Refining and Supply 

Company (ExxonMobil). This QAPP describes the field and laboratory 

procedures that will be implemented during underflow sampling at the North 

Landfarm (NLF) at the ExxonMobil Baytown Refinery (BTRF). Ultimately, this 

underflow sampling data will be incorporated into a F039 waste delisting 

petition to be submitted to the United States Environmental Protection Agency 

(EPA) Region 6. 

The sampling methods, analytical testing, frequency and methods to be utilized 

during the delisting process are described in the Sampling and Analysis Plan 

(SAP); submitted under separate cover. This plan was prepared in accordance 

with EPA guidance including: 

• EPA Requirements for Quality Assurance Project Plans (EPA QA/R-5) 

• Conventionally-accepted Quality Assurance and Quality Control (QA/QC) 

objectives. 

1.1 SITE AND PROCESS DESCRIPTION 

The ExxonMobil Baytown Complex is located in Baytown, Texas, approximately 

25 miles east of Houston (Figure 1). The Baytown Complex, is comprised of the 

ExxonMobil Baytown Refinery (BTRF), the ExxonMobil Baytown Chemical Plant 

(BTCP), the ExxonMobil Basic Chemicals and Intermediates Technology (BCIT) 

and the ExxonMobil Baytown Olefins Plant (BOP) and occupies approximately 

3,386 acres, most of which is situated south of Decker Drive (Spur 330) about 

four miles south of the Interstate Highway 10 exit. The Complex Administration 

Building (CAB) is located at 5000 Bayway Drive. 

The NLF is situated in the northern portion of the BTRF, just west of San Jacinto 

Avenue (Figure 1). The main access road into the NLF area extends east from an 

entry control gate to San Jacinto Avenue. The unit encompasses 44 acres, 

although 15.85 acres are in actual waste service. Internal access to the plots on 

the landfarm is the spine road which is located in the center of the North 

Landfarm. The center of the landfarm is elevated where the internal access road, 

the spine road, is located. The landfarm surface slopes at a 1% grade to the north, 

south, and east. Drainage ditches collect run off at the base of each sloped 

portion of the NLF. The surface of the NLF and the run-off collection ditches are 

surrounded by a perimeter berm. 

Underflow is aqueous solution which seeps through the treatment zone and is 

collected and removed by the underflow management system to reduce the 

potential for downward migration. The amount of water which seeps through 

the treatment zone is a function of the transmissivity of the soils of the treatment 

zones and the amount of water applied to the NLF plots. During periods of 

relative dryness within the treatment zone, water exists in the soils tightly bound 

to the soil particles. During these dry periods seepage is minimal. When free 
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2

water is available within the treatment zone, seepage proceeds at slow velocities. 

Because the clays at the base of the NLF were selected and compacted to produce 

a permeability of approximately 2 x 10-7 cm/sec (1.7 in/day) seepage is 

effectively reduced. Currently, NLF underflow is managed as a listed hazardous 

waste with EPA waste code F039 and is reapplied to the NLF as irrigation water 

to maintain a moisture content appropriate to promote degradation of applied 

wastes by the indigenous microbial communities. 

The BTRF will follow closure plans for the NLF found in the BTRF Resource 

Conservation and Recovery Act (RCRA) permit (Permit Number 50111-000) once 

the NLF has reached the end of its operating life. ExxonMobil desires to delist 

the NLF underflow so that following NLF closure collected underflow can be 

treated and discharged to the BTRF industrial wastewater treatment plant. 

Details regarding this proposed disposal method will be included in the F039 

Delisting Petition to be submitted to the Environmental Protection Agency 

(EPA) at a later date. 

1.2 SCOPE AND OBJECTIVES 

The scope of the QAPP represents the foundation of QA/QC that will be utilized 

to assess and verify that the sampling, testing, and analysis activities are 

executed in a manner consistent with applicable EPA guidance document EPA 

Requirements for Quality Assurance Project Plans (EPA QA/R-5) and conventional 

QA/QC objectives. The objectives of QAPP include: 

• assessing the data generated in terms of representativeness, precision, 

accuracy, completeness and comparability; and 

• documenting the assessment results consistent with the fundamental 

guidelines of the delisting process. 

