Attachment D

Sampling and Analysis Plan    
Sampling and Analysis Plan 

F037 Waste Delisting 

Prepared for: 

ConocoPhillips Company 

Billings Refinery 

401 South 23rd Street 

Billings, Montana 59101 

Prepared by: 

TRC Environmental Corporation 

505 East Huntland Drive, Suite 250 

Austin, Texas 78752 

TRC Project No. 172405 

June 2010 
Sampling and Analysis Plan 

F037 Waste Delisting 

ConocoPhillips Company, Billings Refinery June 2010

Project No. 172405 Table of Contents 

Table of Contents 

Page 

1.0 Objectives of the Sampling Effort ....................................................................... 1-1

2.0 Description of the Waste to be Sampled..............................................................2-1

3.0 Description of the Sampling Strategy..................................................................3-1

4.0 Sampling and Analytical Requirements...............................................................4-1
Sampling and Analysis Plan 

F037 Waste Delisting 

ConocoPhillips Company, Billings Refinery June 2010

Project No. 172405 1-1

1.0 OBJECTIVES OF THE SAMPLING EFFORT 

This document presents the proposed Sampling and Analysis Plan (SAP) to 

support F037 waste delisting for residual solids generated from the oil-recovery process 

for secondary oil-bearing hazardous materials at the ConocoPhillips (COP) Billings, 

Montana Refinery (“the Refinery”). 

The ConocoPhillips Refinery is located at 401 South 23rd Street in Billings, 

Montana and covers approximately 200 acres on the southeastern side of Billings. The 

legal description of the Refinery is Northwest 1⁄4 of Section 2, Township 1 South, Range 

26 East in Yellowstone County, Montana. The Refinery, which began operations in 

1949, currently converts crude oil and condensate, as well as field butane, by various 

processes into liquid petroleum gases, gasoline, jet fuel, diesel fuel, fuel oils, asphalt, and 

petroleum coke. 

As part of current operations at the Refinery, sludge is periodically removed from 

two storm water tanks and processed via centrifuge and/or filter press for oil recovery and 

dewatering. The residual solids from the oil-recovery process are characterized as F037, a 

hazardous waste under the Resource Conservation and Recovery Act (RCRA). COP is 

petitioning the United States Environmental Protection Agency (US EPA), Region 8, to 

exclude from hazardous regulation (i.e., delist), the tank residuals that are currently being 

managed as F037 wastes. This SAP has been prepared to guide the analytical program 

that will be conducted in support of the delisting determination. 

The objective of the sampling effort is to obtain waste characterization data that 

demonstrates: 

• The residual solids do not meet the criteria for which F037 wastes are listed; 

• The residual solids do not exhibit a characteristic of a hazardous waste; and 

• The waste does not contain any other constituents at levels of concern. 

The proposed delisting would authorize periodic disposal of the wastes at a 

permitted RCRA Subtitle D solid waste landfill. ConocoPhillips is requesting delisting 

for approximately 500 tons (measured on a wet weight basis) of residuals per year. 

Although the cleaning cycle for these tanks averages about once every 18-24 months, and 

the volume of residuals is generally less than 500 tons, use of the higher value and annual 

frequency will allow for management of all residuals under the delisting and ensure that 

disposal is protective of human health and the environment. 
Sampling and Analysis Plan 

F037 Waste Delisting 

ConocoPhillips Company, Billings Refinery June 2010

Project No. 172405 2-1

2.0 DESCRIPTION OF THE WASTE TO BE SAMPLED 

Residual solids are generated when sludge is removed from two tanks that receive 

storm water runoff from the Refinery process area, as well as some dry-weather flow 

consisting of water from washdown and maintenance and cleaning activities, steam 

condensate, and heat exchanger back-flushing. The sludge from the tanks meets the 

definition for listing as a hazardous waste, specifically as primary sludge (F037), per 

Title 40 of the Code of Federal Regulations (40 CFR), Section (§) 261.32. The colocated, 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. Figure 2-1 depicts the configuration of 

the tanks. Figure 2-2 depicts the dimensions of the tank. The tanks are a part of the 

Refinery’s Clean Water Act (CWA)-permitted wastewater system. Liquids in the tanks 

are normally directed to the facility wastewater treatment plant and are not part of the 

proposed delisting. Sludge from the tanks is periodically removed, de-oiled and 

dewatered using a refinery filter press (and/or with an additional portable centrifuge), and 

the residual solids are shipped off-site as F037 waste. Initial sampling data does not 

indicate any hazardous characteristic levels for toxicity characteristic (TC) constituents 

(40 CFR §261.24). 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 CWA discharge permit. 

Tank flow is presented in Figure 2-3. Flow from the refinery’s process area storm 

sewer system enters the south tank at its northwestern corner via an underground pipe. 

Incidental run-off from the filter press area enters the north tank at its northwestern 

corner. Flow from the south tank enters the north tank via a valve located at the bottom 

of the dividing wall between the tanks along the eastern side of the wall. Floating suction 

at the northeastern corner of the north tank directs water to the wastewater treatment 

system. 
Sampling and Analysis Plan 

F037 Waste Delisting 

ConocoPhillips Company, Billings Refinery June 2010

Project No. 172405 2-2

Figure 2-1. The Tanks 

Figure 2-2. Tank Dimensions 

30-ft 

30-ft 

130-ft 

8-ft
Sampling and Analysis Plan 

F037 Waste Delisting ConocoPhillips Company, Billings Refinery Project No. 172405 

Figure 2-3. Tank Flow 

Process Area Storm Sewer System (Underground)

Run-Off from Filter Press Area 

Process Area Storm Water Tank - North

Normally open connecting valve located atbottom of dividing wall

Process Area Storm Water Tank - South

Floating Suction
Sampling and Analysis Plan 

F037 Waste Delisting 

ConocoPhillips Company, Billings Refinery June 2010

Project No. 172405 3-1

3.0 DESCRIPTION OF THE SAMPLING PROGRAM 

The sampling program will consist of one sampling event. Eight (8) samples, one 

(1) duplicate, and one matrix spike/matrix spike duplicate (MS/MSD) pair will be 

collected of the filter-pressed material for both totals and Toxicity Characteristic 

Leaching Procedure (TCLP) analyses of the constituents of concern (COC) list provided 

in Section 4.0. The COC list consists of a subset of the Appendix IX constituent list in 40 

CFR Part 264, and is based on: 1) knowledge of Refinery processes and wastes; 2) the 

evaluation of available references, including Exhibit 3 of the March 23, 2000 USEPA 

RCRA Delisting Program Guidance Manual for the Petitioner entitled Constituents of 

Concern for Wastes from Petroleum Processes; 3) the USEPA Region 5 “Skinner List” 

constituents (i.e., those constituents commonly found in Refinery wastes and updated to 

address toxicological and analytical concerns); and 4) the basis for listing constituents for 

F037 per 40 CFR Part 261 Appendix VII (i.e., benzene, benzo(a)pyrene, chrysene, lead, 

and chromium). Each sample will also be analyzed for pH, oil & grease, total cyanide, 

and sulfide levels. Samples will not be analyzed for ignitability or corrosivity since these 

characteristics are not applicable to solids. Two samples of the filter-pressed material 

(one from pressed sludge from each tank) will be analyzed using the additional neutral 

and alkaline pH TCLP extraction fluids presented in the delisting guidance. 

