XOM » Topics » Item 1. Legal Proceedings

This excerpt taken from the XOM 10-K filed Feb 26, 2010.

Item 3.    Legal Proceedings.

 

As reported in the Corporation’s Form 10-Q for the third quarter of 2009, in September 2009, two shareholders filed purported shareholder derivative petitions, which have been consolidated and captioned In re Exxon Mobil, Corp. Derivative Litigation, in the District Court of Dallas County, Texas, naming certain current and former directors as defendants and ExxonMobil as a nominal defendant. The petitions claim that the individual defendants breached their fiduciary duties by, among other things, allegedly failing to properly supervise the management of land leases overlaying hydrocarbon resources in the Point Thomson Unit on the Northern Slope of Alaska. The petitions also allege that the individual defendants caused the company to make materially false and misleading statements concerning the leases and caused the waste of corporate assets. The petitions seek damages from the individual defendants in favor of ExxonMobil, equitable relief to remedy their alleged breaches, and costs and expenses of the action. The defendants have filed pleadings with the court seeking dismissal of both cases for failure to make a demand on the Corporation and failure to plead particularized facts to excuse a demand.

 

As reported in the Corporation’s Form 10-Q for the third quarter of 2009, in October 2009, a purported shareholder complaint captioned Resnik v. Boskin et al., alleging direct and derivative claims, was filed in the United States District Court for the District of New Jersey, naming the present directors, the “named executive officers” listed in the Corporation’s 2009 Proxy Statement (as defined in Securities and Exchange Commission regulations) and ExxonMobil as defendants. The complaint was amended in December 2009, alleging that the defendants made materially false or misleading proxy solicitations in connection with the 2008 and 2009 shareholder votes regarding the election of directors and failed to seek stockholder reapproval of the Exxon Mobil Corporation 2003 Incentive Program to qualify certain incentive compensation paid to the named executive officers as properly deductible expenditures. The amended complaint also alleges, on behalf of the Corporation, that these acts injured the company, breached fiduciary duties and constituted waste. The amended complaint seeks various injunctive remedies, including corrective disclosure, new election of directors after corrective disclosure, enjoining candidates from serving on the Board until a new election occurs, stockholder reapproval of the program, enjoining payments under the program and short term incentive program to the named executive officers, damages from the individual defendants in favor of ExxonMobil, and costs and expenses of the action. The defendants plan to file a motion seeking dismissal of the lawsuit.

 

Refer to the relevant portions of “Note 15: Litigation and Other Contingencies” of the Financial Section of this report for additional information on legal proceedings.

 

This excerpt taken from the XOM 10-Q filed May 5, 2009.

Item 1.  Legal Proceedings


The Wyoming Department of Environmental Quality (WDEQ) has alleged certain violations of the state air permitting and state and federal air quality regulations associated with the operation of the three AGI cogeneration turbines located at the ExxonMobil Shute Creek Treatment Facility in LaBarge, Wyoming.  A notice of violation was issued on September 21, 2007, but no other formal complaint has been filed.  In discussions during the first quarter of 2009, WDEQ indicated that it will seek corrective action and penalties in excess of $100,000 to resolve the matter.


Regarding six previously reported matters involving the Corporation's Baytown Refinery; Baytown Chemical Plant and Baytown Olefins Plant, and ExxonMobil Oil Corporation's Beaumont Refinery, the Texas Commission on Environmental Quality (TCEQ) has entered into an agreement with the Corporation and ExxonMobil Oil Corporation to consolidate and resolve these matters along with fifteen other similar actions.  Each of the actions alleges exceedances of facility air permits and/or violations of applicable air regulations.  The proposed settlement amount is $602,801, half to be paid as a civil penalty and half in the form of a supplemental environmental project.  It is anticipated that this final settlement will be approved by the TCEQ Commissioners in the third quarter of 2009.


Refer to the relevant portions of note 3 on pages 6 and 7 of this Quarterly Report on Form 10-Q for further information on legal proceedings.




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These excerpts taken from the XOM 10-K filed Feb 27, 2009.

Item 3.    Legal Proceedings.

 

On November 21, 2008, the Louisiana Department of Environmental Quality (LDEQ) issued a Consolidated Compliance Order and Notice of Potential Penalty to the Corporation’s refinery located in Baton Rouge, Louisiana. The Order requires the refinery to take corrective actions related to self-disclosed emissions exceedances involving the refinery’s wet gas scrubber and wastewater treatment. Although penalties have not yet been assessed, they are likely to exceed $100,000. The LDEQ has also issued interim permit limits for these sources until the required corrective action steps can be completed during an upcoming scheduled turnaround.

 

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Regarding a previously reported matter, the Corporation and Chalmette Refining, LLC have agreed to pay stipulated penalties demanded by the United States Environmental Protection Agency (EPA) for alleged noncompliance under their respective 2005 and 2006 consent decrees relating to EPA’s New Source Review Enforcement Initiative. The EPA issued its demand for stipulated penalties to Chalmette Refining, LLC ($273,500) on October 17, 2008, and to the Corporation ($6,064,500) on December 17, 2008. Most of the penalties are associated with alleged noncompliance with New Source Performance Standards Subpart J. Chalmette Refining, LLC paid its penalty in November, 2008, and the Corporation paid its penalty in February, 2009.

 

Regarding a previously reported matter, on December 23, 2008, the office of the United States Attorney for the District of Massachusetts filed a misdemeanor criminal information alleging that ExxonMobil Pipeline Company violated 33 U.S.C. Sections 1319(c)(1) and 1321(b)(3) of the Clean Water Act resulting from a spill that occurred on or about January 9-10, 2006, on the Island End River near the Corporation’s Everett Terminal facility in Everett, Massachusetts. A plea agreement intended to resolve the case was also filed with the Federal District Court on that same date. The plea agreement requires that ExxonMobil Pipeline Company plead guilty to a misdemeanor violation 33 U.S.C. Section 1319(c)(1) of the Clean Water Act and agree to the following: (1) a term of probation of three years; (2) fund and implement an environmental compliance plan for the three year probationary period; (3) pay a fine of $359,018 and a special assessment of $125 (4) pay $5,640,982 in community service payments to the North American Wetlands Conservation Act Fund; and (5) pay $179,509 for spill-related cleanup costs. A hearing was held by the court on January 22, 2009, to review the plea agreement. The court took the matter under consideration, with sentencing to occur in the future.

