{"operation":"document","citation":"PI-15-0002","title":"Wacker Polysilicon North America — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-04-02","effective_on":null,"summary":"PI-15-0002 response to Wacker Polysilicon North America concerning 192.1, 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0002","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2015/15-0002.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nAPR 0 2 2015\nMr. Jeremy Copeland, CHMM\nEnvironmental Manager\nWacker Polysilicon North America, LLC\nPO Box 446\nCharleston, TN 3 7310\nDear Mr. Copeland:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nJanuary 12, 2015, you requested an interpretation of the applicability of the 49 CFR Parts 192\nand 195 requirements to your pipelines.\nYou stated that Wacker Polysilicon Notih America. LLC (Wacker) is constructing a chemical\nplant in Charleston, TN. Inc! uded in the plant is the construction of two dedicated chemical\npipelines that will transport chlorine gas and sodium hydroxide liquid from Olin Corporation\n(where the chemicals are manufactured) to Wacker's facility. The overall length of the\naboveground pipeline for both the chlorine gas and sodium hydroxide is approximately 5,000\nfeet. You stated that the pipelines cross underneath a county road through an open-to-air box\nculvert that separates the two facilities (map provided). You asked for an interpretation as to the\napplicability of PHMSA regulations to your pipelines.\nYou stated that § 192.1 does not appear to exclude the chlorine pipeline. It is your belief that\nbecause chlorine gas is both toxic and corrosive. the chlorine pipeline may be regulated under\nPart 192.\nAs to the sodium hydroxide pipeline, you stated that§ 195.1 provides exclusions and you believe\n§ 195.l(b)(3)(ii) exempts the sodium hydroxide line because; (1) the length of line measured\noutside of facility grounds is less than one mile; (2) the pipeline serves a manufacturing facility:\nand (3) the pipeline does not cross a waterway used for commercial navigation. Therefore, it is\nyour belief that the sodium hydroxide pipeline is not regulated under Part 195.\nPmi 192 prescribes minimum safety requirements for pipeline facilities and the transportation of\ngas. including pipeline facilities and the transportation of gas within the limits of the outer\ncontinental shelf(§ 192.1 ). Also, § 192.3 defines the term ''gas\" as natural gas. i1ammable gas.\nor gas which is toxic or corrosive. Therefore, as you stated in your request letter, the\ntransportation of chlorine gas is regulated under Part 192 regulations.\nPart 195 prescribes minimum safety standards and reporting requirements for pipeline facilities\nused in the transportation of hazardous liquids or carbon dioxide. Section 195.2 defines\nThe Pipeline and Hazardous Materials Safety Administration. Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nhazardous liquids as petroleum, petroleum products, or anhydrous ammonia. Therefore,\ntransportation of hazardous liquids by pipeline that is not petroleum, petroleum products, or\nanhydrous ammonia (in this case sodium hydroxide) is not regulated under Part 195.\nIfwe can be offurther assistance, please contact Tewabe Asebe of my staff at 202-366-5523.\nSincerely,\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\n!WACKER II POLYS ILl co Nl\nJEREMY COPELAND\nP-EHICHA\nWacker Polyslllcon\nNorth America LLC\n553 McBryan! Road\nCharleston, TN 37310-0446, USA\nTel. +1 423 780 7953\nFax +1 517 264 4021\njeremy.copeland@wacker.com\nP. 0. Box446\nCharleston, TN 37310-0446, USA\nWacker Polysilicon North America LLC\nOffice of the Chief Counsel\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Ave., SE\nEast Building, 2nd Floor\nWashington, DC 20590-0001\ne-version delivered to phmsa.hm-pipelinesafety@dot.gov\nhardcopy_ via Fed Ex, trackin' no.