Via FedEx

December 16, 2014
Mr. Andrew Bouchard USEPA – Office of Air Quality Planning and Standards Sector Policies and Program Divisions, Coatings and Chemicals Group 109 T.W. Alexander Drive (E143- 0 Research Triangle Park, NC 277 09 Mr. David B. Eppler US Environmental Protection Agency, Region 6 Air Toxics Enforcement Section (6EN 1445 Ross Avenue Dallas, Texas 75202-2733 Subject: Application for Alternative Means of Emission Limitation (AMEL)

Ingleside Ethylene, LLC, Ingleside, San Patricio County, Texas
Dear Mr. Bouchard and Mr. Eppler In May 2014, the United States Environment on Environmental Quality i ssued Prevention of Significant Deterioration (PSD) Permit Numbers PSD TX-1338- GHG and 107530/PSD LLC (Ingleside) to construct an ethylene production unit in Ingleside, Texas. joint venture between Occidental Chemical Corporation and Mexichem, S ethylene production unit is to be built and operated by Occidental Chemical Corporation. Each of the PSD permits contains a requirement for the operated in accordance with 40 Code of Federal R requirements established in an approved equivalency determination. The Ethylene Unit Pressure Flare will be pressure- assisted multi tip velocity req uirements of §60.18. Therefore, Ingleside must obtain authorization to operate the Flare as designed, along with alternative monitoring to ensure proper Flare operation. Based upon guidance received from EPA for this project, we understand that the appro equivalency determination is an Alternative Means of Emissions Limitation (AMEL). Therefore, the enclosed document constitutes Ingleside’s application to EPA for an AMEL High Pressure Flare. We appreciate EPA’s review and approval regarding the information presented in this application, (972) 404-3291 or at Stephanie_Engwall@oxy.com Sincerely,

Stephanie Engwall Manager - Air Quality Occidental Chemical Corporation
Enclosure 

### Occidental Chemical Corporation A subsidiary of Occidental Petroleum Corporation Corporate Health, Environment, Safety, and Security Department

Office of Air Quality Planning and Standards Sector Policies and Program Divisions, Coatings and Chemicals Group 0 1) 09
US Environmental Protection Agency, Region 6 Air Toxics Enforcement Section (6EN -AT)

Application for Alternative Means of Emission Limitation (AMEL) Ingleside Ethylene, LLC, Ingleside, San Patricio County, Texas Mr. Bouchard and Mr. Eppler : In May 2014, the United States Environmental Protection Agency (EPA) and Texas Commission ssued Prevention of Significant Deterioration (PSD) Permit Numbers GHG and 107530/PSD -TX- 1338, respectively, which authorized Ingleside Ethylene, LLC (Ingleside) to construct an ethylene production unit in Ingleside, Texas. Ingleside is a 50/50 joint venture between Occidental Chemical Corporation and Mexichem, S .A.B. de C.V, and the ethylene production unit is to be built and operated by Occidental Chemical Corporation.

permits contains a requirement for the High Pressure Flare to be designed and operated in accordance with 40 Code of Federal R egulations (CFR) §60.18 (§60.18) or alternative requirements established in an approved equivalency determination. The Ethylene Unit assisted multi

- point ground flare that will exceed the maximum flare uirements of §60.18. Therefore, Ingleside must obtain authorization to operate the Flare as designed, along with alternative monitoring to ensure proper Flare operation. Based upon guidance received from EPA for this project, we understand that the appro priate venue for such equivalency determination is an Alternative Means of Emissions Limitation (AMEL). Therefore, the enclosed document constitutes Ingleside’s application to EPA for an AMEL for the Ethylene Unit
approval of this AMEL application

. If you have any questions regarding the information presented in this application, please do not hesitate to contact me at

Stephanie_Engwall@oxy.com

.

OxyChem ® Corporate Health, Environment, Safety, and Security Department 5005 LBJ Freeway, Suite 2200, Dallas, Texas 75244 P.O. Box 809050, Dallas, Texas 75380 Phone 972.404.3291 Fax 972.404.3287 Stephanie_Engwall@oxy.com

Application for Alternative Means of Emission Limitation (AMEL) Ingleside Ethylene, LLC, Ingleside, San Patricio County, Texas

al Protection Agency (EPA) and Texas Commission ssued Prevention of Significant Deterioration (PSD) Permit Numbers

1338, respectively, which authorized Ingleside Ethylene, Ingleside is a 50/50 .A.B. de C.V, and the ethylene production unit is to be built and operated by Occidental Chemical Corporation. Flare to be designed and egulations (CFR) §60.18 (§60.18) or alternative requirements established in an approved equivalency determination. The Ethylene Unit High point ground flare that will exceed the maximum flare uirements of §60.18. Therefore, Ingleside must obtain authorization to operate the Flare as designed, along with alternative monitoring to ensure proper Flare operation. Based upon priate venue for such equivalency determination is an Alternative Means of Emissions Limitation (AMEL). Therefore, the for the Ethylene Unit
If you have any questions please do not hesitate to contact me at 2200, Dallas, Texas 75244

-6152 P.O. Box 809050, Dallas, Texas 75380-9050 Phone 972.404.3291 Fax 972.404.3287 Stephanie_Engwall@oxy.com