1 ConocoPhillips – Billings, Montana Refinery    December 2010

EPA Delisting Petition Framework

Attachment A

EPA Delisting Petition

Framework
2 ConocoPhillips

– Billings, Montana Refinery    December 2010

EPA Delisting Petition Framework
3 ConocoPhillips – Billings, Montana Refinery    December 2010

EPA Delisting Petition Framework

Part 1: Delisting Administrative Information

1. Name of Petitioner

a. Name of Individual or Firm Sending Petition

ConocoPhillips Company, Billings, Montana Refinery

b. Mailing Address of Individual or Firm

Street/P.O. Box: 401 South 23rd Street

City: Billings

State/Zip: Montana  59101‐4337

Telephone: (406) 255‐2500

Fax (406) 255‐2621

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

a.                     Name                                            Title                                           Telephone

Allen Eggen (ConocoPhillips) Waste and Water

Lead

(406) 255‐2626

Mike Holder (TRC) Program Manager (512) 684‐3121

Steve Miller (TRC) Senior Scientist (512) 684‐3122

b. Mailing Address of Contact(s) if Different from Petitioner

Allen Eggen can be reached at the address given in 1. above.  Mike Holder and Steve

Miller are with TRC Environmental Corporation at the following address:

Street/P.O. Box: 505 East Huntland Drive, Suite 250

City: Austin

State/Zip: Texas  78752

Fax: (512) 329‐8750

3. Facility Responsible for Generating Petitioned Waste

a. Name Facility

ConocoPhillips Company, Billings Refinery

b. Location of Facility

Street: 401 South 23rd Street

City: Billings

State/Zip: Montana  59101

c. RCRA ID Number

MTD006229405

4. Location of Petitioned Waste

Same as the facility name and address given in item 3.   
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EPA Delisting Petition Framework

5. Describe the Proposed Delisting Action

As part of current operations at the ConocoPhillips Billings, Montana Refinery, sludge is

periodically removed from two stormwater tanks and processed via centrifuge and/or filter press

for oil recovery and dewatering.  The residual solids from the oil‐recovery process may or may not

be characterized as F037; however, taking a conservative approach and for the purposes of this

petition they are characterized as F037, a hazardous waste under the Resource Conservation and

Recovery Act (RCRA).  ConocoPhillips believes that the residual solids do not pose an unacceptable

risk to human health or the environment and is, therefore, petitioning the United States

Environmental Protection Agency (U.S. EPA), Region 8, to exclude from hazardous regulation (i.e.,

delist), the residual solids resulting from processing the sludge from the two storm water tanks (via

filter press or centrifuge) that are currently being managed as F037 wastes as the most

conservative approach.

6. Provide a Statement of the Need and Justification for the Proposed Action

ConocoPhillips is the generator of the residual solids, and as such, has an interest in having this

waste delisted.  Since ConocoPhillips does not believe that the waste meets the criteria for listing,

the Refinery is seeking to have it delisted to reflect its lowered risk to human health and the

environment.

   

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EPA Delisting Petition Framework

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EPA Delisting Petition Framework

Part 2: Delisting Waste and Waste Management Information

Basis for the Waste Listing

1. Which of the following scenarios best describes the petitioned waste?  (Choose the most

appropriate scenario and provide the information requested for the chosen scenario)

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

Common name of

Petitioned waste:

Petroleum refinery primary oil/water/solids separation sludge

EPA Hazardous

Waste Number:

The residuals from the filter press may or may not be

characterized as F037; however, taking a conservative approach

and for the purposes of this petition the material is characterized

as F037 and is assigned a Hazard Code of “T”

Hazardous Waste  

Description: Any sludge generated from gravitational separation of oil/water/

solids during the storage or treatment of process wastewaters and oily cooling waste‐ 

waters from petroleum refineries.  Such sludges include, but are not limited to, those  

generated in oil/water/solids separators, tanks, and impoundments; ditches and other

conveyances; sumps; and stormwater units receiving dry weather flow.  Sludge

generated in stormwater units that do not receive dry weather flow, sludges generated

from non‐contact once‐through cooling waters segregated for treatment from other

process or oily cooling waters, sludges generated in aggressive biological treatment  

units as defined in §261.31(b)(2) (including sludges generated in one or more additional

units after wastewaters have been treated in aggressive biological treatment units) and  

K051 wastes are not included in this listing.  This listing does include residuals generated

from processing or recycling oil‐bearing hazardous secondary materials excluded under

§261.4(a)(12)(i), if those residuals are to be disposed of.

b. Petitioned waste is a mixture of two or more listed hazardous wastes.

Not Applicable

c. Petitioned waste is a mixture of one or more solid non‐hazardous wastes and one or

more listed hazardous wastes, as described in 40 CFR §261.3(a)(2)(iii‐iv).  

Not Applicable

d. Petitioned waste is generated from the treatment, storage, or disposal of one or more

listed hazardous wastes (or solid non‐hazardous and listed hazardous waste mixture), as

described in 40 CFR §261.3(c)(2)(i).  

Not Applicable

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

The petitioned waste is a sludge processed via filter press or centrifuge (for oil recovery and

dewatering) sludge.

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EPA Delisting Petition Framework

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

(e.g., provide a range).

Based on analytical results, percent solids for the residual from processing the sludge is estimated

to be between 35% and 45%.

History of Waste Generation

4. Which of the following describes the generation of the petitioned waste: (Indicate those that apply

and provide the information requested for each item)

a. Waste has been generated in the past.  

Yes

Provide the year when waste  

was first generated: 2003

Provide the year when waste  

generation ended (if applicable): Not Applicable

b. Waste is presently being generated.  