This QAPP presents the following information for the sampling and analysis of 

the underflow at the North Landfarm facility. 

Project Organization and Responsibility Section 2 

Data Quality Objectives Section 3 

Sampling Procedures Section 4 

Sample Handling, Documentation and Custody Section 5 

Quality Assurance Procedures for Laboratory Activities Section 6 

Quality Assurance Procedures for Field Activities Section 7 

Data Reduction, Assessment And Validation Section 8 

Audits Section 9 

Preventive Maintenance Section 10 

Corrective Action Section 11 
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2.0 PROJECT ORGANIZATION AND RESPONSIBILITY 

This section describes the project organization and specifies personnel 

responsibilities. The project organization presented in this section has been 

developed to guide and assess the quality of sampling and testing procedures for 

obtaining reliable data, and to facilitate effective communication and decisionmaking during the project. 

2.1 PROJECT ORGANIZATION 

The principal entities that are involved in the waste delisting process for the 

facility, and their respective roles, include the following: 

• EPA - Review and approval of waste delisting deliverables; 

• ExxonMobil – Petitioner for waste delisting; and 

• Environmental Resources Management (ERM) – Environmental consultant 

performing waste characterization, managing the quality of the analytical 

data and assisting with the preparation of the waste delisting application. 

• ALS Laboratories, Inc. (ALS) – Analytical laboratory performing analysis of 

underflow samples taken at the NLF. 

Figure 2 shows the organization of the project team for the waste delisting 

activities. 

2.2 RESPONSIBILITY FOR QUALITY ASSURANCE AND QUALITY CONTROL 

The responsibilities of key members of the project team are summarized in the 

following subsections. 

2.2.1 ExxonMobil Refining & Supply Company 

As applicant for the waste delisting application, ExxonMobil is responsible for 

complying with EPA’s procedures and responding to comments, if any, 

regarding EPA’s review of the application. 

2.2.2 Environmental Resources Management 

ERM is responsible for managing the scope and schedule of the delisting 

process. As part of this responsibility ERM will: 

• Maintain the budget and schedule of work; 

• Provide direction to staff and subcontractors; 

• Provide necessary equipment, facilities, and staffing are available to 

implement the project; 

• Develop and execute QA/QC activities; 

• Coordinate with the laboratory in scheduling analyses; 
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• Assess compliance with the QAPP; 

• Evaluate corrective measures if problems occur; 

• Coordinate field activities; and 

• Assist in the preparation of the waste delisting petition. 

2.2.3 Laboratory Subcontractors 

ALS Laboratory Group (ALS) of Houston, Texas has been selected to perform the 

analytical testing for the waste delisting process. 
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3.0 DATA QUALITY OBJECTIVES 

This section presents the intended data usage and QA objectives for the 

sampling and analysis that will be performed during the waste delisting process. 

The overarching Data Quality Objective (DQO) is to generate data that is suitable 

for making decisions regarding the classification of the underflow water from 

the NLF. 

3.1 INTENDED DATA USE 

The data collected during field activities will be used to characterize the 

underflow at the NLF. The data collected during the field activities will be 

compared with EPA defined standards to assess if the underflow:

• contains the constituents of concern for the listed waste F039; 

• exhibits the hazardous waste characteristics listed in 40 CFR 261, Subpart C 

(i.e., characteristics of ignitability, corrosivity, reactivity, or toxicity); and/or 

• exhibits any other factors that could cause it to be considered hazardous. 

The analytical results will be presented in the F039 waste delisting petition to the 

EPA. 

3.2 FIELD INVESTIGATION AND TESTING OBJECTIVES 

The primary objectives of the field investigation and testing objectives include: 

• collecting representative samples of the underflow; and 

• assessing the analytical data from the underflow for use in the delisting 

petition. 

