p.1 

OAR Box 1168 

Prepped by Ollie Stewart 

Document Number: 

89) ll-C-18 

Docket Number: 

A-89-10 

Printed 4/29/2008 11:23:19 AM Sheet 89 of 131 
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A-89-10 

II-C-18 

m r*2; 1930-

EPA A m D;*._* 

Mr. W. F. Buchholtz 

Exxon Chemical Americas 

Baytown Chemical Plant 

Post Office Box 4004 

Baytown, Texas 77522-4004 

Dear Mr. Buchholtz: 

This is in response to your letter of March 6, 1990, to Dr. Hershkowitz 

and me. I appreciate your comments. However, I believe I did understand 

correctly the leak detection and repair program at the Baytown Chemical Plant. 

The point that came up at the recent negotiation meeting did not pertain to 

the program you are now running, but rather, pertained to your comments when I 

asked what you would or could do if you needed to reduce emissions further. 

My notes from the plant tour describe the monthly/quarterly program you 

are now running as you described it in your letter. Based on my notes, you 

use one standard approach which is the least common denominator needed to meet 

EPA, Texas and, I believe, Harris County rules. The program applies to 20 

operating units, which are in physically defined areas. Every unit is in the 

program, except the water plant. JtejM^K||U_U«c -^-rl^

 ou* ty 7 people, at a 

.^Sj^^W'^^'Pfl^-BS^JSliF^' A totS^fj^OoOcompbnent s are involved (which 

tl|n|%j£ $2V0*df^Sponenf/yr).* I do not recall whether the work of the 7 man 

stVff is spread evenly over the quarter or whether it is concentrated in a 

single month. The valve results for individual units ranged from 1.5 percent 

to 0.2 percent leakers with a 10,000 ppm leak definition. The result for 

flanges was 2 leakers out of 50,000 flanges. In view of these low results, I 

asked if you took advantage of the skip program or the 2 percent 

performance/annual monitoring standard in the EPA rule. You responded, in 

part, that you did not because of the desire to keep the crew trained and 

available. The potential for falling back to quarterly from semi-annual would 

make it more difficult to plan work and to have a stable group of trained 

staff. 

Another question I asked was, what you would do if you had to reduce 

emissions further. According to my notes, you said that monthly monitoring 

would be "no problem". (I have checked with 3 others who were present and 

they have the same recollection.) You also made clear that this would be 

costly and that you thought that this would be a waste of money, as the 

facility was already well controlled, and the emissions were very low relative 

to motor vehicle emissions in the area. This seems to differ from your 

letter, where you stated that "pure monthly monitoring for all components is 

not practical at Baytown or at other large plants." I am not sure what you 
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mean by not practical, but if you mean that it would not be possible for some 

reason, that conflicts with what I understood you to say during the tour. 

Furthermore, I do not understand what factors would make this or any other 

monitoring program impractical at a large plant. It seems to me that the 

proximity of operating units, on a common site, with a central environmental 

and engineering staff would lead to economies of scale and other efficiencies. 

It is not my intent here to get into a who said what argument. The more 

important point is that the committee is working hard to develop a good rule 

that reflects the best performance and that is practical. One of the 

principal reasons that EPA chose to pursue this through "reg neg" was that 

this process provides an opportunity to produce a better rule than might 

result from traditional in-house rulemaking. However, in order to accomplish 

this goal, the committee needs to obtain as much factual information as 

possible. The committee has never considered requiring monthly monitoring as 

a base program (i.e., pure monthly monitoring). Rather, the approach we are 

pursuing is designed to encourage effective, industry designed quality 

assurance/quality control programs, such as the one Ron Bergland suggested, by 

offering reduced monitoring frequencies as a reward for effective control. 

General statements, such as yours, that pure monthly monitoring is 

impractical, are of little use. If you have cost or technical data that show 

that there are problems with what we are considering, or that there are better 

approaches, this would be helpful. However, at this point, I believe that my 

understanding, which is the basis for the comments I made to Bruce Davis at 

the meeting, is correct. 

Sincerely, 

Robert L. Ajax 

Chief 

Standards Development Branch 

cc: Phil Harter (for distribution 

to the committee) 

0AQPS:ESD:SDB:RLAjax:eaeleanor:629-5578(MD-13):3/13/90