Texas Registered Engineering Firm F-2393 

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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 Pertai ning to this Petition.



## a. Name:

Amy E. Climo



## b. Title:

Baytown Refinery Waste and Water Section Supervisor



## c. Company:

ExxonMobil Refining & Supply Company Baytown Refine ry



## d. Telephone No.:

281-834-0100



## e. Mailing address:

Same as petitionerTexas Registered Engineering Firm F-2393 

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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 Wast e.



## a. Name of facility:

ExxonMobil Refining & Supply Company, Baytown Refin ery (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 th e underflow water generated at the North Landfarm (NLF) at the Baytown, Texas refinery, show n in Figure 1. Figure 2 is a plot plan ofTexas Registered Engineering Firm F-2393 

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### PART 2: DELISTING W ASTE 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 F0 39 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 r eceives various hazardous waste streams from the BTRF. The NLF underflow is an aqu eous 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 ExxonMob il 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: 1989Texas Registered Engineering Firm F-2393 

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## c. Waste will be generated in the future.

The waste will continue to be generated while the N LF 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 genera tion (2002–2008) of waste and estimated future generation amounts.

HISTORY OF WASTE MANAGEMENT



## 6. As appropriate, describe the present, past, and pro posed waste management methods for the petitioned waste.



## a. Present waste management methods, and off-site faci lity or facilities used (name, address, and waste management method).

Underflow is generated at the NLF by the downward m igration of irrigation water, rainwater, and wastes applied to the NLF through th e treatment zone.

The amount of water which seeps through the treatme nt 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 withi n the treatment zone, water exists in the soils tightly bound to the soil particles. Duri ng these dry periods seepage is minimal. When free water is available within the treatment z one, 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.Texas Registered Engineering Firm F-2393 

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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 l iquids which seep through the treatment zone. A cross section of the NLF’s perch ed-bed system design feature is provided in Figure 3. The collection system consist s of approximately 70 two-inch diameter perimeter lateral HDPE pipes, 50 feet apar t, which slope at 1% grade into a six inch diameter collector system. The collector syst em is sloped at a 0.18% grade to carry fluids to the underflow collection sump which is lo cated on the eastern side of the NLF’s perimeter berm. The lateral (two inch) pipes are pe rforated to accept the drainage and are wrapped with a geotextile designed to filter out fi ne 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 rei nforced-concrete, approximately six feet in diameter and approximately 15 feet in heigh t. 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 irrigat ion 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 transpo rted off site for disposal. In the event of equipment failure at the underflow sump, the und erflow would continue to accumulate in the underflow collection sump. To prevent overfl ow from the system, the walls of the sump extend well above the natural grade at the sum p. 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 usin g temporary pumps or vacuum tanks. If needed, the collection system can be evacuated u sing temporary pumps or vacuum trucks and pumped to Tank 102 or frac tanks and the n used as irrigation water or sent off-site for disposal.



## b. Past waste management methods, if different from pr esent, and off-site facility or facilities used (name, address, and waste managemen t method).

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



## c. Proposed waste management methods if delisting peti tion is granted, and off-site facility or facilities to be used (name, address, a nd waste management method).

The proposed waste management for the underflow wat er while the NLF is active is to collect the underflow water in the underflow sump a nd reapply it to the NLF as irrigation water as described above in Section 6.a.

In the future, ExxonMobil will pursue closure of th e 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 und erflow 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 wast e water treatment system (WWTS). The underflow will continue to be collected by the underflow coll ection system and accumulated in Tank 102. When th e water level in Tank 102 reaches a predetermined lev el, a sample of the water will be collected and analyzed for target constituents. Once analytical results indicate that target constituent concentrat ionsTexas Registered Engineering Firm F-2393 

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### are less than target concentrations (established du ring the delisting process), the water in Tank 102 will be routed to a series of open drainage ditches to t he underground BTRF East Sewer via a series of open ditches and culverts where it is commingled with pr ocess unit wastewaters. This process of management of water in Tank 102 will continue until the date o f 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 E PA 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 b e 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 sen t through one of three oil-water preseparators that operate in parallel. These separators skim off fre e oil for reprocessing and settled sludge is remove d periodically for dewatering and processing at our d elayed coker. After the preseparators, the wastewat er travels through the stormwater diversion box, throu gh a lift station, and then to API Separator 12. Oi l 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 prio r 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 stabilizatio n 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.Texas Registered Engineering Firm F-2393 

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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 cr ude 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 faci lity.

The BTRF employs a number of petroleum processing s teps to produce the following principle products: motor gasoline, jet fuel, kerosene, heati ng oil, diesel oil, regular and low-sulfur fuel oil s, asphalt, coke, solvents, lubricating oils, and chem ical feedstock (olefins and aromatics).



## 3. List and describe all wastes (including all hazardo us wastes) generated at the facility.

See Table 2.



## 4. Describe your manufacturing and waste treatment are as and waste management units. Attach schematics showing the layout of the facilit y.

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 Can al (UOC), Retention Basin 1 (RB1), and the Lower Outfall Canal (LOC)) manage only nonh azardous wastewaters and sludges under delay-of-closure. The location of these waste mana gement units is shown in Figure 1. Wastes are also transported to off-site facilities for disposa l.



## 5. Describe the regulatory status of all on-site waste treatment, storage, and disposal units. Include a list of all hazardous waste permits and o ther permits issued under Federal and State environmental statutes. Include the permit n umbers in this list.

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

See Table 4 for a summary Federal and State permits maintained by the BTRF.Texas Registered Engineering Firm F-2393 

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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 m aterial 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 wel l 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 wat er and moisture from waste applied to the surface is the only process at the NLF that contrib utes to the generation of the underflow water. The amount of water which seeps through the treatme nt 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 des ign feature is provided in Figure 3. The system consists of a three foot thick soil zone com posed of clayey soils with a high cation exchange capacity and compacted to a permeability of approxi mately 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 res idence 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 underfl ow 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 soi ls were exposed by removal of overlying topsoils or debris, and the to p foot was carefully recompacted to compensate for any disruption.



## 8. Describe, and identify on the schematic, exactly wh ere the petitioned waste is generated (if generated by a manufacturing process).