Yes

Provide the year when waste  

was first generated:

2003

c. Waste will be generated in the future.  

Yes

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)?

Yes [Answer item 5a]

No [Answer item 5b]

a. Petitioned waste is/will be a fixed quantity.  

No

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

Average

Quantity

Maximum

Quantity

Unit of

Measurement

Monthly Volume: 14.6 16.7 cubic yards

Annual Volume: 175 200 cubic yards

   

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9

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EPA Delisting Petition Framework

Describe the method of volume estimation

Analytical results from delisting sampling were evaluated using DRAS software.  

Theoretical volumes were entered to maximize individual constituent delisting

concentrations while taking into consideration the amount of waste actually generated

(based on past volumes).  The indicated maximum volume is 200 yd3

.  All other values

were mathematically derived.

History of Waste Management

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

petitioned waste.

Past and Present Management:

Sludge is collected in two tanks.  The co‐located, in‐ground concrete tanks are approximately 30‐

feet (ft) wide by 130‐ft long by 8‐ ft deep, with each having a capacity of approximately 175,000

gallons.  The tanks are separated by a concrete wall running east‐west.  Sludge from the tanks is

periodically removed (at approximately 18 month intervals), de‐oiled and dewatered using a filter

press (and/or with an additional portable centrifuge), and the resulting solids are shipped off‐site

as F037 waste as the most conservative approach.  Recovered oil is reinserted into the refining

process and water from dewatering is routed to the Refinery’s on‐site wastewater treatment plant

for discharge via the Refinery’s Clean Water Act discharge permit.

Future Management:

If delisting is granted, residual solids will be sent for periodically disposal at a permitted RCRA

Subtitle D solid waste landfill.  Additionally, waste will be sampled and analyzed periodically

according to the Quality Assurance Project Plan (QAPP) presented in Attachment G.
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EPA Delisting Petition Framework

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Part 3: Delisting Process Information

General Operations at the Generating Facility

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

The Refinery converts crude oil and condensate, as well as field butane, by various processes

into liquid petroleum gases, gasoline, jet fuel, diesel fuel, fuel oils, and petroleum coke.

SIC Code: 2911 – Petroleum Refining

2. List and Describe products manufactured at the facility.

The Refinery converts crude oil and condensate, as well as field butane, by various processes

into liquid petroleum gases, gasoline, jet fuel, diesel fuel, fuel oils, and petroleum coke.

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

The petitioned waste  may or may not be characterized as F037; however, taking a conservative

approach and for the purposes of this petition they are characterized as F037 which is defined

as “Petroleum refinery primary oil/water/solids separation sludge.”  Other hazardous and non‐

hazardous wastes are generated at the facility in conjunction with typical Refinery operations,

but are not associated with the F037 waste and are, therefore, not listed.

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

schematics showing the layout of the facility.

The location of the Refinery is depicted in Figure 1 of Attachment B.  The facility’s layout and the

location of the stormwater tanks at the Refinery are shown in Figure 2.  Figure 3 shows the

stormwater tanks and the immediately surrounding area.  Figure 4 is the operations flow

diagram for the facility.  Figure 5 depicts water flow at the Refinery.

As shown in Figure 4, significant production processes/units at the Billings Refinery include:

• Crude Units

• Gas Processing

• Fluid Catalytic Cracking (FCC)

• Hydrotreating of naphtha, distillate, and gas oil

• Alkylation

• Delayed Coking

• Catalytic Reforming

• Hydrogen Production
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EPA Delisting Petition Framework

Using these production processes, the Billings Refinery makes petroleum gases, gasoline, jet

fuel, diesel, fuel oil, and petroleum coke.

Hazardous wastes from manufacturing processes are generally stored in a <90 day storage area

and numerous satellite accumulation containers.

There are no active permitted units or Treatment Storage and Disposal Facilities.

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

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

environmental statutes.  Include the permit numbers in this list.

There are no active permitted units or Treatment Storage and Disposal Facilities.

Environmental permits include:

Type Permit No. Comment

MPDES MT0000256 Wastewater

Title V OP2615‐03 Air

Air 2619‐25 Preconstruction Permit

RCRA MTHWP‐02‐01 Corrective Action

Contributing Manufacturing Processes

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

processing before primary manufacturing operations, including surface and equipment

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

and schematics.

The primary raw materials used at the Refinery are crude oil, condensate, and field butane.  

Supply logistics for raw materials include shipping via piping infrastructure and a limited number

of tanker trucks to the Refinery.  Source raw material stocks vary as market conditions warrant,

but the general composition of the raw materials remains relatively constant.

7. Provide a step‐by‐step description and schematic of each manufacturing process contributing to

the petitioned waste.  Include each process step, reactions occurring, flow rates, and material

inputs and outputs, as well as reaction intermediates and byproducts.  Identify and describe

waste inputs and outputs on the schematic(s) and show how each waste is managed.

Sediment in storm water tanks is accumulated from stormwater runoff from the Refinery’s

process area, as well as some dry‐weather flow consisting of water from washdown,

maintenance, and cleaning activities as well as steam condensate and heat exchanger back‐

flushing.  As such, the sediment is not accumulated at a constant rate.  Rather, the sediment is

gradually deposited over time and is currently being removed from the tanks at approximately

18 month intervals.  The sludge is periodically removed and processed for oil recovery and
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EPA Delisting Petition Framework

dewatering.  A process diagram depicting filter press operation is included in Attachment B as

Figure 6.

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

generated by a manufacturing process).