Characterization of Spatial and Temporal Variability 

Sampling will adequately characterize both spatial and temporal variability. The 

samples will be collected in the spring/summer of 2010, approximately eight months 

following the most recent tank cleanout. This time frame will allow for sufficient 

accumulation of refinery wastewater/sludge materials 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 COCs will be 

random with respect to the generating event. By allowing an eight-month accumulation 

window, representative collection of material normally entering the tanks will be 

achieved. 

To account for spatial variability, each tank will be divided into four quarters 

along the 130-ft dimension and sludge will be drawn 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. 

The distribution of the COCs within the tank quarters is expected to be random based on 

the events contributing to the deposition of material. 
Sampling and Analysis Plan 

F037 Waste Delisting 

ConocoPhillips Company, Billings Refinery June 2010

Project No. 172405 3-2

Sludge Collection Strategy 

The sludge collection strategy is designed to mimic actual tank clean-out 

procedures. These include: 

1. A vacuum truck will be utilized for sludge recovery from the tanks 

2. The hose/nozzle assembly of the vacuum truck will be 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) 

3. Sludge will be collected from at least four locations within each tank quarter 

4. Solids will be removed from the vacuum truck and placed in the mix tank of 

the filter press 

5. Approximately 50 barrels of material will be processed through the filter press 

6. Samples of the filter pressed material will be collected for laboratory 

submission 

7. The filter press and vacuum truck will be cleaned between sludge 

collection/processing from each tank quarter 

Sludge Collection Team 

Paul Lemire will provide sludge collection and sampling oversight for this 

project. Technicians will be Michael Ewert and Michael Connoly. Current resumes for 

these individuals are presented in Attachment A to this document. 

Sludge Collection Locations 

Each tank will be divided into quarters along the 130-ft wall. Each quarter will 

measure approximately 32.5-ft by 30-ft. Each quarter will be divided into thirds along 

each side (i.e., 10-ft intervals along the 30-ft dimension and 10.8-ft intervals along the 

32.5-ft dimension) with sludge collected at the intersections of these lines. Approximate 

sludge collection locations are shown in Figure 3-1. 

Sludge collection locations within each tank may be re-located based on 

availability of material; however, collection locations will remain within each tank 

quarter and, at a minimum, sludge will be collected from four locations within each 

quarter. 

Health and Safety Procedures 

All sludge collection activities will be conducted in accordance with the 

Refinery’s approved RCRA Corrective Action Sitewide Health and Safety Plan (HASP). 
Sampling and Analysis Plan 

F037 Waste Delisting ConocoPhillips Company, Billings Refinery Project No. 172405 

 = Approximate Sample Collection Location 

Figure 3-1. Sample Collection Locations

Process Area Storm Water Tank - North

N

Process Area Storm Water Tank - South

32.5-ft 32.5-ft 32.5-ft 32.5-ft

SouthQ1 SouthQ2 SouthQ3 SouthQ4

NorthQ1 NorthQ2 NorthQ3 NorthQ4
Sampling and Analysis Plan 

F037 Waste Delisting ConocoPhillips Company, Billings Refinery Project No. 172405 

Table 3-1. Anticipated Samples 

Total 

Samples VOCs1 SVOCs1 Metals1 Cyanide2 Sulfide3

Oil & 

Grease pH Moisture Acid5 

NorthQ1 9 9 9 9 9 9 9 9 9 NorthQ2 9 9 9 9 9 9 9 9 9 NorthQ3 9 9 9 9 9 9 9 9 9 NorthQ4 9 9 9 9 9 9 9 9 9 SouthQ1 9 9 9 9 9 9 9 9 9 SouthQ2 9 9 9 9 9 9 9 9 9 SouthQ3 9 9 9 9 9 9 9 9 9 SouthQ4 9 9 9 9 9 9 9 9 9 Field Duplicate9 9 9 9 9 9 9 9 9 9 MS10 9 9 9 9 9 9 -- 9 9 MSD10 9 9 9 9 9 9 -- 9 9 

1 See Table 4-1 for target analyte lists for volatile organic compounds (VOCs), semivolatile organic compounds (SVOCs) and metals 

2 Total and amenable cyanide – Methods 9014/9213. 3 Methods 9034/9215 4 TCLP analyses will be required for VOCs, SVOCs, and metals including mercury. 5 “Acid” refers to the extraction fluid pH as determined using Method 1311. 6 “Neutral” refers to the extraction fluid pH (DI water). 7 “Basic” refers to the extraction fluid pH (according to Standard Methods for the Examination of Water and Wastewater). 8 Sample material (filter-pressed material) from two quarters (one from each tank) will be submitted for TCLP analyses using the addi

extraction fluids. Based on previous experience, sample material from filter-pressed sludge from NorthQ4 and SouthQ1 are selected extractions and analyses. The specific locations of these samples may be altered based on the availability of sludge and/or any other 

9 Extra filter-pressed sample material from one location will be submitted as a field duplicate. 10 Extra filter-pressed sample material from one location will be submitted for matrix spike (MS) analyses and duplicate MS (MSD) an
Sampling and Analysis Plan 

 F037 Waste Delisting 

 ConocoPhillips Billings, Montana, Refinery June 2010

Project No. 172405 4-1

4.0 SAMPLING AND ANALYTICAL REQUIREMENTS 

The overall quality objective is to implement procedures that will provide 

scientifically valid results that are sufficient to meet the objectives of the sampling 

program. 

Table 4-1 presents analytical method and targeted reporting limits for metals, total 

and amenable cyanide, and organic analytes. 

Order of Sample Collection 

Samples for volatile organics must be collected immediately following filter press 

processing and compositing of the grab samples in order to minimize the loss of target 

analytes. The remaining samples will be collected in the following order: semivolatile 

organics, oil & grease, metals, cyanide, and the remaining parameters. 