The petitioned waste is generated by downward verti cal migration of liquid through the NLF. The underflow is transported by the collection syst em to the NLF underflow sump which is the point of waste generation. Figures 2 and 5 illustr ate the location of the sump.Texas Registered Engineering Firm F-2393 

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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 underflo w collection system, and underflow sump the NLF also includes ancillary equipment and structure s (to the east of the land treatment area) as illustrated on Figures 2 and 5. The ancillary equip ment and structures include a control building, holding pads for solids, roads, parking a reas, 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 person nel to complete administrative functions and operations monitoring. Located outside and immediat ely west of the control building is a boot wash station. The truck wash rack is used to decont aminate vehicles prior to leaving the landfarm treatment area, and it consists of a concrete found ation and catch basin to collect wash waters. Above this catch basin is metal grating over struct ural steel supports. Trucks drive onto the wash rack for cleaning and rinse waters are collect ed 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 ou tside the run-off control berms of the NLF near Tank 102 (Figure 2). This sump, which is prefabrica ted double-walled high-density polyethylene (HDPE) tank, is used to collect (via gravity) poten tially contaminated water from the Tank 102 containment area, the sludge transfer pump area, th e truck unloading area catch basins, the truck wash rack, and the control building boot wash stati on and drains. The sump is automatically emptied, as needed, by pumping the water into Tank 102.

Six concrete solids holding pads, attached to the s pine 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 th e 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, w eekly, 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 manufacturi ng processes, operations, process materials, or generated wastes have varied in the p ast or may vary in the future.

The NLF contributing processes, operations, or proc ess materials have not varied in the past. The wastes applied to the NLF are regulated by BTRF RCR A 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 lan dfarm 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.Texas Registered Engineering Firm F-2393 

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## 12. Describe how the composition and generation rate of the petitioned waste may periodically vary due to any aspect of manufacturin g process variability.

The composition of the petitioned waste will not va ry beyond the parameters specified in the attached sampling data. The generation rate is lik ely to vary with the amount of rainfall and waste from the BTRF received each month; however, t he 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 pe titioned 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 proc ess steps, reactions occurring, flow rates, material inputs, and waste inputs and output s.

Not Applicable. The NLF does not have a waste trea tment process that contributes to the petitioned waste. The petitioned waste is generate d by vertical migration of wastes applied, rain water, or irrigation water through the NLF.



## 15. Describe, and identify on the schematic, exactly wh ere 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 c ollects 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 t he 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 approxima tely 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.Texas Registered Engineering Firm F-2393 

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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, weekl y, or other period basis, as appropriate. Identify periods when treatment waste s 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 p rocesses, 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 contributi ng 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 param eters specified in the attached sampling data. The generation rate varies with the amount of rainf all 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-bas ed unit?

Yes, as irrigation water.

PROCESS MATERIALS



## 23. List all materials used in the operations that cont ribute to the petitioned waste. The list
should include:



## a. The name of the material(s).

Rain water, irrigation water (underflow water and f ire water), and moisture from the waste applied to the NLF contribute to the petition ed 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 co ntent sufficient to promote an active microbial community.Texas Registered Engineering Firm F-2393 

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## d. Approximate annual quantities used.

The annual quantities of waste used to create the u nderflow water is a function of the amount of rainfall, irrigation water, and waste rec eived each month.



## 24. Provide Material Safety Data Sheets (MSDS) and any other compositional information
for trade name and non-elemental materials. Includ e raw materials, cleaners, oils, solvents, strippers and any by-products generated b y 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 generat ed by a multiple waste treatment facility (MWTF)?

NoTexas Registered Engineering Firm F-2393 

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### PART 4: DELISTING ANALYTICAL PLAN DEVELOPMENT



## 1. Provide a complete list of the constituents and par ameters of concern identified for your petitioned waste based on appropriate waste constit uent 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 petit ioned 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 gr eater than detection limits were used to help create the final list of COCs.

An initial sample of the petitioned waste was colle cted 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 o f 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, i ncluded as Attachment 1).

The final list of COCs is included in Table 7, as w ell as the reason the COC remained on the list. The analytical results from historical sampling eve nts can be found in Attachment 8 of the SAP (included as Attachment 1).



## 2. Provide mass balance demonstrations for those const ituents of concern in your list for which analyses were not conducted. Provide all cal culations and assumptions.

Not applicable. Laboratory analyses were conducted to identify COCs.



## 3. Explain why any other delisting constituent of conc ern is not on the constituent of concern list for your petitioned waste.

Not Applicable. The final list of COCs for the peti tioned waste was established to include those constituents reported at concentrations greater tha n 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 wa ste characteristics and the petitioned waste did not exhibit any hazardous waste characteristics

.Texas Registered Engineering Firm F-2393 

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### PART 5: DELISTING SAMPLE AND ANALYSIS INFORMATION



## 1. Has a draft sampling and analysis plan been submitt ed to EPA for review before petition preparation?

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

Environmental Protection Agency (EPA) on December 1 6, 2009 and approved on January 14, 2010. These documents have been inc luded 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 i n-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 followin g 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 GeologistTexas Registered Engineering Firm F-2393 

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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 represe ntative.



## a. Identify which process point discharges, containmen t areas (e.g. , lagoons), or other areas (e.g. , soil) were sampled and why these areas were selec ted for sample collection.

The petitioned waste is generated by downward verti cal filtration of liquid through the NLF. This liquid is ultimately collected in the und erflow sump. Samples were collected from the underflow sump.



## b. Describe the techniques and guidelines used to sele ct waste sampling points (e.g. , random sampling procedure or fixed transect and o ffset sampling procedure).

Because the underflow water accumulates at the unde rflow sump, there is no spatial variability within the petitioned waste. All sampl es 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 a nd times selected for sample collection, the number of grab samples collected fo r 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 continu ally, so temporal variability was characterized by collecting five samples of underfl ow 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 l owered into the sump until the bailer was filled with underflow water. Once the bailer was f ull, it was raised to the surface where sample bottles were filled by pouring underflow wat er from the bailer into the sample bottles. This procedure was repeated until the nec essary 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 temperatur e 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 app licable documentation used during the sampling activity.Texas Registered Engineering Firm F-2393 

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### These procedures were used because they provide obj ective and useable results for evaluation.



## d. Describe the sampling devices used for sample colle ction and the basis for selecting the devices.

Samples were collected using a disposable plastic b ailer. A disposable bailer was selected in order to protect the integrity of samples.



## e. Identify and discuss any deviations from your origi nal sampling plan and strategy and the impact of these deviations on wast e characterization.

Not Applicable. There were no deviations from the SAP.



## f. Explain why you believe the samples collected are n on-biased and sufficiently represent the petitioned waste. In this explanatio n, fully address the potential for waste uniformity or spatial and temporal variab ility and how the strategy ensured collection of representative samples.

The SAP meets the requirements of non-biased repres entation of the underflow water due to the number of samples collected, temporal variab ility, quality assurance, and the comprehensive analytical analysis of the samples.