The location of the stormwater tanks is presented on Figure 2. The filter press or centrifuge is

typically located adjacent to the storm water tanks.  The waste is generated at the point the

solids resulting from processing the sludge exit the filter press or centrifuge.

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

the operating parameters.

An operational flow diagram for the Refinery is presented as Figure 4 in Attachment B.   

The Refinery processes an annual average of approximately 58,000 barrels per day of a mixture

of Canadian light crudes as well as heavy Canadian high‐sulfur and medium‐sulfur crudes.  These

crudes are delivered by a company‐operated Glacier pipeline system (which is also connected to

third‐party systems).   

Crude oil is heated in a heat exchanger and furnace and fed to a vertical distillation column at

atmospheric pressure where most of the feed is vaporized and separated into its various

fractions by condensing on fractionation trays, each corresponding to a different condensation

temperature.  The lighter fractions condense and are collected towards the top of the column.  

Heavier fractions, which may not vaporize in the column, are further separated later by vacuum

distillation.  Within each atmospheric distillation tower, a number of side streams of low‐boiling

point components are removed from the tower from different trays.  These low‐boiling point

mixtures are in equilibrium with heavier components which must be removed.  The side streams

are each sent to a different small stripping tower where steam is injected.  The steam strips the

light‐end components from the heavier components and both the steam and light‐ends are fed

back to the atmospheric distillation tower above the corresponding side stream draw tray.  

Fractions obtained from atmospheric distillation include naphtha, gasoline, kerosene, light fuel

oil, diesel oils, gas oil, lube distillate, and heavy bottoms.  Another product produced in

atmospheric distillation is refinery fuel gas (mainly methane and ethane).  Typically this gas also

contains hydrogen sulfide and ammonia gases.  The gas is sent to a refinery gas processing

system which removes sulfur compounds and ammonia so that it can be used as fuel in the

refinery heating furnaces.

Heavier fractions from the atmospheric distillation unit are vacuum distilled.  Vacuum distillation

is the distillation of petroleum fractions at a very low pressure (0.2 to 0.7 psia) to increase

volatilization and separation.  The heavier fractions from the vacuum distillation column are

processed downstream into more valuable products through coking operations
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Certain fractions from the distillation of crude oil are further refined in coking, catalytic cracking,

hydrotreating, alkylation, catalytic reforming, and other operations. These downstream

processes change the molecular structure of hydrocarbon molecules either by breaking them

into smaller molecules, joining them to form larger molecules, or reshaping them into higher

quality molecules.

Delayed coking produces hydrocarbon products, intermediates, and petroleum coke (essentially

solid carbon with varying amounts of impurities) by breaking large molecules.  The delayed

coking feed stream of residual oils are heated in a furnace and then fed to an insulated coke

drum where the coke is formed.  Hot vapors from the coke drums, containing cracked lighter

hydrocarbon products, hydrogen sulfide, and ammonia, are collected and fractionated so they

can be drawn off as products.  Steam is then injected into the full coke drum to remove

hydrocarbon vapors, water is injected to cool the coke, and the coke is removed. Typically, high

pressure water jets are used to cut the coke from the drum.

Catalytic cracking uses heat, pressure, and a catalyst to break larger hydrocarbon molecules into

smaller, lighter molecules.  In the fluid catalytic cracking (FCC) process, oil is heated and

contacted with hot catalyst.  The fluidized catalyst and the reacted hydrocarbon vapor separate

mechanically in the reactor.  The cracked oil vapors are then fed to a fractionation tower where

the various desired fractions are separated and collected.  The catalyst flows into a separate

vessel(s) for regeneration by burning off coke deposits with air.

Hydrotreating is a process used to remove impurities such as sulfur, nitrogen, oxygen, halides,

and trace metal impurities.  Hydrotreating is necessary to meet sulfur‐in‐fuels requirements and

may also upgrade the quality of fractions by converting olefins and diolefins to paraffins.  The

process utilizes specialized catalysts in the presence of substantial amounts of hydrogen under

high pressure and temperature to react the feedstocks and impurities with hydrogen.

Alkylation is used to produce a high octane gasoline blending stock from the isobutane formed

primarily during catalytic cracking and coking operations, but also from catalytic reforming,

crude distillation, and gas processing.  Alkylation joins an olefin and an isoparaffin compound

using an acidic catalyst. The products are alkylates, including propane and butane liquids.

Catalytic reforming uses catalytic reactions to process primarily low octane heavy straight run

(from the crude distillation unit) gasolines and naphthas into high octane products.

Finished petroleum products from the Refinery are delivered to the company‐operated

Yellowstone, Seminoe, Pioneer, and Cheyenne pipelines as well as by rail and truck to markets in

Montana, Washington, Colorado, Wyoming, Idaho, Utah, Nebraska, and South Dakota.

10. Describe all of your operating cycles (batch cycles, versus continuous operation, start‐up, shut‐

down, maintenance, cleaning) on a daily, weekly, or other period basis, as appropriate.  Identify

periods when process wastes are not generated (e.g., plant shutdowns or routine equipment

maintenance).
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The Billings Refinery is operated on a continuous basis (i.e., not on a batch basis) with

production occurring 24 hours per day, 7 days per week, and 365 days per year.

Sludge in the stormwater tanks is accumulated primarily through stormwater runoff with some

intermittent dry‐weather flow (such as water from washdown, maintenance, and cleaning

activities; steam condensate; and heat exchanger back‐flushing).  The petitioned waste is the

residual solids resulting from processing, via filter press or centrifuge, the sludge from two

storm water tanks and is currently being generated at approximately 18‐month intervals.