Sample Collection Protocol 

Four independent grab samples will be collected from each batch (each quarter) of 

filter-pressed material. These grab samples will be composited and placed into 

appropriate containers for submission to the laboratory (see Table 4-2). 

Sample Numbering 

The following items will be used to name samples: 

• Sample material will be collected from filter-pressed sludge 

• The filter press will process sludge from each tank quarter 

• There is a north tank and a south tank 

Therefore, samples will be named according to the tank and quarter from which 

the material was collected (with quarters being numbered 1-4 from east to west [see 

Figure 3-1]). For example, the sample collected from the third quarter of the north tank 

will be named NorthQ3. 

Field duplicates will be numbered by adding a 2 to the end of the sample name. 

For example, if a field duplicate is collected from the first quarter of the south tank, then 

the original sample would be named SouthQ1 and the field duplicate would be named 

SouthQ12. 

Trip blanks will be named beginning with a “TB”, followed by the date collected, 

and including consecutive letters. For example, the first trip blank submitted on May 1, 
Sampling and Analysis Plan 

 F037 Waste Delisting 

 ConocoPhillips Billings, Montana, Refinery June 2010

Project No. 172405 4-2

2010 would be named TB050110A, the second trip blank submitted on the same day 

would be named TB050110B, etc. 

Sample Containers and Preservation 

Holding times, preservation requirements, and typical containers for solid 

samples, are presented in Table 4-2. 

Sample Documentation 

Specific procedures for chain-of-custody will be in accordance with the 

Refinery’s Standard Operating Procedures (SOPs). 

Sample Shipment 

A completed COC form will accompany samples during each step of custody 

transfer and shipment. When physical possession of samples is transferred, both the 

individual relinquishing the samples and the individual receiving them will sign, date, 

and record the time on the COC form. In the case of sample shipment by an overnight 

courier, a properly prepared air bill (waybill) will serve as an extension of the COC form 

while the samples are in transit. 

The following steps must be followed when packing environmental samples for 

shipment by air: 

1. Select a sturdy cooler in good condition. Secure and tape the drain plug with 

duct tape. 

2. Ensure the caps on all bottles are tight (will not leak); check to see that labels 

and chain-of-custody records are completed properly. 

3. Place all bottles in separate and appropriately sized plastic zip-top bags and 

close the bags. Bottles may be wrapped in bubble wrap. It is preferable to 

place glass sample bottles and jars into the cooler vertically. Due to the 

strength properties of a glass container, there is much less chance for breakage 

when the container is packed vertically rather then horizontally. 

4. Place two to four inches of packing peanuts, vermiculite, or other cushioning 

material into the bag in the cooler and then place the bottles and cans in the 

bag with sufficient space to allow for the addition of more packing peanuts or 

vermiculite between the bottles and cans. 
Sampling and Analysis Plan 

 F037 Waste Delisting 

 ConocoPhillips Billings, Montana, Refinery June 2010

Project No. 172405 4-3

5. Put ice in large plastic zip-top bags and properly seal. Place these ice bags on 

top of and between the samples. Fill all remaining space between the bottles 

or cans with packing peanuts, bubble wrap, or vermiculite. 

6. Place the completed Chain-of-Custody Record into a plastic zip-top bag, tape 

the bag to the inner side of the cooler’s lid, and then close the cooler. 

7. Wrap strapping tape around each end of the cooler two times, and completed 

custody seals affixed to the top on adjacent sides of the cooler. Place the 

custody seals so that the cooler cannot be opened without breaking the seal. 

Place clear shipping tape over the custody seals. 

8. A label containing the name and address of the shipper shall be placed on the 

outside of the container, preferably using a handle-tag or secured with extra 

tape across the top of the cooler. 

Laboratory 

ALS Laboratory Group in Houston, Texas will perform analyses associated with 

this project. 

• The laboratory contact is Hector Coronado 

• The telephone number is (281) 530-5656 

Toxicity Characteristic Leaching Procedure (TCLP) 

Samples will be analyzed for both total and TCLP volatiles, semivolatiles, and 

metals. Regarding TCLP analyses, all samples will be extracted using the appropriate 

extraction fluid as determined using TCLP method (SW846 Method 1311) criteria and 

procedures. Additionally, sufficient filter-pressed sample material of sludge from one 

quarter of each tank (i.e., NorthQ4 and SouthQ1) will be extracted using extraction fluids 

with pH values of 7.0 and 10.1 (as noted in delisting guidance documents) with 

subsequent analyses for volatiles, semivolatiles, and metals. The laboratory must be 

contacted well in advance of receiving samples to discuss the generation and use of these 

non-standard extraction fluids. 

The extraction fluid with a neutral pH is described in Method 1311, Section 5.2 as 

reagent water and has a pH of 7.0 ± 0.5 standard units. 

The extraction fluid with an alkaline pH is described in Standard Methods for the 

Examination of Water and Wastewater. It is prepared by mixing 2.092 grams of 0.025 

molar sodium bicarbonate (NaHCO3) and 2.640 grams of 0.025 molar sodium carbonate 
Sampling and Analysis Plan 

 F037 Waste Delisting 

 ConocoPhillips Billings, Montana, Refinery June 2010

Project No. 172405 4-4

in 1000 mL aqueous solution at 25°C. This solution must have a pH of 10.01 ± 0.05 

standard units. 

Reporting Limits 

A majority of the critical delisting levels are expected to be determined primarily 

for the groundwater ingestion pathway. Therefore, obtaining data with the lowest 

possible reporting limits is of utmost importance – especially for TCLP results. Since the 

sample matrix is sediment, target reporting limits are likely to be unattainable. Every 

effort must be made by the laboratory to report the lowest practical reporting limit. 

Table 4-1 presents analytical method and targeted reporting limits for metals, total 

and amenable cyanide, and organic analytes. 

Quality Control Samples 

As previously discussed, the residual solids are not expected to show significant 

variability and should be relatively homogeneous. Combined sampling and analytical 

variability will be measured by the collection of a duplicate sample. The field duplicate 

will be collected by filling two sets of sample containers from the composite sample of 

one batch of material processed through the filter press. 

A trip blank will be used to assess sample container and potential transportation 

impacts. 

A matrix spike/matrix spike duplicate pair (MS/MSD) will be collected and 

analyzed to assess analytical precision and accuracy. 

