part a and part b application signature pages€¦ · tceq part b application citgo refining and...

Part A and Part B Application Signature Pages

Revised Part B Application Pages

(For Inclusion or Replacement in Existing Application)

TCEQ Part B Application CITGO Refining and Chemicals Co., L.P. TCEQ-00376 (Rev. 9-29-2017 M.L. Shannon) Rev 2 – January 2019

Appendix III.C

Facility Security

TCEQ Part B Application Page 1 of 1 CITGO Refining and Chemicals Co., L.P. TCEQ-00376 (Rev. 9-29-2017 M.L. Shannon) Rev 2 – January 2019

Appendix III.C Facility Security

Facility entry is controlled by an artificial barrier (chain-link fence) surrounding the plant. Security

guards are on duty 24-hours a day and routinely patrol the refinery. All valves which permit

outward flow and starter controls on all oil pumps are located at sites accessible only to

authorized personnel. Warning signs (“Danger – Unauthorized Personnel Keep Out”) are posted

at all points of access to the active portions of the facility and along the chain-link fence. The

signs are in English and Spanish and visible from at least 25 feet away. The entire plant is well

lighted and subject to routine surveillance by the Security Department each shift.


Appendix III.D

Inspection Schedule

EXAMPLE CLOSED EQUALIZATION BASIN INSPECTION LOG

Date/Time Inspector Gate Locked

Fence Signs Cap and Drainage

Action Taken


Appendix VI.B

Facility Groundwater Item VI.B.1 – Closed Equalization Basin Monitor Well Location Map

Item VI.B.2 – Historical Water Levels

Item VI.B.3 – Detection Monitoring Program

Item VI.B.4 – Sampling and Analysis Plan

Item VI.B.5 – Recent Analytical Laboratory Report

Table VI.B.3.b. – Unit Groundwater Detection Monitoring Systems

Table VI.B.3.c. – Groundwater Detection Monitoring Parameters


Item VI.B.4 – Sampling and Analysis Plan

3833 S. Staples Street, Suite N229, Corpus Christi, Texas, USA T + 1 361 855 7335 F +1 361 855 7410 W www.rpsgroup.com/usa

Energy | Environmental Risk | Infrastructure | Ocean Science

P:\CITGO\022219 - WP RCRA Permit Renewal\Technical NOD\CITGO WP RCRA SAP 01-19.docx

CITGO West Plant RCRA Groundwater Monitoring

Sampling and Analysis Plan

CITGO Refining and Chemicals Company L.P. Corpus Christi, Texas

June 2009 Revised June 2012

Revised March 2013 Revised March 2016

Revised January 2019

i

Table of Contents

List of Sections

Groundwater Sampling Procedures .......................................................................................... 1 Field Sampling Procedures ....................................................................................................... 1 Personal Protective Equipment ................................................................................................. 2 Monitor Well Inspections ........................................................................................................... 2 Fluid Level Measurements ........................................................................................................ 3 Well Purging .............................................................................................................................. 4 Sample Collection ..................................................................................................................... 4 Chain-of-Custody Program ........................................................................................................ 6 Groundwater Analytical Parameters .......................................................................................... 6 Laboratory Quality Assurance Program .................................................................................... 6

List of Tables Table 1 West Plant Equalization Basin Analytical Parameters Table 2 Analytical Parameters, Preservatives, Containers, Methods and Holding Times

List of Appendices Appendix A Well Sampling Form Appendix B Chain-of-Custody Form Appendix C Monitor Well Location Map

1

Groundwater Sampling Procedures CITGO’s West Plant groundwater monitoring is conducted for 7 monitor wells which are

constructed of 2-inch ID PVC. These 7 monitor wells monitor groundwater in the vicinity of the

West Plant Equalization Basin. Table 1 lists the laboratory analytical parameters for the West

Plant Equalization Basin. Table 2 presents the analytical parameters, preservatives, containers,

analytical method and holding times.

Field Sampling Procedures Field activities associated with monitor well sampling will include:

Preparation for sampling activities; Fluid level measurements; Monitor well inspections; Monitor well purging; and Monitor well sampling.

All sampling procedures will be conducted in accordance with the guidelines set forth in

USEPA’s publication entitled RCRA Ground-Water Monitoring: Draft Technical Guidance

(TEGD Update) (November 1992, USEPA).

Preparation for Sampling Activities Sampling personnel should prepare for the sampling event by coordinating with the contract

laboratory to ensure that they provide prepared sample bottles adequate for all wells, trip blanks

and one duplicate sample. Upon receipt of the bottle sets from the laboratory, check bottles for

proper preservatives, if appropriate, and the number of bottles. Bottles are to be properly

labeled to identify what the sample is to be analyzed for.

Ensure that all equipment and associated items are available. These include the following:

pH meter with temperature probe Specific Conductance Meter Turbidity Meter Water level measuring equipment (E-line and interface probe) Necessary calibration fluids or equipment Project specific Sampling and Analysis Plan De-ionized or distilled water Site specific Health and Safety Plan Required personal protective equipment Field data sheets and/or logbook

Sample containers Disposable bailers

2

Rope Buckets and intermediate containers Coolers First-Aid Kit Paper Towels Plastic Sheeting

Calibrate all necessary equipment in accordance with the manufacturer’s recommendations.

Upon arrival at the site the sampling team will record the following information in the field

logbook or on forms developed for groundwater monitoring (Appendix A):

Date of sampling; Time of arrival on location; Weather conditions (i.e. wind velocity, ambient temperature, etc.); The names of all field sampling personnel; and The names of all other personnel present during the sampling event and their affiliation

(i.e. CITGO, TCEQ, EPA, etc.).

The sampling team will then proceed with the field sampling activities.

Procedures to Prevent Contamination Prior to taking fluid levels or sampling, to ensure that contamination is not introduced into the

well from the rope or bailer, use clean gloves, plastic sheeting or tarp or stands to keep the rope

or bailer from contacting the ground or other potential contamination sources. Care should be

taken to ensure that soil or other material does not fall onto the plastic sheeting. Do not place

tools, meters or other equipment on the sheeting unless it has been cleaned.

Personal Protective Equipment Personal protective equipment will be worn by sampling personnel for each sampling event.

Safety equipment will include hard hat, safety glasses, safety shoes or boots, flame retardant

coveralls (i.e. Nomex®) and nitrile gloves. Respiratory protection is typically not necessary, but

respirators with organic vapor cartridges would be utilized if needed.

Monitor Well Inspections The sampling team will inspect each monitor well to evaluate the condition of the:

Well pad; Protective casing; Well casing; Well cap and lock as applicable; Protective posts; Well measuring point;

3

Well identification tag; Resistance to bailer movement; and Indication of well contamination.

.

Data will be recorded in the field logbook or on the well sampling form (Appendix A). A copy of

the completed form for each well will be submitted to CITGO at the completion of the sampling

event.

Fluid Level Measurements Fluid level measurements will be taken at each well. Each sampler will don a pair of nitrile

gloves prior to measuring fluid levels. An electronic water level indicator (E-line) or equivalent

will be utilized to obtain fluid level information. If an immiscible layer is suspected in a well, an

interface probe (ORS or equivalent) will be utilized for fluid measurements. In either case, the

probe will also be utilized to obtain depth to well bottom. Measurements will be taken from a

permanent survey mark (which is typically a mark in the casing) at the top of the casing. A

licensed surveyor has established all survey marks. Fluid levels will be measured to the nearest

0.01-foot. The following information will be recorded in the field logbook or on the sampling

form:

Well identification number; Time and date of fluid measurements and well purging; Top of casing elevation; Depth to hydrocarbon (if applicable); Depth to water; Total well depth; Fluid column length; Calculated purge volume; and Actual purge volume.