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

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

Manufacturing processes at the Refinery do not directly impact any variation that may occur in

the deposition of sediment material in the stormwater tanks.  The sediment accumulates

primarily through stormwater runoff with some intermittent dry‐weather flow (such as water

from washdown, maintenance, and cleaning activities; steam condensate; and heat exchanger

back‐flushing).   The sludge is soil and coke plus the materials that adhere to the soil and coke

particles (mainly oil and water).   

Because the material entering the tanks accumulates for many months, variability from year‐to‐

year is minimal.

In the past, some efforts have been made to minimize the amounts of solid material entering

the tanks (e.g., using a street sweeper on‐site, having laborers sweep up areas instead of

washing into the storm sewers, etc.).   

It is not expected that the composition of the petitioned waste will vary consequentially in the

future.

12. Describe how the composition and generation rate of the petitioned waste may periodically vary

due to any aspect of manufacturing process variability.

Manufacturing processes at the Refinery do not directly impact any variation that may occur in

the deposition of solid material in the tanks.  The sediment accumulates primarily through

stormwater runoff with some intermittent dry‐weather flow (such as water from washdown,

maintenance, and cleaning activities; steam condensate; and heat exchanger back‐flushing).

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

No

Yes [Continue with item 14]

No [Skip to item 22]

   

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Contributing Waste Treatment Processes

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

to the petitioned waste.  Include process steps, reactions occurring, flow rates, material inputs,

and waste inputs and outputs.

Not Applicable

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

applicable).

Not Applicable

16. Identify and describe waste inputs and outputs on the schematic and show how each waste is

managed.

Not Applicable

17. Describe all non‐process wastes entering the waste treatment process, including composition,

rate of inputs, and source.

Not Applicable

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

the operating parameters.

Not Applicable

19. Describe all of your operating cycles (batch cycles, versus continuous operation, start‐up, shut‐

down, maintenance, cleaning) on a daily, weekly, or other period basis, as appropriate.  Identify

periods when process wastes are not generated (e.g., plant shutdowns or routine equipment

maintenance).

Not Applicable

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

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

Not Applicable

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

due to any aspect of manufacturing process variability.

Not Applicable

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

Yes [Continue with item 23]

No [Skip to item 25]

The waste is managed on‐site in containers, typically roll‐off bins.

Waste Management Operations

23. Provide the following information (items 23a through 23g) for each unit that is (or was) used to

manage the petitioned waste:

a. Unit location/address (show if on‐ or off‐site).

b. Description of unit construction (current design materials).

c. History of unit design (e.g., chronological summary of any changes to original

construction).

d. Purpose and description of any unit design and operating changes.

e. Estimated surface area.

f. Estimated unit capacity volume

g. Listing of waste and material inputs which have occurred throughout the life of the unit,

if known.

Not Applicable

24. Provide detailed schematic(s) of the waste unit(s) of the waste unit(s) showing (as appropriate)

unit dimensions, influent point(s), effluent point(s), and waste thickness.

Not Applicable

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

include:

a. The name of the material(s).

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

process, waste management operations).

c. Function of each material in the process.

d. Approximate annual quantities.

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EPA Delisting Petition Framework

Sludge is generated from stormwater runoff from the Refinery’s process area, as well as some

dry‐weather flow consisting of water from washdown, maintenance, and cleaning activities as

well as steam condensate and heat exchanger back‐flushing.  The petitioned waste is residual

solids resulting from processing, via filter press or centrifuge, the sludge from the two storm

water tanks.  The approximate annual quantity of petitioned waste generated is 175 cubic yards.

26. Provide Material Safety Data Sheets (MSDS) and any other compositional information for trade

name and non‐elemental materials.  Include raw materials, cleaners, oils, solvents, strippers,

and any by‐products generated by the process.

Not Applicable

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

entering the process.

It is not anticipated that hydraulic fluid is entering the process.  All oil and grease originates as

crude oil or condensate.  All deposition in the tanks is associated with water use or storm water.  

As such, the quality of oil and grease cannot be considered virgin.  Additionally, the sludge is

removed from the tanks via vacuum truck or pump and the petitioned waste is the residual

resulting prom processing the sludge to remove water and oil.

Special Information

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

generated in the future?  

No

Yes [Continue with item 29]

No [Skip to item 32]

29. Explain how the bench‐scale or pilot‐scale process demonstration adequately models the

proposed full‐scale process.

Not Applicable

30. Explain any real or potential differences between the two processes.

Not Applicable

31. Describe the impact of those differences on the character of the petitioned waste.

Not Applicable

   

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

(MWTF)?

No

Yes [Continue with item 33]  

No [Skip to Part 4]

33. Describe your procedure for prescreening clients and wastes and how this procedure will be

carried out should your waste be excluded.

Not Applicable

34. Describe the procedures by which you will make sure that: (1) treatment levels needed by an

exclusion are maintained and (2) a hazardous waste is not disposed improperly as non‐

hazardous.

Not Applicable

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Part 4: Delisting Analytical Plan Development

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

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

engineering analysis.  Identify those constituents quantitated by laboratory analysis and those

quantitated using mass balance demonstrations.

Constituents of concern for this project are listed below.  These analytes were selected based on

process knowledge of the Billings Refinery’s operations, the Delisting Guidance Manual, and the

U.S. EPA Region 5 Skinner List.

