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 27709

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 issued 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 requirements 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

01)

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 Regulations (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 appropriate 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