Data from the well measurements and condition of the samples will be evaluated prior to the

next sampling event to determine if there are problems associated with excessive silting. The

current total well depth measurements will be compared to the previous measurement. If the

well depth has decreased by more than a foot, or if more than 10% of the well screen is silted in,

the well will be redeveloped prior to the next sampling event.

If NAPL is present, the interface probe will be decontaminated after use by the following

method. Phosphate-free detergent and distilled water wash, followed by a distilled water rinse

and finally dried with a clean paper towel. Wastewater generated during this procedure will be

disposed of with the monitor well purge water to CITGO’s wastewater treatment system.

4

Decontamination procedures for the e-line will consist of a phosphate-free detergent and

distilled water wash, followed by a distilled water rinse and finally dried with a clean paper towel.

These procedures will be conducted after each use.

Well Purging Each of the monitor wells will be purged (using disposable bailer equipped with rope made of an

inert material) to remove a minimum of three casing volumes (or to dryness) of groundwater

prior to sample collection. Field personnel purging the wells will cover the ground surface

around the well with clean plastic sheeting and wear clean nitrile gloves to prevent

contamination of the disposable bailers and rope during purging activities. The rope will be

handled in a fashion which will prevent it from touching the ground. The purge volume will be

calculated by subtracting depth from the top of the casing to the first fluid level from the depth to

the well bottom. The resulting well column length will be multiplied by 0.49 (constant for 2-inch

diameter wells) to determine the volume (in gallons) of water equal to three times the casing

volume. Bailed groundwater will be poured from the bailer into a graduated bucket to measure

the purged water volume. The purge volume calculation will be logged in the field logbook or on

the sampling form (Appendix A) prior to the start of purging.

The sampling team will remove the calculated volume of groundwater from the well. If the well

bails to dryness before the calculated volume of water is evacuated, the well will be allowed to

recharge a minimum of one hour before groundwater samples are collected. The actual purge

volume will be recorded in the field logbook or on the sampling form. Purged fluids will be

placed in a drum or portable tank for disposal to CITGO’s wastewater treatment system at the

completion of sampling or as needed.

Sample Collection Sample bottles and preservatives for the analytes depicted in Table 1 will supplied by CITGO’s

contract analytical laboratory. Sample sets will include a trip blank for the following parameters:

Chromium (total and filtered) Hexavalent Chromium Lead (total and filtered) Benzene Toluene Benzo(a)pyrene Chrysene

5

Blanks will be provided by the contract laboratory and will be carried into the field in coolers.

Trip blanks will be transported back to the laboratory with the groundwater samples. Sample

bottles will be sealed in plastic bags prior to being placed in an ice-filled cooler. Samplers will

wear nitrile gloves during sampling activities and will replace the gloves with a fresh pair prior to

sampling each monitor well. Groundwater samples will be collected in the following manner:

The sample label will be completed with the site name, well number, sampling date, time

of sample collection and the name or initials of the sampler;

The bailer will be slowly lowered into the well and slowly retrieved when full;

The 40-ml bottle for the volatile organics sample will be filled first. The vial will be

completely filled to the top to eliminate headspace. The sample bottle will be inverted

after it is capped and checked for air bubbles. If air space is present in the sample,

additional sample will be added to the vial and rechecked for air space.

pH, specific conductivity, temperature and turbidity will be analyzed next using portable

pH, conductivity and turbidity meters. The meters will be calibrated prior to sampling in

accordance with the manufacturer’s instructions. The pH meter will be calibrated using

4.00 and 7.00 buffer solutions, and all calibrations will be recorded in the field logbook or

on the sampling form. The specific conductance meter will be calibrated per the

manufacturer’s instructions. The turbidity meter will be checked with the blanks included

with the meter. The groundwater sample will be collected in a clean container and the

pH, specific conductivity, temperature and turbidity will be measured immediately. One

measurement will be collected at each well. All field analytical data will be entered in the

field logbook or on the sampling form.

Following the collection of field parameters, the remaining sample containers will be

filled.

Filled sample bottles will be sealed in plastic bags and placed in an ice chest with ice.

Chain-of-custody documentation will be completed as each well is sampled. Once an

ice chest is filled, the excess water will be drained and the cooler repacked with ice. The

completed chain-of-custody form will accompany the samples to CITGO’s contract

laboratory. An example chain-of-custody form appears in Appendix B.

6

Samples in glass containers will be braced with bubble-wrap or similar packing material.

The ice chest will be latched shut and the lid will be secured with a custody seal; the

samples will be delivered to CITGO’s contract laboratory upon completion of daily

sampling activities.

Chain-of-Custody Program Sampling personnel will assure through a chain-of-custody program that the possession and

handling of groundwater samples collected can be traced from the point of collection through

analysis and final disposition. At a minimum, the program will conform to the chain-of-custody

program described in Test Methods for Evaluating Solid Waste: Physical/Chemical methods

(EPA SW-846).

Groundwater Analytical Parameters Groundwater analytical parameters for the West Plant Equalization Basin appear in Table 1.

Analytical parameters, preservatives, containers, methods and holding times can be found in

Table 2.

Laboratory Quality Assurance Program The contract laboratory selected by CITGO will have an ongoing quality assurance/quality

control (QA/QC) program. The laboratory will use EPA-approved QA/QC methods as published

in Test Methods for Evaluating Solid Waste: Physical/Chemical methods (EPA SW-846). The

implementation of the QA/QC process will be documented and verified for each sampling

through the standard and comprehensive quality control data reports to be supplied by the

laboratory and a final review and evaluation of the QC results by CITGO.

CITGO will ensure that the laboratory also utilizes the methods of analysis assurance outlined in

EPA SW-846 and EPA 600/4-79-020. A copy of the selected contract laboratory’s QA manual

will be provided to the TCEQ upon request.

Tables

Revision #1 06-20-12 Revision #2 03-04-13 Revision #3 03-23-16 Revision #4 01-14-19

Table 1 West Plant Equalization Basin Analytical Parameters

Sampling Schedule: January and July West Plant Equalization Basin: Consists of seven wells, five downgradient (MW01, MW02,

MW03, MW06RRR, MW07R) and two upgradient (MW04, MW05)

Sampling Sequence: To be determined in the field based on previous sampling event.

Detection Monitoring Analytical Parameters

1. Detection monitoring parameters for statistical evaluation. Specific methods of analysis from EPA SW-846. Approved statistical evaluation methods and established concentration levels are specified in Hazardous Waste Permit No. 50353.

Detection Monitoring

Parameter

Analytical Method

Method Quantitation Limit (mg/L)

Chromium (filtered) 6010 & 200.7 6020 & 200.8

0.002

Chromium (unfiltered) 6010 & 200.7 6020 & 200.8

0.002

Hexavalent Chromium 7196 & SM3500 Cr-B 0.003

Lead (filtered) 6010 & 200.7 6020 & 200.8

0.002

Lead (unfiltered) 6010 & 200.7 6020 & 200.8

0.002

Benzene 8260 & 624 0.001 Toluene 8260 & 624 0.001 Benzo(a)pyrene 8270 & 625 0.005 Chrysene 8270 & 625 0.005 Note: One sample is required to be collected for each detection monitoring parameter on upgradient and downgradient wells. In addition, one sample for Total Dissolved Solids is required to be collected from each well. 2. Additional parameters for field monitoring only (single analysis)

pH Specific Conductance Temperature Turbidity (nephelometric turbidity units)

3. Trip blank for the following parameters:


Revision #1 03-04-13

Table 2 Analytical Parameters, Preservatives, Containers, Methods and Holding Times

(All samples will be cooled to 4 degrees C)

Analytical Parameter Preservative Container SW-846 and

EPA Methods Holding Time

Benzo(a)pyrene None 950 mL - 1.25 L Amber

Glass 8270 & 625

Extract – 7 days Analyze – 40

days

Chrysene None 950 mL – 1.25 L Amber

Glass 8270 & 625


days

Benzene HCl 40 mL Teflon Septum 8260 & 624 14 days

Toluene HCl 40 mL Teflon Septum 8260 & 624 14 days

Chromium (filtered and unfiltered)

None /HNO3 250 mL – 1 L Plastic 6010 & 200.7 6020 & 200.8

6 months

Hexavalent Chromium None 250 mL – 1 L Plastic 7196 &

SM3500Cr-B 24 hours

Lead (filtered and unfiltered)


6 months

Total Dissolved Solids None 500 mL – 1 L Plastic SM2540C 7 days

Note: Sample container sizes are approximate, as provided by the laboratory.