Inorganics

Antimony

Arsenic

Barium

Beryllium

Cadmium

Chromium

Cobalt

Lead

Nickel

Selenium

Silver

Vanadium

Zinc

Mercury

General Chemistry

Cyanide

Moisture Content

pH

Sulfide

Reactive Sulfide

Reactive Cyanide

Volatile Organics

Benzene

Carbon disulfide

Chlorobenzene

Chloroform

1,2‐Dichlorobenzene

1,3‐Dichlorobenzene

1,4‐Dichlorobenzene

1,2‐Dichloroethane

1,1‐Dichloroethane

1,1‐Dichloroethene

1,4‐Dioxane

Ethylbenzene

Ethylene dibromide

Methyl ethyl ketone

Methyl t‐butyl ether

Naphthalene

Styrene

Tetrachloroethene

Toluene

1,1,1‐Trichloroethane

Trichloroethene

Xylenes (total)

Semivolatile Organics

Acenaphthene

Anthracene

Benzo(a)anthracene

Benzo(a)pyrene

Benzo(b)fluoranthene

Benzo(k)fluoranthene

Bis(2‐ethylhexyl)phthalate

Butyl benzyl phthalate

Chrysene

o‐, m‐, p‐Cresol

Dibenz(a,h)anthracene

Diethyl phthalate

Dimethyl phthalate

Di‐n‐butyl phthalate

2,4‐Dimethylphenol

2,4‐Dinitrophenol

2,4‐Dinitrotoluene

Di‐n‐octyl phthalate

Fluoranthene

Fluorene

Indeno(1,2,3‐cd)pyrene

Nitrobenzene

4‐Nitrophenol

Phenanthrene

Phenol

Pyrene

Pyridine

Quinoline

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

analyses were not conducted.  Provide all calculations and assumptions.

This item is not applicable.  Analyses were performed for all constituents of concern.

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

for your petitioned waste.

The Billings Refinery does not manufacture or use listed pesticides, herbicides, PCBs, and

dioxins/furans.   

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

which analysis was not conducted.

Analyses for hazardous characteristics (reactivity, corrosivity, ignitability, and toxicity) were

conducted for all collected samples.  Results of these analyses indicate that the petitioned waste

is not hazardous.  Therefore, this item is not applicable.

  
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Part 5: Delisting Sample and Analysis Information

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

preparation?

Yes

Yes [Answer items 1a and 1b]  

No [Skip to Part 4]

a. Submittal date of the sampling and analysis plan:

February 2, 2010 and June 8, 2010

b. Log number assigned by EPA to your draft submittal:

Unknown

Waste Sampling Information

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

No

Yes [Answer items 1a and 1b]  

No [Skip to Part 4]

a. Name and address of the organizations(s) or company(s) responsible for designing the

sampling strategy and collecting samples.

Sampling Strategy

Name: TRC Environmental Corporation

Address: 505 East Huntland Drive, Suite 250

City: Austin State: Texas Zip: 78752

Telephone (512) 329‐6080

Sample Collection

Name: Tetra Tech

Address: 618 South 25th Street

City: Billings State: Montana Zip: 59101

Telephone (406) 248‐9161

   

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24 ConocoPhillips – Billings, Montana Refinery    December 2010

EPA Delisting Petition Framework

b. For each individual person (in‐house and otherwise) who designed the sampling plan,

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

resume of qualifications and the following information:

Personnel from ConocoPhillips and TRC Environmental (TRC) prepared the Sampling and

Analysis Plan (Attachment D). Resumes for the specific individuals involved in the

preparation are presented in Attachment E.   

Personnel from Tetra Tech performed sample collection.  Their resumes are included in

the Sampling and Analysis Plan (Attachment D).

Sampling and Analysis Plan

Name: Allen Eggen

Affiliation: ConocoPhillips – Billings Refinery

Title: Waste and Water Lead

Name: Mike Holder

Affiliation: TRC ‐ Austin

Title: Program Manager

Name: Steve Miller

Affiliation: TRC ‐ Austin

Title: Senior Scientist

Sample Collection

Name: Paul E. Lemire

Affiliation: Tetra Tech – Billings

Title: Senior Hydrogeologist / Project Scientist

Name: Michael Shane Ewert

Affiliation: Tetra Tech – Billings

Title: Environmental Technician

Name: Michael J. Connolly

Affiliation: Tetra Tech – Billings

Title: Environmental Technician

   
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EPA Delisting Petition Framework

Sampling Strategy

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

to make sure that the samples were representative.

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

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

Sludges were collected from two tanks that receive stormwater runoff from the Refinery

process area, as well as some dry‐weather flow consisting of water from wash down and

maintenance and cleaning activities, steam condensate, and heat exchanger back‐

flushing.  The co‐located, in‐ground concrete tanks are approximately 30‐feet (ft) wide

by 130‐ft long by 8‐ ft deep, with each having a capacity of approximately 175,000

gallons.

These tanks are the locations where sludge is generated; therefore, material was

collected from the tanks.

b. Describe the techniques and guidelines used to select the waste sampling points (e.g.,

random sampling procedure or fixed transect and offset sampling procedure).

Each tank was divided into four equal quarters along the 130‐ft dimension and sludge

samples were collected from a full vertical profile (i.e., from the top of the sludge to the

bottom of the tank) at four locations within each quarter (see Figure 3‐1 in the Sampling

and Analysis Plan [Attachment D]).

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

containers specific to certain analyses) procedures used during the sample collection

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

number of grab samples collected for each composite sample, and why these

procedures were used.

A vacuum truck was used for sludge recovery from the tanks.  The hose/nozzle assembly

of the vacuum truck was lowered through the water column to collect material from the

top of the sludge to the bottom of the tank (i.e., a full vertical profile of the sludge).  

Sludge was collected from four locations within each tank quarter.  Solids were then

removed from the vacuum truck and placed in the mix tank of the filter press.  