All quality control (QC) samples will be collected in accordance with the 

frequencies in Table 4-3 

Decontamination 

Prior to sample collection and processing, the filter press and vacuum truck will 

be decontaminated. Generally, refinery effluent water will be processed through the 

vacuum truck and filter press for decontamination purposes. The filter press and vacuum 

truck will also be decontaminated between collection at tank quarters. 

If disposable equipment is used for sampling, each location will have dedicated 

equipment that will be used for one sample, then discarded. If non-disposable equipment 

is used, any other equipment that might come into contact with the sample will be 

thoroughly decontaminated prior to taking the first sample and between tank quarters. 

This decontamination procedure includes the following steps: 
Sampling and Analysis Plan 

 F037 Waste Delisting 

 ConocoPhillips Billings, Montana, Refinery June 2010

Project No. 172405 4-5

1. Lay out sufficient polyethylene sheeting on the ground or floor to allow 

placement of the equipment being decontaminated. 

2. Remove non-aqueous phase liquids (NAPL), if present, with an absorbent pad or 

other suitable device. 

3. Remove any solid material (to the degree possible) with a brush and potable tap or 

distilled water. 

4. Wash the equipment with a brush, laboratory grade non-phosphate detergent (e.g., 

Liquinox, Alconox), and potable tap or distilled water. 

5. Rinse the equipment with potable tap or distilled water. 

6. Rinse the equipment with 10 percent methanol. 

7. Rinse the equipment with distilled water. 

8. Reassemble equipment, if necessary, and wrap completely in clean, unused 

aluminum foil, shiny side out for transport and/or storage. Re-use of equipment 

on the same day without wrapping in foil is acceptable. 

Record all decontamination procedures in the field logbook or appropriate field form. 

A list of potential sample collection equipment is provided in Table 4-4. 
Sampling and Analysis Plan 

 F037 Waste Delisting 

 ConocoPhillips Billings, Montana, Refinery June 2010

Project No. 172405 4-6

Table 4-1. Analytical Methods and Target Reporting Limits 

Analyte Method 

Total Target 

Reporting 

Limit 

(mg/kg)1

TCLP Target 

Reporting 

Limit 

(mg/L)1

Inorganics 

Antimony 0.5 0.005 

Arsenic 0.5 0.005 

Barium 0.5 0.005 

Beryllium 0.5 0.005 

Cadmium 0.5 0.005 

Chromium 0.5 0.005 

Cobalt 0.5 0.005 

Lead 0.5 0.005 

Nickel 0.5 0.005 

Selenium 0.5 0.005 

Silver 0.5 0.005 

Vanadium 0.5 0.005 

Zinc 

6010; 

6020 

0.5 0.005 

Mercury 7471 0.005 0.0002 

Volatile Organics 

Benzene 0.005 0.005 

Carbon disulfide 0.010 0.010 

Chlorobenzene 0.005 0.005 

Chloroform 0.005 0.005 

1,2-Dichlorobenzene2 0.005 0.005 

1,3-Dichlorobenzene2 0.005 0.005 

1,4-Dichlorobenzene2 0.005 0.005 

1,2-Dichloroethane 0.005 0.005 

1,1-Dichloroethane 0.005 0.005 

1,1-Dichloroethylene 0.005 0.005 

1,4-Dioxane 0.10 0.10 

Ethylbenzene 0.005 0.005 

Ethylene dibromide 0.005 0.005 

Methyl ethyl ketone 0.010 0.010 

Methyl t-butyl ether 0.005 0.005 

Naphthalene2 0.005 0.005 

Styrene 0.005 0.005 

Tetrachloroethylene 0.005 0.005 

Toluene 0.005 0.005 

1,1,1-Trichloroethane 0.005 0.005 

Trichloroethylene 0.005 0.005 

Xylenes (total) 

8260 

0.005 0.015 
Sampling and Analysis Plan 

 F037 Waste Delisting 

 ConocoPhillips Billings, Montana, Refinery June 2010

Project No. 172405 4-7

Table 4-1. Analytical Methods and Target Reporting Limits (continued) 

Analyte Method 

Total Target 

Reporting 

Limit 

(mg/kg)1

TCLP Target 

Reporting 

Limit 

(mg/L)1

Semivolatile Organics

Acenapthene 0.167 0.005 

Anthracene 0.167 0.005 

Benzo(a)anthracene 0.167 0.005 

Benzo(a)pyrene 0.167 0.005 

Benzo(b)fluoranthrene 0.167 0.005 

Benzo(k)fluoranthene 0.167 0.005 

Bis(2-ethylhexyl)phthalate 0.167 0.005 

Butyl benzyl phthalate 0.167 0.005 

Chrysene 0.167 0.005 

o, m, p-Cresol 0.167 0.005 

Dibenz(a,h)anthracene 0.167 0.005 

Diethyl phthalate 0.167 0.005 

Dimethyl phthalate 0.167 0.005 

Di-n-butyl phthalate 0.167 0.005 

2,4-Dimethylphenol 0.167 0.005 

2,4-Dinitrophenol 0.167 0.005 

2,4-Dinitrotoluene 0.167 0.005 

Di-n-octyl phthalate 0.167 0.005 

Fluoranthene 0.167 0.005 

Fluorene 0.167 0.005 

Indeno(1,2,3-cd)pyrene 0.167 0.005 

Nitrobenzene 0.167 0.005 

4-Nitrophenol 0.167 0.005 

Phenanthrene 0.167 0.005 

Phenol 0.167 0.005 

Pyrene 0.167 0.005 

Pyridine 0.167 0.005 

Quinoline

8270 

0.167 0.005 1

 Reporting limits presented here represent ideal conditions. Actual limits will differ based on samplespecific factors (e.g., percent moisture, dilution factor, etc.). 2

 Analysis can be performed using Method 8260 or Method 8270. 
Sampling and Analysis Plan 

 F037 Waste Delisting 

 ConocoPhillips Billings, Montana, Refinery June 2010

Project No. 172405 4-8

Table 4-2. Sample Handling Requirements 

Analyte Method 

Typical 

Containers1 Preservative

Holding 

Time 

No. 