Appendix A

Well Sampling Form

I:\Corpus\Projects\CITGO\RCRA GROUNDWATER MONITORING\GROUNDWATER SAMPLING and ANALYSIS PLANS\West Plant SAP 03-16\App A

WELL SAMPLING FORM

GENERAL INFORMATION

CITGO Refining and Chemicals Company L.P. Date: Time:

Location:

Weather Conditions:

Field Personnel:

Others present: (i.e., CITGO, EPA, TCEQ, etc.)

WELL INSPECTION

Well Number:

Well Pad: _____Yes _____No Condition: _____Good _____Needs repair If repair needed, explain: Protective Casing: _____Yes _____No Condition: _____Good _____Needs repair If repair needed, explain:

Well Casing Condition: _____Good _____Needs repair If repair needed, explain:

Lock/Cap: _____Yes _____No Condition: _____Good _____Needs repair If repair needed, explain:

Bumper Poles – Condition: _____Good _____Needs repair If repair needed, explain:

Survey Mark – Condition: _____Good _____Resurvey Well Identification Tag: _____Yes _____No

Additional comments/observations:

WELL PURGE INFORMATION

Date: Time: Top of Casing Elevation (ft msl):

Total well depth: Depth to hydrocarbon: Depth to water: Fluid column length: (to 0.01') (if applicable) (to 0.01') (total depth - depth to fluid)

Purge Volume Calculation: Fluid Column Length X 0.49 (for 2” well) = Three Casing Volumes

Calculated purge volume Actual purge volume

WELL SAMPLING INFORMATION

Date: Time:

Weather Conditions:

Conduct. meter model: pH meter model: Turbidity meter model:

Calibration Date: Time: Calibration Date: Time: Calibration Date: Time:

Standard: Reading: Buffer: Reading: Standard: Reading:

Standard: Reading: Buffer: Reading: Standard: Reading:

pH: Conductivity: Turbidity: Temp(°C):

Number of sample containers: Sample temperature (°C):

Appearance (turbidity, color, etc.): Odor:

HOUSEKEEPING

Trash picked up? _____Yes _____No Well locked? _____Yes _____No Permit Returned/Signed Out? _____Yes _____No ____NA

If answer to any of the above is no, please explain:

Purge water disposal method:

Appendix B

Chain-of-Custody

I:\Corpus\Projects\CITGO\RCRA GROUNDWATER MONITORING\GROUNDWATER SAMPLING and ANALYSIS PLANS\West Plant SAP 03-16\App B

Date Time Type Matrix

Rush TAT

Standard TAT

RPS 3833 S. Staples Street, Suite N229 Corpus Christi, Texas 78411 (361)-855-7335 (361) 855-7410 fax

APPENDIX B CHAIN OF CUSTODY RECORD

Requested Analysis

Project Manager:

Project Location:

Phone/Fax Number:

Pres

erva

tive

Client

Project Name:

No.

of C

onta

iner

s

Sampler(s) Signatures

Received By:

Relinquished By:

Received By:

Time

Time

Special Instructions ( QC requirements, lists, methods, routing of results, etc.)

Time

Date

Date

TimeDate

Sample Identification Number

Relinquished By:Relinquished By: Time

TimeReceived For Lab By:

Date

DateDate

Appendix C

Monitor Well Location Map

MW03

MW05MW04

MW01

MW02

MW07R

MW06RRR

WEST PLANT CLOSED EQUALIZATION BASIN

(BG)

(POC)

(BG)

(POC)(POC)

(POC)

(POC)

WEST PLANTCORPUS CHRISTI REFINERY

MONITOR WELL LOCATION MAPLEGEND

FENCE

PROPERTY BOUNDARY

RCRA MONITOR WELL LOCATIONAND IDENTIFICATION NUMBERMW01

BGPOINT OF COMPLIANCE WELL

BACKGROUND WELL


Austin, Texas 78735Parkway 2, Suite 1504801 Southwest Parkway

TBPE No. 1298

POC



Unit/Waste Management Area: Closed Equalization Basin

Well No(s): MW01, MW02, MW03, MW04, MW05, MW06RRR, MW07R

Parameter Sampling Frequency Analytical Method

Method Detection Limit (MDL) or Method

Quantification Limit (MQL) Value, (units), MDL

or MQL2

Concentration Limit1

Chromium (filtered) Semiannual 6010 & 200.7 6020 & 200.8 2 µg/L MQL 70 µg/L

Chromium (unfiltered) Semiannual 6010 & 200.7 6020 & 200.8 2 µg/L MQL 70 µg/L

Hexavalent Chromium Semiannual 7196 & SM3500 Cr-B 3 µg/L MQL 70 µg/L

Lead (filtered) Semiannual 6010 & 200.7 6020 & 200.8

2 µg/L MQL 40 µg/L

Lead (unfiltered) Semiannual 6010 & 200.7 6020 & 200.8

2 µg/L MQL 40 µg/L

Benzene Semiannual 8260 & 624 1 µg/L MQL 5 µg/L

Toluene Semiannual 8260 & 624 1 µg/L MQL 5 µg/L

Benzo(a)pyrene Semiannual 8270 & 625 5 µg/L MQL 10 µg/L

Chrysene Semiannual 8270 & 625 5 µg/L MQL 10 µg/L

1 The concentration limit is the basis for determining whether a release has occurred from the waste management unit/area. The Evaluation Method is a direct

comparison to the specified PQLs. 2 a. Enter the laboratory expected Method Detection Limit if determination of Statistically Significant Increase (SSI) occurrence is based on detection of the

presence of the constituent of concern in the sample. 2 b. Enter the laboratory expected Method Quantification Limit if determination of SSI is based on statistical analysis of detection monitoring data or direct

comparison to a limit value. This should be based on the laboratory’s minimum expected level of performance. Please designate which type of limit has been entered for each constituent, with

its value and units.


Appendix IX

Releases From Solid Waste Management Units and Corrective Action

3833 South Staples, Suite N-229, Corpus Christi, TX 78411 USA

T 361 855 7335 W rpsgroup.com/usa


Preliminary Review Releases from Solid Waste Management Units

and Corrective Action

CITGO Refining and Chemicals Company L.P. West Plant

Corpus Christi Refinery

September 2018 Revised January 2019


Table of Contents

Summary ................................................................................................................ 1

Preliminary Review Facility Checklist ..................................................................... 2

Preliminary Review Unit Checklist - Equalization Basin (closed as a landfill) ......... 4

Attachments

Copy of April 25, 2003 No Further Action Letter


Summary

A preliminary review checklist is required as part of the RCRA Hazardous Waste Permit

HW-50353 renewal process.