The NLF operates continually and the petitioned und erflow water is continuously collected at the underflow sump. The strategy to ad dress temporal variability involved collecting five samples at two week intervals to en compass 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 r ange 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 sa mples 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 colle cted?

One initial characterization sample was collected i n 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 co llected.

An initial sample of the petitioned waste was colle cted 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 o f COCs for the petitioned waste was established to include those constituents reported at concentrations greater than the detectionTexas 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 li st.

Is the number of samples taken different from the n umber of samples agreed upon during the pre-petition scoping meeting? Explain the deviation.

The number of samples collected is as agreed upon d uring 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 fo llowing sample-specific information (items 5a through 5g).



## a. For each sample included in item 4, provide the sam ple 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 i s (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 poi nt of collection from the petitioned waste. If a sample is a composite of gr abs, provide the number of grab samples collected for the composite sample, th e sampling location for each grab sample, the volume of each grab sample, and th e volume of the composite sample.

The petitioned waste was collected from the underfl ow sump at the NLF for each sampling event. Each sample was a grab sample of a pproximately 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 poin ts shown in a diagram.

The petitioned waste was collected from the underfl ow 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 collec ted by directly pouring the underflow water from the bailer into the sample bot tles.



## e. Provide a physical description of each sample at ti me 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 dat e when the grab samples were collected and the time and date when the sampl e was composited, as applicable.

Not Applicable.



## g. Describe the handling and preparation techniques us ed 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 container s were used to collect the samples. Various preservatives were used provided in the bot tles by the laboratory, as appropriate for the analytical method. The table below describe s 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 samp ling 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 S W -846 followed?

Yes [Skip to item 11]

No [Continue with item 10]



## 10. Provide a description of the quality control proced ures and documentation system used to track sample location and maintain sample integr ity during transportation to the laboratory. Copies of the chain-of-custody forms m ay be provided, but are not needed.

Not Applicable.

LOCALIZED AREA OF CONTAMINATION



## 11. Have you collected samples to characterize a locali zed 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 diag ram) and the dimensions (e.g.

, depth, width and length) of the hot spot.

Not Applicable.



## 14. Identify the samples specifically collected to char acterize 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 f ollowing 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 Attachme nt 3, ALS Laboratory Group, Company Profile, for the resumes of key personnel r esponsible for data reduction, validation and laboratory quality control. Attachm ent 2 (QAPP) includes the Analytical Laboratory Quality Assurance Plan for ALS Laborator y 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 an d each analyses.



## a. Sample identification numbers as logged during coll ection and as assigned by the laboratory.

The Work Order Sample Summary of each analytical re port summarizes this information. Analytical reports are located in Atta chment 4.



## b. Type of sample (e.g. , waste sample, waste sample replicate, equipment b lank, field blank).

The Work Order Sample Summary of each analytical re port summarizes the sample matrix. Samples with field identification of Underf low Delisting are underflow sump water samples. Those identified as Dup are duplicat e samples. Samples with field identifications of TB are trip blanks. Analytical r eports are located in Attachment 4.



## c. Date of sample receipt by the laboratory.

The Work Order Sample Summary of each analytical re port indicates the collection date and time of each sample, in addition to the date an d time of receipt by the laboratory. Analytical reports are located in Attachment 4.



## d. The sample workup or preparation method and referen ce for the method (e.g.

, SW -846 Method 3500).

The Analytical Results section of each analytical r eport 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 r eport 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 r eport 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 r eport summarizes this information. Analytical reports are located in Attachment 4.



## h. The test method used and the source of the test met hod (e.g. , SW -846 Method 8020).

The Analytical Results section of each analytical r eport 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 r eport 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 an d 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 an d the results section of each analytical report, located in Attachment 4.



## l. The quantitation limits.

The analytical results are summarized in Table 8 an d the results section of each analytical report, located in Attachment 4.



## 20. Provide the names and model numbers of all equipmen t used during analysis.

The names and model numbers of all equipment used d uring the analysis are included in Attachment 5.



## 21. Provide all other information necessary to fully in terpret the test procedures or results.

Not Applicable.



## 22. For each quality control analysis that involved a m atrix or a surrogate spike and spike duplicate analysis, provide the following informati on.

Because of the volume of information requested, ple ase 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 unspi ked sample.



## c. The amount of the spike analyte added.



## d. The measured amount of the spike in both spiked sam ples.



## e. The calculated percent recovery of the spike and me thod of calculation.



## f. The acceptance criterion for recovery of each matri x spike.



## g. The relative percent difference (RPD) between the d uplicate results.



## h. The acceptance criterion for the RPD.



## 23. Identify whether the waste analytical data was corr ected based on quality control results (e.g. , blank analysis) and explain how the correction wa s made.

Any corrections to the analytical data are indicate d 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 i nterferences 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, fo r 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 INFORMATI ON



## 1. Show which of the following describes the managemen t 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 monito ring is needed under 40 CFR Part 264 or 265 or authorized Sate equivalent, or o ther Federal, state, or local requirements; or if ground-water monitoring informa tion is otherwise available
for the unit.

Yes. The ground water around the NLF is being moni tored semiannually as part of the Ground Water Detection Monitoring Program for the R esource Conservation and Recovery Act (RCRA) permit and has been monitored s ince 1990. The constituents that are analyzed for include dissolved chromium and lea d, benzene, toluene, total phenol, 1- methylnahpthalene, naphthalene, total dissolve soli ds, 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 avail able).



## b. The petitioned waste was once managed (but is no lo nger) in a land-based waste management unit (on-site or off-site) and ground-wa ter monitoring was needed under 40 CFR Part 264 or 265 or authorized State eq uivalent, or other Federal, state, or local requirements; or if ground-water mo nitoring information is
otherwise available for the unit.

Not Applicable.



## c. The petitioned waste is currently managed, or was o nce managed, in a landbased waste management unit, but ground-water monit oring requirement has
been waived.

Not Applicable.



