To: Michelle Walker Owenby

From: Amelia Poe

Background: An explosion occurred at Wacker Polysilicon North America LLC (Wacker) in Charleston
Tennessee at approximately 4:00 PM on September 7, 2017. The facility issued a shelter in place for Wacker
staff. Two employees required minor medical treatment as a result of firefighting activities. Roadways in
close proximity to the plant were closed during the incident and a shelter in place was implemented for the
residents in close proximity to the plant. Wacker environmental staff notified the Division of Air Pollution
Control’s (Division) Emergency Services Coordinator, Robert Brawner, of the incident on September 7, 2017,
and Division Chattanooga Field Office Manager, Amelia Poe, on September 8, 2017. Following the explosion,
the facility suspended operations.

On December 7, 2017, Division Deputy Director Martie Carpenter and Amelia Poe met with Wacker
Environmental Manager Jeremy Copeland and Environmental Engineer Shane Geren on site. Facility
personnel stated that polysilicon production would be suspended and all associated operations would be
shut down for the remainder of 2017 and the start of 2018. The purpose of the visit was to obtain
information on the September 7, 2017 incident to help the Division:

 Evaluate the cause of the event

 Determine emissions resulting from the event

 Identify mitigation that took place during the event

 Evaluate the impact on permitted sources and air pollution control equipment

 Evaluate the facility’s operating status

On March 20, 2018, Division Deputy Director Quincy Styke, Division Enforcement Manager Kevin McClain,
Martie Carpenter, and Amelia Poe met with Wacker Senior Director Timothy Sloan and Jeremy Copeland at
the Chattanooga Field Office. The purpose of this meeting was to obtain additional information on the
September 7, 2017 to help the Division:

 Determine the root cause of the event

 Identify corrective actions Wacker has implemented as a result of the event

 Evaluate the incident within the context of APC rule 1200-03-02-.01(z) (i.e. malfunction)

 Evaluate the incident within the context of APC rule 1200-03-20-.02(1) (i.e. reasonable measures to
minimize emissions)

Division of Air Pollution Control • William R. Snodgrass Tennessee Tower, 15th Floor • 312 Rosa L. Parks Avenue•
Nashville, TN 37214 • Tel: (615) 532-0554 • Fax: (615) 532-0614• http://www.tn.gov/environment/

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Description of the September 7, 2017, event: At approximately 3:47 PM there was an equipment failure
in the T-103 compressor room in the hydrogen recovery building (Building B156). The piston in the #2
cylinder became structurally compromised and allowed hydrogen gas to enter an adjoining variable
frequency drive room. The control room operator stopped the process and halted the flow of process
gasses to the compressor. At approximately 4:00 PM the hydrogen gas that had entered the variable
frequency drive room was ignited by an electrical component and resulted in the explosion and subsequent
fire.

During the event Wacker deployed 3 brigades consisting of 30 Wacker firefighters, Captains and Chiefs, two
fire engines and one turbo fire engine designed to suppress Hydrochloric Acid (HCL). Assets from the
Bradley County Fire Department, Bradley County Emergency Management Agency (EMA), Cleveland Fire
Department, Tri-Community Fire Department, Polk County, Hamilton County EMA, Hamilton County Rescue,
and the Chattanooga Fire Department were utilized during the event. At approximately 4:00 AM September
8, 2017, emergency response activities were completed.

No permitted air sources or air pollution control equipment were involved or impacted in the incident.

The facility reported on September 12, 2017, that the explosion damaged surrounding piping and
equipment resulting in a release of Trichlorosilanes (TCS). TCS converts to HCL when released into the
atmosphere. The reportable quantity under the Emergency Planning and Community Right-To-Know Act
and Comprehensive Environmental Response, Compensation & Liability Act for HCL is 5,000 pounds. It is
estimated that approximately 1,784 pounds of HCL were released during the event.

Wacker conducted on-site and off-site mobile air quality monitoring during the event. Wacker emergency
response staff performed mobile air monitoring on and off site using a Gasmet DX4040R Portable IR
analyzer. The air monitoring data was collected beginning 4:34 PM on September 7, 2017 and continued
through 1:18 AM on September 8, 2017. The air monitoring data reported included measurements for HCL
and TCS along with Carbon Dioxide (CO2 ). HCL is an atmospheric decomposition by-product formed when
TCS is released into the atmosphere along with microscopic crystalline Silicon dioxide. The monitoring data
was distributed to the Division of Air Pollution Control as attachments to three emailed reports identified as
Wacker Air Emissions Monitoring (I), II and III. The monitoring reports included a site designation for each of
the sampling points or locations investigated along with a map identifying the sampling locations and
whether or not the locations were considered to be “on” or “off” site. A compiled table of all of the sampling
results and a location map is included in attachment D of the Wacker Hydrogen Compressor Incident
Report. The measurement data provided by Wacker can be characterized as instantaneous measurements
or snap shots of air quality at ground level.