 

Refer to the relevant portions of “Note 15: Litigation and Other Contingencies” of the Financial Section of this report for additional information on legal proceedings.

 

Item 3.    Legal Proceedings.

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On November 21, 2008, the Louisiana Department of Environmental Quality
(LDEQ) issued a Consolidated Compliance Order and Notice of Potential Penalty to the Corporation’s refinery located in Baton Rouge, Louisiana. The Order requires the refinery to take corrective actions related to self-disclosed emissions
exceedances involving the refinery’s wet gas scrubber and wastewater treatment. Although penalties have not yet been assessed, they are likely to exceed $100,000. The LDEQ has also issued interim permit limits for these sources until the
required corrective action steps can be completed during an upcoming scheduled turnaround.

 


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Regarding a previously reported matter, the Corporation and Chalmette Refining, LLC have agreed to pay
stipulated penalties demanded by the United States Environmental Protection Agency (EPA) for alleged noncompliance under their respective 2005 and 2006 consent decrees relating to EPA’s New Source Review Enforcement Initiative. The EPA issued
its demand for stipulated penalties to Chalmette Refining, LLC ($273,500) on October 17, 2008, and to the Corporation ($6,064,500) on December 17, 2008. Most of the penalties are associated with alleged noncompliance with New Source Performance
Standards Subpart J. Chalmette Refining, LLC paid its penalty in November, 2008, and the Corporation paid its penalty in February, 2009.

 

STYLE="margin-top:0px;margin-bottom:0px; text-indent:4%">Regarding a previously reported matter, on December 23, 2008, the office of the United States Attorney for the District of Massachusetts filed a
misdemeanor criminal information alleging that ExxonMobil Pipeline Company violated 33 U.S.C. Sections 1319(c)(1) and 1321(b)(3) of the Clean Water Act resulting from a spill that occurred on or about January 9-10, 2006, on the Island End River near
the Corporation’s Everett Terminal facility in Everett, Massachusetts. A plea agreement intended to resolve the case was also filed with the Federal District Court on that same date. The plea agreement requires that ExxonMobil Pipeline Company
plead guilty to a misdemeanor violation 33 U.S.C. Section 1319(c)(1) of the Clean Water Act and agree to the following: (1) a term of probation of three years; (2) fund and implement an environmental compliance plan for the three year probationary
period; (3) pay a fine of $359,018 and a special assessment of $125 (4) pay $5,640,982 in community service payments to the North American Wetlands Conservation Act Fund; and (5) pay $179,509 for spill-related cleanup costs. A hearing was held by
the court on January 22, 2009, to review the plea agreement. The court took the matter under consideration, with sentencing to occur in the future.

 

STYLE="margin-top:0px;margin-bottom:0px; text-indent:4%">Refer to the relevant portions of “Note 15: Litigation and Other Contingencies” of the Financial Section of this report for additional
information on legal proceedings.

 

This excerpt taken from the XOM 10-Q filed Nov 4, 2008.

Item 1.  Legal Proceedings


On August 1, 2008, the Connecticut Department of Environmental Protection (CTDEP) requested a Consent Order as a result of an alleged June 2007 discharge of gasoline at a Mobil-branded service station in South Windsor, Connecticut.  The proposed Consent Order seeks a penalty of $180,000.  ExxonMobil is assessing its response to the CTDEP.


Regarding a previously reported matter, on September 11, 2008, Exxon Mobil Corporation entered into a Consent Decree with the State of Maryland Department of the Environment (MDE) to resolve the lawsuit filed by the MDE on May 15, 2006.  In the litigation, the MDE alleged that a dealer-operated Exxon-branded service station in Jacksonville, Maryland, released petroleum from an underground storage tank.  The Consent Decree requires ExxonMobil to pay a $4 million penalty and complete remediation in exchange for a release of all claims asserted in the lawsuit.  


Regarding a previously reported matter, the Puerto Rico Environmental Quality Board (EQB) issued an order on May 21, 2001, alleging that Esso Standard Oil Company (Puerto Rico) (Esso) failed to investigate and remediate alleged hydrocarbon contamination associated with underground storage tanks at a service station in Barranquitas, Puerto Rico. The EQB sought a penalty of $75.9 million. On November 7, 2006, after granting Esso’s motion for summary judgment, the District Court issued a permanent injunction prohibiting the EQB from conducting any administrative proceedings against Esso related to the penalty. The EQB Defendants appealed and, on April 10, 2008, the U.S. Court of Appeals for the First Circuit issued its decision upholding the permanent injunction.  The time for appeals has now passed and on September 19, 2008, the District Court, on remand, granted Esso’s request for attorney fees and costs and ordered the EQB Defendants to pay Esso approximately $1.7 million in fees and expenses. An appeal of that order is expected.


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Regarding a previously reported matter, on August 21, 2008, a Consent Agreement and Final Order (CAFO) was filed with Region 9 of the Environmental Protection Agency (EPA) to resolve alleged violations under the Toxic Substances Control Act.  The EPA sought enforcement under the Act for alleged leaks of PCB-containing oil from transformers and related alleged violations of PCB disposal requirements at the Santa Ynez Unit Platform Hondo facility, offshore California. Under the terms of the CAFO, on September 2, 2008, Exxon Mobil Corporation paid a civil administrative penalty of $2,642,000.  Prior to the completion of the CAFO, the transformers were replaced with new PCB-free transformers.


Refer to the relevant portions of note 3 on pages 6 and 7 of this Quarterly Report on Form 10-Q for further information on legal proceedings.



This excerpt taken from the XOM 10-Q filed Aug 5, 2008.

Item 1.  Legal Proceedings


On February 16, 2007, the South Coast Air Quality Management District (AQMD) issued a Notice of Violation (NOV) alleging that a hole in the roof of one of the Torrance Refinery's waste water/recovery oil tanks violated certain AQMD rules and applicable facility permit conditions.  As part of a larger settlement of 10 other AQMD notices of violation on May 13, 2008, the AQMD and ExxonMobil Oil Corporation agreed to resolve the alleged violations in this NOV with a penalty payment of $320,000.  Each of the other ten NOVs had an associated penalty of less than $100,000, resulting in a total penalty amount of $469,500 for settlement of all 11 NOVs.