3.3 DATA QUALITY/MEASUREMENT OBJECTIVES 

The purpose of DQOs is to establish target levels data that are collected (through 

the sampling and analytical program) can be compared to assess if they are of 

appropriate quality to produce documented, consistent, and technicallydefensible results. These results ultimately will define the characteristics and 

constituent concentrations present in the underflow. Accordingly, in order to 

verify that chemical analyses and laboratory QA/QC is consistent, a laboratory 

that follows the National Environmental Laboratory Accreditation Conference 

(NELAC) standards and follows the United States Environmental Protection 

Agency (USEPA) SW-846 test methods will be utilized. 

The quality of measurements made and the data generated will be evaluated in 

terms of the following characteristics: 

• Representativeness; 

• Precision and Accuracy; 
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• Completeness; and 

• Comparability. 

Specific objectives for each characteristic are established to develop sampling 

protocols and identify applicable documentation, sample handling procedures, 

and measurement system procedures. These objectives are established based on 

site conditions, objectives of the project, and knowledge of available 

measurement systems. 

In addition, the following criteria for chemical sample handling and analysis will 

help attain the DQOs: 

• Standard EPA chain-of-custody procedures (which are described in later 

sections of this report); and 

• Analytical testing will be performed according to SW-846 methods. 

3.3.1 Representativeness 

Measurements will be made so that analytical results are as representative as 

practical of the actual field conditions. Sampling protocols will be utilized to 

help assure that samples collected are reasonably representative of the media 

present in the field. 

Sample handling protocols, including such tasks as storage, transportation, and 

preservation, will be used to protect the representativeness of the samples 

gathered during the project. Proper documentation in the field and the 

laboratory will verify whether protocols are followed, and whether sample 

identification and integrity are preserved. 

Representativeness will be assessed also by comparing the results of field 

duplicates to assess the variability in the analytical results. The results of QC 

blanks will be examined for evidence of contamination unrelated to the site on 

sampling activities. Such contamination may be cause for invalidation or 

qualification of affected samples. Sample analytical data classified as 

“questionable” or “qualitative” by any of the above criteria may be invalidated. 

3.3.2 Precision and Accuracy 

Precision is a characteristic that reflects the ability to replicate a previously 

obtained value using identical testing procedures, while accuracy reflects the 

ability to obtain a value that equals, or approaches with certain predetermined 

limits, the true value of a certain phenomenon. DQOs for precision and accuracy 

are established under the Contract Laboratory Program (CLP) guidelines for 

each major parameter to be measured during the project. 
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Accuracy measurements will be performed by the contract laboratory on 

fortified samples as specified in Appendix A. Duplicate samples will be 

collected as defined in the SAP. Precision of sample collection can be measured 

by comparing analytical results of samples and duplicate samples. The variation 

in results is a measure of precision. Precision can be expressed as the relative 

percent difference (RPD), which is determined using the formula shown in 

Appendix A (and in SW-846). 

The precision and accuracy control limits (in terms of spike recoveries, replicate 

results, etc.) that must be met for the Routine Analytical Services (RAS) 

analytical data to be considered acceptable are established under CLP 

guidelines. Appendix A provides acceptable precision and accuracy limits for 

waste delisting sampling activities. These control limits for accuracy and 

precision will be utilized to identify outliers (data results outside the specified 

control limits). If outliers occur or if contamination is detected in the blanks, the 

corresponding analytical results will be flagged as follows: 

• The problem will be discussed in the data validation report. (Including a list 

of the potentially affected samples); 

• The problem and its implications will be discussed in the appropriate report; 

and 

• The compounds will be noted and explanatory test included in the summary 

table. 

3.3.3 Completeness 

The characteristic of completeness is a measure of the amount of valid data (or 

samples) obtained compared to the amount that was specified to be obtained 

under normal conditions. The objective for completeness is to provide enough 

valid data to ensure the goals of the field investigation are met. 

3.3.4 Comparability 

The characteristic of comparability expresses the confidence that one set of 

analytical data may be compared with another. Data sets that can be used for 

comparison include results of studies conducted previously in the area. 

Comparability is maintained by use of standard analytical methods, and units 

consistent with those used in previous studies. Also, the personnel involved in 

data acquisition and reduction must operate measurement systems within the 

calibrated range of the particular instrument as well as utilize analytical 

methodologies that produce comparable results. 