The Preliminary Review covers the following permitted and former permitted units:

Equalization Basin (NOR 13), Permitted unit in post-closure care (Closed 1995)

Coker Oily Sludge Tank (NOR 16), Former permitted unit that was clean closed (2008)

A Preliminary Review Unit Checklist has been prepared for the Equalization Basin at the request of TCEQ and follows the Preliminary Review Facility Checklist.

The Preliminary Review also covers the following and solid waste management units (SWMUs):

Oily Sludge Tanks - RFI Unit 1 (NOR 001), Issued an NFA (April 25, 2003)

Container Storage Area -RFI Unit 2 (NOR 005), Issued an NFA (April 25, 2003)

Caustic Storage Tank - RFI Unit 3 (NOR 008), Issued an NFA (April 25, 2003)

Coker Oily Sludge Tank - RFI Unit 4 (NOR 016), Issued an NFA (April 25, 2003)

Dissolved Air Flotation (DAF) Tank - RFI Unit 5 (NOR 015), Issued an NFA (April 25, 2003).

RCRA Facility Assessments (RFIs) were conducted on the SWMUs starting in 1997. A

Final RCRA Facility Investigation Report was submitted in January 2002. Results of the

RFIs demonstrated that contaminant concentrations at RFI Units 1, 3, 4, and 5 are

below the Tier 1 residential PCLs for soils, based on Class 3 groundwater classification,

under Remedy Standard A. Contaminants remaining at RFI Unit 2 (Container Storage

Area) are below the Tier 1 Commercial/Industrial PCLs for soils, based on Class 3

groundwater classification, under Remedy Standard A. Proof of deed certification for

the Container Storage Area was submitted to TCEQ on March 19, 2003.

TCEQ issued an NFA letter dated April 25, 2003. No further action is needed on these

units.


Preliminary Review Facility Checklist

Facility: CITGO Refining and Chemicals Company, L.P. City: Corpus Christi

ISW Reg No: 33763 Date: August 15, 2018

Permit No: 50353 Reviewer: Mark S. Katterjohn, P.G.

EPA ID No: TXD981153711

A. Waste Management Units:

RCRA Regulated Units:

NOR No. Description Status

013 Equalization Basin (Process Code SO4) Permitted Unit in Post Closure Care (Closed 1995)

016 Coker Oily Sludge Tank (Process Code S02)

Clean Closed (2008)

Solid Waste Management Units:


001 Oily Sludge Tanks - RFI Unit 1 (above-grade storage tank - Process Code SO2)

NFA (April 25, 2003)

005 Container Storage Area -RFI Unit 2 (Process Code SO1)


008 Caustic Storage Tank - RFI Unit 3 (above-grade storage tank - Process Code SO2)


016 Coker Oily Sludge Tank - RFI Unit 4 (above-grade storage tank - Process Code SO2)


015 Dissolved Air Flotation (DAF) Tank - RFI Unit 5 (treatment tank - Process Code T01)


B. Reviewed Documents:

RCRA:

Part A: Process flow diagrams for the RFI Units from previous Part A applications included

Part B: RFI Work Plans and RFI Reports prepared per HW Permit No. 50353

Permit: Section IX.C of HW Permit No. 50353 identifies the five SWMUs listed above. The permit notes “no further action required (April 25, 2003)” for each RFI Unit

Revised Closure and Post Closure Care Plans, Equalization Basin – West Plant Refinery, April 5, 1993.

CERCLA: Inspection Reports: N/A Enforcement Actions: N/A Exposure Information: N/A Other Information: N/A


C. Summary:

A RCRA Facility Assessment was conducted on January 17, 1997. No visible evidence of releases or records of known releases or spills were found during the RFA. CITGO was issued Permit No. 50353 on April 3, 1998 that required an RFI for the five SWMUs. The RFIs were conducted in accordance with an approved RFI Work Plan (dated July 1998). A Phase I RFI Report was submitted to TCEQ in April 2000 and proposed a Phase II RFI to complete delineation of contamination at several SWMUs and recommended the RFI be packaged into an APAR. The Phase I RFI was approved on August 23, 2000. The Final Phase II RFI Report (organized as an APAR) was submitted in November 2000. TCEQ issued comments in a letter dated July 10, 2001 and an Addendum to the November 2000 Final RCRA Facility Investigation Report was submitted in January 2002.

Results of the RFIs demonstrated that contaminant concentrations at RFI Units 1, 3, 4, and 5 are below the Tier 1 residential PCLs for soils, based on Class 3 groundwater classification, under Remedy Standard A. Contaminants remaining at RFI Unit 2 (Container Storage Area) are below the Tier 1 Commercial/Industrial PCLs for soils, based on Class 3 groundwater classification, under Remedy Standard A. Proof of deed certification for the Container Storage Area was submitted to TCEQ on March 19, 2003.

TCEQ issued an NFA letter dated April 25, 2003. A copy of the letter is attached.

D. Recommended Action: None. All units have been issued an NFA.


Preliminary Review Unit Checklist





Waste Management Unit: Equalization Basin (Closed as a Landfill)

A. NOR No: 013

B. Description: Equalization Basin (Process Code SO4)

C. Dates of Operation: 1983 to 1994 (11 Years) - Closed in 1995

D. Wastes Managed: Primary Sludge, Waste Code 0017489H; F037

E. Evidence of Release: None. Unit has been under detection monitoring under Permit No. 50353.

F. Pollutant Dispersal Pathways: Surface flow from the cap and cover will flow within adjacent stormwater runoff control ditches to the northwest corner of the unit. Surface flow continues to the north toward Tule Lake located about 600 feet to the north. The unit is not located within wetlands or the 100-year floodplain.

As indicated in the Geology Report (Appendix VI.A of the application), the upper 50 feet of the soils consist of approximately 7-11 feet of high plasticity, stiff clay grading into sandy clay, clay sand and fine sand with depth. The estimated hydraulic conductivity of the near surface clays range from 10-7 to 10-9 cm/sec. Shallow groundwater beneath the unit does not produce significant quantities of water and the water quality is unsuitable as a drinking water source. If a release to groundwater were to occur, contamination would migrate toward the Corpus Christi Ship Channel at an approximate rate of 0.02 feet per day.

G. Summary: The unit was a combined above grade/below-grade surface impoundment with containment dikes located on the north, west, and south sides and, on the east side, a 20-foot wide unpaved road that served as a run-on protection dike. The unit has a minimum of 2 feet of compacted clay at the base. The unit was closed by stabilizing the remaining sludge, backfilling with compacted soil, and constructing a clay cap and cover over the unit. The closed impoundment has a surface area of approximately 3.2 acres and an estimated capacity of 6.5 million gallons.

H. Recommended Action: No Further Action. The unit is closed and capped and under a Detection Monitoring Program with no evidence of a release.


Attachments

Robert J. Huston. Chairman

R B. Marquez. Commissioner

Kathleen .Hartnett \Vhite, Commissioner

Margaret Hoffman, Kr:ecutive Director

Protecting Texas by Reducing and Preventing Pollution

Mr. Kevin Kenai! Environmental Engineer CITGO Refining & Chemicals, L.P. P.O. Box 9176 Corpus Christi, Texas 78469

Re: Remedy Standard A Approval

April 25, 2003

Acceptance of Deed Certification and Release From Post-Response Action Care Responsibilities CITGO Refining & Chemicals Company, L.P. -West Plant 7350 Interstate Highway 37, Corpus Christi TCEQ SWR No. 33763 TCEQ Hazardous Waste Permit No. HW- 50353 EPA lD No. TXD981153711

Dear Mr. Kenai!:

The Texas Commission on Environmental Quality (TCEQ) received a letter dated March 19, 2003 submitted by CITGO containing proof of deed certification for the Container Storage Area (RFI Unit No. 2). The certification states that contaminants remaining at the Container Storage Area are below the Tier I Commercial/Industrial Protective Concentration Levels (PCLs) for soils, based on Class 3 groundwater classification, under Remedy Standard A pursuant to Title 30 Texas Administrative Code (T AC) Chapter 350.