On May 20, 2008, the Illinois Attorney General and Illinois EPA filed a civil complaint against ExxonMobil Oil Corporation in the Circuit Court of Will County, Illinois, alleging that the Joliet Refinery violated certain air emission regulations and caused petroleum sheens at the facility wharf, in violation of federal and State of Illinois requirements.  The Complaint includes eight counts alleging a total of five water related violations and 12 air related violations.  The air emission events relate to several electrical power outages suffered at the refinery during the period 2005 through 2007.  The Complaint seeks a civil penalty in excess of $100,000.  The Complaint also seeks an Order requiring ExxonMobil to conduct “an independent engineering evaluation of the adequacy of the Refinery’s power system" and to undertake “the necessary corrective action to permanently eliminate source areas” of petroleum contamination in the wharf area.


As previously reported, the Texas Commission on Environmental Quality (TCEQ) issued a Notice of Enforcement and Proposed Agreed Order on November 22, 2006, alleging that the Company's Beaumont Refinery violated provisions of the Texas Health and Safety Code and the Texas Water Code.  The allegations related to permit and reporting requirements applicable to certain of the refinery's aboveground storage tanks.  The TCEQ initially proposed a penalty of $136,200.  The matter has been resolved as of July 10, 2008.  The TCEQ agreed to eliminate throughput and emissions exceedance allegations and added one allegation for late submittal of a Permit by Rule.  ExxonMobil agreed to pay a total of $55,200, with half of that amount to be paid as a penalty and half to be paid to fund a Supplemental Environmental Project for retrofit/replacement of Jefferson County heavy vehicles.  The agreed order is expected to be signed in the next several months.


The U.S. Environmental Protection Agency (EPA) and U.S. Department of Justice (DOJ) have alleged certain violations of Clean Air Act air permitting requirements and air quality rules associated with certain storage tanks and loading racks at ExxonMobil affiliates' Cabras Terminal (Guam) and Saipan Terminal (Saipan).  No formal complaint has been filed in this matter, but the EPA and DOJ have indicated that they will seek corrective action and penalties in excess of $100,000 to resolve the matter.


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On April 14, 2008, ExxonMobil executed a Compliance Order on Consent with the Colorado Department of Public Health and Environment (CDPHE) to resolve an enforcement action relating to excess air emissions events at the Piceance Creek Unit Gas Plant.  The issues were identified during agency inspections and internal reviews in 2006 and 2007.  The Company also self-disclosed an issue associated with emissions that were not reflected in the air permit, but discovered during testing.  As part of the settlement, ExxonMobil agreed to pay a total penalty settlement amount of $738,430 and also agreed to install and operate a thermal oxidizer to control emissions of volatile organic compounds consistent with state and federal air permitting requirements.  The settlement amount consists of two components: i) $285,500 as an administrative penalty, of which $228,400 may be offset via performance of one or more supplemental environmental projects, and ii) $452,930 as an economic benefit penalty.



Refer to the relevant portions of note 3 on pages 6 and 7 of this Quarterly Report on Form 10-Q for further information on legal proceedings.



This excerpt taken from the XOM 10-Q filed May 6, 2008.

Item 1.  Legal Proceedings


On February 15, 2008, the Texas Commission on Environmental Quality (TCEQ) filed a Preliminary Report and Petition seeking an administrative penalty and corrective action related to a July 24, 2004, emissions event and alleged violations discovered in a 2005 TCEQ inspection at the Baytown Refinery.  TCEQ is seeking an administrative penalty of $192,720.  ExxonMobil has filed its Answer to the Petition and requested a contested case hearing.  The matter is now pending before the State Office of Administrative Hearings.


Refer to the relevant portions of note 3 on pages 6 and 7 of this Quarterly Report on Form 10-Q for further information on legal proceedings.




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These excerpts taken from the XOM 10-K filed Feb 28, 2008.

Item 3.    Legal Proceedings.

 

On October 4, 2007, the Company received a proposed agreed order from the Texas Commission on Environmental Quality (TCEQ) relating to an alleged unauthorized air emission event at the Company’s Baytown, Texas chemical plant on May 14, 2007. The TCEQ is seeking an administrative penalty of $118,675, and it has referred the matter to its litigation division. ExxonMobil disputes the penalty calculation methodology utilized by the TCEQ. Once this matter is accepted by the State Office for Administrative Hearings, the Company will have the opportunity to meet with the TCEQ to attempt to resolve the penalty calculation dispute.

 

Refer to the relevant portions of “Note 15: Litigation and Other Contingencies” of the Financial Section of this report for additional information on legal proceedings.

 


Item 3.    
Legal Proceedings.

 

STYLE="margin-top:0px;margin-bottom:0px; text-indent:4%">On October 4, 2007, the Company received a proposed agreed order from the Texas Commission on Environmental Quality (TCEQ) relating to an alleged
unauthorized air emission event at the Company’s Baytown, Texas chemical plant on May 14, 2007. The TCEQ is seeking an administrative penalty of $118,675, and it has referred the matter to its litigation division. ExxonMobil disputes the
penalty calculation methodology utilized by the TCEQ. Once this matter is accepted by the State Office for Administrative Hearings, the Company will have the opportunity to meet with the TCEQ to attempt to resolve the penalty calculation dispute.

 

Refer to the relevant portions of “Note 15: Litigation
and Other Contingencies” of the Financial Section of this report for additional information on legal proceedings.

 

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Item 4.    
Submission of Matters to a Vote of Security Holders.

 

STYLE="margin-top:0px;margin-bottom:0px; text-indent:4%">None.

 


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This excerpt taken from the XOM 10-Q filed Nov 7, 2007.

Item 1.  Legal Proceedings


On October 9, 2007, ExxonMobil Oil Corporation received a proposed agreed order from the Texas Commission on Environmental Quality (TCEQ) relating to three separate air emissions events (in January, April and May of 2007) at the Beaumont, Texas refinery.  The events are associated with, respectively, a power disruption, a feed tank roof landing, and coker flaring due to low feedrate to the Wet Gas Compressor as the coker unit moved into turnaround.  The TCEQ alleges that the three events were avoidable.  In the proposed order, the TCEQ has assessed a penalty of $106,000.  The Company is assessing the appropriate response to the proposed order.  


On September 14, 2007, the TCEQ issued a proposed agreed order relating to the Company's Baytown, Texas refinery.  The enforcement action relates to three separate air emissions events, occurring in October 2005, June 2006 and October 2006.  The events are associated with, respectively, a forced draft fan trip at a fluid catalytic cracking unit, flooding/foaming in the delayed coker unit lean oil absorber, and a power plant relay trip.  The TCEQ has assessed an administrative penalty of $160,000 in the aggregate.  The Company is contesting enforcement related to the October 2006 power plant event (for which $60,000 of the penalty is being sought), and negotiations are ongoing regarding the amount of penalty for the other two events.