\n77Z.> S7..3<j 4£/. 0\n0 As discussed\n0 Thank you\n0 To be kept on file\nRequested action:\n0 For your information\n181 For review and comment\n0 Take appropriate action\n0 Contactme\n0 Please return\nJanuary 12, 2015\nRe: Regulatory Jurisdiction Request, Wacker Polysilicon North America,\nLLC; Charleston, TN\nDear Sir or Madam:\nWacker Polysilicon North America, LLC (Wacker) is constructing a chemical plant in\nCharleston, TN located at 553 McBryant Road NW, Charleston, TN 37310. Included in the\nplant is the construction of two, dedicated chemical pipelines that will transport chlorine gas\nand sodium hydroxide liquid from Olin Corporation (where the chemicals are manufac-\ntured) to Wacker's facility. The overall length of the aboveground pipeline is approximately\n5,000 feet and it crosses underneath a county road (through an open to air box culvert) that\nseparates the two facilities. Please refer to Appendix A that provides an aerial view of the\nroute of the pipelines.\nChlorine\nThe scope of Title 49 CFR Part 192.1 includes pipelines that transport gas. Some exclu-\nsions are listed in the rule, but none that appear to exclude the chlorine pipeline. It is\nWacker's interpretation that the chlorine pipeline may be regulated under 49 CFR part 192;\nbased primarily on the fact that chlorine gas is both toxic and corrosive.\nSodium Hydroxide\nThe scope of Title 49 CFR Part 195.1 includes pipelines that transport hazardous liquid.\nWacker interprets that the exclusion listed in 49 CFR Part 195.1 (b )(3)(ii) exempts the sodi-\num hydroxide line because; (1) the length of line measured outside of facility grounds is\nless than one mile, (2) the pipeline serves a manufacturing facility, and (3) the pipeline\ndoes not cross a waterway used for commercial navigation. Therefore, Wacker concludes\n\n<<<PAGE 4>>>\n\nthat the sodium hydroxide pipeline is not regulated by the Federal Department of Transpor-\ntation (USDOT).\nAs requested by USDOT personnel and pursuant to 49 CFR 190.11 (b); Wacker is request-\ning written regulatory interpretation of the US DOT regulatory jurisdiction/PHMSA rules ap-\nplicability to each of the the Wacker pipelines described above. Please refer to our user ID\napplication request already filed with PHMSA and attached as Appendix B. This applica-\ntion was filed in June 2014 based on our own rule interpretation that the chlorine line is\nregulated. Since filing the application request, Wacker inquired to USDOT as to the status\nof the processing of the application and we were directed to send this regulatory interpreta-\ntion request to the Office of Chief Counsel.\nIf you have any questions necessary to provide clarifications or aid in processing our re-\nquest or would like to discuss the topics for any reason, please contact me at (423) 780-\n7953. You may return your response to Wacker either electronically at:\nJeremy.Copeland@wacker.com or via hardcopy to: Jeremy Copeland, Environmental\nManager, Wacker Polysilicon North America, PO Box 446, Charleston, TN 37310.