Based on the previously approved RCRA Facility Investigation Addendum Report and Response to the TCEQ NOD Regarding the RFI Report received January 14, 2002, it has been demonstrated that contaminant concentrations at the following Solid Waste Management Unit (SWMUs) are below the Tier 1 Residential PCLs for soils, based on Class 3 groundwater classification, under Remedy Standard A:

1. Oily Sludge Tanks- RFI Unit No. 1; 2. Caustic Storage Tank- RFI Unit No.3; 3. Coker Oily Sludge Tank- RFI Unit No.4; and 4. Dissolved Air Flotation (DAF) Tank- RFI Unit No. 5.

In order to attain Remedy Standard, all industrial solid waste and municipal hazardous waste and waste residues must be removed or decontaminated to health based standards and criteria. Contaminants allowed to remain in place in media of concern (i.e., soil, ground water, surface water and air) must not exceed the health based clean up levels as specified in 30 TAC §350.75. A Final Report, documenting that remediation at the facility has attained Remedy Standard A such that no post-response action care or engineering control measures are required, was previously accepted by the TCEQ in our letter dated December 6, 2002.

P.O. Box 13087 • Austin, Texas 78711-:3087 * 512/239-1000 * Internet address: \VYV\\'.tceq.state.tx.us

Mr. Kevin Kenall Page 2

After review of the proof of deed certification, it appears that the institutional control requirements of 30 TAC §350.111 have been completed. The TCEQ hereby releases the facility from post-response action care responsibilities for the above referenced units.

Please submit a written request to the TCEQ Registration and Reporting Section at Mail Code MC-129 to update your Notice of Registration (NOR) with a copy of this letter as an attachment.

Please be aware that it is the continuing obligation of persons associated with a site to ensure that municipal hazardous waste and industrial solid waste are managed in a manner which does not cause the discharge or imminent threat of discharge of waste into or adjacent to waters in the state, a nuisance, or the endangerment of the public health and welfare as required by 30 T AC §335.4. If the actual remediation fails to comply with these requirements, the burden remains upon CIT GO to take any necessary and authorized action to correct such conditions. A TCEQ field inspector may review your Final Report and condnct a closure inspection of the site.

Questions concerning this letter should be directed to me at (512) 239-6210. When responding by mail, please submit an original and one copy of all correspondence and reports to the Corrective Action Section at Mail Code MC-127 with an additional copy submitted to tbe TCEQ Region 14 Office in Corpus Christi. The TCEQ Solid Waste Registration Number and Unit Description or Name/TCEQ NOR Unit No. should be referenced in all submittals.

Sincerely,

Kelly Wilson, Project Manager Team I, Corrective Action Section Remediation Division Texas Commission on Environmental Quality

KC/kc

cc: Waste Program Manager, TCEQ Region 14 Office, Corpus Christi

Redline-Strikeout Version of Revised Part B Application Pages

TCEQ Part B Application Page 1 of 1 CITGO Refining and Chemicals Co., L.P. TCEQ-00376 (Rev. 9-29-2017 M.L. Shannon) Rev 2 – January 2019Rev 0 – September 2018

Appendix III.C Facility Security

Facility entry is controlled by an artificial barrier (chain-link fence) surrounding the plant.

Security guards are on duty 24-hours a day and routinely patrol the refinery. All valves which

permit outward flow and starter controls on all oil pumps are located at sites accessible only to

authorized personnel. Warning signs (“Danger – Unauthorized Personnel Keep Out”) are posted

at all points of access to the active portions of the facility and along the chain-link fence. The

signs are in English and Spanish and visible from at least 25 feet away. The entire plant is well

lighted and subject to routine surveillance by the Security Department each shift.

3833 S. Staples Street, Suite N229, Corpus Christi, Texas, USA T + 1 361 855 7335 F +1 361 855 7410 W www.rpsgroup.com/usa

3833 S. Staples Street, Suite N229, Corpus Christi, Texas, USA T + 1 361 855 7335 F +1 361 855 7410 W www.rpsgroup.com


P:\CITGO\022219 - WP RCRA Permit Renewal\Technical NOD\CITGO WP RCRA SAP 01-19.docx

United States | Canada | Brazil | UK | Ireland | Netherlands Australia Asia Pacific | Russia | Middle East | Africa

I:\Corpus\Projects\CITGO\RCRA GROUNDWATER MONITORING\GROUNDWATER SAMPLING and ANALYSIS PLANS\West Plant SAP 03-16

CITGO West Plant RCRA Groundwater Monitoring

Sampling and Analysis Plan

CITGO Refining and Chemicals Company L.P. Corpus Christi, Texas

June 2009 Revised June 2012

Revised March 2013 Revised March 2016

Revised January 2019

I:\Corpus\Projects\CITGO\RCRA GROUNDWATER MONITORING\GROUNDWATER SAMPLING and ANALYSIS PLANS\West Plant SAP 03-16 i

Table of Contents

List of Sections

Groundwater Sampling Procedures .......................................................................................... 1 Field Sampling Procedures ....................................................................................................... 1 Personal Protective Equipment ................................................................................................. 2 Monitor Well Inspections ........................................................................................................... 2 Fluid Level Measurements ........................................................................................................ 3 Well Purging .............................................................................................................................. 4 Sample Collection ..................................................................................................................... 4 Chain-of-Custody Program ........................................................................................................ 6 Groundwater Analytical Parameters .......................................................................................... 6 Laboratory Quality Assurance Program .................................................................................... 6

List of Tables Table 1 West Plant Equalization Basin Analytical Parameters Table 2 Analytical Parameters, Preservatives, Containers, Methods and Holding Times

List of Appendices Appendix A Well Sampling Form Appendix B Chain-of-Custody Form Appendix C Monitor Well Location Map

I:\Corpus\Projects\CITGO\RCRA GROUNDWATER MONITORING\GROUNDWATER SAMPLING and ANALYSIS PLANS\West Plant SAP 03-16 1

Groundwater Sampling Procedures CITGO’s West Plant groundwater monitoring is conducted for 7 monitor wells which are

constructed of 2-inch ID PVC. These 7 monitor wells monitor groundwater in the vicinity of the

West Plant Equalization Basin. Table 1 lists the laboratory analytical parameters for the West

Plant Equalization Basin. Table 2 presents the analytical parameters, preservatives, containers,

analytical method and holding times.

Field Sampling Procedures Field activities associated with monitor well sampling will include:

Preparation for sampling activities; Fluid level measurements; Monitor well inspections; Monitor well purging; and Monitor well sampling.

All sampling procedures will be conducted in accordance with the guidelines set forth in

USEPA’s publication entitled RCRA Ground-Water Monitoring: Draft Technical Guidance

(TEGD Update) (November 1992, USEPA).

Preparation for Sampling Activities Sampling personnel should prepare for the sampling event by coordinating with the contract

laboratory to ensure that they provide prepared sample bottles adequate for all wells, trip blanks

and one duplicate sample. Upon receipt of the bottle sets from the laboratory, check bottles for

proper preservatives, if appropriate, and the number of bottles. Bottles are to be properly

labeled to identify what the sample is to be analyzed for.