On September 4, 2007, the TCEQ issued a proposed agreed order in which it assessed an administrative penalty of $133,000 relating to two separate air emissions events occurring in February 2007 at the Company's Baytown, Texas refinery.  The events are associated with, respectively, a compressor trip at Booster Station 4 and an air blower interval of surge at the Flexicoker.  ExxonMobil is not contesting the enforcement of either event, but negotiations are in progress regarding the penalty amount.


Pursuant to a proposed agreed order received in August 2007, the Colorado Department of Public Health and Environment (CDPHE) is pursuing an enforcement action against the Company relating to excess air emissions (VOC, NOx, HAPs) events at the Piceance Creek Unit Gas Plant.  The issues were identified during agency inspections and internal reviews in 2006 and 2007.  The violations were due to reciprocating engine exhaust catalyst failure and glycol dehydrator control device failure, as well as associated recordkeeping issues.  The Company also self-disclosed an issue associated with emissions that were not reflected in the air permit, but discovered during testing.  The Company is engaged with the CDPHE in settlement discussions to enter into a Compliance Order on Consent that will require the installation of a new control device (thermal oxidizer) as well as payment of penalties.  The initial administrative penalty demand and associated economic benefit penalty demand exceed $500,000, but are under negotiation.



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The Environmental Protection Agency (EPA) is evaluating enforcement under the Toxic Substances Control Act for alleged leaks of PCB-containing oil from transformers and related alleged violations of PCB disposal requirements at the Company's  Santa Ynez Unit Platform Hondo facility, offshore California.  The EPA has indicated that they intend to seek civil penalties in excess of $100,000.


The Department of Justice (DOJ) and the U.S. Fish and Wildlife Service are evaluating enforcement for alleged violations of the Migratory Bird Treaty Act at the Company's Piceance Creek production unit in Colorado, the LaBarge, Wyoming production facility, and isolated production facilities in Kansas, Oklahoma and Texas.  The DOJ has indicated that it intends to seek fines and restitution in excess of $100,000.


Refer to the relevant portions of note 3 on pages 7 and 8 of this Quarterly Report on Form 10-Q for further information on legal proceedings.




This excerpt taken from the XOM 10-Q filed Aug 7, 2007.

Item 1.  Legal Proceedings


Regarding previously reported matters, the Corporation and Chalmette Refining, L.L.C. (which is fifty-percent owned by the Corporation) have identified and reported noncompliance with certain air pollution control provisions for certain streams at their U.S. refineries under their respective 2005 and 2006 consent decrees with the U.S. Environmental Protection Agency ("EPA") et al. relating to EPA's New Source Review Enforcement Initiative.  Although penalties have not yet been assessed and no formal enforcement proceedings have been commenced under these consent decrees, the total penalties associated with disclosed noncompliance items are likely to exceed $100,000.  


Regarding another previously reported matter, on June 15, 2007, ExxonMobil Oil Corporation ("EMOC") entered into a Consent Order with the New York State Department of Environmental Conservation ("NYSDEC") to resolve the penalty phase of an enforcement action that had commenced in 2002.  In June 2002, the NYSDEC issued a Notice of Hearing and Complaint with respect to EMOC's distribution terminal in New Windsor, New York, alleging discharges of petroleum into waters of the State that were allegedly neither timely reported nor immediately contained.  In 2003, EMOC entered into a Consent Order with the State and agreed to a scope of work, with the issue of penalties reserved.  The present Consent Order settles the outstanding penalty issue for $250,000.  


Regarding the previously reported matter concerning the Corporation's Brooklyn, New York, terminal, on July 17, 2007, the New York Attorney General ("AG") filed a civil lawsuit against the Corporation in U.S. District Court for the Eastern District of New York. The AG alleges that (1) the Corporation wrongfully discharged, and has failed to timely investigate and remediate, several million gallons of petroleum and non-petroleum “pollutants,” which have contaminated air, subsurface soils, groundwater, wetlands and surface water in Greenpoint; (2) the plume continues to migrate into Newtown Creek; (3) the Corporation has wrongfully discharged certain petroleum constituents from its remediation system into Newtown Creek; (4) the Corporation violated its Consent Orders (and state law) by suspending operation of its remediation system in 2007; and (5) the discharge has placed area residents at risk due to potential toxic vapors from the contamination.  The complaint alleges that the Corporation violated several federal laws (RCRA, CWA, CERCLA and the Oil Pollution Act) and state statutes (i.e., New York Navigation Law and Environmental Conservation Law) and that the Corporation is liable under common law theories of public nuisance, indemnification and restitution. The State seeks, among other things, reimbursement of past and future remediation expenses, civil penalties under various state and federal statutes, natural resource damages and costs of restoration, injunctive relief and attorney fees. The complaint does not specify an amount of penalties or damages sought.



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On May 16, 2007, the ExxonMobil Baytown Olefins Plant received a proposed Agreed Order from the Texas Commission on Environmental Quality ("TCEQ") relating to two alleged unauthorized air emissions events (January 1, 2006, and December 10, 2005), and one alleged violation of the related release reporting requirements for the December event. The Corporation is contesting the enforcement relating to the January 1, 2006, emissions event. TCEQ has argued for a total administrative penalty of $170,190, of which $160,000 is related to the contested issues.  The TCEQ referred the matter to its litigation division in July.


The U.S. Coast Guard, U.S. Environmental Protection Agency and the Department of Justice have alleged that the Company is responsible for a spill that occurred on or about January 10, 2006, on the Island End River near the Company's Everett Terminal facility in Everett, Massachusetts.  The Department of Justice has indicated that it intends to seek corrective action and penalties in excess of $100,000.


Refer to the relevant portions of note 3 on pages 7 and 8 of this Quarterly Report on Form 10-Q for further information on legal proceedings.



This excerpt taken from the XOM 10-Q filed May 8, 2007.