## d. The petitioned waste is currently managed, or was o nce managed, in one or more land-based waste management units containing also s ignificant amounts of other wastes, and you consider ground-water data from the se non-dedicated units are immaterial in evaluating the petitioned waste’s imp act 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) 600-1000TABLE 1Effluent Limitations for Outfall 001 at the BaytownRefineryNorth Landfarm Underflow Delisting PetitionExxonMobil Baytown RefineryBaytown, TexasDaily Average (lb/day) Daily Maximum (lb/day) SingleGrab (mg/L) Measurement Frequency Sample TypeCarbonaceousBiochemical OxygenDemand, 5-Day(CBOD5)7,808 15,616 56 1/week CompositeTotal Organic Carbon(TOC)37,725 70,490 255 1/week CompositeTotal Suspended Solids(TSS)14,819 23,559 85 2/week CompositeOil and Grease5,346 10,097 36 1/ 2 weeks GrabPhenolic Compounds88.2 233 0.846 1/ 2 weeks GrabAmmonia as Nitrogen(NH3-N)2,000 4,000 15 1/week CompositeNitrate (as N) (x2)Report (mg/L) Report (mg/L) N/A 1/week CompositeSulfide73.7 163 0.591 1/ 2 weeks GrabTotal Chromium105 300 1.08 1/ 2 months CompositeHexavalent Chromium10.0 22.5 0.081 1/ 2 weeks CompositeTemperature98 deg F 98 deg F 98 deg F FWAT * 3 RecordpHN/AN/A6-9 (standard units) 1/day GrabNOTES:N/A = Not applicableFWAT = Flow-Weighted Average TemperatureDischarge LimitationMinimum Self Monitoring RequirementsEffluent CharacteristicEffluent Limitations per TPDES Permit 0000592Texas Registered Engineering Firm F-2393G:\2010\0102974\15096H Petition TableTABLE 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, D00 5 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 TableTABLE 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 TableTABLE 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 TableTABLE 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, D00 3, 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 TableTABLE 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 TableTABLE 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, F005Waste or Spent NonHalogen Solvent 0510203H 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 TableWaste 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 Organ ics and/or Inorganics, OAP and Lagoon Sludges,
HAFO Tank Bottoms
Wastewater Oxidation Unit (WOU) Active Industrial Was tewater, WOU Sludge Upper Outfall Canal (UOC) Active Industrial Wastewate r, UOC Sludge Retention Basin 1 (RB1) Active Industrial Wastewater, SRB Sludge Lower Outfall Canal (LOC) Active Industrial Wastewate r, LOC Sludge

NOTES:

Waste streams listed are those that are currently m anaged at each unit. Waste that is no longer manag ed 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 Age ncy

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 TableNorth 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, D01 8, K169, K170, K171, K172, D002, D004, D007, D008, D003 Heat Exchanger Bundle Cleaning Sludge K050, D018, D0 01, 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, D 019, D028, D029, D030, D032, D033, D034, D036, D037, D038, D039, D040, D042, D04 3, 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, K05 2, 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 Unive rsal Treatment Standards and Land Disposal Restrictions TABLE 5

Current and Historical Wastes Applied to North Land farm

ExxonMobil Baytown Refinery Baytown, Texas

Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H Petition TableNorth Landfarm Underflow Delisting PetitionContributory Processes Operating Time Operation CycleScheduled Shutdown and/or MaintenanceRain WaterAverage annual rainfall for Baytown, Texas is 29.47inchesContinuous throughput NoneIrrigation Water (Underflow and Fire Water) ContinuousContinuous throughput NoneMoisture from waste applied to NLF ContinuousContinuous throughput NoneNOTE:Source for rainfall average: www.wunderground.comTABLE 6NLF Underflow Generation Contributing ProcessesExxonMobil Baytown RefineryBaytown, TexasTexas Registered Engineering Firm F-2393G:\2010\0102974\15096H Petition TableNorth 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 N LF 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 Constituen t List