Ensure that all equipment and associated items are available. These include the following:

pH meter with temperature probe Specific Conductance Meter Turbidity Meter Water level measuring equipment (E-line and interface probe) Necessary calibration fluids or equipment Project specific Sampling and Analysis Plan De-ionized or distilled water Site specific Health and Safety Plan Required personal protective equipment Field data sheets and/or logbook

Sample containers Disposable bailers


Rope Buckets and intermediate containers Coolers First-Aid Kit Paper Towels Plastic Sheeting

Calibrate all necessary equipment in accordance with the manufacturer’s recommendations.

Upon arrival at the site the sampling team will record the following information in the field

logbook or on forms developed for groundwater monitoring (Appendix A):

Date of sampling; Time of arrival on location; Weather conditions (i.e. wind velocity, ambient temperature, etc.); The names of all field sampling personnel; and The names of all other personnel present during the sampling event and their affiliation

(i.e. CITGO, TCEQ, EPA, etc.).

The sampling team will then proceed with the field sampling activities.

Procedures to Prevent Contamination Prior to taking fluid levels or sampling, to ensure that contamination is not introduced into the

well from the rope or bailer, use clean gloves, plastic sheeting or tarp or stands to keep the rope

or bailer from contacting the ground or other potential contamination sources. Care should be

taken to ensure that soil or other material does not fall onto the plastic sheeting. Do not place

tools, meters or other equipment on the sheeting unless it has been cleaned.

Personal Protective Equipment Personal protective equipment will be worn by sampling personnel for each sampling event.

Safety equipment will include hard hat, safety glasses, safety shoes or boots, flame retardant

coveralls (i.e. Nomex®) and nitrile gloves. Respiratory protection is typically not necessary, but

respirators with organic vapor cartridges would be utilized if needed.

Monitor Well Inspections The sampling team will inspect each monitor well to evaluate the condition of the:

Well pad; Protective casing; Well casing; Well cap and lock as applicable; Protective posts; Well measuring point;


Well identification tag; Resistance to bailer movement; and Indication of well contamination.

.

Data will be recorded in the field logbook or on the well sampling form (Appendix A). A copy of

the completed form for each well will be submitted to CITGO at the completion of the sampling

event.

Fluid Level Measurements Fluid level measurements will be taken at each well. Each sampler will don a pair of nitrile

gloves prior to measuring fluid levels. An electronic water level indicator (E-line) or equivalent

will be utilized to obtain fluid level information. If an immiscible layer is suspected in a well, an

interface probe (ORS or equivalent) will be utilized for fluid measurements. In either case, the

probe will also be utilized to obtain depth to well bottom. Measurements will be taken from a

permanent survey mark (which is typically a mark in the casing) at the top of the casing. A

licensed surveyor has established all survey marks. Fluid levels will be measured to the nearest

0.01-foot. The following information will be recorded in the field logbook or on the sampling

form:

Well identification number; Time and date of fluid measurements and well purging; Top of casing elevation; Depth to hydrocarbon (if applicable); Depth to water; Total well depth; Fluid column length; Calculated purge volume; and Actual purge volume.

Data from the well measurements and condition of the samples will be evaluated prior to the

next sampling event to determine if there are problems associated with excessive silting. The

current total well depth measurements will be compared to the previous measurement. If the

well depth has decreased by more than a foot, or if more than 10% of the well screen is silted in,

the well will be redeveloped prior to the next sampling event.

If NAPL is present, the interface probe will be decontaminated after use by the following

method. Phosphate-free detergent and distilled water wash, followed by a distilled water rinse

and finally dried with a clean paper towel. Wastewater generated during this procedure will be

disposed of with the monitor well purge water to CITGO’s wastewater treatment system.


Decontamination procedures for the e-line will consist of a phosphate-free detergent and

distilled water wash, followed by a distilled water rinse and finally dried with a clean paper towel.

These procedures will be conducted after each use.

Well Purging Each of the monitor wells will be purged (using disposable bailer equipped with rope made of an

inert material) to remove a minimum of three casing volumes (or to dryness) of groundwater

prior to sample collection. Field personnel purging the wells will cover the ground surface

around the well with clean plastic sheeting and wear clean nitrile gloves to prevent

contamination of the disposable bailers and rope during purging activities. The rope will be

handled in a fashion which will prevent it from touching the ground. The purge volume will be

calculated by subtracting depth from the top of the casing to the first fluid level from the depth to

the well bottom. The resulting well column length will be multiplied by 0.49 (constant for 2-inch

diameter wells) to determine the volume (in gallons) of water equal to three times the casing

volume. Bailed groundwater will be poured from the bailer into a graduated bucket to measure

the purged water volume. The purge volume calculation will be logged in the field logbook or on

the sampling form (Appendix A) prior to the start of purging.

The sampling team will remove the calculated volume of groundwater from the well. If the well

bails to dryness before the calculated volume of water is evacuated, the well will be allowed to

recharge a minimum of one hour before groundwater samples are collected. The actual purge

volume will be recorded in the field logbook or on the sampling form. Purged fluids will be

placed in a drum or portable tank for disposal to CITGO’s wastewater treatment system at the

completion of sampling or as needed.

Sample Collection Sample bottles and preservatives for the analytes depicted in Table 1 will supplied by CITGO’s

contract analytical laboratory. Sample sets will include a trip blank for the following parameters:



Blanks will be provided by the contract laboratory and will be carried into the field in coolers.

Trip blanks will be transported back to the laboratory with the groundwater samples. Sample

bottles will be sealed in plastic bags prior to being placed in an ice-filled cooler. Samplers will

wear nitrile gloves during sampling activities and will replace the gloves with a fresh pair prior to

sampling each monitor well. Groundwater samples will be collected in the following manner:

The sample label will be completed with the site name, well number, sampling date, time

of sample collection and the name or initials of the sampler;

The bailer will be slowly lowered into the well and slowly retrieved when full;

The 40-ml bottle for the volatile organics sample will be filled first. The vial will be

completely filled to the top to eliminate headspace. The sample bottle will be inverted

after it is capped and checked for air bubbles. If air space is present in the sample,

additional sample will be added to the vial and rechecked for air space.

pH, specific conductivity, temperature and turbidity will be analyzed next using portable

pH, conductivity and turbidity meters. The meters will be calibrated prior to sampling in

accordance with the manufacturer’s instructions. The pH meter will be calibrated using

4.00 and 7.00 buffer solutions, and all calibrations will be recorded in the field logbook or

on the sampling form. The specific conductance meter will be calibrated per the

manufacturer’s instructions. The turbidity meter will be checked with the blanks included

with the meter. The groundwater sample will be collected in a clean container and the

pH, specific conductivity, temperature and turbidity will be measured immediately. One

measurement will be collected at each well. All field analytical data will be entered in the

field logbook or on the sampling form.

Following the collection of field parameters, the remaining sample containers will be

filled.

Filled sample bottles will be sealed in plastic bags and placed in an ice chest with ice.

Chain-of-custody documentation will be completed as each well is sampled. Once an

ice chest is filled, the excess water will be drained and the cooler repacked with ice. The

completed chain-of-custody form will accompany the samples to CITGO’s contract

laboratory. An example chain-of-custody form appears in Appendix B.


Samples in glass containers will be braced with bubble-wrap or similar packing material.

The ice chest will be latched shut and the lid will be secured with a custody seal; the

samples will be delivered to CITGO’s contract laboratory upon completion of daily

sampling activities.

Chain-of-Custody Program Sampling personnel will assure through a chain-of-custody program that the possession and

handling of groundwater samples collected can be traced from the point of collection through

analysis and final disposition. At a minimum, the program will conform to the chain-of-custody

program described in Test Methods for Evaluating Solid Waste: Physical/Chemical methods

(EPA SW-846).

