January 8, 2015

Via e-mail
Ms. Jodi Howard Environmental Engineer USEPA QAQPS/SPPD/RCG (Mail Code E143-01) 109 T. W. Alexander Drive Research Triangle Park, NC 27711 Subject: Supplement to Submittal of PVC and Copolymer MACT Process Vent

and Other Information in Response to EPA’s May 15, 2014 Request under Section 114 of the Clean Air Act (42 U.S.C. § 7414)
Dear Ms. Howard: This letter and enclosures constitute a supplement to our November 17, 2014 response to May 15, 2014 request for process vent testing and other information pertaining to the Oxy Vinyls, LP (OxyVinyls) Deer Park, Texas, polyvinyl chloride (PVC) production facility, in accordance with the Clean Air Act (CAA) Section 114. This supplement provides the emission source sampling results and operating parameter data associated with the sampling event. Enclosed with this letter are the following non-confidential documents in electronic format, which are provided on a single USB flash drive:

Description Filename Certification Statement CERTIFICATION STATEMENT.pdf Documentation and Information Related to Completion of CAA Section 114 Information Collection Request for Polyvinyl Chloride and Copolymers Production (MACT Survey) 2014 (Revision 1) OxyVinyls_Deer Park PVC_Survey Summary 2014.pdf

PVC MACT Survey Workbook (Forms P and Q only) EPA PVC MACT Survey_(OxyVinyls)_(Deer Park PVC)_(P&Q ONLY)_2014.xls Source Emissions Survey Report OxyVinyls_Deer Park PVC_ 2014 Survey - Sampling Report.pdf ERT Submittal Package Oxy Vinyls, LP - Deer Park PVC_01-07- 2015_17-46_PKG.zip Source and Control Device Operating Data OxyVinyls_Deer Park PVC_Operating Data Supplement.pdf Source and Control Device Operating Parameter Monitor Calibrations OxyVinyls_Deer Park PVC_Operating Parameter Monitor Calibration.pdf Occidental Chemical Corporation OxyChem ® A subsidiary of Occidental Petroleum Corporation Corporate Health, Environment, Safety, and Security Department 5005 LBJ Freeway, Suite 2200, Dallas, Texas 75244

-6152 P.O. Box 809050, Dallas, Texas 75380-9050 Phone 972.404.3291 Fax 972.404.3287 Stephanie_Engwall@oxy.comSupplement to Submittal of CAA 114 Response

Ms. Jodi Howard, USEPA January 8, 2014 Page 2 As presented in Section 7 of the Test Plan approved by the United States Environmental Protection Agency (EPA) on September 29, 2014, and as discussed with EPA on multiple occasions, OxyVinyls experienced three unplanned equipment issues that resulted in maintenance activities and previously scheduled plant and equipment outages that prevented us from conducting the performance test at maximum production rates as originally scheduled on September 29, 2014. That sampling event was aborted, and testing resumed on November 11, 2014. Therefore, per your direction, OxyVinyls is submitting with this supplement a completed Form P, the stack sampling report, and supporting operating parameter data for the November 2014 sampling event. The Method 25A and 26A sampling results are being submitted via EPA’s Electronic Reporting Tool (ERT). Similarly, three unplanned equipment issues that resulted in maintenance activities and previously scheduled plant and equipment outages prevented OxyVinyls from collecting 30 days of THC data prior to November 17, 2014. OxyVinyls commenced sampling on October 3, 2014, with the intention of collecting a partial data set prior to a scheduled Plant turnaround that commenced on October 10, 2014. The THC sampling was conducted utilizing a temporary methane/non-methane THC continuous emissions monitoring system (CEMS), which contains a methane channel and a non-methane channel. Shortly after sampling commenced on October 3, 2014, the methane channel malfunctioned. A replacement monitor was not available until October 7, 2014. The replacement monitor was calibrated and put on line at 10:00 Hrson October 7, 2014, and valid sample data collection resumed. Although the nonmethane THC channel was functional during the methane channel downtime, the lack of methane data caused the data collected during this time period to be invalid. Therefore, per your direction, the original submittal of Form Q included valid data collected during the October 3 through 10 sampling event (i.e., October 3 from 10:25 through 14:25 Hrs and October 7 at 11:35 through October 10 at 08:12 Hrs). OxyVinyls resumed sampling on November 11, 2014, and continued the second sampling event with intention of obtaining 30 consecutive days of data. A fugitive equipment leak, for which repair required a shutdown of the PVC process unit, caused data collection to cease at 11/15/2014 06:56, resuming 11/20/2014 13:31. Therefore, OxyVinyls continued data collection to 12/21/2014 06:53. It should be noted that a calibration issue on November 30 invalidated one day of data. With this supplement, OxyVinyls is providing a revised Form Q that contains THC sampling data for a period greater than 30 days.Supplement to S ubmittal of CAA 114 Response

Ms. Jodi Howard, USEPA January 8, 2014 Page 3 OxyVinyls truly appreciates your guidance during If you have questions or comments hesitate to contact me at 972

- Sincerely,

Stephanie Engwall Manager of Air Quality Occidental Chemical Corporation
Electronic Enclosures cc: Mr. Greg Valentine , USEPA, Region 6 (6EN 1445 Ross Avenue, Suite 1200, Mr. Michael Beatty, TX Commission on Environmental Quality Post Office Box 13087, ubmittal of CAA 114 Response

OxyVinyls truly appreciates your guidance during the preparation of this supplement. ou have questions or comments regarding the information provided , please

- 404-3291.

Occidental Chemical Corporation

, USEPA, Region 6 (6EN -AA), Toxics Section Suite 1200, Dallas, TX 75202-2733 Mr. Michael Beatty, TX Commission on Environmental Quality (MC 224) Post Office Box 13087, Austin, TX 7871 1-3087 preparation of this supplement.

, please do not

(MC 224) ,