Item 1.  Legal Proceedings


The State of New York Attorney General (AG) sued a number of parties, including ExxonMobil, in New York state court, Albany County, relating to an alleged discharge of petroleum in Baldwin, New York at a former Mobil-branded service station and a service station owned/operated by an unrelated party.  The suit (captioned "State of New York v. Task Oil Corp., Exxon Mobil Corp., et al.") alleges that discharges from each service station have commingled and contaminated the soil and groundwater in the vicinity of the service stations.  Although the AG filed the complaint under the New York State Navigation Law against ExxonMobil and the other parties in September 2000, no specific penalty demand was made at that time.  In discovery proceedings, the AG indicated it will seek a civil penalty against ExxonMobil for an amount above $100,000.  The AG is also seeking compensatory damages for the costs of investigation and remediation in excess of $1,500,000.


The Texas Commission on Environmental Quality (TCEQ) alleges that the Company's Beaumont refinery has violated provisions of the Texas Health and Safety Code and the Texas Water Code.  Specific allegations include that the refinery failed to properly surface coat and timely inspect certain aboveground storage tanks, failed to comply with tank throughput representations in its permit, and violated certain permit limitation and reporting requirements.  The TCEQ issued a Notice of Enforcement and Proposed Agreed Order on November 22, 2006.  The Company disagrees with certain allegations, including that the throughput information raises a permit representation issue.  The TCEQ enforcement personnel referred the matter to its litigation group in December, 2006.  The TCEQ has proposed a penalty of $136,200 for this matter.  


On March 22, 2007, ExxonMobil experienced a failure in the sulfur recovery unit (SRU) at the Torrance refinery, which subsequently caused the cascading shutdown or idling of numerous other pieces of equipment and process units.  The incident led to emissions of oxides of nitrogen (NOx), carbon dioxide (CO2), particulate matter (PM), oxides of sulfur (SOx), and volatile organic compounds (VOCs).  In addition, similar emissions were expected to occur during the subsequent re-start process.  The South Coast Air Quality Management District (AQMD) alleged that these emissions violated permit conditions and applicable AQMD rules.  ExxonMobil agreed to pay a civil penalty of $250,000 and to spend a maximum of $2,000,000 for the development, implementation and completion of one or more Supplemental Environmental Project(s) intended to mitigate excess CO2, VOC and/or PM emissions resulting from operations associated with the SRU incident.  


The Company also settled with the AQMD 23 Notices of Violation covering a number of alleged violations of air permit and air quality regulatory matters at the Torrance refinery occurring from October 12, 2005 to October 17, 2006.  The settlement included the payment of a $150,000 civil penalty.


Refer to the relevant portions of note 3 on pages 7 and 8 of this Quarterly Report on Form 10-Q for further information on legal proceedings.



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This excerpt taken from the XOM 10-K filed Feb 28, 2007.

Item 3.    Legal Proceedings.

 

As previously reported, the Puerto Rican Environmental Quality Board (“EQB”) issued an order on May 21, 2001, alleging that Esso Standard Oil Company (Puerto Rico) (“Esso”) failed to investigate and remediate alleged hydrocarbon contamination associated with underground storage tanks at a service station in Barranquitas, Puerto Rico. The EQB sought a penalty of $75.9 million. Esso filed a federal law suit challenging the constitutionality of the procedures used in the EQB administrative process related to the penalty assessment. In March 2005, the federal District Court in the suit concluded that the EQB proceeding was impermissibly biased against Esso and issued a preliminary injunction prohibiting the EQB from continuing its penalty hearing or imposing the $75.9 million penalty on Esso. On November 7, 2006, after granting Esso’s motion for summary judgment, the District Court issued a permanent injunction that similarly prohibits EQB actions with respect to the penalty proceeding. The EQB may appeal this decision.

 

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As previously disclosed, the New York State Department of Environmental Conservation (“NYSDEC”) issued a Notice of Hearing and complaint on March 24, 2004, alleging that ExxonMobil Oil Corporation in whole or in part is responsible for a discharge of 17 million gallons of petroleum prior to 1978 in connection with past operations at its Brooklyn terminal. The NYSDEC also alleged that the Brooklyn terminal had numerous spills after 1978, in violation of New York Navigation Law. The NYSDEC sought natural resource damages. On June 19, 2006, the NYSDEC referred the matter to the New York State Attorney General (“AG”). On November 30, 2006, the NYSDEC advised the Administrative Law Judge that it was withdrawing the pending administrative enforcement case, without prejudice. On February 8, 2007, the AG issued two notices of intent to sue ExxonMobil in connection with its remedial activities at the Brooklyn terminal site. The first notice relates to alleged violations under the Clean Water Act. The State indicates it will seek civil penalties and injunctive relief for allegedly ongoing, unpermitted discharges of pollutants by the company into Newtown Creek. The second notice relates to alleged violations of the Resource Conservation and Recovery Act (RCRA) as a result of solid or hazardous waste contamination of soils, groundwater, and the surface waters and sediments of Newtown Creek. This notice names ExxonMobil and four unrelated entities as potential parties and indicates the State is seeking injunctive relief.

 

In another previously reported matter, Mobil Pipe Line Company (“Mobil”) agreed in January 2007 to sign a Consent Assessment of Civil Penalty issued by the Pennsylvania Department of Environmental Protection (“PDEP”) on May 11, 2006, pursuant to the Pennsylvania Clean Streams Law. This Consent Assessment resolves PDEP’s allegations that Mobil discharged gasoline into the soil and groundwater in South Whitehall Township, Pennsylvania. The release allegedly occurred from a pipeline and also caused a fire beginning on February 1, 2005, and continuing until February 4, 2005. Mobil will pay a combined civil penalty and cost reimbursement amount of $122,000. This is full and final resolution of any existing or potential liability of Mobil to the PDEP for the incident at issue.

 

Regarding a previously disclosed matter, on January 26, 2007, ExxonMobil Oil Corporation and California’s Department of Toxic Substances Control (“DTSC”) signed a Consent Order settling allegations made by the DTSC in a Summary of Violations issued to the Torrance Refinery in December 2003. The DTSC had alleged that the refinery had discharged wastewater containing soluble selenium above one part per million to the sewer that leads to the county treatment facility in violation of California hazardous waste rules. The Consent Order calls for the refinery to comply with the hazardous waste regulations as they relate to its discharge into the sewer of wastewater containing selenium and calls for the following payments totaling $650,000: administrative penalty - $350,000; supplemental environmental project - $150,000; reimbursement of DTSC costs - $100,000; and payment to the Western States Project Training Fund - $50,000.