Samples2

Total and Amenable 

Cyanide 

9014; 

9213 

4 ounce 

Glass Cool to 4°C 14 days 9 

Hexane-Extractable 

Material (Oil & 

Grease) 

9071 4 ounce 

Glass Cool to 4°C 14 days 9 

Metals 6010; 

6020 

4 ounce 

Glass Cool to 4°C 180 days 9 

Mercury 7471 4 ounce 

Glass Cool to 4°C 28 days 9 

Moisture Content ASTM 

D2216 

4 ounce 

Glass Cool to 4°C 28 days 9 

pH 9045 4 ounce 

Glass Cool to 4°C 7 days 9 

Semivolatile 

Organics 8270 4 ounce Glass Cool to 4°C 

14 days to 

extraction; 

40 days 

from 

extraction to 

analysis 

9 

Volatile Organics 8260 4 or 8 ounce 

Glass Cool to 4°C 14 days 9 

Sulfide 9034; 

9215 

4 ounce 

Glass 

Cool to 4°C; 

Zn Acetate 

until surface 

moistened 

7 days 9 

Reactive Sulfide SW-846 

Chapter 7 

4 ounce 

Glass Cool to 4°C 14 days 9 

Reactive Cyanide SW-846 

Chapter 7 

4 ounce 

Glass Cool to 4°C 14 days 9 

TCLP 1311a See Determinative Method 

pH 7.0 – 2 

pH 4.93 – 9 

pH-10.1 - 2 1

 Containers presented here assume one sample for one method is being submitted for analysis. The 

laboratory may use larger containers and/or use the material from one container for multiple methods. 

Contact the laboratory for specific advice regarding containers. 

2

 The number of samples listed here include eight (8) samples plus one (1) field duplicate. Sufficient 

sample material from one (1) location will also be submitted to the laboratory for MS/MSD analyses 

for all analytes excluding TCLP using extraction fluids at pH values of 7.0 and 10.1. 

a

 Per delisting guidance, TCLP must be performed using a minimum of three different extraction fluids 

in a pH range from 3-11 (i.e., 4.93, 7.0, and 10.01). Two (2) samples will require extraction using 

these three fluids (i.e., the remaining six (6) samples will be extracted using the one fluid described in 

Method 1311). Contact the laboratory prior to sample collection to discuss this modification to the 

TCLP method.
Sampling and Analysis Plan 

 F037 Waste Delisting 

 ConocoPhillips Billings, Montana, Refinery June 2010

Project No. 172405 4-9

Table 4-3. QC Sampling Frequencies 

QC Sample Type Frequency 

Field Duplicate 5 %a

Matrix Spike/Matrix Spike 

Duplicate Pair 5 %a

Trip Blanks1 One per cooler containing samples 

for volatile organic analyses 

a 5 % frequency means one QC sample (or one MS/MSD pair) 

is collected for every twenty or fewer field samples. 1 Trip blanks are only analyzed for volatile organic target 

compounds.
Sampling and Analysis Plan 

 F037 Waste Delisting 

 ConocoPhillips Billings, Montana, Refinery June 2010

Project No. 172405 4-10

Table 4-4. Potential Sample Collection Equipment 

Item Purpose 

Sample Collection Equipment 

FRP Coveralls Safety 

Steel-Toed Boots Safety 

Hard Hats Safety 

Safety Glasses Safety 

Hearing Protection Safety 

Nitrile Gloves Outer Gloves 

Blue Mesh Sample Protection 

Visqueen ® Plastic Sheeting Sample Protection 

Stainless Steel Bowls Sample Containment 

Stainless Steel Scoops Sample Manipulation 

Coolers Sample Storage and Shipment 

Ice Sample Preservation 

Laboratory Supplied Containers Sample Containers 

Decontamination Equipment 

Laboratory Suitable Detergent Decontamination 

Distilled Water Soapy Water and Pre-Wash Water 

10% methanol Solvent Rinse 

Distilled Water Final Rinse 

Buckets Contain Pre-Wash and Soapy Water 

Brushes Scrubbing 

Visqueen ® Plastic Sheeting Contain Accidental Spills 

Shipping Supplies 

Chain-of-Custody Forms Documenting Individual Sample Information 

Sample Labels Container Contents Identification 

Absorbent Paper Sample Packing 

Shipping Labels Laboratory Address 

Sample Analysis and Target Analyte Lists Laboratory Notification 

Overnight Carrier Shipping Forms Timely Delivery 

Custody Seals Indicator of Tampering With Cooler 

“Fragile” Labels Proper Handling of Cooler 

“This Side Up” Labels Proper Handling of Cooler 

Packing Peanuts or Vermiculite Sample Packing 

Clear Tape Shipping Label Protection 

Reinforced Tape Ensuring Cooler Closure 

Resealable Plastic Bags Ice and Documentation Containment 
Attachment A 

Sampling Team Resumes
Tetra Tech Page 1 

PAUL E. LEMIRE 

Senior Hydrogeologist / Project Scientist 

EDUCATION 

MS, Hydrology, University of New Hampshire, 1982 

BS, Zoology, Montana State University, 1976 

REGISTRATIONS/CERTIFICATIONS 

Monitoring Well Constructor: Montana (#404, 2008) 

EXPERIENCE SUMMARY 

Mr. Lemire has over 27 years of experience working on water resource and environmental projects for the 

insurance, oil and gas, wood preserving, and railroad industries and governmental agencies. He has 

conducted soil and groundwater investigations for environmental emergency response action as well as 

Resource Conservation and Recovery Act (RCRA) hazardous waste sites; Comprehensive Emergency 

Response, Compensation and Liability Act (CERCLA) Superfund sites; and underground storage tank (UST) 

sites. Tasks have included environmental emergency response on-site coordination, work plan preparation, 

monitoring well installation, soil sampling, groundwater monitoring, aquifer testing, groundwater modeling, and 

hydrogeologic and chemical data interpretation. Mr. Lemire has also served as an expert witness and 

negotiated with environmental regulators on technical and compliance issues. 

PROJECT EXPERIENCE 

Environmental Emergency Response 

• Vehicle Diesel Spill, Yellowstone National Park. Project Manager/ER Coordinator responsible for 

directing several investigations and cleanup of diesel fuel spill from vehicle accidents in Yellowstone 

National Park. Excavated fuel-impacted soil and prevented fuel from impacting nearby surface water 

bodies. All emergency response projects were closed by the Wyoming Dept. of Environmental Quality. 