The comparability of field investigation tasks (e.g., underflow sampling 

technique) will be maintained by following the applicable EPA Technical 

Guidance documents, and/or the SAP. 
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3.4 ANALYTICAL METHODS AND DQOS 

Analytical testing will be performed according to SW-846 methods. Table 1 of 

this QAPP provides a summary of various analytical methods that are specified 

for use during the waste delisting activities. The QA manuals included in 

Appendix A of this QAPP enlist the numerical DQOs for the specified methods 

listed in Table 1. 
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4.0 SAMPLING PROCEDURES 

The objective of underflow sampling procedures is to obtain samples and 

measurements that are representative of the medium being investigated. 

Through the use of proper sampling tools, sampling techniques, and equipment 

decontamination procedures, the potential for cross contamination due to trace 

levels of chemicals will be reduced. 

These procedures are described further in the SAP. 
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5.0 SAMPLE HANDLING, DOCUMENTATION, AND CUSTODY 

The purpose of specific procedures for sample handling, documentation and 

custody is to maintain the integrity of samples during collection, transportation, 

analysis and reporting. These procedures are necessary to validate the history of 

sample data, from collection through reporting, by providing adequate 

documentation. 

The sample handling, documentation and custody procedures are provided in 

the SAP. QA/QC checks will be performed during the field activities to assess 

whether the procedures elaborated in the SAP are followed. A designated field 

person will perform the QA/QC check prior to packaging the samples and 

transportation to the designated laboratory. 
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6.0 QUALITY ASSURANCE PROCEDURES FOR ANALYTICAL LABORATORY 

ACTIVITIES 

ALS will perform the underflow analysis during the delisting activities. A copy 

of ALS’s laboratory Quality Assurance Manual is provided in Appendix A. This 

plan includes the laboratory’s internal QA/QC procedures that cover the aspects 

of QA/QC during implementation of laboratory procedures. The technical 

quality systems that are described in the Quality Assurance Manual can be found 

in Appendix A 
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7.0 QUALITY ASSURANCE PROCEDURES FOR FIELD ACTIVITIES 

This section describes the QA/QC procedures related to field activities during 

the collection, handling, labeling, packaging, preservation, and custody of 

samples for chemical analysis. These procedures also are described in the SAP. 

Field QA/QC samples will be used to verify that sample collection and handling 

do not affect the quality of samples that will be subjected to chemical analyses. 

This section discusses the preparation and collection frequency of field QA/QC 

samples consisting of trip blanks, duplicates, matrix spike/matrix spike 

duplicate and equipment blanks for underflow. This section also provides a 

general guidance on maintaining QA/QC on the subsequent activities to ensure 

the goals of the field activities are met. 

7.1 INTERNAL QUALITY CONTROL 

Field QA/QC samples will follow the procedures set forth in Section 5.0 of this 

report and in accordance with the SAP. The required analyses and the amount 

of sample needed to complete the analyses will be evaluated prior to sampling. 

The required quantity of sample matrix to perform the analyses will be collected. 

Duplicates - Five underflow samples will be collected during the delisting 

petition preparation project. Unless otherwise indicated by analytical results or 

other factors, one duplicate sample will be collected every other sampling event, 

beginning with the second sampling event, for a total of two duplicates. These 

duplicates will be assigned separate sample identification numbers from the 

actual field sample such that the laboratory will not be able to identify that this is 

the same as one of the other samples. The underflow duplicates will be 

submitted for the same analysis as underflow samples. 

Equipment Blanks – An equipment blank will not be collected in the field since 

dedicated sampling equipment will not be used to collected the underflow 

samples. During each sampling event a new disposable bailer will be used to 

collect the underflow samples. 