Groundwater Analytical Parameters Groundwater analytical parameters for the West Plant Equalization Basin appear in Table 1.

Analytical parameters, preservatives, containers, methods and holding times can be found in

Table 2.

Laboratory Quality Assurance Program The contract laboratory selected by CITGO will have an ongoing quality assurance/quality

control (QA/QC) program. The laboratory will use EPA-approved QA/QC methods as published

in Test Methods for Evaluating Solid Waste: Physical/Chemical methods (EPA SW-846). The

implementation of the QA/QC process will be documented and verified for each sampling

through the standard and comprehensive quality control data reports to be supplied by the

laboratory and a final review and evaluation of the QC results by CITGO.

CITGO will ensure that the laboratory also utilizes the methods of analysis assurance outlined in

EPA SW-846 and EPA 600/4-79-020. A copy of the selected contract laboratory’s QA manual

will be provided to the TCEQ upon request.


Tables

I:\Corpus\Projects\CITGO\RCRA GROUNDWATER MONITORING\GROUNDWATER SAMPLING and ANALYSIS PLANS\West Plant SAP 03-16 Revision #1 06-20-12 Revision #2 03-04-13 Revision #3 03-23-16 Revision #4 01-14-19

Table 1 West Plant Equalization Basin Analytical Parameters

Sampling Schedule: January and July West Plant Equalization Basin: Consists of seven wells, five downgradient (MW01, MW02,

MW03, MW06RRR, MW07R) and two upgradient (MW04, MW05)

Sampling Sequence: To be determined in the field based on previous sampling event.

Detection Monitoring Analytical Parameters

1. Detection monitoring parameters for statistical evaluation. Specific methods of analysis from EPA SW--846. Approved statistical evaluation methods and established concentration levels are specified in Hazardous Waste Permit No. 50353.background levels.

Detection Monitoring

Parameter

Analytical Method

Method Quantitation Limit (mg/L)Evaluation Method(1) Direct Comparison to PQL

(g/L)

Chromium (filtered) 6010 & 200.7 6020 & 200.8

0.00270

Chromium (unfiltered) 6010 & 200.7 6020 & 200.8

0.00270

Hexavalent Chromium 7196 & SM3500 Cr-B 0.00370

Lead (filtered) 6010 & 200.7 6020 & 200.8

0.00240

Lead (unfiltered) 6010 & 200.7 6020 & 200.8

0.00240

Benzene 8260 & 624 0.0015 Toluene 8260 & 624 0.0015 Benzo(a)pyrene 8270 & 625 0.00510 Chrysene 8270 & 625 0.00510 Note: One sample is required to be collected for each detection monitoring parameter on upgradient and downgradient wells. In addition, one sample for Total Dissolved Solids is required to be collected from each well. 2. Additional parameters for field monitoring only (single analysis)

pH Specific Conductance Temperature Turbidity (nephelometric turbidity units)

3. Trip blank for the following parameters:


I:\Corpus\Projects\CITGO\RCRA GROUNDWATER MONITORING\GROUNDWATER SAMPLING and ANALYSIS PLANS\West Plant SAP 03-16 Revision #1 03-04-13

Table 2 Analytical Parameters, Preservatives, Containers, Methods and Holding Times

(All samples will be cooled to 4 degrees C)

Analytical Parameter Preservative Container SW-846 and

EPA Methods Holding Time

Benzo(a)pyrene None 950 mL - 1.25 L Amber

Glass 8270 & 625


days

Chrysene None 950 mL – 1.25 L Amber

Glass 8270 & 625


days

Benzene HCl 40 mL Teflon Septum 8260 & 624 14 days

Toluene HCl 40 mL Teflon Septum 8260 & 624 14 days

Chromium (filtered and unfiltered)


6 months

Hexavalent Chromium None 250 mL – 1 L Plastic 7196 &

SM3500Cr-B 24 hours

Lead (filtered and unfiltered)


6 months

Total Dissolved Solids None 500 mL – 1 L Plastic SM2540C 7 days

Note: Sample container sizes are approximate, as provided by the laboratory.


Appendix A

Well Sampling Form


Appendix B

Chain-of-Custody


Appendix C

Monitor Well Location Map

MW03

MW05MW04

MW01

MW02

MW07R

MW06RRR


(BG)

(POC)

(BG)

(POC)(POC)

(POC)

(POC)

WEST PLANTCORPUS CHRISTI REFINERY

MONITOR WELL LOCATION MAPLEGEND

FENCE

PROPERTY BOUNDARY

RCRA MONITOR WELL LOCATIONAND IDENTIFICATION NUMBERMW01

BGPOINT OF COMPLIANCE WELL

BACKGROUND WELL


Austin, Texas 78735Parkway 2, Suite 1504801 Southwest Parkway

TBPE No. 1298

POC

TCEQ Part B Application CITGO Refining and Chemicals Co., L.P. TCEQ-00376 (Rev. 9-29-2017 M.L. Shannon) Rev 0 2 – September 2018January 2019


Unit/Waste Management Area: Closed Equalization Basin

Well No(s): MW01, MW02, MW03, MW04, MW05, MW06RRR, MW07R

Parameter Sampling Frequency Analytical Method

Method Detection Limit (MDL) or Method

Quantification Limit (MQL) Value, (units), MDL

or MQL2Practical Quantification Limit2

(mg/l)

Concentration Limit1

(mg/l)

Chromium (filtered) Semiannual 6010 & 200.7 6020 & 200.8

2 µg/L MQL<BG 70 µg/LBG (2)

Chromium (unfiltered) Semiannual 6010 & 200.7 6020 & 200.8


Hexavalent Chromium Semiannual 7196 & SM3500 Cr-B 3 µg/L MQL<BG 70 µg/LBG (2)

Lead (filtered) Semiannual 6010 & 200.7 6020 & 200.8


Lead (unfiltered) Semiannual 6010 & 200.7 6020 & 200.8


Benzene Semiannual 8260 & 624 1 µg/L MQL<BG 5 µg/LBG (2)

Toluene Semiannual 8260 & 624 1 µg/L MQL<BG 5 µg/LBG (2)

Benzo(a)pyrene Semiannual 8270 & 625 5 µg/L MQL<BG 10 µg/LBG (2)

Chrysene Semiannual 8270 & 625 5 µg/L MQL<BG 10 µg/LBG (2)

1 The concentration limit is the basis for determining whether a release has occurred from the waste management unit/area. The Evaluation Method is a direct

comparison to the specified PQLs. 2 a. Enter the laboratory expected Method Detection Limit if determination of Statistically Significant Increase (SSI) occurrence is based on detection of the

presence of the constituent of concern in the sample. 2 b. Enter the laboratory expected Method Quantification Limit if determination of SSI is based on statistical analysis of detection monitoring data or direct

comparison to a limit value.

TCEQ Part B Application CITGO Refining and Chemicals Co., L.P. TCEQ-00376 (Rev. 9-29-2017 M.L. Shannon) Rev 0 2 – September 2018January 2019

This should be based on the laboratory’s minimum expected level of performance. Please designate which type of limit has been entered for each constituent, with its value and units.

2 BG – Background (BG) shall be based on the statistical test employed for the unit (Equalization Basin). BG values for each hazardous constituent cannot be reliably determined if the concentration is lower than PQL values identified in 40 CFR 264, Appendix IX. If BG values are lower than constituent PQLs, permittee may choose respective PQLs as concentration limits for hazardous constituents.

