# Exhibit C

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

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30 TAC air quality rules USCA Case #14-1083 Document #1514095 Filed: 09/25/2014 Page 4 of 4