 

Refer to the relevant portions of “Note 15: Litigation and Other Contingencies” of the Financial Section of this report for additional information on legal proceedings.

 

This excerpt taken from the XOM 10-Q filed Nov 8, 2006.

Item 1.  Legal Proceedings


ExxonMobil Oil Corporation has settled with the State of New York Attorney General allegations that a discharge at a former Mobil-branded service station located in Hopewell Junction (Dutchess County), New York, impacted soil and groundwater in the vicinity of the service station.  ExxonMobil entered into a Settlement Agreement with the State of New York effective July 21, 2006, and paid $720,000, of which $600,000 was for remediation costs and prejudgment interest, and $120,000 was a civil penalty under New York's Navigation Law.  The case was filed in New York state court, Albany County.  This matter was previously reported in the Company's second quarter 2006 Form 10-Q.


Refer to the relevant portions of note 4 on pages 9 and 10 of this Quarterly Report on Form 10-Q for further information on legal proceedings.




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This excerpt taken from the XOM 10-Q filed Aug 4, 2006.

Item 1.  Legal Proceedings


The State of New York Attorney General (AG) sued Mobil Oil Corporation and a number of other parties in New York state court, Albany County, under the New York State Navigation Law, alleging that petroleum was discharged at a former Mobil-branded service station located in Hopewell Junction (Dutchess County), New York.  The AG alleges that the discharge has impacted soil and groundwater in the vicinity of the service station.  Although the AG filed the complaint in 1998, no specific penalty demand was made against Mobil at that time.  In early 2006, the AG asserted for the first time during settlement negotiations a demand to ExxonMobil for a penalty of $120,000.  Negotiations continue between ExxonMobil and the AG.      


The State of New York Attorney General (AG) sued a number of parties, including ExxonMobil, in New York state court, Albany County, seeking penalties relating to an alleged discharge of petroleum at a Mobil-branded service station in Uniondale, New York.  The suit (captioned "State of New York v. United Gas Corp. et al.") alleges that the discharge has impacted soil and groundwater in the vicinity of the service station.  Although the AG filed the complaint under the New York State Navigation Law against ExxonMobil and the other parties in September 2004, no specific penalty demand was made against Mobil at that time.  In early 2006, it became evident in discussions between ExxonMobil and the AG that the AG likely will seek a civil penalty against ExxonMobil for an amount above $100,000.  


The State of Maryland Department of the Environment (MDE) has filed a complaint seeking injunctive relief, penalties and damages against ExxonMobil with respect to an alleged release of petroleum from an underground storage tank at a dealer-operated, Exxon-branded service station in Jacksonville, Maryland.  The MDE filed its complaint on May 15, 2006 seeking a civil penalty of in excess of $100,000 and unspecified damages.  The case is captioned "State of Maryland, Department of the Environment v. Exxon Mobil Corporation" and was filed in the Circuit Court for Baltimore County, State of Maryland.





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On May 11, 2006, the Pennsylvania Department of Environmental Protection (PDEP) issued a proposed Consent Assessment of Civil Penalty to Mobil Pipe Line Company pursuant to the Pennsylvania Clean Streams Law to resolve its allegations that Mobil discharged gasoline into the soil and groundwater in South Whitehall Township, Pennsylvania.  The release allegedly occurred from a pipeline and also caused a fire beginning on February 1, 2005 and continuing until February 4, 2005.  The proposed Consent Assessment of Civil Penalty provides for payment of $122,000 as a combined civil penalty and cost reimbursement amount.  Negotiation of the terms of the Consent Assessment of Civil Penalty and the payment amount are ongoing.


As previously reported, The New York State Department of Environmental Conservation (NYSDEC) issued a Notice of Hearing and Complaint on March 24, 2004 alleging that ExxonMobil Oil Corporation in whole or in part is responsible for a discharge of 17 million gallons of petroleum prior to 1978 in connection with past operations at its Brooklyn terminal. The NYSDEC also alleges that the Brooklyn terminal had numerous spills after 1978, in violation of New York navigational law.  In May 2006, the NYSDEC requested a penalty of $3 million, an environmental benefits project worth $7 million, a $2 million payment for a natural resource damages assessment, and a $1 million payment for oversight costs.  In late May, the NYSDEC notified ExxonMobil that it was discontinuing negotiations with ExxonMobil.  On June 19, 2006, the NYSDEC referred the matter to the New York State Attorney General (AG).  The AG has made no decision on whether to file suit and will meet with ExxonMobil before making that decision.  The Corporation has been conducting investigations and remediation activities in accordance with two NYSDEC consent orders since 1990.


Refer to the relevant portions of note 4 on pages 9 and 10 of this Quarterly Report on Form 10-Q for further information on legal proceedings.



This excerpt taken from the XOM 10-Q filed May 4, 2006.

Item 1.  Legal Proceedings


On April 19, 2006, in a case captioned United States v. Chalmette Refining, L.L.C., the United States District Court for the Eastern District of Louisiana accepted a plea agreement reached by Chalmette Refining (a 50-percent owned, indirect subsidiary of the Corporation) with the U.S. Department of Justice and the U.S. Environmental Protection Agency. In accordance with the terms of the agreement, Chalmette Refining pled guilty on January 25, 2006, to a one-count misdemeanor violation of the Clean Water Act for a negligent discharge of benzene on February 5, 2000, at the Chalmette, Louisiana refinery and was sentenced to and paid a fine of $200,000 on April 19th.  The violation involved a discharge into the Mississippi River that resulted from a leak in a heat exchanger.  When the source of the leak was identified, the heat exchanger was immediately replaced and new procedures implemented to prevent a recurrence.  Chalmette Refining has also agreed to make $25,000 community service donations to the Louisiana State Police Right to Know Fund and to the Southern Environmental Enforcement Network.


Refer to the relevant portions of note 4 on pages 9 and 10 of this Quarterly Report on Form 10-Q for further information on legal proceedings.




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This excerpt taken from the XOM 10-K filed Feb 28, 2006.

Item 3.    Legal Proceedings.

 

Regarding a previously reported matter, the Corporation and the Texas Commission on Environmental Quality (“TCEQ”) have agreed to settle a Notice of Enforcement issued on August 29, 2003, alleging leak detection and repair violations and inadequate notifications of several emissions events as required by air quality regulations at ExxonMobil Oil Corporation’s (“EMOC”) Beaumont, Texas refinery. Under the terms of the settlement, EMOC has agreed to pay a civil penalty totaling $80,444, half of which will be paid through a supplemental environmental project involving county vehicle retrofits. The parties expect to execute an Agreed Order by the end of March 2006.