\nCordially,\nJeremy Copeland, CHMM\nEnvironmental Manager\nWacker Polysilicon North America, LLC\n\n<<<PAGE 5>>>\n\nAPPENDIX A\nAerial Layout\n\n<<<PAGE 6>>>\n\nNORTH\nHIWASSEE RIVER\nWACKER CONFIDENTIAL\nPond\nOld Lower-River Rd\nHin\nCHLOR ALKALI\nCL2 AND NaCH\nPIPELINE\nWACKER OWNED\nAND OPERATED\nQUINER/OPERATOR\nDIVISION LINE\nMouse Creek Valley\nRiver-RD.NW\nWACKER\n\n<<<PAGE 7>>>\n\nAPPENDIX B\nOPID Assignment Request\n\n<<<PAGE 8>>>\n\nNotice: This report is required by 49 CFR Parts 191 and 195. Failure lo report may resul t in a civil penalty nollo exceed $100,000 for\neach violation for each day the violation continues up to a max imum of$1,000,000 as provided in 49 USC 60122.\nForm Approved\nOMB o. 213 7-0627\nExpiration Dale: 12/31/2014\n~' U.S. Department of Transportation I\n~W Pipeline and Hazardous Materials Safety\nAdministration\nOPID ASSIGNMENT\nREQUEST\nI DOT USE ONLY\nA federal agency may not conduct or sponsor, and a person is not required to respond to, nor shall a person be subject to a penalty for faiJw·e to comply with a\ncollection of infonnation subject to the requirements of the Paperwork Reduction Act unless that collection of info!Ulation displays a current valid OMB Control\nNumber. The OMB Control Number for this inf01mation coll ection is 2137-0627. Public reporting for this collection of information is estimated to be\napproximately 60 minutes per response, including the time for reviewing instructions, gathering the data needed, and completing and reviewing the collection of\ninformation. All responses to tltis collection of infom1ation are mandatory. Send comments regarding tltis burden estimate or any other aspect of tl1is collection\nof information, including suggestions for reducing this burden to: lnformation Collection Clearance Officer, PHMSA, Office of Pipeline Safety (PHP-30) 1200\nNew Jersey Avenue, SE, Washington, D.C. 20590.\nSTEP 1 - ENTER BASIC REPORT INFORMATION I\nDate of this OPID Assignment Request:\n1. Month Day Year\nAre the pipelines and/or facilities covered by this OPID Assignment Request subject to regulation under all or any part of 49 CFR Parts 191 ,\n192, 193, 194, and/or1 95?\n~ Yes\nD No --> No Further action needed.\n2. Are the pipelines and/or faci lities covered by this OPID Assignment Request:\n0 Newly constructed pipelines and/or facilities\n3. 4. 5. 6. 7. --> Approximate start date of construction: 07 14 14\nMonth Day Year\n--> Anticipated date of operational start-up: 04 01 15\nMonth Day Year\n0 Existing pipelines and/or facilities --> 2a. Were they previously operated under another OPID?\nNo\nYes-> 2b. Is the Previous OPID Number known?\n0 No\n0 Yes - > List Previous OPID Number:\nPrevious Operator name:\nName of Operator as you would like it to appear in PHMSA records: WACKER POL YSILICON NORTH AMERICA. LLC\nOperator Headquarters address: 553 MCBRYANT RD. , PO BOX 446\nCity: CHARLESTON State/Province: TN Zip/Postal Code: 37310\nName of Operator contact for this OPID Assignment Request:\nLast: Copeland First: Jeremy Ml: Q\nPhone number of Operator contact for this OPID Assignment Request: !423)780-7953\nIs this Operator a wholly owned subsidiary of another company?\n0 No\n~ Yes ->Company name: W acker-Chemie Achte Venture GmbH\n[End STEP 1]\nForm PHMSA F 1000.1 Pg. 1 of7\nReproduction of this form is permitted.\n\n<<<PAGE 9>>>\n\nNoti ce: This report is required by 49 CFR Parts 1 91 and 195. Failure to report may result in a civil penalty not to exceed $100,000 for\neach violation for each day the violation continues up to a maximwn of$1 ,000,000 as provided in 49 USC 60122.\nForm Approved\nOMB No. 213 7-0627\nExpiration Date: 121 3l/20 14\nSTEP 2 - ENTER DESCRIPTION OF\nPIPELINES AND/OR FACILITIES\nThe questions in this STEP allow PHMSA to accurately portray the scope and nature of\nthe pipelines and/or facilities covered by this particular OP/0 Assignment Request and\nwill also be used by PHMSA for their inspection planning.