(2002, 2003, 2006, 2008) 

• Petroleum Pipeline Crude Oil Spill Emergency Response, Montana. As Senior Hydrogeologist, 

provided emergency response coordination of environmental efforts, conducted investigation of surface 

and subsurface petroleum impacts and proposed remediation measures. (2001) 

• Petroleum Pipeline Diesel Fuel Spill Emergency Response, Montana. As Senior Hydrogeologist, 

provided response coordination, surface soil investigation efforts and provided proposed remediation 

measures. (2004) 

• Tractor/Trailer Gasoline Spill Emergency Response, South-central Montana. Project Manager/ 

Senior Hydrogeologist responsible for directing a subsurface soil and groundwater investigation for a 

4,000-gallon gasoline spill on a secondary highway. Excavated petroleum hydrocarbon-impacted soil, 

negotiated with local landowners for land treatment site, land-treated the soil to environmental agency 

cleanup levels and conducted a groundwater investigation. (2003) 

• Tractor/Trailer Gasoline Spill Emergency Response, Southwestern Wyoming. Project Manager/ 

Senior Hydrogeologist responsible for directing a subsurface soil and groundwater investigation for a 

12,000-gallon gasoline spill on a secondary highway. Excavated petroleum hydrocarbon-impacted soil, 

land-treated the soil at an off-site location to environmental agency cleanup levels and conducted a 

groundwater investigation. (2003) 

• Tractor/Trailer Diesel Spill Emergency Response, Southwestern Wyoming. Project Manager/ Senior 

Hydrogeologist responsible for directing a subsurface soil and surface water investigation for a 4,000-

gallon diesel spill on a secondary highway. Excavated diesel-impacted soil, land-treated the soil at an offsite location to environmental agency cleanup levels and conducted a surface water investigation for 

diesel spills into a creek. (2003) 
 Paul E. Lemire 

Tetra Tech Page 2 

• Carbon Tetrachloride Spill Emergency Response, Oklahoma. As Senior Hydrogeologist, directed a 

subsurface investigation of carbon tetrachloride in unconsolidated sediments and fractured bedrock. Spill 

resulted from a railroad derailment. (1996) 

Remedial Investigation / Feasibility Study 

• RCRA Facility Investigations (RFI) and Corrective Measures Studies at Oil Refineries, Montana. 

Project Manager/ Senior Hydrogeologist responsible for RFI and corrective measures studies at three 

Yellowstone County oil refineries. Work included installation of monitor wells, oil and dissolved chemical 

recovery wells, soil and groundwater investigations for solid waste management units, and land treatment 

unit investigations. Responsible for liaison and negotiation with state and federal environmental agencies. 

(1991 to present) 

• Oil Refinery RFI, Northwestern Washington. Project Manager/ Senior Hydrogeologist responsible for 

preparing the RFI work plan and implementing fieldwork to complete the first RFI in the United States. 

Work included installation of monitor wells, soil and groundwater investigations for solid waste 

management units, and land treatment unit investigations. Responsible for liaisons and negotiations with 

state and federal environmental agencies. (1993) 

• Site Investigations/Remediation, Wood Preserving Facilities, Paradise and Somers, Montana. 

Principal Hydrogeologist responsible for site investigations and remediation at railroad tie wood 

preserving facilities. Installed over 40 monitor wells, conducted RCRA solid waste management unit 

investigations, conducted aquifer tests, designed and implemented creosote recovery systems using 

wells, and prepared RCRA Part B permits for a land treatment unit and waste management pile. 

Responsible for liaison and negotiation with state and federal environmental agencies. (1992) 

• Site Investigation, Wood Preserving Facility, Kalispell, Montana. Principal Hydrogeologist 

responsible for site investigation at a post and pole wood preserving facility using pentachlorophenol. 

Installed monitor wells and conducted soil and groundwater investigations and agency negotiations. 

(1995) 

• Petroleum Refinery Site Investigation, Louisiana. Senior Hydrogeologist responsible for the site 

investigation of an ethylene dichloride spill at petroleum refinery loading docks. (1995) 

• Hazardous Waste Reviews, Wood Preserving Facilities, Florida, Georgia and Mississippi. As 

Principal Hydrogeologist, reviewed waste management at facility, disposal facilities, waste disposal 

volumes, RCRA hazardous waste review, and hydrogeologic setting of waste disposal facilities to 

determine RFI issues and quantity of solid waste management units and areas of concern. (1990) 

• RI/FS and Site Clean-up, Used Oil Recycling Site, Yellowstone County, Montana. Project 

Manager/Senior Hydrogeologist responsible for RI/FS work plan preparation, the remedial investigation, 

and site cleanup for a Montana Superfund site. Subsurface soils and groundwater at the site were 

impacted with petroleum hydrocarbons and heavy metals. (1996) 

• RI/FS and Remediation, Metal Recycling Facility, Nebraska. Project Manager responsible for RI/FS 

investigation and remediation of subsurface soils and groundwater impacted by lead and sulfuric acid. 

(1992) 

Environmental Site Assessments 

• Phase I Environmental Site Assessments (ESAs), Montana and Wyoming. Project Manager/ 

Principle Investigative Officer responsible for Phase I ESAs for 26 cellular telephone sites in Montana and 

Wyoming and numerous commercial properties in Montana. (1994) 

Expert Witness 

• Hydrogeologic and Environmental Litigation, Montana. Expert Witness during hearings to determine 

oil pipeline right-of-way condemnation and property damages due to groundwater impacts from a 

petrochemical disposal site. (1998) 
 Paul E. Lemire 

Tetra Tech Page 3 

Petroleum Release Investigations and Corrective Actions 

• Fuel Release Investigation and Remediation, Rail Yards, Montana and Washington. Project 

Manager/ Senior Hydrogeologist responsible for a site investigation and remediation efforts at two rail 

yards in Montana. Installed numerous monitor wells, oil recovery wells, Responsible for site 

characterization, hydrogeologic investigations, fuel recovery, river sediment investigation, and soil and 

groundwater remedial design at two Montana and two Washington railroad fueling facilities. Responsible 

for negotiations with the supervisory agencies. (1996) 

Regulatory Compliance 

• Regulation of Hazardous Waste Facilities, Montana. As Environmental Specialist, regulated 

hazardous waste facilities using state and federal RCRA and CERCLA rules for Montana Department of 

Environmental Quality. (1995) 

Risk Assessment 

• Oil Refinery RCRA Closure, Permitting and Investigation, Montana. Project Manager responsible for 

RCRA facility closure, permitting of land treatment facilities and investigation of RCRA solid waste 

management units at a Montana oil refinery. (1995) 

Fisheries Studies / Management 

• Fisheries Studies, Montana. Hydrogeologist responsible for conducting fisheries studies for Montana 

Department of Fish, Wildlife and Parks. (1976 to 1979) 