Approximately 50 barrels of sludge material were processed through the filter press for

each tank quarter.  Samples of residual solids from the filter press were collected for

laboratory submission.  The filter press and vacuum truck were cleaned between sludge

collections/processing from each tank quarter.

The samples were collected in July 2010, approximately eight months following the

most recent tank cleanout.  This time frame allowed for sufficient accumulation of
26 ConocoPhillips – Billings, Montana Refinery    December 2010

EPA Delisting Petition Framework

sediment in the tanks to account for temporal variability.  Specifically, the material is

deposited in the tanks primarily during storm events and maintenance/cleaning

activities.  Thus, the deposition of specific target analytes should be random with

respect to the generating event.  By allowing an eight‐month accumulation window,

representative collection of material normally entering the tanks was achieved.

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

devices.

Sampling devices included a vacuum truck (and accessories) and various stainless steel

implements (trowels, knifes, bowls, etc.) for compositing sample material and placing it

into laboratory‐supplied containers.

The vacuum truck and filter press were selected to mimic the typical storm water tank

sediment removal and sludge processing procedure.  The other implements were

selected to minimize the potential for introduction of target analytes from sources other

than the tank sludge.

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

the impact of these deviations on waste characterizations.

There were no significant deviations from the procedures detailed in the Sampling and

Analysis Plan (Attachment D).

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

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

uniformity or spatial and temporal variability and how the strategy ensured collection of

representative samples.

Spatial Variability –The sludge collection strategy was designed to mimic actual tank

clean‐out procedures that have been used in the past.  Further, sludge was collected

from sixteen (16) locations within each tank (see Figure 7 in Attachment B).  The

distribution of the COCs within the tank quarters should be random based on the events

contributing to the deposition of material.  Therefore, spatial variability was adequately

characterized by the samples collected

Temporal Variability – Material was allowed to accumulate over a period of

approximately eight months.  The distribution of the COCs within the tank quarters

should be random based on the events contributing to the deposition of material.  

Therefore, temporal variability will be adequately characterized by the samples

collected

   
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Sample Specific Information

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

A total of nine composite samples (eight samples and one field duplicate) were collected and

analyzed.  Each tank was divided into quarters and sample material from four locations within

each quarter was composited, processed through the filter press, and the resulting residual

solids were collected to provide material for each laboratory sample.

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

pre‐petition meeting?  Explain the deviation.

The number of samples collected is consistent with the number discussed in the pre‐petition

scoping meeting (i.e., 4‐8 samples).

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

(items 5a through 5g).

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

appears in your field logbook and other records), the date the sample was taken, an

indication as to what type of sample it is (waste sample versus quality control sample

and whether or not it is a composite sample).

See Table 1 in Attachment C

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

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

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

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

Each sample is a composite of filter‐pressed material that originated at four locations

within each quadrant of two tanks (see Figure 3‐1 in the Sampling and Analysis Plan

[Attachment D]).  Material was collected using a vacuum truck with a hose and nozzle

attachment.  The nozzle was lowered through an initial layer of water until it reached

the sludge, then a full vertical profile of the sludge was collected (i.e., top of the sludge

to the bottom of the tank).  As such, specific volumes at each sampling point were not

measured.   

Sludge was mixed in the tank of the vacuum truck, then removed from the tank and

filter pressed.  Material exiting the filter press was submitted for laboratory analysis.  

The sample volume values presented in Table 1 are based on the assumptions that

approximately 50 barrels of material were collected in each tank quarter and that each

grab contributed 25% of the 50 barrels.
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EPA Delisting Petition Framework

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

and the specific sampling points (e.g., specific location in the quadrant).  You may refer

to numbered sampling points shown in a diagram.

See Figure 7 in Attachment B.

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

mixing).

Sludge was mixed in the tank of the vacuum truck, then removed from the tank,

mechanically mixed in the feed tank of the filter press, and filter pressed.  Residual

solids exiting the filter press were submitted for laboratory analysis.

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

whether phase separation occurred soon after collection).

See Table 1 in Attachment C

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

collected and the time and date when the sample was composited, as applicable.

See Table 1 in Attachment C

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

of containers used and techniques employed for container preparation) and types and

amounts of preservatives used.

Containers were supplied by the laboratory.  Containers included 4 and 8 ounce jars.  

See Table 4‐2 of the Sampling and Analysis Plan (Attachment D) for specific preservation

techniques and holding times.

Other General Information

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

The sampling team was on‐site at the Billings Refinery from approximately 8:00 am until 4:00

pm on July 1, 2010.  The team returned between approximately 8:30 am and 10:00 am on July 2,

2010.  For both days, the temperature was approximately 65°F at 8:00 am and reached the daily

high of about 95°F between 2:00 pm and 3:00 pm.  Light breezes (10 mph or less) were generally

from east.  There was no precipitation on either day.

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

have affected sample representativeness.

Sludge was collected and filter‐pressed during routine facility operations.  It is not expected that

facility activities affected sample representativeness.
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EPA Delisting Petition Framework

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

collection.

Disposable devices were not used for sample collection.

Decontamination was performed per the requirements given in Section 4.0 of the Sampling and

Analysis Plan (Attachment D).

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

Yes

Yes [Skip to item 11]  

No [Continue with item 10]

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

sample location and maintain sample integrity during transportation to the laboratory.  Copies

of chain‐of‐custody forms may be provided, but are not needed.

Not Applicable.

Localized Area of Contamination

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

within the petitioned waste?

No

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

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

and length) of the hot spot.

Not Applicable

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

Not Applicable

   

9

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EPA Delisting Petition Framework

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

Yes [Continue with item 17]  

No [Skip to item 21]

17. List and describe the untreated wastes that were treated and are represented by the treatment

residue samples collected during the sampling period.