 

Regarding a previously reported matter, the Corporation signed an Administrative Consent Agreement in December 2005 setting forth the terms of settlement of an Administrative Consent Agreement and Enforcement Order regarding underground oil storage tank and air activities received from the Maine Department of Environmental Protection (“MDEP”) in March 2005. The MDEP alleged violations at 12 service stations of regulations under the state’s Stage II vapor

 

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Index to Financial Statements

recovery program and underground storage tank program, including those relating to record-keeping, monitoring, equipment, clean-up and testing. The Corporation paid a civil penalty of $269,400 for settlement of the alleged violations. The Agreement is awaiting final execution by the State of Maine.

 

In another previously reported matter, the Corporation and the Environmental Protection Agency (EPA) filed a Consent Agreement and Final Order with the Administrative Law Judge on January 9, 2006, reflecting the parties’ agreement to settle an Administrative Complaint captioned “In the Matter of ExxonMobil Production Company”. The EPA had alleged violations of the Clean Water Act at the Hawkins Field (in Wood County, Texas) related to 13 spills of produced water into potential waters of the United States occurring from June 2000 to August 2004. The Corporation has agreed to pay a $31,000 civil penalty and to perform a supplemental environmental project valued at $91,000 relating to enhanced detection of upset conditions at the Hawkins Field.

 

Refer to the relevant portions of note 14 beginning on page 68 of the Financial Section of this report for additional information on legal proceedings.

 

This excerpt taken from the XOM 10-Q filed Nov 4, 2005.

Item 1.  Legal Proceedings


Regarding previously reported matters, the Corporation, the U.S. Environmental Protection Agency ("EPA") and the U.S. Department of Justice have reached a settlement of matters stemming from the EPA's New Source Review Enforcement Initiative.  In this enforcement initiative, the EPA had issued various Notices of Violation and Findings of Violations ("NOVs") alleging violations of the Clean Air Act at the Corporation's refineries in Baytown and Beaumont, Texas; Chalmette, Louisiana (owned by Chalmette Refining, LLC, which is operated and 50-percent owned by wholly-owned subsidiaries of the Corporation); Baton Rouge, Louisiana; and Joliet, Illinois.  The global settlement of these NOVs and certain other environmental claims (including a previously reported Violation Notice issued by the Illinois Environmental Protection Agency on August 22, 2003) consists of two consent decrees, one involving Exxon Mobil Corporation and ExxonMobil Oil Corporation and the other involving Chalmette Refining, LLC, filed in the U.S. District Court for the Northern District of Illinois and the U.S. District Court for the Eastern District of Louisiana, respectively, on October 11, 2005.  The consent decrees include an aggregate penalty amount of $8.7 million and supplemental environmental projects totaling $9.7 million.  Additionally, the decrees include emission limits and other environmental requirements with respect to the above refineries, as well as the Billings, Montana and Torrance, California refineries, some of which will require capital investments over the next several years.  The consent decrees are subject to public comment as well as approval of the two courts where the decrees are filed.


Regarding a matter reported in the Corporation's Form 10-Q for the first quarter of 2005, ExxonMobil Oil Corporation ("EMOC") and the Montana Department of Environmental Quality ("MDEQ") signed an agreed consent order effective October 5, 2005, relating to a March 31, 2005, Enforcement Action for Air Quality Violation.  The MDEQ had alleged that EMOC's Billings, Montana refinery violated particulate matter emissions limits and had opacity exceedances in violation of the Montana Environmental Protection Act and the Clean Air Act.  Pursuant to the terms of the consent order, EMOC has paid a civil penalty in the amount of $133,000.


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In another previously reported matter, EMOC and the Attorney General of the State of Illinois entered into an Agreed Final Order on August 18, 2005, relating to case captioned "People of the State of Illinois, ex rel. James E. Ryan, Attorney General of the State of Illinois, and ex rel. James W. Glasgow, State's Attorney for Will County, Illinois v. Mobil Oil Corporation".  In the case, the state alleged that a July 2, 1999, release of water and gas from the coker unit of EMOC's Joliet, Illinois refinery violated several provisions of the Illinois Environmental Protection Act, created a public nuisance and violated a 1998 Consent Order.  Under the Agreed Final Order, EMOC agreed to pay a penalty of $150,000, fund four supplemental environmental projects at a total cost of $110,000, and pay $21,846 in past government costs.


Regarding another previously reported matter, the Corporation and the EPA filed a Consent Agreement and Final Order ("CAFO") on October 7, 2005, which resolves all issues in the EPA's August 13, 2004, complaint captioned "In the Matter of ExxonMobil Chemical Company, Baytown, Texas".  The Complaint arose out of an inspection at the Corporation's Baytown Chemical Plant in August 1999, and alleged various violations of the Clean Air Act.  Under the CAFO, the Corporation will make a cash payment of $17,325, with the remainder of the $69,300 penalty to be offset by the performance of a supplemental environmental project.


A settlement agreement has been entered into by the Louisiana Department of Environmental Quality and Chalmette Refining, LLC regarding previously reported Consolidated Compliance Orders and Notices of Potential Penalty ("NOPPs") issued in connection with the Chalmette refinery (which is operated and fifty-percent owned by wholly-owned subsidiaries of the Corporation).  The NOPPs alleged non-compliance with Louisiana's environmental laws and regulations, including unauthorized discharges of pollutants to the air or water, violation of release reporting requirements, violations of fugitive emissions and other monitoring regulations, and failure to adequately maintain certain pollution control devices.  Under the terms of the settlement, Chalmette has agreed to donate air monitoring equipment valued at approximately $800,000 to the State of Louisiana.  No penalty was assessed.  The settlement terms were published in October and are subject to a public comment period and approval by the Louisiana Attorney General's office.


Refer to the relevant portions of note 4 on pages 10 through 12 of this Quarterly Report on Form 10-Q for further information on legal proceedings.


-29-



This excerpt taken from the XOM 10-Q filed Aug 4, 2005.

Item 1.  Legal Proceedings


An Administrative Complaint captioned "In the Matter of ExxonMobil Production Company" was filed by the Environmental Protection Agency ("EPA") on April 27, 2005.  The EPA alleges violations of the Clean Water Act at the Hawkins Field (in Wood County, Texas) related to 13 spills of produced water into potential waters of the United States, occurring from June 2000 to August 2004.  The government is seeking a penalty of up to $157,500 and appropriate injunctive relief.


