Olin — Pipeline Safety Interpretation

Page 1U.S. Department ofTransportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue SE Washington DC 20590 'APR 2 9 2019 Ms. Stacie Campbell-Eckhoff Environmental Superintendent Olin 1186 Lower River Road Charleston, 1N 3 7310 Dear Ms. Campbell-Eckhoff: In an April 30, 2018, letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you requested an interpretation of 49 CFR Part 192. Specifically, you requested interpretation for the applicability of Part 192 to your pipeline. You stated that Olin and Wacker own and operate separate portions of a 4-inch diameter, 9,965- foot long(~ 1.9 miles) pipeline in Charleston, Tennessee used to transport chlorine gas from the Olin manufacturing facility to Wacker the customer. You stated that the Wacker-owned portion of the pipeline is a transmission line. Olin owns and maintains 5,240 feet (~I-mile) of the line that is completely within Olin's property line. You stated that just before the end of the Olin portion of the pipeline (where the pipeline transfers to Wacker) there is a manual block valve and directly upstream of the manual block valve there is an automatic shutoff valve that can be operated in the field by an "emergency stop" button or remotely from a central control room by Olin. Also, you mentioned an August 2010 PHMSA interpretation you believe indicates PHMSA does not apply the safety regulations to lines like yours. You asked whether Olin's portion of the line is regulated under Part 192. Interpretation PI-09-0020, (Illinois Commerce Commission (Aug. 11, 2010)) responded to a request for an interpretation regarding whether "in-plant piping" operated by a large volume customer is subject to the pipeline safety laws and regulations. PHMSA stated that such piping downstream of where pressure control changes from a transmission pipeline operator to a large volume customer would not be subject to the pipeline safety regulations. The August 2010 Interpretation does not apply to your case, however, because Olin is not operating in-plant piping as a large volume customer receiving gas from a transmission line. In this case, the pipeline in question transports chlorine gas (a toxic and corrosive gas) from the Olin manufacturing facility to the Wacker transmission line. The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.#

Page 22 Part 192 prescribes minimum safety requirements for pipeline facilities and the transportation of gas, including pipeline facilities and the transportation of gas within the limits of the outer continental shelf ( 49 CFR 192.1 ). In-plant pipelines that are involved in the transportation of gas are subject to the Part 192 regulations. It is the opinion of this office that the Olin owned and operated 5,240-foot pipeline line is involved in the transportation of gas and is subject to the regulations in 49 CFR Part 192. Ifwe can be of further assistance, please contact Tewabe Asebe at 202-366-5523. Sincerely, . Gae Director, Office of Standards and Rulemaking (' The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the fonn of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how·to comply with the regulations.#

Page 3Certified Mail - Return Receipt Requested 7013 2250 0002 2995 4030 Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590 Re: PHMSA Applicability Interpretation Request Olin is requesting a formal interpretive letter on the applicability of the Transportation of Natural and Other Gas by Pipeline Regulations at 49 CFR Part 192 to Olin's portion of the Olin/Wacker pipeline. The Olin-owned portion of the pipeline is not on and does not cross public property, is owned and operated solely by Olin and is less than one mile in length. PHMSA's Interpretation #PI-09- 0020 (August 11, 2010) appears to indicate that PHMSA elects not to apply the Federal gas pipeline safety regulations to such lines. Olin and Wacker own and operate a pipeline in Charleston, Tennessee that is used to transport chlorine gas from the manufacturer (Olin) to the customer (Wacker). Part of the Wacker-owned portion of the pipeline crosses public land (Old Lower River Road) and is registered as a transmission line. Please see the attached color map of the pipeline (attachment 1), with Olin's portion of the line delineated in green, and Wacker's portion of the line delineated in blue. Also attached is a more detailed diagram of the pipeline (attachment 2). General Description of the Pipeline At Olin's Charleston Facility, gaseous chlorine is transferred to the neighboring Wacker Plant via a 4" diameter, insulated, electrically heat traced, Schedule 80, ASTM A106-B carbon steel transmission pipeline. The entire pipeline is approximately 9965 feet long running from the discharge of either the A or B train compressor on Olin's property to Wacker's HCl burner. Chlorine is not stored between the compressor and burner. Olin owns and maintains the 5240 feet of pipeline on contiguous Olin property, terminating 330 feet north of Old Lower River Road at a manual block valve. Directly upstream of the manual block valve is an automatic shutoff valve that ]l#

Page 4American Chemistry Council Responsible Care ® program and the Tennessee OSHA Voluntary Protection Program. The chlorine piping system was designed, constructed, and operated using Chlorine Institute Pamphlets 6 and 60, the industry standard or "recognized and generally accepted good engineering practice", i.e., REGAGEP. In addition, chlorine monitors are located every 500 feet along the pipeline. Routine visual, external and corrosion pipeline inspections are conducted. If you require further information or have any questions, please contact me at 423-336-4724 or sjcampbell-eckhoff@olin.com. Thank you for your consideration, Stacie Shell-Sikhall Stacie Campbell-Eckhoff Olin Responsible Care Environmental Superintendent Attachments): Attachment 1 - Color Map of the Pipeline Attachment 2 - Detailed Diagram of the Pipeline 2#

Page 5REFERENCE DRAWING - INSTRUMENTATION SYMBOL CL 2 HEAT TRACE PANEL 65701) NOTES NOTE 4 CORONATE LOCATING WITH SOO FEET ALONG COS ALARM ON HEAT TRACE FAILURE. VEN IS AND FLANGE 057019) LOCATE NEAR XV-057012 NOTE 5 057-SWTCH FOR REMOTE 1/0 PANEL 057-002. SWITCH FOR REMOTE 1/O PANEL 057024 TEMP DENSITY • 0 - 0 — О - 1057011057017057017 FOI 1057017 PIC 12 2 (06701) FROM A&R TRAIN CHLORINE COMPRESSORS D-6247-050-09-0987 4"х3" MASS 057017 NOTE 3 057012E 4"-CH-050-099118-018-ET-2" CHLORINE TO WACKER INTERLOCK NOTES: 3-CH-057-000116-018 SEE DWG D-6247-050-09-0987 D-6247-050-09-1034 3"-CH-057-000117-018 HYPO No 1/No 2 MIX TANK SEE DWG D-6247-050-09-0991 • BLOWDOWN KNOCKO D-6247-050-09-1034 BY CHRIS WEEKS REASED CORDESIGN - DATE 12-1-14 ROBINS & MORTON power & industrial ADDED INTERLOCK NOTES REV INSIR BUBBLE ADD VALVE REV CONT. TEXT BB 3/6/15 RALEIGH-DURHAM BIRMINGHAM THIS DRAWING CONTAINS PSM CAUTION! DRAWING REINSTATED 2/20/15| VDID DRAWING. SUPERSEDED BY D-9082-157-09-0001 2/6/15 CATERED Alin ICHI ПР-ДІ КАЇЇ БАСТІ ТТУ PROJ. CAR REV. RELEASED FOR DESIGN (PIPE LINE> 11-23-15 APPROVED PIANT ENGINEERING P & I DIAGRAM LINES (CL2 OR S02) CHARLESTON PLANT "A" AND "B" COMPRESSOR DESCRIPTIEN DRAWN DATE CHK'DI APPROVED 12/01/14 PROJECT NO C.A.R. NO. CHLORINE METERING NONE PRAVNG 9082-057-09-0001 REV#