\n1. The pipelines and/or facilities covered by this OPID Assignment Request are associated with the following types of facilities\nand transport the following types of commodities: (select all that apply)\n(Complete STEPS 2 and 3 once for each top level facility type in this question that is included in this OP/0 Assignment\nRequest.)\n0 LNG Plant(s) I Facility(ies)\n0 LNG Storage\nc Gas Distribution\n0 Natural Gas\n0 Propane Gas\nD Other Gas --> Name:\n12) Gas Transmission\nGas Transmission\nD Natural Gas\nD Propane Gas\nD Synthetic Gas\nD Hydrogen Gas\n0 Other Gas --> Name: Chlorine\n0 Gas Storage Facilities--> Total Number:\n~\n0 Gas Gathering\n0 Hazardous Liquid\nHazardous Liquid Trunkline (regulated non-gathering)\n0 Crude Oil\n0 Refined and/or Petroleum Product (non-HVL)\n0 HVL or Anhydrous Ammonia\nAnhydrous Ammonia\nLPG (Liquefied Petroleum Gas) I NGL (Natural Gas Liquid)\nOther HVL -> Name:\n0 C02 (Carbon Dioxide)\n0 Biofuel/ Alternative Fuel (including ethanol blends, but excluding Fuel Grade Ethanol)\n0 Fuel Grade Ethanol (also referred to as Neat Ethanol)\n0 Regulated Hazardous Liquid Gathering\n0 Hazardous Liquid Breakout Tanks-> Total Number:\nForm PHMSA F 1000.1\nPg. 2 of7\nRepraductio11 of this form is permitted_\n\n<<<PAGE 10>>>\n\nNotice: This report is required by 49 CFR Part s 191 and 195. Failure to report may result in a civi l penalty not to exceed $ 1 00,000 for\neach violation for each day the violation continues up to a maximum of $ 1,000,000 as provided in 49 USC 60122.\nFarm Approved\nOMB No. 2137-0627\nExp iration Date: 12/31 /2014\n2. Will any single pipeline or pipeline facility included in this OPID Assignment Request be subject to BOTH 49 CFR Part 192\nAND 49 CFR Part 195 due to the planned transportation of commodities which are subject to both Parts?\nEl No 0 Yes\n[STEP 2 continued]\n3. For the top level pipeline and/or facility type selected in STEP 2, Question 1, complete the following:\nFor Gas Transmission, the pipelines and/or facilities covered by this OPID Assignment Request are: (select Interstate and/or\nIntrastate, and complete Questions 3a-j for each set of Interstate assets and/or Intrastate assets, and for each selection of Gas\nTransmission facilities.)\nIntrastate\n0 Onshore\n3a. Approximate number of regulated transmission/trunkline pipeline miles: 1 miles\n3b. List all of the States and Counties in which these pipelines are physically located:\nI State 1: TN Counties BRADLEY\nI\n3c. Approximate number of regulated Hazardous Liquid gathering miles\n3d. List all of the States and Counties in which these Hazardous Liquid gathering lines are physically\nlocated:\n3e. List all of the States and Counties in which other facilities (including storage/breakout tanks) are\nphysically located, if different than the States and Counties listed in Questions 3b or 3d above:\n4. Provide a brief and general description of the pipelines and/or facilities covered by this OPID Assignment Request. Describe\neach second level selection from STEP 2, Question 1 separately.\nIn addition to the information provided below, Operators are encouraged to provide a general overview map (or maps) depicting the\napproximate geographic location of the pipelines and/or facilities covered by this OP/0 Assignment Request.