ExxonMobil Baytown Refinery

Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H Petition TableTABLE 8Summary of North Landfarm Underflow Sampling DataNorth Landfarm Underflow Delisting PetitionExxonMobil Baytown RefineryBaytown, TexasDelisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicate - 02 Delisting - 052-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May-10 18-May-10ConstituentResult (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L)MetalsAntimony1.9 ND NS NS NS NS NS NSArsenic1.4 ND ND ND ND ND ND NDBarium1.2 0.0192 0.0202 0.0216 0.025 0.0224 0.0224 0.0299Beryllium0.82 ND NS NS NS NS NS NSCadmium0.69 ND ND ND ND ND ND NDChromium2.77 ND ND ND ND ND ND NDCobalt--- NS ND ND ND 0.000953 J 0.000926 J NDCopper--- NS ND ND ND 0.00223 J 0.00207 J NDLead0.69 ND ND ND ND 0.000947 J 0.000104 J NDLithium--- NS ND ND ND ND ND NDManganese--- NS 0.0249 0.0218 0.0774 0.427 0.406 0.666Molybdenum--- NS 0.0157 0.0141 0.0130 0.0156 0.0150 0.0166Nickel3.98 ND NS NS NS NS NS NSSelenium0.82 ND ND ND 0.00516 ND ND NDSilver0.43 ND ND ND ND ND ND NDThallium1.4 ND NS NS NS NS NS NSVanadium4.3 ND NS NS NS NS NS NSZinc--- NS 0.0605 0.0378 0.0440 0.0317 0.0316 0.0483Mercury0.15 ND ND ND ND ND ND ND---Semivolatiles---1,2,4,5-Tetrachlorobenzene0.055 ND NS NS NS NS NS NS1,2,4-Trichlorobenzene0.055 ND NS NS NS NS NS NS1,2-Diphenylhydrazine0.087 ND NS NS NS NS NS NS1,3-Phenylenediamine--- ND NS NS NS NS NS NS1,4-Dinitrobenzene0.32 ND NS NS NS NS NS NS2,3,4,6-Tetrachlorophenol0.03 ND NS NS NS NS NS NS2,4,5-Trichlorophenol0.18 ND ND ND ND ND ND ND2,4,6-Trichlorophenol0.035 ND ND ND ND ND ND ND2,4-Dichlorophenol0.044 ND NS NS NS NS NS NSNOTES: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 SolidsF039 Threshold Value(mg/L)aaProvided in "Treatment Standards for Hazardous Waste" in 40--- = Threshold Value not provided for constituentPage 1 of 9Texas Registered Engineering Firm F-2393G:\2010\0102974\15096H Petition TableTABLE 8 (Cont'd)Summary of North Landfarm Underflow Sampling DataNorth Landfarm Underflow Delisting PetitionExxonMobil Baytown RefineryBaytown, TexasDelisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicate - 02 Delisting - 052-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May-10 18-May-10ConstituentResult (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L)Semivolatiles (cont.)2,4-Dimethylaniline0.01 ND NS NS NS NS NS NS2,4-Dimethylphenol0.036 ND NS NS NS NS NS NS2,4-Dinitrophenol0.12 ND NS NS NS NS NS NS2,4-Dinitrotoluene0.32 ND ND ND ND ND ND ND2,6-Dichlorophenol0.044 ND NS NS NS NS NS NS2,6-Dinitrotoluene0.55 ND NS NS NS NS NS NS2-Acetylaminofluorene0.059 ND NS NS NS NS NS NS2-Chloronaphthalene0.055 ND NS NS NS NS NS NS2-Chlorophenol0.044 ND NS NS NS NS NS NS2-Methylphenol0.11 ND ND ND ND ND ND ND2-Naphthylamine0.52 ND NS NS NS NS NS NS3&4-Methylphenol0.77 ND ND ND ND ND ND ND3-Methylcholanthrene0.0055 ND ND ND ND ND ND ND3-Methylphenol0.77 NS NS NS NS NS NS NS4,4 ́-Methylene-bis(2-chloroaniline)0.5 ND NS NS NS NS NS NS4,6-Dinitro-2-methylphenol0.28 ND NS NS NS NS NS NS4-Aminobiphenyl0.13 ND NS NS NS NS NS NS4-Bromophenyl phenyl ether0.055 ND NS NS NS NS NS NS4-Chloro-3-methylphenol0.018 ND NS NS NS NS NS NS4-Chloroaniline0.46 ND NS NS NS NS NS NS4-Methylphenol0.77 NS NS NS NS NS NS NS4-Nitroaniline0.028 ND NS NS NS NS NS NS4-Nitrophenol0.12 ND NS NS NS NS NS NS5-Nitro-o-toluidine0.32 ND NS NS NS NS NS NSAcenaphthene0.059 ND NS NS NS NS NS NSAcenaphthylene0.059 ND NS NS NS NS NS NSAcetophenone0.01 ND NS NS NS NS NS NSAniline0.81 ND NS NS NS NS NS NSAnthracene0.059 ND NS NS NS NS NS NSAramite0.36 ND NS NS NS NS NS NSBenzo(a)anthracene 0.059 ND ND ND ND ND ND NDBenzo(b)fluoranthene0.11 ND ND ND ND ND ND NDNOTES: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 SolidsaProvided in "Treatment Standards for Hazardous Waste" in 40F039 Threshold Value(mg/L)a--- = Threshold Value not provided for constituentPage 2 of 9Texas Registered Engineering Firm F-2393G:\2010\0102974\15096H Petition TableTABLE 8 (Cont'd)Summary of North Landfarm Underflow Sampling DataNorth Landfarm Underflow Delisting PetitionExxonMobil Baytown RefineryBaytown, TexasDelisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicate - 02 Delisting - 052-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May-10 18-May-10ConstituentResult (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L)Semivolatiles (cont.)Benzo(ghi)perylene 0.0055 ND NS NS NS NS NS NSBenzo(a)pyrene0.061 ND ND ND ND ND ND NDBenzo(k)fluoranthene0.11 ND ND ND ND ND ND NDBis(2-chloroethoxy)methane0.036 ND NS NS NS NS NS NSBis(2-chloroethyl)ether0.033 ND NS NS NS NS NS NSBis(2-chloroisopropyl)ether0.055 ND NS NS NS NS NS NSbis(2-ethylhexyl)pthalate 0.28 ND NS NS NS NS NS NSButyl benzyl phthalate0.017 ND NS NS NS NS NS NSChlorobenzilate0.1 ND NS NS NS NS NS NSChrysene0.059 ND ND ND ND ND ND NDDibenzo(a,h)anthracene 0.055 ND NS NS NS NS NS NSDibenzo(a,e)pyrene0.061 ND NS NS NS NS NS NSDiethyl phthalate0.2 ND NS NS NS NS NS NSDimethyl phthalate0.047 ND NS NS NS NS NS NSDi-n-butyl phthalate 0.057 ND NS NS NS NS NS NSDi-n-octyl phthalate0.017 ND NS NS NS NS NS NSDiphenylamine0.92 ND NS NS NS NS NS NSDisulfoton0.017 ND NS NS NS NS NS NSEthyl parathion0.014 ND NS NS NS NS NS NSFamphur0.017 ND NS NS NS NS NS NSFluoranthene0.068 ND NS NS NS NS NS NSFluorene0.059 ND NS NS NS NS NS NSHexachlorobenzene0.055 ND ND ND ND ND ND NDHexachlorobutadiene0.055 ND ND ND ND ND ND NDHexachlorocyclopentadiene0.057 ND NS NS NS NS NS NSHexachloroethane0.055 ND ND ND ND ND ND NDHexachloropropene0.035 ND NS NS NS NS NS NSIndeno(1,2,3-cd)pyrene 0.0055 ND NS NS NS NS NS NSIsodrin0.021 ND NS NS NS NS NS NSIsosafrole0.081 ND NS NS NS NS NS NSKepone0.0011 ND NS NS NS NS NS NSMethapyrilene0.081 ND NS NS NS NS NS NSNOTES: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 SolidsaProvided in "Treatment Standards for Hazardous Waste" in 40F039 Threshold Value(mg/L)a--- = Threshold Value not provided for constituentPage 3 of 9Texas Registered Engineering Firm F-2393G:\2010\0102974\15096H Petition TableTABLE 8 (Cont'd)Summary of North Landfarm Underflow Sampling DataNorth Landfarm Underflow Delisting PetitionExxonMobil Baytown RefineryBaytown, TexasDelisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicate - 02 Delisting - 052-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May-10 18-May-10ConstituentResult (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L)Semivolatiles (cont.)Methylchrysene--- NS NS NS NS NS NS NSMethyl methanesulfonate0.018 ND NS NS NS NS NS NSMethyl parathion0.014 ND NS NS NS NS NS NSN-Nitroso-di-n-butylamine0.4 ND NS NS NS NS NS NSN-Nitrosodi-n-propylamine0.4 ND NS NS NS NS NS NSN-Nitrosodimethylamine0.4 ND NS NS NS NS NS NSN-Nitrosodiphenylamine0.92 ND NS NS NS NS NS NSN-Nitrosomethylethylamine0.4 ND NS NS NS NS NS NSN-Nitrosomorpholine0.4 ND NS NS NS NS NS NSN-Nitrosopiperidine0.013 ND NS NS NS NS NS NSN-Nitrosopyrrolidine0.013 ND NS NS NS NS NS NSNaphthalene0.059 ND NS NS NS NS NS NSNitrobenzene0.068 ND ND ND ND ND ND NDo-Anisidine0.01 ND NS NS NS NS NS NSp-Cresidine0.01 ND NS NS NS NS NS NSPentachlorobenzene0.055 ND NS NS NS NS NS NSPentachloronitrobenzene0.055 ND NS NS NS NS NS NSPentachlorophenol0.089 ND ND ND ND ND ND NDPhenacetin0.081 ND NS NS NS NS NS NSPhenanthrene0.059 ND NS NS NS NS NS NSPhenol0.039 ND NS NS NS NS NS NSPhorate0.021 ND NS NS NS NS NS NSPhthalic anhydride0.055 ND NS NS NS NS NS NSPronamide0.093 ND NS NS NS NS NS NSPyrene0.067 ND NS NS NS NS NS NSPyridine0.014 ND ND ND ND ND ND NDSafrole0.081 ND NS NS NS NS NS NSTris(2,3-dibromopropyl) phosphate0.11 ND NS NS NS NS NS NSVolatiles1,1,1,2-TetrachloroethaneND NS NS NS NS NS NS1,1,1-TrichloroethaneND NS NS NS NS NS NSNOTES: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 constituentF039 Threshold Value(mg/L)aaProvided in "Treatment Standards for Hazardous Waste" in 40Page 4 of 9Texas Registered Engineering Firm F-2393G:\2010\0102974\15096H Petition TableTABLE 8 (Cont'd)Summary of North Landfarm Underflow Sampling DataNorth Landfarm Underflow Delisting PetitionExxonMobil Baytown RefineryBaytown, TexasDelisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicate - 02 Delisting - 052-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May-10 18-May-10ConstituentResult (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L)Volatiles (cont.)1,1,2,2-Tetrachloroethane0.057 ND NS NS NS NS NS NS1,1,2-Trichlor-1,2,2-trifluoroethane0.057 ND NS NS NS NS NS NS1,1,2-Trichloroethane0.054 ND NS NS NS NS NS NS1,1-Dichloroethane0.059 ND NS NS NS NS NS NS1,1-Dichloroethene0.025 ND ND ND ND ND ND ND1,2,3-Trichloropropane0.85 ND NS NS NS NS NS NS1,2-Dibromo-3-chloropropane0.11 ND NS NS NS NS NS NS1,2-Dibromoethane0.028 ND NS NS NS NS NS NS1,2-Dichlorobenzene0.088 ND NS NS NS NS NS NS1,2-Dichloroethane0.21 ND ND ND ND ND ND ND1,2-Dichloropropane0.85 ND NS NS NS NS NS NS1,3-Dichlorobenzene0.036 ND NS NS NS NS NS NS1,4-Dichlorobenzene0.09 ND ND ND ND ND ND ND1,4-Dioxane12 ND NS NS NS NS NS NS2-Butanone0.28 ND ND ND ND ND ND ND2-Chloro-1,3-butadiene0.057 ND NS NS NS NS NS NS4-Methyl-2-pentanone0.14 ND NS NS NS NS NS NSAcetone0.28 ND NS NS NS NS NS NSAcetonitrile5.6 ND NS NS NS NS NS NSAcrolein0.29 ND NS NS NS NS NS NSAcrylonitrile0.24 ND NS NS NS NS NS NSAllyl Chloride0.036 ND NS NS NS NS NS NSBenzene0.14 ND ND ND ND ND ND NDBromodichloromethane0.35 ND NS NS NS NS NS NSBromoform0.63 ND NS NS NS NS NS NSBromomethane0.11 ND NS NS NS NS NS NSCarbon disulfide3.8 ND NS NS NS NS NS NSCarbon tetrachloride0.057 ND ND ND ND ND ND NDChlorobenzene0.057 ND ND ND ND ND ND NDChloroethane0.27 ND NS NS NS NS NS NSChloroform0.046 ND ND ND ND ND ND NDChloromethaneND NS NS NS NS NS NSNOTES: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 constituentaProvided in "Treatment Standards for Hazardous Waste" in 40F039 Threshold Value(mg/L)aPage 5 of 9Texas Registered Engineering Firm F-2393G:\2010\0102974\15096H Petition TableTABLE 8 (Cont'd)Summary of North Landfarm Underflow Sampling DataNorth Landfarm Underflow Delisting PetitionExxonMobil Baytown RefineryBaytown, TexasDelisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicate - 02 Delisting - 052-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May-10 18-May-10ConstituentResult (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L)Volatiles (cont.)cis-1,3-Dichloropropene0.036 ND NS NS NS NS NS NSCyclohexanone0.36 ND NS NS NS NS NS NSDibromochloromethane0.057 ND NS NS NS NS NS NSDibromomethane0.11 ND NS NS NS NS NS NSDichlorodifluoromethane0.23 ND NS NS NS NS NS NSDiethyl Ether0.12 ND NS NS NS NS NS NSEthyl acetate0.34 ND NS NS NS NS NS NSEthyl methacrylate0.14 ND NS NS NS NS NS NSEthylbenzene0.057 ND NS NS NS NS NS NSEthylene oxide0.12 ND NS NS NS NS NS NSIodomethane0.19 ND NS NS NS NS NS NSIsobutyl alcohol5.6 ND NS NS NS NS NS NSMethacrylonitrile0.24 ND NS NS NS NS NS NSMethyl methacrylate0.14 ND NS NS NS NS NS NSMethylene chloride0.089 ND NS NS NS NS NS NSn-Butyl alcohol5.6 ND NS NS NS NS NS NSPropionitrile0.24 ND NS NS NS NS NS NSTetrachloroethene0.056 ND ND ND ND ND ND NDToluene0.08 ND NS NS NS NS NS NStrans-1,2-Dichloroethene0.054 ND NS NS NS NS NS NStrans-1,3-Dichloropropene0.036 ND NS NS NS NS NS NSTrichloroethene0.054 ND ND ND ND ND ND NDTrichlorofluoromethane0.02 ND NS NS NS NS NS NSVinyl chloride0.27 ND ND ND ND ND ND NDXylenes0.32 ND NS NS NS NS NS NSNOTES: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 constituentaProvided in "Treatment Standards for Hazardous Waste" in 40F039 Threshold Value(mg/L)aPage 6 of 9Texas Registered Engineering Firm F-2393G:\2010\0102974\15096H Petition TableTABLE 8 (Cont'd)Summary of North Landfarm Underflow Sampling DataNorth Landfarm