Exhibit C

USCA Case #14-1083 Document #1514095 Filed: 09/25/2014 Page 1 of 4
Emission Event Report

http://www11.tceq.texas.gov/oce/eer/index.cfm?fuseaction=main.getDetails&target=117132[9/9/2014 4:22:54 PM]

Emission Event Reporting Database

Regulated

entity

name

DOW TEXAS OPERATIONS

FREEPORT

Physical

location

Regulated

entity RN

number

RN100225945 City, County FREEPORT,

BRAZORIA

Type(s) of

air

emissions

event:

EMISSIONS EVENT Event began: 11/28/2008

5:25AM

This is

based on

the:

FINAL REPORT Event ended: 11/28/2008

5:40AM

Cause

Loss of refrigeration caused an increase in temperature and pressure

in the crude vinyl system. This increase in pressure in the crude vinyl

system caused emergency safety valve 215 to relieve. Emergency

safety valve 215 did not reseat properly.

Action

taken

Emergency procedures were followed to shutdown, secure and remove

all energy sources from the crude vinyl system. A water curtain was

applied to the relieving emergency safety valve 215 to help reduce

emissions.

Based on engineering principles. 1.How many reportable and

recordable emissions events (including this incident) have occurred at

the facility/facilities contributing emissions during this incident for the

12 month period prior to this incident? This event is the only

reportable or recordable emissions event at this facility in the past 12

months. 2. What were the facility/facilities total actual operating hours

during the past 12 months? Approximately 6917 hours. 3. Identify the

cause or causes of the emissions event and include all contributing

factors that led to the emissions event. Discuss how the emissions

event could not have been avoided by good design, maintenance, and

operation practices, if applicable. Discuss any sudden breakdown of

equipment or process that was beyond the owner/operator¿s control,

if applicable. The C300 refrigeration unit tripped. This loss of

refrigeration allowed an increase in temperature and pressure in the

crude vinyl system. This increase in pressure in the crude vinyl

SITE SEARCH:

SUBJECT INDEX

Air Water Waste

Search TCEQ Data

Agency Organization Map

USCA Case #14-1083 Document #1514095 Filed: 09/25/2014 Page 2 of 4
Emission Event Report

http://www11.tceq.texas.gov/oce/eer/index.cfm?fuseaction=main.getDetails&target=117132[9/9/2014 4:22:54 PM]

Emissions

estimation

method

system caused emergency safety valve 215 to relieve. Emergency

safety valve 215 did not reseat properly. 4. How were the air pollution

control equipment or processes (if any) maintained and operated in a

manner consistent with good practice for minimizing emissions and

reducing the number of emissions events? Air pollution control

equipment and processes were not involved in this event. 5. How

soon was action taken to achieve compliance once the operator knew

or should have known that applicable emission limitations were being

exceeded? Immediate action was taken to isolate energy sources

from the system and to vent excess pressure to abatement devices.

Water curtain was applied to mitigate release to atmosphere. 6. How

were the amount and duration of the unauthorized emissions and any

bypass of pollution control equipment minimized? Emergency

procedures were followed to shutdown, secure and remove all energy

sources from the crude vinyl system. A water curtain was applied to

the relieving emergency safety valve 215 to help reduce emissions. 7.

What was the operational status of all emission monitoring systems at

the facility/facilities during this emissions event? If any emission

monitoring systems were not kept in operation during the emissions

event, explain why they weren¿t kept in operation. Continuous air

monitors (CAMs) were functional throughout the event. They detected

0.45 ppm southeast of the release. To help put this concentration into

context, the short term exposure limit for workers is 5 ppm in a 15

minute time period. 8. How were the owner or operator¿s actions in

response to the unauthorized emissions contemporaneously

documented? The unauthorized emissions were documented in the

plant log book notes, Event and Action Tool and STEERs. 9. Have

other similar incidents occurred at this/these facility/facilities in the

past that might be indicative of inadequate design, operation, or

maintenance? No similar incidents have occurred in the last 12

months 10. Identify any information you have (e.g., complaints from

neighbors, fence line monitoring, air modeling) which indicates an offsite impact. Identify any information you have which indicates the

unauthorized emissions caused or contributed to an exceedance of the

national ambient air quality standard (NAAQS), a prevention of

significant deterioration (PSD) increment, or to a condition of air

pollution. The facility does not have information indicating any o

Source 1: POSV-215 , EPN number n/a

Contaminant Authorization Limit Amount Released

Ethylene dichloride NSR 19041 0.0 7604.0 lbs (est.)

Hydrogen chloride NSR 19041 0.0 3341.0 lbs (est.)

Vinyl Chloride NSR 19041 0.0 5611.0 lbs (est.)

Source 2: Vinyl Chloride Unit 5 , FIN number OC5SV403

USCA Case #14-1083 Document #1514095 Filed: 09/25/2014 Page 3 of 4
Emission Event Report

http://www11.tceq.texas.gov/oce/eer/index.cfm?fuseaction=main.getDetails&target=117132[9/9/2014 4:22:54 PM]

Source 3: Vinyl Chloride Unit 5 , FIN number

No other sources

Return to search form

Air subjects

Region contact information

Air emissions events/maintenance activity forms

30 TAC air quality rules

USCA Case #14-1083 Document #1514095 Filed: 09/25/2014 Page 4 of 4