\nGas Transmission Pipeline Description: Wacker Polysilicon North America, LLC (Wacker) manufacturing facility will\nreceive gaseous chlorine manufactured and transported by Olin Chemical\n(Olin) via an above ground pipeline. The pipeline exits Olin's manufacturing\nplant and travels approximately one mile on a piperack into Wacker's\nmanufacturing plant. The pipeline travels underneath a public roadway\n(Lower River Road) via a box culvert. This public road exists between the two\nfacilities and is the only location where the pipeline is not located on\ncompany property of either party.\nForm PHMSA F 1000.1 Pg. 3 of7\nReproducthm of this form i.~ permitted.\n\n<<<PAGE 11>>>\n\nNotice: This report is required by 49 CFR Parts 191 and 195. Failure to report may result in a civil penalty not to exceed $ 100,000 for\neach violation for each day tbe violation continues up to a maximum of $ 1,000,000 as provided in 49 USC 60 122.\nForm Approved\nOMB No. 2137-0627\nExpiration Date: 12/31/20 14\nSTEP 3 - PROVIDE PHMSA-REQUIRED PIPELINE\nSAFETY PROGRAM OR LNG SAFETY PROGRAM\nINFORMATION\nSometimes, existing pipelines, pipeline segments, pipeline facilities, or LNG\nFacilities are covered under a common PHMSA-required pipeline safety program or\nLNG safety program which also involves other assets covered by additional OP/Ds.\n(These common safety programs are sometimes referred to as \"umbrella\" safety\nprograms.) This STEP serves to notify PHMSA of these relationships so that\ncompliance performance can be accurately portrayed, as well as to facilitate\nPHMSA 's resource planning and preparation in the conduct of inspections of these\nPHMSA-required safety programs.\nGas Transmission\n1. Are the pipelines and/or facilities covered by this OPID Assignment Request included with other OPIDs for the purposes of compliance\nwith one or more PHMSA-required pipeline safety program(s) or LNG safety program(s)? (select only one)\nD Not known at this time. (Note: The Operator must submit an Operator Registry Notification informing PHMSA of the primary\nresponsibility for managing or administering these PHMSA-required safety programs within 60 days after they are known.\nOperators should note that many of these programs are required to be in place before initial operations of the pipelines and/or\nfacilities commence.)\nNo, the pipelines and/or facilities covered by this OPID Assignment Request have their own independent PHMSA-required safety\nprograms which include no other OPIDs for the following, when applicable:\n[For ALL facilities] Anti-Drug Plan and Alcohol Misuse Plan (199.101, 199.202)\n[For Gas Distribution, Gas Gathering, Gas Transmission, and Hazardous Liquid Pipeline Facilities]\nProcedure Manual for Operations, Maintenance, and Emergencies (192.605, 192.615, 195.402); Damage\nPrevention Program (192.614, 195.442); Public Awareness/Education Program (192.616, 195.440); Control\nRoom Management Proced ures (192.631 , 195.446); Operator Qualification Program (192.805, 195.505); and ,\nIntegrity Management Program (192.907, 192.1005, 195.452).\n[For Hazardous Liquid Pipeline Facilities ONLY] Response Plan for Onshore Oil Pipelines (or Alternative\nState Plan) (194.1 01).\n[For LNG Facilities ONLY] LNG Plans & Procedures (193.2017).\n[STEP 3, Question 1 continued]\nForm PHMSA F 1000.1 Pg. 4 of7\nReproduction of this form is permitted.\n\n<<<PAGE 12>>>\n\nNo tice: This report is required by 49 CFR Parts L 9 L and L 95. Failure to report may result in a civi l penalty not to exceed $ 100,000 fo r\neach violation for each day the violation continues up to a maximum of $1 ,000,000 as provided in 49 USC 60 122.\nForm Approved\nOMB No. 2lJ7-0627\nExpiration Date: 12/31/2014\nD\nYes, the pipelines and/or facilities covered by this OPID Assignment Request have one or more PHMSA-required pipeline\nsafety program(s) or LNG safety program(s) that also apply to pipeline assets with other OPID numbers for the purposes of\ncompliance with PHMSA regulations.