Underflow Delisting PetitionExxonMobil Baytown RefineryBaytown, TexasDelisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicate - 02 Delisting - 052-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May-10 18-May-10ConstituentResult (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L)Metals TCLPArsenic--- NS NS NS NS NS NS NSBarium--- NS NS NS NS NS NS NSCadmium--- NS NS NS NS NS NS NSChromium--- NS NS NS NS NS NS NSLead--- NS NS NS NS NS NS NSSelenium--- NS NS NS NS NS NS NSSilver--- NS NS NS NS NS NS NSMercury--- NS NS NS NS NS NS NSSemivolatiles TCLP2,4-Dinitrotoluene--- NS NS NS NS NS NS NSHexachlorobenzene --- NS NS NS NS NS NS NSHexachlorobutadiene --- NS NS NS NS NS NS NSHexachloroethane--- NS NS NS NS NS NS NSNitrobenzene--- NS NS NS NS NS NS NS2-Methylphenol--- NS NS NS NS NS NS NS4-Methylphenol--- NS NS NS NS NS NS NSPentachlorophenol --- NS NS NS NS NS NS NS2,4,5-Trichlorophenol --- NS NS NS NS NS NS NS2,4,6-Trichlorophenol --- NS NS NS NS NS NS NSPyridine--- NS NS NS NS NS NS NSVolatiles TCLPBenzene--- NS NS NS NS NS NS NSCarbon Tetrachloride --- NS NS NS NS NS NS NSChlorobenzene--- NS NS NS NS NS NS NSChloroform--- NS NS NS NS NS NS NS1,4-Dichlorobenzene --- NS NS NS NS NS NS NS1,2-Dichloroethane --- NS NS NS NS NS NS NSNOTES: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 constituentaProvided in "Treatment Standards for Hazardous Waste" in 40F039 Threshold Value(mg/L)aPage 7 of 9Texas Registered Engineering Firm F-2393G:\2010\0102974\15096H Petition TableTABLE 8 (Cont'd)Summary of North Landfarm Underflow Sampling DataNorth Landfarm Underflow Delisting PetitionExxonMobil Baytown RefineryBaytown, TexasDelisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicate - 02 Delisting - 052-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May-10 18-May-10ConstituentResult (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L)Volatiles TCLP (cont.)1,1-Dichloroethene --- NS NS NS NS NS NS NSTetrachloroethene--- NS NS NS NS NS NS NSTrichloroethene--- NS NS NS NS NS NS NSVinyl Chloride--- NS NS NS NS NS NS NSMethyl Ethyl Ketone --- NS NS NS NS NS NS NSChlorinated Herbicides2,4,5-T0.72 ND NS NS NS NS NS NS2,4,5-TP (Silvex)0.72 ND NS NS NS NS NS NS2,4-D0.72 ND NS NS NS NS NS NSDinoseb0.066 ND NS NS NS NS NS NSPesticides4,4 ́-DDD0.023 ND NS NS NS NS NS NS4,4 ́-DDE0.031 ND NS NS NS NS NS NS4,4 ́-DDT0.0039 ND NS NS NS NS NS NSAldrin0.021 ND NS NS NS NS NS NSalpha-BHC0.00014 ND NS NS NS NS NS NSbeta-BHC0.00014 ND NS NS NS NS NS NSChlordane0.0033 ND NS NS NS NS NS NSdelta-BHC0.023 ND NS NS NS NS NS NSDieldrin0.017 ND NS NS NS NS NS NSEndosulfan I0.023 ND NS NS NS NS NS NSEndosulfan II0.029 ND NS NS NS NS NS NSEndosulfan sulfate0.029 ND NS NS NS NS NS NSEndrin0.0028 ND NS NS NS NS NS NSEndrin aldehyde0.025 ND NS NS NS NS NS NSgamma-BHC0.0017 ND NS NS NS NS NS NSHeptachlor0.0012 ND NS NS NS NS NS NSHeptachlor epoxide0.016 ND NS NS NS NS NS NSMethoxychlor0.25 ND NS NS NS NS NS NSToxaphene0.0095 ND NS NS NS NS NS NS2,4 ́-DDD0.023 ND NS NS NS NS NS NS2,4 ́-DDE0.031 ND NS NS NS NS NS NS2,4 ́-DDT0.0039 ND NS NS NS NS NS NSNOTES: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 SolidsF039 Threshold Value(mg/L)aaProvided in "Treatment Standards for Hazardous Waste" in 40--- = Threshold Value not provided for constituentPage 8 of 9Texas Registered Engineering Firm F-2393G:\2010\0102974\15096H Petition TableTABLE 8 (Cont'd)Summary of North Landfarm Underflow Sampling DataNorth Landfarm Underflow Delisting PetitionExxonMobil Baytown RefineryBaytown, TexasDelisting - 01 Delisting - 02 Duplicate - 01 Delisting - 03 Delisting - 04 Duplicate - 02 Delisting - 052-Feb-2010 22-Mar-2010 22-Mar-2010 20-Apr-10 3-May-10 3-May-10 18-May-10ConstituentResult (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L) Result (mg/L)PCBs0.1Aroclor 1016--- ND NS NS NS NS NS NSAroclor 1221--- ND NS NS NS NS NS NSAroclor 1232--- ND NS NS NS NS NS NSAroclor 1242--- ND NS NS NS NS NS NSAroclor 1248--- ND NS NS NS NS NS NSAroclor 1254--- ND NS NS NS NS NS NSAroclor 1260--- ND NS NS NS NS NS NSMiscellaneousOil and Grease--- NS NS NS NS NS NS NSIgnitability (deg F)--- NS NS NS NS NS NS NSpH (s.u.)--- NS NS NS NS NS NS NSTSS--- NS NS NS NS NS NS NSFluoride35 0.513 0.720 0.710 0.531 0.402 0.384 0.573Total Kjeldahl Nitrogen --- NS NS NS NS NS NS NSPhosporous, Total --- NS ND ND ND 0.0950 0.0400 J NDTotal Organic Carbon --- NS NS NS NS NS NS NSCyanide, Total1.2 ND ND ND ND ND ND 0.007Sulfide14 ND NS NS NS NS NS NSMethanol5.6 ND NS NS NS NS NS NSDioxins and Furans2,3,7,8-TCDD--- ND ND ND ND ND ND1,2,3,7,8-PeCDD--- ND ND ND ND ND ND1,2,3,4,7,8-HxCDD --- ND ND ND ND ND ND1,2,3,6,7,8-HxCDD --- ND ND ND ND ND ND1,2,3,7,8,9-HxCDD --- ND ND ND ND ND ND1,2,3,4,6,7,8-HpCDD 3.5E-05 ND ND ND ND ND NDOCDD6.3E-05 ND ND ND 2.91E-09 ND 7.670E-092,3,7,8-TCDF--- ND ND ND ND ND ND1,2,3,7,8-PeCDF--- 3.39E-10 ND ND ND ND ND2,3,4,7,8-PeCDF--- ND ND ND ND ND ND1,2,3,4,7,8-HxCDF --- ND ND ND ND ND ND1,2,3,6,7,8-HxCDF --- ND ND ND ND ND ND2,3,4,6,7,8-HxCDF --- ND ND ND ND ND ND1,2,3,7,8,9-HxCDF --- ND ND ND ND ND ND1,2,3,4,6,7,8-HpCDF 3.5E-05 ND ND ND ND ND ND1,2,3,4,7,8,9-HpCDF 3.5E-05 2.06E-09 ND ND ND ND NDOCDF6.3E-05 ND ND ND ND ND NDTotal-TCDD6.3E-05 ND ND 2.14E-09 ND ND NDTotal-PeCDD6.3E-05 ND ND ND ND ND NDTotal-HxCDD6.3E-05 1.28E-09 ND ND 1.54E-09 ND NDTotal-HpCDD--- ND ND ND ND ND NDTotal-TCDF6.3E-05 ND ND ND ND ND NDTotal-PeCDF3.5E-05 3.39E-10 ND ND ND ND NDTotal-HxCDF6.3E-05 ND ND ND ND ND NDTotal-HpCDF--- 2.06E-09 ND ND ND ND NDNOTES: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 SolidsF039 Threshold Value(mg/L)a--- = Threshold Value not provided for constituentaProvided in "Treatment Standards for Hazardous Waste" in 40Page 9 of 9Texas Registered Engineering Firm F-2393G:\2010\0102974\15096H Petition TableG:\2010\0102974\15096H Delisting Petition.doc 

