Plant managers across the country are faced with complex safety requirements in the operation of a water treatment plant. Heightened US Environmental Protection Agency (USEPA) requirements are expected when chlorine gas is used as a disinfectant because chlorine is designated as an Extremely Hazardous Substance (EHS) as defined in 40 CFR Part 355. Certain emergency planning activities known as Risk Management (RMP) Studies are also required by federal and many state agencies when chlorine is stored above a certain threshold quantity (TQ). Additionally, the method of storing chlorine will influence the scope and extent of the emergency plan preparation that is required by the RMP regulations. This article discusses the impact of total containment on the preparation of federal RMP studies. It is recommended that state and local regulations be reviewed for additional requirements when preparing emergency plans.
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