PROFESSSIONAL AFFILIATONS 

National Ground Water Association, Member 

CONTINUING EDUCATION 

40-hr OSHA HAZWOPER, 1986 

8-hr OSHA HAZWOPER Refresher, March 2006 

Comprehensive First Aid/First Response Training, 2004 

Dense Non-aqueous Phase Liquids Fate and Transport, 1995 

Groundwater Modeling, 1993 

PROFESSIONAL EMPLOYMENT HISTORY 

Senior Hydrogeologist/ Project Scientist, Tetra Tech, 1999 to Present 

Senior Hydrogeologist, Environmental Technologies & Solutions, Inc., 1996 to 1998 

Senior Hydrogeologist, Remediation Technologies, Inc.. 1988 to 1996 

Senior Hydrogeologist, Lambier-Stevenson Engineers, 1988 

Hydrogeologist, Remediation Technologies, Inc., 1987 to 1988 

Hydrogeologist, Montana Department of Health and Environmental Sciences, 1985 to 1987 

Hydrogeologist, Montana Department of Natural Resources and Conservation, 1982 to 1985 

Fisheries Biologist, Montana Department of Fish and Game, 1976 to 1979 
Tetra Tech Page 1 

MICHAEL SHANE EWERT 

Environmental Technician 

EDUCATION 

Associate of Science in Architectural Drafting, DIT – Denver, CO 1996 

1 year general studies, MSUB – Billings, MT 1993-94 

1.5 years general engineering, MSU – Bozeman, MT 1991-92 

REGISTRATIONS/CERTIFICATIONS 

Concrete Field Testing Technician, Grade I: (#01090084, Exp. 11/10/11) 

Safe Operation of Nuclear Soil Moisture-Density Gauges: MT (12/18/06) 

EXPERIENCE SUMMARY 

Mr. Ewert has 2.5 years of professional experience as an Environmental Technician and over 5 years in the 

environmental field. He is responsible for all phases of environmental sampling and field characterization for 

groundwater, surface water, and soils. Handling and shipping field samples for analysis, calibrating and 

maintaining field equipment, design and installation of product recovery and groundwater remediation 

systems are also some of his common tasks and responsibilities. Mr. Ewert also has an extensive 

background in various types of construction and provides oversight and inspection on civil, geotechnical, and 

environmental projects. 

PROJECT EXPERIENCE 

Computer Aided Drafting 

 Various remediation systems, Denver, Colorado. As environmental drafting manager and 

draftsperson, prepared CAD drawings and design assistance on various Soil Vapor Extraction and Air 

Sparge Systems, architectural plans, architectural and structural detailing, mechanical and electrical 

layouts, and civil construction designs. (Summer 1996 thru Spring 2002) 

Environmental Science 

 Lockwood Solvent Groundwater Plume Site, MDEQ, Lockwood, Montana. As environmental field 

technician, conduct tap water, surface water, and groundwater sampling, including waste water 

management. (Spring 2007) 

 GWIS shutdown quarterly water monitoring, ConocoPhillips Company, Billings, Montana. As 

environmental field technician, conduct water levels, and groundwater sampling, sample handling, and 

sample shipping. (quarterly, 2006 to present) 

 Low/High water Semi-annual water monitoring, ConocoPhillips Company, Billings, Montana. As 

environmental field technician, conduct water levels, and groundwater sampling, sample handling, and 

sample shipping. (Semi-annual, 2006 to present) 

 Semi-annual groundwater monitoring, Cenex Harvest States, Laurel, Montana. As environmental 

field technician, conduct water levels, and groundwater sampling and sample handling. (Semi-annual, 

2006 to present) 

 Quarterly groundwater monitoring, Western Sugar, Billings, Montana. As environmental field 

technician, conduct water levels, and groundwater sampling and sample handling. (Semi-annual, 2006 to 

present) 

 Quarterly groundwater monitoring, Billings Landfill, Billings, Montana. As environmental field 

technician, conduct water levels, and groundwater sampling and sample handling. (Semi-annual, 2006 to 

present) 

 SOSP Remediation and Reuse Project, ConocoPhillips Company Refinery. As environmental 

technician, excavation oversight of RCRA regulated South Oily Sludge Pits site, material field screening 

and handling. (July 2008 to November 2008)
 Michael Shane Ewert 

Tetra Tech Page 2 

Industrial Hygiene 

 Coal Dust Monitoring, PPL Montana, Colstrip, Montana. As environmental technician, conduct 

exposure monitoring for lead and hexavalent chromium. (Various turnarounds – 2006 to present) 

 Troy Asbestos Property Evaluations, EPA / MT DEQ, Troy, Montana. As environmental technician, 

inspect and sample local properties for presence of asbestos containing vermiculite. (April 2007 to August 

2007)

CONTINUING EDUCATION 

Hazardous Waste Operations and Emergency Response, August 2006 

8-hour HAZWOPER Refresher, March 2008 

DOT Hazardous Materials Transportation Online Course, October 2008 

Contractor Safety Training Orientation Program, October 2008 

OSHA Asbestos Awareness Training, August 2008 

AHA CPR, March 2008 

PROFESSIONAL EMPLOYMENT HISTORY 

Environmental Technician, Tetra Tech, 2006 to present 

Leadman, JTL Construction, 2004 to 2006 

Sales Manager, United Rentals HT, 2002 to 2004 

Architectural Sales, Tri-Jack Architectural Design Products, 1998 to 2002 

Environmental Drafting Manager, Terracon Environmental Inc., 1996 to 1998 
Tetra Tech Page 1 

MICHAEL J. CONNOLLY 

Environmental Technician 

EDUCATION 

AD, Drafting, Butte Vocational-Technical Center, 1993 

Drafting Certificate, Butte Vocational-Technical Center, 1984 

REGISTRATIONS/CERTIFICATIONS 

Underground Storage Tank Remover: Montana (R-0104-172, 2004) 

Mine Safety and Health Administration Certified Instructor for First Aid Courses (1994) 

EXPERIENCE SUMMARY 

Mr. Connolly has over 15 years of experience as an environmental technician. He performs Phase I site 

investigations and is responsible for all phases of environmental sampling and field characterization for 

groundwater, surface water, and soils. He also labels and ships field samples for lab analysis and calibrates, 

maintains, and repairs field equipment. He performs site design and installs, operates, and maintains soil 

vapor extraction, product recovery, pump-and-treatment remediation, and chemical injection systems for 

temporary and permanent site conditions. Mr. Connolly also provides drafting support and construction 

inspection and job oversight for municipal, geotechnical, and environmental projects. He has extensive 

experience in various levels of personal protective equipment. 