# Figures

August 12, 2010 Project No. 0102974

Environmental Resources Management Southwest, Inc.

15810 Park Ten Place, Suite 300 Houston, Texas 77084-5140 (281) 600-1000DECKER 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:

SCALE: DATE:

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 G

D C

B A

E F E

NLF TRUCK WASH RACK
& BOOT WASH

SPINE ROAD 

## F

LANDFARMED SURFACE

LANDFARMED SURFACE Plant
North

1

PERIMETER RUN-OFF COLLECTION DITCH

PERIMETER BERM1%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 BERM1%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:

SCALE: DATE:

W.O. NO.: DESIGN:

H:\DWG\F10\0102974a202.dwg , 6/25/2010 4:21:07 PM 6/9/2010ERM-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

### ZONE OF INCORPORATION (DISKED)

CLEAN SOIL

SAND
DRAINAGE LAYER

IMPORTED CLAY LAYER (COMPACTED) 1% SLOPETHICKNESSVARIES2'1'1'TzBTz



### PRECIPITATION & IRRIGATION WATER

PERFORATED PIPEUNDERFLOWUNDERFLOWUNDERFLOWUNDERFLOW

UNDERFLOW UNDERFLOW

CHKD.:

REV.: DRAWN:

SCALE: DATE:

W.O. NO.: DESIGN:

H:\DWG\F10\0102974a203.dwg , 6/25/2010 4:21:16 PM 6/25/2010ERM-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 LEGENDSOURCE: MODIFIED FROM RADIAN INTERNATIONAL LLC DWG. No. D2393Z, APRIL 21, 1997. 

### 2% (TYP.)TREATMENT ZONE



### DRAINAGE LAYER12" AVG.DEPTH3"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:

SCALE: DATE:

W.O. NO.: DESIGN:

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### FIGURE 4 TYPICAL SECTION THROUGH UNDERFLOW COLLECTION SYSTEM

NLF UNDERFLOW DELISTING PETITION ExxonMobil Baytown Refinery Baytown, Texas PJG RLM PJG

AS SHOWN 4/14/10SPINE 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:

SCALE: DATE:

W.O. NO.: DESIGN:

H:\DWG\F10\0102974a205.dwg , 6/25/2010 4:21:33 PM 6/9/2010ERM-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 4/14/10G:\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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### 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 StructuresE n v i r o n m e n t a l R e s o u r c e s M a n a g e m e n t 

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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 freeE n v i r o n m e n t a l R e s o u r c e s M a n a g e m e n t 

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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.E n v i r o n m e n t a l R e s o u r c e s M a n a g e m e n t 

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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 andE n v i r o n m e n t a l R e s o u r c e s M a n a g e m e n t 

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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;E n v i r o n m e n t a l R e s o u r c e s M a n a g e m e n t 

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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.E n v i r o n m e n t a l R e s o u r c e s M a n a g e m e n t 

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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.E n v i r o n m e n t a l R e s o u r c e s M a n a g e m e n t 

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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 formswill 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);E n v i r o n m e n t a l R e s o u r c e s M a n a g e m e n t 

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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.E n v i r o n m e n t a l R e s o u r c e s M a n a g e m e n t 

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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.E n v i r o n m e n t a l R e s o u r c e s M a n a g e m e n t 

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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.E n v i r o n m e n t a l R e s o u r c e s M a n a g e m e n t 

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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.E n v i r o n m e n t a l R e s o u r c e s M a n a g e m e n t 

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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.G:\2010\0102974\15096H(Att1).doc Texas Registered Engineering Firm F-2393 

# Tables

December 16, 2009 Project No. 0102974

Environmental Resources Management Southwest, Inc.

15810 Park Ten Place, Suite 300 Houston, Texas 77084-5140 (281) 600-1000TABLE 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 Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H(Att1)tbs.xlsTABLE 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 Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H(Att1)tbs.xlsTABLE 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

Page 3 of 4 Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H(Att1)tbs.xlsTABLE 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

Page 4 of 4 Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H(Att1)tbs.xlsConstituent 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

Page 1 of 1 Texas Registered Engineering Firm F-2393 G:\2010\0102974\15096H(Att1)tbs.xlsG:\2010\0102974\15096H(Att1).doc 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) 600-1000G:\2010\0102974\15096H(Att1).doc Texas Registered Engineering Firm F-2393 

# 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) 600-1000G:\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.comG:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

### ii 

### 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 14G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

### iii 

### 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.)G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

### iv 

### 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 ActivitiesEnvironmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

### 1 

### 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 freeEnvironmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

### 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 11Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

### 3 

### 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 forobtaining 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;Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

### 4 • 

### 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.Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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 ofappropriate 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;Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

### 6 • 

### 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.Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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.Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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.Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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.Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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.Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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 AEnvironmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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 investigationEnvironmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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.Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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).Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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.Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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.Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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.Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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### 10.0 PREVENTIVE MAINTENANCE

Preventive maintenance for laboratory equipment is described in Appendix A.Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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.Environmental Resources Management G:\2010\0102974\15096H(Att2).doc Texas Registered Engineering Firm F-2393 

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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

.