Matrix Spike/Matrix Spike Duplicate (MS/MSD) - As part of the laboratory’s 

internal QA/QC procedures, MS/MSD samples will be analyzed to provide a 

measurement of matrix effects on analytical procedures. An MS/MSD sample 

will be collected during one sampling event in addition to, and at the same time 

as, one of the investigative samples. One MS/MSD sample will be collected 

during the course of the investigation 
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7.2 EQUIPMENT 

Appropriate tools and equipment will be utilized for collecting samples during 

the field investigations. Using the correct equipment for sampling is important 

in meeting the objectives of QA/QC. Laboratory supplied equipment such as 

sample containers are generally uncontaminated. However, a simple visual 

QA/QC check of any containers in cases that were opened may identify certain 

potential issues. Preprinted labels with relevant information will be ordered 

from the laboratory to maintain consistency in identification of the samples and 

to prevent any errors in marking the bottles. 

7.2.1 Sampling Equipment Decontamination 

The sample tool (disposable bailer) that will be used for the sampling events are 

disposable. A new disposable bailer will be used for each sampling event which 

will reduce the potential for cross-contamination of samples and will preserve 

the integrity and representativeness of the field conditions. 

7.2.2 Supplies and Consumables 

Sampling tools required for the collection of the samples will be inspected prior to the 

sampling event. Initially the packages in which the tools are supplied will be 

inspected. If there is any indication that the packages are torn or previously opened, 

these tools will not be utilized and will be discarded. Standard material such as 

sample containers, and distilled water will be inspected for tamper proof seals. If the 

seals appear to be broken, the material will not be used in the collection of the 

samples. Reuseable equipment will be decontaminated prior to, and between the 

uses as specified in the SAP. 

7.3 FIELD DOCUMENTATION 

Field logs, documentation forms, and calculation work sheets (if any) utilized 

during the field investigations will be maintained accurately and in accordance 

with the requirements of the SAP. Copies of field logs will be included in the 

project reports as appropriate. 

7.4 PROCEDURES TO ASSESS PRECISION, ACCURACY, COMPLETENESS AND 

COMPARABILITY 

Quantitative levels for precision and accuracy have not been specified for field 

measurements because field instruments will not be used in the underflow sampling 

process. 

 
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7.5 CORRECTIVE ACTION 

If QA audits of data result in detection of unacceptable data, ERM will be 

responsible for developing and initiating corrective action. Corrective action for 

sampling procedures may include evaluating and amending sampling procedures, 

or re-sampling (see section 11 for additional details regarding potential corrective 

action). 
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8.0 DATA REDUCTION, ASSESSMENT AND VALIDATION 

8.1 LABORATORY DATA 

Reduction of laboratory measurements and laboratory reporting of analytical 

parameters will be in accordance with the procedures specified for each 

analytical method (i.e., perform laboratory calculations in accordance with the 

method-specified procedure). Upon receipt of the laboratory data, the 

designated project team member will execute the following reduction, 

assessment and reporting scheme: 

• Laboratory data will be screened for inclusion and frequency of the 

necessary QC supporting information (i.e., detection limit verification, initial 

calibration, continuing calibration, duplicates, spikes, reagent blanks). QC 

information not included, or of insufficient frequency, will be cause to 

designate the affected measurement data as qualified or rejected. Requests 

for reanalysis or for additional QC supporting information can be made at 

this point. 

• QC supporting information will then be screened for QC data outside 

established control limits and, if out-of-control data are discovered, for 

appropriate corrective action. Certain out-of-control data without 

appropriate corrective action will be cause to designate the affected 

measurement data as qualified or rejected. Requests for re-analysis can be 

made at this point. 

For the other out-of-control QC samples and criteria, either samples are assigned 

laboratory flags qualified per the CLP Statements of Work or no corrective action 

is specified. This includes serial dilution, matrix spikes and duplicates, and 

EPA-approved standards. 

Thus, it is recognized that, if a laboratory is operating per protocol and no error 

or anomaly has occurred during sample preparation and analysis, the data were 

generated by a system that was in control. The existence of qualified results 

does not automatically invalidate data. This latter point is repeatedly 

emphasized in the EPA Functional Guidelines for Evaluating Inorganics 

Analysis (EPA 1988) and is inherently acknowledged by the very existence of the 

data validation/flagging guidelines. 

The goal to produce the best possible data does not necessarily mean producing 

data without QC qualifiers. Some qualifiers can provide useful information. 