\nIf Yes, please list the Operator-designated \"primary\" OPID for each common PHMSA-required pipeline safety\nprogram or LNG safety program associated with this OPID Assignment Request. Those programs not selected\nwill be considered to be either not required or independent programs which cover only the pipelines and/or\nfacilities covered by this OPID Assignment Request: (select all that apply)\n1 a. Anti-Drug Plan and Alcohol Misuse Plan (199.1 01 , 199.202)\nOPID # 0 ISP 0 Unknown\n1 b. Procedure Manual for Operations, Maintenance, and Emergencies (192.605, 192.615, 195.402)\nOPID # 0 ISP 0 Unknown\n1c. Damage Prevention Program (192.614, 195.442)\nOPID # 0 ISP 0 Unknown\n1d. Public Awareness/Education Program (192.616, 195.440)\nOPID # 0 ISP 0 Unknown\n1e. Control Room Management Procedures (1 92.631, 195.446)\nOPID # 0 ISP 0 Unknown\n1f. Operator Qualification Program (192.805, 195.505\nOPID# 0 ISP Unknown\n1g. Integrity Management Program (192.907, 1 92 . 100 ~195.45 2)\nOPID # 0 ISP u Unknown\n1h. Response Plan for Onshore Oil Pipelines (or Alternative State Plan) (194.101)\nOPID # 0 ISP 0 Unknown\n1 i. LNG Plans & Procedures (193.2017)\nOPID# 0 ISP 0 Unknown\n[End STEP 3)\nForm PHMSA F 1000.1 Pg. 5 of7\nR eproduction ofthi.,\n·form is permitted.\n\n<<<PAGE 13>>>\n\ncach violation for each day the violation continues up to a maximum of$1.000,000 as provided in 49 USC 60122.\nNotice: This report is required by 49 CFR Parts 191 and 195. Failure to report may resull in a civil penalty not to exceed S100,000 for\nOMB No. 2137-0627\nFom Approved\nExpiration Date: 12/31/2014\nSTEP 4 - PROVIDE CONTACT INFORMATION\nforms of Agency-Operator interaction that may occur\nThis STEP ensures that PHMSA has the contact information it needs for the basic\n1. Operator contact overseeing compliance with 49 CFR Parts 191-199, i.e. the primary contact for regulatory issues:\nName: Last: Copeland First: Jeremy MI: D\nAddress:\nTitle: Environmental Manager\nStreet/P.O. Box: 553 MCBRYANT RD., PO BOX 446.\nCity: CHARLESTON State/Province: TN\nZip/Postal Code: 37310\nPhone: (423)780-7953 E-mail: jeremy.copeland@wacker.com\n2.\nOperator contact for information pertaining to PHMSA's inspection scheduling, if different from above: (Provide one contact for\neach PHMSA Regional Office where pipelines and/or facilities covered by this OPID Assignment Request are physically located)\nPHMSA Region: N/A\nName: Last Copeland First Jeremy MID\nAddress:\nTitle: Environmental Manager\nStreet/P.O. Box: 553 MCBRYANT RD., PO BOX 446,\nCity: CHARLESTON State/Province: IN Zip/Postal Code: 37310\nPhone: (423)780-7953 E-mail: jeremy.copeland@wacker.com\n3.\n24/7 Operator contact for emergency situations (natural disasters, national emergencies, security threats, extreme weather events.\netc.):\nName: Last: King First: Dan MI:\nTitle: Emergency Prepardeness Manager\nAddress:\nStreet/P,O. Box: 553 MCBRYANT RD., PO BOX 446.\nCity: CHARLESTON State/Province: TN Zip/Postal Code: 37310\nPhone: (423)780-8150\nE-mail: dan.king@wacker.com\n4. 24/7 Operator phone number for normal operations:\nPhone: (423)310-3874\n5. 24/7 Operator Control Center phone number:\nPhone: (423)829-7106\n6.\nOperator's Senior Executive Official:\nName: Last: Bachhuber First: Konrad ME\nAddress:\nTitle: Vice-President & Site Manager\nCity: CHARLESTON State/Province: TN Zip/Postal Code: 37310\nStreet/P.O. Box: 553 MCBRYANT RD., PO BOX 446,\nPhone: (423)780-8800 E-mail: konrad.bachhuber@wacker.com\nForm PHMSA. F 1000.1\nReproduction of this form is permitted.