Regarding a previously reported matter, Mobil Oil Australia Pty Ltd ("MOA") and the EPA executed a settlement agreement effective May 18, 2005, relating to a November 2003 notice of violation ("NOV") alleging that MOA transferred for distribution on the U.S. territory of American Samoa 23 barge loads of gasoline that did not contain additives required by the Clean Air Act.  These allegations were based on self-disclosure by MOA.  The NOV also alleged that the 23 barge loads were not accompanied by complete product transfer documents.  MOA took corrective action.  Under the terms of the settlement agreement, MOA will pay a civil penalty in the amount of $69,000, and will undertake a supplemental environmental project in the amount of $160,454, which consists of the purchase of respiratory equipment for the hospital in Pago Pago, American Samoa.


In another previously reported matter, ExxonMobil Oil Corporation ("EMOC") and the New York State Department of Environmental Conservation ("NYSDEC") entered into a Consent Order on May 24, 2005, relating to a 2002 NOV and subsequent Notice of Hearing and Complaint served on EMOC regarding the Port Mobil Terminal in Staten Island, New York.  The NYSDEC had alleged violations of regulations under New York's Petroleum Bulk Storage and Chemical Bulk Storage programs, including that certain above-ground storage tanks holding petroleum products were not being managed in accordance with regulatory requirements or were in violation of permit requirements.  Under the Consent Order, EMOC has agreed to pay a civil penalty of $200,000 and to demolish a number of out-of-service tanks at the terminal (which was recently sold to a third party).


Refer to the relevant portions of note 3 on pages 7 through 9 of this Quarterly Report on Form 10-Q for further information on legal proceedings.



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This excerpt taken from the XOM 10-Q filed May 5, 2005.

Item 1.  Legal Proceedings


Regarding a previously reported matter, on April 8, 2005, the Department of Justice, on behalf of the Environmental Protection Agency, filed a complaint and a proposed consent decree for the matter of United States of America v. Mobil Exploration and Producing U.S., Inc. ("MEPUS") in the Federal District Court in Salt Lake City, Utah.  This was a consolidation of a 1997 and a 1999 notice and finding of violation.  The complaint related to allegations that MEPUS's operations of the Aneth Field in Utah had violated the federal Clean Air Act, including violations of a Prevention of Significant Deterioration permit, New Source Performance Standards for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants and the National Emission Standards for Hazardous Air Pollution for asbestos.  Under the Consent Decree, MEPUS must pay a civil penalty in the amount of $350,000, plus interest at a rate of 1.29% from August 21, 2003, until date of payment, and undertake a supplemental environmental project in the amount of $99,849.  The Consent Decree is subject to a 30-day public comment period following publication in the Federal Register on April 28, 2005.


In another previously reported matter, the Corporation and the State of New York have settled a case captioned "State of New York v. Exxon Corporation, Arrow Petroleum, and Tartan Oil Corp, and 3rd party action Exxon Corporation v. 150 Fulton Realty Corp., Oil City Gas Company, and Martin Meyer".  The case related to allegations that petroleum discharged at an Exxon-branded service station in Farmingdale, New York impacted soil and groundwater in the vicinity of a Dart service station located across the street, in violation of New York State Navigation Law.  The New York State Department of Environmental Conservation began remediation at the Dart service station in 1988.  Prior to commencement of trial, the State amended its complaint to demand penalties in excess of $100 million.   In the settlement, ExxonMobil agreed to pay $3.2 million in past and future costs, plus interest, and no penalty.


Also in a previously reported matter, a settlement has been reached in the case captioned "Illinois v. Wolverine Pipeline Company", relating to alleged violations of Illinois water pollution laws by Wolverine Pipeline Company ("Wolverine"). ExxonMobil Oil Corporation


-22-


("EMOC") owns 36.1% of the common stock of Wolverine, and provides certain services on behalf of Wolverine.  The incident in question involves a September 1, 2001, alleged product release at Lockport, Illinois.  After the incident, Wolverine commenced a voluntary, remedial clean-up of the affected area. On February 17, 2005, the Circuit Court of Will County, Illinois entered into a Consent Order, which reflects the terms of the settlement.  Wolverine agreed to the payment of a civil penalty in the amount of $85,000, which has been paid. Wolverine is also obligated to continue certain monitoring and remediation activities.


On March 8, 2005, the Corporation received an Administrative Consent Agreement and Enforcement Order captioned "In the Matter of Exxon Mobil Corporation; Ashburn, Virginia; Underground Oil Storage Tank and Air Activities" from the Maine Department of Environmental Protection ("MDEP").  The MDEP alleges violations at 12 service stations of regulations under the state's Stage II vapor recovery program and underground storage tank program, including those relating to record-keeping, monitoring, equipment, clean-up and testing.  The MDEP is seeking a civil penalty in the amount of $292,400 for all violations. Settlement discussions are underway.


On March 31, 2005, the Montana Department of Environmental Quality ("MDEQ") issued an Enforcement Action for Air Quality Violation, alleging that the Corporation's Billings, Montana refinery violated particulate matter emission limits on two days in October 2003 during stack testing (as self-reported) and that the refinery had 198 opacity exceedances between February 2003 and April 2004 related to startups and shutdowns to address malfunctioning cyclones.  The initial penalty demand is $266,484.  The Corporation has requested a meeting with the MDEQ to discuss the allegations.


Refer to the relevant portions of note 3 on pages 7 through 9 of this Quarterly Report on Form 10-Q for further information on legal proceedings.


This excerpt taken from the XOM 10-K filed Feb 28, 2005.

Item 3.    Legal Proceedings.

 

On November 30, 2004, the New York State Department of Environmental Conservation (“NYSDEC”) proposed a statewide settlement of petroleum bulk storage compliance issues at all active petroleum bulk storage sites in New York, and any investigation and remediation required at those sites. The proposal includes requirements that the company perform a compliance audit at each site, undertake a $1.5 million environmental benefit project, pay a penalty of $5 million, and pay oversight costs. ExxonMobil is evaluating the offer and will respond to the NYSDEC. No formal action has been taken by the NYSDEC regarding these matters.

 

Refer to the relevant portions of note 16 beginning on page 70 of the Financial Section of this report for additional information on legal proceedings.

 

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