PROJECT EXPERIENCE 

Bioterrorism Response 

 Anthrax Contamination Emergency Response, Capitol Hill, Washington DC. Emergency Response 

Team Member assisting the US Environmental Protection Agency with biological sampling of anthrax 

found in the Hart Senate Office Building and Senate Mail Processing Facility. Managed multiple sampling, 

oversight, reconnaissance and remediation teams in the Hart building during both the anthrax and 

chlorine dioxide gassing events where wipe, swab, and high efficiency particulate air vacuum sampling for 

anthrax contamination was conducted in several offices. Ensured proper technique for sample collection, 

managed collected samples, decontaminated sample containers and maintained proper chain-of-custody 

for collected samples. (2002) 

Industrial Hygiene 

 Exposure Monitoring near Potentially Radioactive Material, Idaho. Environmental Technician 

responsible for conducting exposure monitoring during volatile organic compound and groundwater 

sampling activities and during soil removal and containment activities of potentially radioactive material. 

Conducted industrial hygiene noise measurement; heat stress monitoring; personal sampling for air 

contaminants using dragger tubes and SKC sampling pumps; dust, mist and fume screening; and 

continuous air sampling with a photo-ionization detector meter for volatile organics. (1993) 

 Weather Surveillance, Idaho National Engineering and Environmental Laboratory Projects, Idaho. 

Environmental Technician responsible for conducting weather surveillance, including wind speed and 

lightning monitoring. (1994) 

 Exposure Monitoring, Hydrocarbon Release Sites, Montana. As Environmental Technician, conduct 

exposure monitoring during excavation and installation of water and sewer lines through known 

hydrocarbon release sites. Screen soil during removal of known contaminated materials and ensure that 

sampling, containment and disposal activities are properly reported and completed per local, state and 

federal guidelines. Completed numerous projects for the City of Billings. (1992 to present) 

 Noise and Audibility Compliance Monitoring, Montana. As Environmental Technician, field-tested 

locomotive air horn operations to ensure compliance with Department of Transportation standards for 

railroad crossing, locomotive distance and audibility. (1992) 

 Exposure Monitoring, Colstrip, Montana. As Environmental Technician, conduct level “B” entry into 

vaults containing hydrochloric acid. Identify the leaking source area and sample the floor material to 

facilitate determination of the concentration of known material and the type of cleanup operation needed. 

Provide the client with accurate vault configuration information. (2001 to present) 
 Michael J. Connolly 

Tetra Tech Page 2 

 Personal and Area Exposure Monitoring at Coal Mine, Colstrip, Montana. As Environmental 

Technician, conducted emergency response exposure monitoring during turn-around of Colstrip furnace 

maintenance. Located and identified the potential source causing workers to feel ill. Conducted area and 

personnel monitoring of coal dust. (2003, 2005) 

Computer Aided Drafting 

 Computer-Aided Drafting (CAD) Drawings, Montana, Idaho, and New York. As Drafter, prepared 

CAD drawings of process flow diagrams, piping and instrumentation drawings, electrical/mechanical 

drawings, architectural drawings, structural steel support and construction drawings, certificates of survey 

and geological/geophysical maps and contours. (1989, 1997) 

Health and Safety 

 Emergency Response Courses, Montana and Idaho. As Trainer, provided health and safety training 

for environmental consulting firms; construction, drilling, chemical and mining companies; and various 

Montana communities. (1998) 

 Health and Safety Services, Billings, Montana. As Health and Safety Coordinator, maintained the 

continued effectiveness of Tetra Tech’s health and safety program. Wrote site-specific health and safety 

plans, conducted tailgate safety meetings, conducted job site safety inspections, and assisted with 

monthly safety meetings. (2000) 

Emergency Response 

 Field Operation Emergency Responses, Montana and Wyoming. As Environmental Scientist/ Field 

Technician, provide initial and continuing response to gasoline/diesel releases of pipelines, refinery 

processing units, sump/ drain overfills and highway tanker spills. Tasks include over-excavation of spill 

sites, placement of clean replacement materials, and transportation and disposal of contaminated 

materials. Projects include a pipeline release along Sevenmile Creek at Glendive, Montana; tanker truck 

rollovers near Bridger, Montana; tanker rollovers near Riverton, Wyoming: and sump overspills and gas 

station site spills throughout Montana. (1990 to present) 

Environmental Site Assessments 

 Environmental Site Assessments, Bureau of Indian Affairs (BIA), Montana, Wyoming, North 

Dakota, and South Dakota. As Environmental Scientist/ Field Technician, performed field inspection of 

BIA-funded school facilities for mercury, PCB, mold and radon. Sites include all BIA-funded schools in 

North Dakota. (2004 to 2005) 

Compliance Audits 

 Compliance Audits, BIA-Funded Facilities, Montana and Wyoming. As Environmental Scientist/ Field 

Technician, conducted field audit / inspection of BIA-funded facilities for development of a spill, control 

and containment program as required by Title 40 Code of Federal Regulations (CFR), Part 112. (2005) 

 Compliance Audits, Montana Department of Transportation (MT DOT), Montana. As Environmental 

Scientist/ Field Technician, conducted field audit / inspection of MT DOT facilities for development of spill, 

control and containment program as required by Title 40 CFR, Part 112. (2004) 

 Compliance Audits, Montana Department of Fish, Wildlife and Parks (FWP), Montana. As 

Environmental Scientist/ Field Technician, conducted field audit / inspection of all FWP facilities prior to 

development of an updated hazardous communications plan and chemical inventory as required under 

Occupational Safety and Health Administration (29CFR) Part 910.1200 and 1926.59.Trained FWP 

personnel in hazardous communications plan and awareness, use of chemical inventory binders and 

Access database inventory. (2004 to 2005) 
 Michael J. Connolly 

Tetra Tech Page 3 

CONTINUING EDUCATION 

40-hr OSHA HAZWOPER, 1991 

8-hr OSHA HAZWOPER Refresher, March 2007 

Emergency Medical Services (EMS) Operations & Planning for Weapons of Mass Destruction (WMD) (24-hr), 

2002 

EMS Basic Concepts for WMD Incidents (8-hr), 2002 

WMD/Terrorism Awareness for Emergency Responders (8-hr), 2002 

PROFESSIONAL EMPLOYMENT HISTORY 

Environmental Technician, Tetra Tech, 2000 to Present 

Environmental Technician/Drafter/Emergency Response Trainer, MSE-HKM, 1995 to 2000 

Drafter, MSE, Inc., 1990 to 1995 

Environmental Technician, MSE, Inc., 1992 to 1995 

Drafter, Multi - tech Services Division of MSE, Inc., 1984 to 1985