Not Applicable

18. Provide the percentage of total wastes treated annually that was represented by the sampling

period.

Not Applicable

19. List and briefly describe the untreated wastes that also are treated at the facility but were not

represented by the sampling period.

Not Applicable

20. Explain why the wastes not represented by the sampling period are not expected to contain any

other hazardous constituents of concern, different levels of constituents of concern, or other

different characteristics than that represented by the sampling period.

Not Applicable

Waste Analysis Information

21. Was sample analysis done by in‐house staff?

No

Yes [Answer item 21b]  

No [Answer items 21a and 21b]

   

9

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

analyses.

Name: ALS Laboratory Group

Address: 10450 Stancliff Road, Suite 210

City: Houston State: Texas Zip: 77099‐4341

Telephone (281) 530‐5656

b. For each individual person (in‐house or otherwise) who conducted analyses or was

responsible for data reduction, validation, and laboratory quality control, please provide

a resume of qualifications and the following information:

Name: Joe Credeur

Affiliation: ALS Laboratory Group

Title: Laboratory Director

Name: Hoai T. Van

Affiliation: ALS Laboratory Group

Title: Technical Director

Name: Rebecca L. Pierrot

Affiliation: ALS Laboratory Group

Title: Quality Assurance Manager

Name: Hector Coronado

Affiliation: ALS Laboratory Croup

Title: Client Services Supervisor

Name: Hillery Williams

Affiliation: ALS Laboratory Group

Title: Volatiles Supervisor

Name: Sunil Singh

Affiliation: ALS Laboratory Group

Title: Inorganic Supervisor

Name: Stephanie Anderson

Affiliation: ALS Laboratory Group

Title: Extractions Supervisor

Name: Presenta Cabascango

Affiliation: ALS Laboratory Group

Title: Analyst
32 ConocoPhillips – Billings, Montana Refinery    December 2010

EPA Delisting Petition Framework

Name: Willard Richards

Affiliation: ALS Laboratory Group

Title: Analyst

Name: Andrew Neir

Affiliation: ALS Laboratory Group

Title: Analyst

Name: Jaycee Cegura

Affiliation: ALS Laboratory Group

Title: Analyst

Name: Johnnie B. Allen, Jr.

Affiliation: ALS Laboratory Group

Title: Analyst

Name: Ivan Brown

Affiliation: ALS Laboratory Group

Title: Analyst

Resumes for these individuals are presented in Attachment E.

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

quality control analyses.

Analytical data (including QA/QC results and data evaluation) are provided in Attachment F.

23. Provide the following information on each sample and each analysis.

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

laboratory.

See Table 2 in Attachment C

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

blank)

See Table 2 in Attachment C

c. Date of sample receipt by laboratory

All samples were received at ALS in Houston, Texas on July 3, 2010.

d. The sample workup or preparation method and reference for the method

See Table 3 in Attachment C.

   
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e. The date of sample workup or preparation

See Table 4 in Attachment C

f. The name of the person conducting the analysis

See Table 4 in Attachment C

g. The date of extraction and analysis

See Table 4 in Attachment C

h. The test method used and the source of the test method (e.g., SW‐846 Method 8020)

See Table 4 in Attachment C

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

See Table 4 in Attachment C

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

Total results are presented in Table 8 of Attachment C.  TCLP results are presented in

Table 9 of Attachment C.

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

Total results are dry‐weight corrected.  The correction is denoted in data packages

(Attachment F) in the units for each individual analyte by the addition of “‐dry”.

l. The quantitation limits.

Quantitation limits for non‐detected analytes are presented in Tables 8 and 9.  

Quantitation limits for all reported analytes are given in the data packages (Attachment

F).

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

See Table 10

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

As noted in the Sampling and Analysis Plan, the cleaning cycle for the tanks averages about once

every 18‐24 months, and the volume of residuals is generally less than 200 tons.  In order to

determine the volume of waste represented by 200 tons (i.e., volume to enter into DRAS

software), a portion of the material submitted to the laboratory for analysis was used to

determine its specific gravity (see work order 1008246 in Attachment F).
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EPA Delisting Petition Framework

Analytical results indicate that the specific gravity of the waste is 2.15 at 20°C.  Given that

specific gravity is defined as the ratio of the mass of a solid or liquid to the mass of an equal

volume of distilled water and water = 1000 kg/m3

, it is calculated that 1 m3 of the petitioned

waste = 2150 kg.

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

analysis, provide the following information.

a. The name of the spiked analyte.

See Table 5 in Attachment C for volatile organic surrogates.  See Table 6 in Attachment C

for semivolatile surrogates.  See Table 7 in Attachment C for MS/MSD results for sample

South Q2.

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

Surrogates are not expected to be found in environmental samples and are spiked into

all analyses; therefore, there is no information pertaining to surrogate concentrations in

unspiked samples.  See Table 7 in Attachment C for MS/MSD results for sample South

Q2.

c. The amount of the spiked analyte added.

Spiking concentrations for surrogates are not reported by the laboratory.  See Table 7 in

Attachment C for MS/MSD results for sample South Q2.

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

Measured amounts of surrogate compounds are not reported by the laboratory.  See

Table 7 in Attachment C for MS/MSD results for sample South Q2.

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

See Table 5 in Attachment C for volatile organic surrogates.  See Table 6 in Attachment C

for semivolatile surrogates.  See Table 7 in Attachment C for MS/MSD results for sample

South Q2.