\nP9. 6 of 7\n\n<<<PAGE 14>>>\n\nNotice: This report is required by 49 CFR Parts 1 91 aod 195. Failure 1 0 report may result in a civil penally not to exceed $ 100,000 for\neach violation for each day the violation continues up to a maximum of$ 1,000,000 as provided in 49 USC 60 122.\nFonn Approved\nOMB No. 2137-0627\nExpiration Date: 12/31120 1 4\n7. Operator contact for information pertaining to NPMS submissions:\nName: Last: Copeland First: Jeremv Ml: Q\nTitle: Environmental Manager\nAddress:\nStreet!P.O. Box: 553 MCBRYANT RD .. PO BOX 446 ,\nCity: CHARLESTON State/Province: TN Zip/Postal Code: 37310\nPhone: (423)780-7953 E-mail : jeremv.copeland@wacker.com\n8. Operator contact responsible for assuring compliance with DOT's Anti-Drug and Alcohol Misuse regulations (49 CFR 199):\nName: Last: Burk First: Erika Ml :\nTitle: Director of Human Resources\nAddress:\nStreet!P. O. Box: 553 MCBRYANT RD .. PO BOX 446 ,\nCity: CHARLESTON State/Province: TN Zip/Postal Code: 37310\nPhone: (423)780-8301 E-mail: erika.burk@wacker.com\n9. User Fee contact:\nName: Last: Copeland First: Jeremy Ml: Q\nTitle: Environmental Manager\nAddress:\nStreet!P.O. Box: 553 MCBRYANT RD., PO BOX 446 ,\nCity: CHARLESTON State/Province: TN Zip/Postal Code: 37310\nPhone: (423)780-7953 E-mail: jeremy.copeland@wacker.com\n[End STEP 4)\nForm PHMSA F 1000.1\nPg. 7 of7\nReproduction of this form is permitted.\n\n<<<PAGE 15>>>\n\nJEREMY COPEL\nJ\nLAND\nP-EHS-E/CHA\nP\nW\nWacker Polysili\ncon\nN\nNorth America LL\nLC\n5\n553 McBryant Ro\noad\nC\nCharleston, TN 3\nA\n37310-0446, USA\nT\nTel. +1 423 780 7\n7953\nF\nFax +1 517 264 4\n4021\nj\neremy.copeland\n@wacker.com\nP. O. Box 446\nP\nC\nCharleston, TN 3\nA\n37310-0446, USA\nWacker\nr Polysilicon Nort\nth America LLC\n553 Mc\nBryant Road, Ch\nharleston, TN 373\n310-0446, USA\nMr. T\nTewabe Ase\nebe\nUnite\ned States De\nepartment o\nof Transpor\nrtation\nPipel\nine and Haz\nzardous Ma\naterials Safe\nety Adminis\nstration\nAs discussed\nThank you\nTo be kept on\nn file\nR\nRequested actio\non:\nFor your infor\nrmation\nFor review an\nnd comment\nTake appropr\nriate action\nContact me\nPlease return\nn\nFebru\n5\nuary 6, 2015\nSubje\nect: Respo\nonse to Sod\ndium Hydro\noxide Pipe\nline Questi\nion\nDear\nMr. Asebe,\n,\nOn Ja\nanuary 22, 2\n2015 you e\nmailed to W\nWacker the f\nfollowing qu\nuestion, rela\nated to Wac\ncker’s reque\nest for\nregula\natory determ\nmination reg\ngarding the\nsodium hyd\ndroxide and\nd chlorine p\nipelines:\nPer o\nour telephon\nne conversa\ntion, would\nd you confirm\nm if your so\nodium hydro\noxide pipelin\nne is a low-\n-stress\nPipel\nline? If so,\nwould you p\nplease prov\nvide me with\nh the maxim\nmum operatin\nng pressure\ne.\nSectio\non 195.2 def\nefines a low-\n-stress pipe\nline as:\nLow-s\nstress pipel\nline means a\na hazardous\ns liquid pipe\neline that is\ns operated in\nn its entirety\ny at a stress\ns level\nof 20\npercent or\nless of the s\nspecified mi\ninimum yiel\nld strength o\nof the line p\npipe.\nWack\nker’s sodium\nm hydroxide\ne pipeline is\na low-stres\nss pipeline,\nmaxim\nmum opera\nting pressu\nre of the lin\ne is 95psig\n.\nas defined\nat 49 CFR\n§195.2. Th\nhe\nIf you\nu require an\ny further inf\nformation re\negarding thi\nis topic or a\nany topic rel\nated to Wa\ncker’s dete\nrmi-\nnation\nn request, p\nplease conta\nact me dire\nctly via ema\nail at jeremy\ny.copeland@\n@wacker.co\nom or via ph\nhone\nat (42\n23) 780-795\n53.\nCordi\nially,\nJerem\nmy Copelan\nnd, CHMM\nEnvir\nonmental M\nManager","truncated":false,"body_characters":25381}