Data Summary HCL: There were no measurements of HCL reported by the facility that exceeded any
exposure guidance levels. All of the measurements provided by the facility were below the following
exposure guidance levels: AEGL-1 (1.8 PPM 10 Min.), ERPG-1 (3 PPM 60 Min.), NIOSH IDLH (50 PPM 30 Min.),
NIOSH REL (5 PPM 480 Min.) and the OSHA PEL-TWA (5 PPM 480 Min.). It is therefore anticipated that no
known health impacts would be associated with the low HCL measurements observed both on and off site.

Division of Air Pollution Control • William R. Snodgrass Tennessee Tower, 15th Floor • 312 Rosa L. Parks Avenue•
Nashville, TN 37214 • Tel: (615) 532-0554 • Fax: (615) 532-0614• http://www.tn.gov/environment/

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Data Summary TCS: There were 4 measurements reported by the facility in excess of the AEGL-1 TCS
exposure guideline level of 0.60 PPM for 10 minutes observed at offsite monitoring locations. There were 7
measurements reported by the facility in excess of the 0.60 PPM AEGL-1 guidance level observed at onsite
monitoring locations. However, the measurement data reported were not 10 minute averages but
instantaneous measurements collected for extremely short time periods (usually over a few minutes) while
the facility monitoring staff moved from one location to another. There was one measurement reported by
the facility in excess of the 3.7 PPM AEGL-2 (4 and 8 hour exposure guidance level) observed at an onsite
monitoring location. However, the measurement data reported were not 4 or 8 hour averages but
instantaneous measurements collected for extremely short time periods (usually over a few minutes) while
the facility monitoring staff moved from one location to another. There were no reported measurements at
or above the AEGL-3 levels (10 min - 210 PPM, 30 min – 70 PPM, 60 min – 33 PPM, 240 min – 8.7 PPM or 480
min – 8.7 PPM minute averages/concentration level) observed for any instantaneous measurements
collected on or offsite and it is anticipated that no known health impacts would be associated with the low
TCS measurements observed both on and off site.

Assessment of incident cause: The facility hired an independent third party to investigate the incident.
IFO Group conducted the investigation, https://ifogroup.com/. The T-103 compressor was modified in May
of 2017 to change the diameter of the compressor cylinders and pistons from 525 mm to 615 mm to
increase throughput. The piston in the #2 Cylinder of the T-103 Compressor failed after only being in service
127 days. Metallurgical analysis indicated that the #2 cylinder failed due to high cyclic fatigue cracking and
fracturing of the piston face. SGS conducted the metallurgical analysis,
https://www.sgsgroup.us.com/en/industrial-manufacturing/services-related-to-production-and-
products/materials-testing/metal-testing.

Corrective Actions: Following the September 7, 2017 event Wacker suspended polysilicon production and
all associated operations were shut down at the Charleston facility for approximately 9 months. The facility
is in the process of refitting the compressor with the original 525 mm diameter cylinders and pistons. The
facility is implementing enhanced quality control inspections for compressor pistons used in hydrogen
service. The facility is installing additional systems to limit chemical releases. This will include revised shut-
down procedures and possibly additional instrumentations.

Assessment of incident response: Rule 1200-03-20-.02(1) of the Tennessee Comprehensive Rules and
Regulations requires air contaminant sources to take all reasonable measures to minimize emissions during
malfunctions. These measures include alternate control systems, changes in operating methods or
procedures, cessation of operating until the process equipment and/or air pollution control equipment is
repaired, maintaining sufficient spare parts, use of overtime labor, use of outside consultants and
contractors, and other appropriate means.

Wacker’s response to the September 7, 2017 incident and subsequent suspension of facility operations
satisfies the requirements of 1200-03-20-.02(01).

Division of Air Pollution Control • William R. Snodgrass Tennessee Tower, 15th Floor • 312 Rosa L. Parks Avenue•
Nashville, TN 37214 • Tel: (615) 532-0554 • Fax: (615) 532-0614• http://www.tn.gov/environment/

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Conclusion: Rule 1200-03-02.01(z) of the Tennessee Comprehensive Rules and Regulations defines a
malfunction as any sudden and unavoidable failure of air pollution control equipment or process
equipment, or for a process to operate in an abnormal and unusual manner.

The evidence suggests that the September 7, 2017 incident was due to a sudden and unavoidable failure of
process equipment. Because the event meets the definition of a malfunction, and it is unlikely that public
health or the environment were impacted due to the excess HCL and TCS emissions, it is recommended that
no enforcement action be taken for the excess emissions resulting from the event.

Division of Air Pollution Control • William R. Snodgrass Tennessee Tower, 15th Floor • 312 Rosa L. Parks Avenue•
Nashville, TN 37214 • Tel: (615) 532-0554 • Fax: (615) 532-0614• http://www.tn.gov/environment/

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