8.2 DATA MANAGEMENT 

Upon successful completion of the data assessment process, the data generated 

for the investigation will be stored in a central location and/or database. Data 

summaries and results will be submitted to the EPA in the delisting petition. 

Data management details are also provided in the SAP. 
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8.3 DATA VALIDATION 

The data packages will receive a data package completion check from the 

corresponding laboratory generating the data package to help assess whether the 

deliverable requirements specified for this project have been satisfied. Data 

reviews will be conducted as the data are received to assess whether the QC 

criteria established for the associated analytical methods and the DQOs 

established for this project have been met. ERM will perform a full data 

validation on a minimum of 100 percent of the data packages generated. The full 

data validation will be performed on the quality control data associated with a 

second sample. 
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9.0 AUDITS 

Quality assurance audits will be performed to assess whether the QA/QC 

measures are being utilized to provide data of acceptable quality. The audits 

will be completed to verify that subsequent calculation, interpretation, and other 

project outputs are checked and validated. 

9.1 FIELD SYSTEMS AUDIT 

Field systems audits will address whether field tools are selected and used in 

such a manner as to meet the requirements specified by the project objectives 

stated in this plan. 

Field documentation and sample custody records will be reviewed. During the 

audit, data handling procedures will be reviewed with the appropriate 

personnel. Accuracy, consistency, documentation, and appropriate selection of 

methodologies will be discussed. 

9.2 LABORATORY AUDIT 

No laboratory audits are proposed. 
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10.0 PREVENTIVE MAINTENANCE 

Preventive maintenance for laboratory equipment is described in Appendix A. 
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11.0 CORRECTIVE ACTION 

Corrective or preventive action is required when potential or existing conditions 

are identified that may have an adverse impact on data quality. Corrective 

action can be immediate or long term. In general, any member of the project 

staff who identifies a condition adversely affecting quality can initiate corrective 

action by notifying in writing their supervisor. The written communication will 

identify the condition and explain how it may affect data quality. 

Corrective action in the field is the responsibility of the on-site staff. This 

includes reviewing the procedures to be followed prior to sampling events and 

checking the procedures taking place after the sampling event is completed. 

Corrective action with regard to laboratory analysis is the responsibility of the 

designated laboratory, and is described in Appendix A. 

11.1 IMMEDIATE CORRECTIVE ACTION 

This type of corrective action is usually applied to spontaneous, nonrecurring 

problems, such as instrument malfunction. The individual who detects or 

suspects nonconformance to previously established criteria or protocol in 

equipment, instruments, data, methods, etc., will immediately notify his/her 

supervisor. The supervisor and the appropriate task leader will then investigate 

the extent of the problem and take necessary corrective steps. 

If a large quantity of data is affected, ERM will prepare a memorandum to 

ExxonMobil. ERM and ExxonMobil will collectively decide on a course of action 

to correct the deficiencies while the project continues to proceed. If the problem 

is limited in scope, the task leaders will decide on a corrective action measure, 

document the solution, and notify the project team. 

11.2 LONG-TERM CORRECTIVE ACTION 

Long-term corrective action procedures are devised and implemented to reduce 

the potential for the recurrence of a potentially serious problem. The project 

team will be notified of the problem and will conduct an investigation to 

determine the severity and extent of the problem. Corrective actions may be 

initiated as a result of other activities such as audits. 

ExxonMobil will be responsible for documenting the notification, 

recommendations, final decisions, and notifying project staff and implementing 

the agreed upon course of action. The development and implementation of 

preventive and corrective actions will be timed, to the extent possible, to assess 

any adverse impact on project schedules and subsequent data 

generation/processing activities. However, scheduling delays will not override 

the decision to correct the data collection deficiencies before proceeding with 

additional data collection. ERM will be responsible for developing and 

implementing routine program controls to reduce the need for corrective action. 
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REFERENCES 

EPA 1999b. EPA Requirements For Quality Assurance Project Plans EPA QA/R-5, 

United States Environmental Protection Agency, Interim Final, 

December 2099.