TCEQ Part B Application CITGO Refining and Chemicals Co., L.P. TCEQ-00376 (Rev. 9-29-2017 M.L. Shannon) Rev 20 – January 2019September 2018

Appendix IX

Releases From Solid Waste Management Units and Corrective Action Item IX.1 – Preliminary Review Facility Checklist


Item IX.1 – Preliminary Review Facility Checklist

3833 South Staples, Suite N-229, Corpus Christi, TX 78411 USA

T 361 855 7335 W rpsgroup.com/usa


Preliminary Review Releases from Solid Waste Management Units

and Corrective Action

CITGO Refining and Chemicals Company L.P. West Plant

Corpus Christi Refinery

September 2018 Revised January 2019


Table of Contents

Summary ................................................................................................................ 1

Preliminary Review Facility Checklist ..................................................................... 2

Preliminary Review Unit Checklist - Equalization Basin (closed as a landfill) ......... 4

Attachments

Copy of April 25, 2003 No Further Action Letter

TCEQ Part B Application Page 1 of 34 CITGO Refining and Chemicals Co., L.P. TCEQ-00376 (Rev. 9-29-2017 M.L. Shannon) Rev 20 – January 2019September 2018

Summary

A preliminary review checklist is required as part of the RCRA Hazardous Waste Permit

HW-50353 renewal process. Only the Preliminary Review Facility Checklist is required.

The Preliminary Review covers the following permitted and former permitted units:

Equalization Basin (NOR 13), Permitted unit in post-closure care (Closed 1995)

Coker Oily Sludge Tank (NOR 16), Former permitted unit that was clean closed (2008)

A Preliminary Review Unit Checklist has been prepared for the Equalization Basin at the request of TCEQ and follows the Preliminary Review Facility Checklist.

The Preliminary Review also covers the following and solid waste management units (SWMUs):

Oily Sludge Tanks - RFI Unit 1 (NOR 001), Issued an NFA (April 25, 2003)

Container Storage Area -RFI Unit 2 (NOR 005), Issued an NFA (April 25, 2003)

Caustic Storage Tank - RFI Unit 3 (NOR 008), Issued an NFA (April 25, 2003)

Coker Oily Sludge Tank - RFI Unit 4 (NOR 016), Issued an NFA (April 25, 2003)

Dissolved Air Flotation (DAF) Tank - RFI Unit 5 (NOR 015), Issued an NFA (April 25, 2003).

RCRA Facility Assessments (RFIs) were conducted on the SWMUs starting in 1997. A

Final RCRA Facility Investigation Report was submitted in January 2002. Results of the

RFIs demonstrated that contaminant concentrations at RFI Units 1, 3, 4, and 5 are

below the Tier 1 residential PCLs for soils, based on Class 3 groundwater classification,

under Remedy Standard A. Contaminants remaining at RFI Unit 2 (Container Storage

Area) are below the Tier 1 Commercial/Industrial PCLs for soils, based on Class 3

groundwater classification, under Remedy Standard A. Proof of deed certification for

the Container Storage Area was submitted to TCEQ on March 19, 2003.

TCEQ issued an NFA letter dated April 25, 2003. No further action is needed on these

units.


Preliminary Review Facility Checklist





A. Waste Management Units:

RCRA Regulated Units:


013 Equalization Basin (Process Type Code SO4)

Permitted Unit in Post Closure Care (Closed 1995)

016 Coker Oily Sludge Tank (Process Type Code S02)

Clean Closed (2008)

Solid Waste Management Units:


001 Oily Sludge Tanks - RFI Unit 1 (above-grade storage tank - Process Code SO2)


005 Container Storage Area -RFI Unit 2 (Process Code SO1)


008 Caustic Storage Tank - RFI Unit 3 (above-grade storage tank - Process Code SO2)


016 Coker Oily Sludge Tank - RFI Unit 4 (above-grade storage tank - Process Code SO2)


015 Dissolved Air Flotation (DAF) Tank - RFI Unit 5 (treatment tank - Process Code T01)


B. Reviewed Documents:

RCRA:

Part A: Process flow diagrams for the RFI Units from previous Part A applications included

Part B: RFI Work Plans and RFI Reports prepared per HW Permit No. 50353

Permit: Section IX.C of HW Permit No. 50353 identifies the five SWMUs listed above. The permit notes “no further action required (April 25, 2003)” for each RFI Unit

Revised Closure and Post Closure Care Plans, Equalization Basin – West Plant Refinery, April 5, 1993.

CERCLA: Inspection Reports: N/A Enforcement Actions: N/A Exposure Information: N/A Other Information: N/A


C. Summary:

A RCRA Facility Assessment was conducted on January 17, 1997. No visible evidence of releases or records of known releases or spills were found during the RFA. CITGO was issued Permit No. 50353 on April 3, 1998 that required an RFI for the five SWMUs. The RFIs were conducted in accordance with an approved RFI Work Plan (dated July 1998). A Phase I RFI Report was submitted to TCEQ in April 2000 and proposed a Phase II RFI to complete delineation of contamination at several SWMUs and recommended the RFI be packaged into an APAR. The Phase I RFI was approved on August 23, 2000. The Final Phase II RFI Report (organized as an APAR) was submitted in November 2000. TCEQ issued comments in a letter dated July 10, 2001 and an Addendum to the November 2000 Final RCRA Facility Investigation Report was submitted in January 2002.

Results of the RFIs demonstrated that contaminant concentrations at RFI Units 1, 3, 4, and 5 are below the Tier 1 residential PCLs for soils, based on Class 3 groundwater classification, under Remedy Standard A. Contaminants remaining at RFI Unit 2 (Container Storage Area) are below the Tier 1 Commercial/Industrial PCLs for soils, based on Class 3 groundwater classification, under Remedy Standard A. Proof of deed certification for the Container Storage Area was submitted to TCEQ on March 19, 2003.

TCEQ issued an NFA letter dated April 25, 2003. A copy of the letter is attached.

D. Recommended Action: None. All units have been issued an NFA.


Preliminary Review Unit Checklist





Waste Management Unit: Equalization Basin (Closed as a Landfill)

A. NOR No: 013

B. Description: Equalization Basin (Process Code SO4)

C. Dates of Operation: 1983 to 1994 (11 Years) - Closed in 1995

D. Wastes Managed: Primary Sludge, Waste Code 0017489H; F037

E. Evidence of Release: None. Unit has been under detection monitoring under Permit No. 50353.

F. Pollutant Dispersal Pathways: Surface flow from the cap and cover will flow within adjacent stormwater runoff control ditches to the northwest corner of the unit. Surface flow continues to the north toward Tule Lake located about 600 feet to the north. The unit is not located within wetlands or the 100-year floodplain.

As indicated in the Geology Report (Appendix VI.A of the application), the upper 50 feet of the soils consist of approximately 7-11 feet of high plasticity, stiff clay grading into sandy clay, clay sand and fine sand with depth. The estimated hydraulic conductivity of the near surface clays range from 10-7 to 10-9 cm/sec. Shallow groundwater beneath the unit does not produce significant quantities of water and the water quality is unsuitable as a drinking water source. If a release to groundwater were to occur, contamination would migrate toward the Corpus Christi Ship Channel at an approximate rate of 0.02 feet per day.

G. Summary: The unit was a combined above grade/below-grade surface impoundment with containment dikes located on the north, west, and south sides and, on the east side, a 20-foot wide unpaved road that served as a run-on protection dike. The unit has a minimum of 2 feet of compacted clay at the base. The unit was closed by stabilizing the remaining sludge, backfilling with compacted soil, and constructing a clay cap and cover over the unit. The closed impoundment has a surface area of approximately 3.2 acres and an estimated capacity of 6.5 million gallons.

H. Recommended Action: No Further Action. The unit is closed and capped and under a Detection Monitoring Program with no evidence of a release.


Attachments