The method of calculation for surrogates is:

  ൌ ݕݎ݁ݒ݋% ܴ݁ܿ

݊݀ݑ݋ܨ݊ ݋݅ݐܽݎݐ݊ܿ݁݊݋ܥ

100 ൈ  ݀݀݁݀ܣ݊ ݋݅ݐܽݎݐ݊ܿ݁݊݋ܥ

The method of calculation for MS/MSD is:

  ൌ ݕݎ݁ݒ݋% ܴ݁ܿ

ܥ௦ െ ܥ௨

௡ܥ

 ൈ 100
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EPA Delisting Petition Framework

Where:

Cs Measured concentration in the spiked analysis

Cu Measured concentration in the unspiked analysis

Cn Concentration spiked

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

See Table 5 in Attachment C for volatile organic surrogates.  See Table 6 in Attachment C

for semivolatile surrogates.  See Table 7 in Attachment C for MS/MSD results for sample

South Q2.

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

See Table 7 in Attachment C for MS/MSD results for sample South Q2.

h. The acceptance criterion for the RPD.

See Table 7 in Attachment C for MS/MSD results for sample South Q2.

27. Identify whether the waste analytical data was corrected based on quality control results (e.g.,

blank analysis) and explain how the correction was made.

Blank subtraction was not performed on the reported analytical results.

Analytical results were corrected for moisture content per analytical method requirements.  

Corrected results are denoted in the analytical data packages via the addition of “‐dry” to the

units for an individual analyte.  Moisture correction was performed per the guidance given in

SW‐846 Method 8000, Section 11.10.5 (March 2003).

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

should include the observed analytical interferences and what actions were taken to resolve the

problem.

See the data evaluation report included in Attachment F.

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

Mobile Metal Concentration) please include all calculation sheets.

Not Applicable

   
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Part 6: Delisting Groundwater Monitoring Information

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

a. The petitioned waste is currently managed in a land‐based waste management unit (on‐

site or off‐site), and groundwater monitoring is needed under 40 CFR Part 264 or 265 or

authorized State equivalent, or other Federal, state, or local requirements; or if

groundwater monitoring information is otherwise available for the unit.

[Go to item 2]

No

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

management unit (on‐site or off‐site) and groundwater monitoring was needed under

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

requirements; or if groundwater monitoring information is otherwise available for the

unit.

[Go to item 2]

No

c. The petitioned waste is currently managed, or was once managed, in a land‐based

waste management unit, but groundwater monitoring requirement has been waived.

[Go to item 9]

No

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

based waste management units containing also significant amounts of other wastes,

and you consider groundwater data from these non‐dedicated units are immaterial in

evaluating the petitioned waste’s impact on groundwater quality.

[Go to item 10]

No

e. None of the above management scenarios apply.

[Go to item 11]

Yes

   
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EPA Delisting Petition Framework

2. Has the appropriate responsible party previously submitted groundwater monitoring

information for the subject units to an EPA Regional office or an authorized State in response to

40 CFR Part 264 or 265 requirements (or authorized State equivalent)?

Yes [Continue with item 3]  

No [Skip to item 5]

Not Applicable

3. Do you wish that we directly get the groundwater monitoring information from the EPA Region

or State?

Yes [Complete item 4 and continue with item 6]  

No [Skip to item 5]

Not Applicable

4. Indicate the EPA Regional or State contact for getting the groundwater monitoring information

(include name of contact, affiliation, mailing address, and phone number).

a. Name of Contact:   

b. Affiliation:   

c. Title of report (if applicable):   

d. Street/P.O. Box:   

City:   

State/Zip:   

e. Phone   

Not Applicable

5. Provide all available and relevant (e.g., for each unit used to manage the petitioned waste)

groundwater monitoring information and reports which, at a minimum, should include:

a. A description of site geology and hydrology.

b. A description of the groundwater monitoring systems for the units in which petitioned

waste is (or was) managed.

c. The results obtained from analysis of groundwater samples.

d. A discussion of sampling and analytical procedures followed in getting and analyzing the

groundwater samples.
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EPA Delisting Petition Framework

e. Any additional information necessary to characterize the petitioned waste’s impact on

groundwater quality.

f. An analysis and discussion of whether the above listed information and data that show

contamination of the groundwater is attributable to the petitioned waste.

Not Applicable

6. Is the unsaturated (vadose) zone monitored at any of the subject units?

Yes [Continue with item 7]  

No [Skip to item 8]

Not Applicable

7. Provide the following information on vadose zone monitoring (e.g., lysimeter information) in as

much detail as possible (as requested for groundwater monitoring systems).

a. A description of regional, local, and unit‐specific geology and hydrology, and soil

characteristics.

b. A description of the monitoring system(s) (e.g., design and construction).

c. A description of the sampling and analytical procedures followed.

d. Analytical and QC data obtained from sample analysis.

e. An interpretation of the information and data presented.

Not Applicable

8. Discuss whether groundwater contamination exists on the site and, if it does, identify the

source.  If the source is not the petitioned waste, explain, with supporting information, why the

petitioned waste has not contributed to the contamination.

Not Applicable

9. Provide documentation on the waiver or exemption of groundwater monitoring at the land‐

based waste management unit containing the petitioned waste.

Not Applicable

   
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10. Identify the units in question, provide estimates of the relative volumes of the petitioned and

other wastes disposed in the units, and discuss in detail why you consider groundwater data

from these non‐dedicated units are immaterial in evaluating the petitioned waste’s impact on

groundwater quality.

Not Applicable

11. Describe why groundwater monitoring is not needed for your petitioned waste.

The petitioned waste is managed in containers, not a land‐based unit.  If delisting is granted,

wastes will be sent for periodically disposal at a permitted RCRA Subtitle D solid waste landfill.