Chlorine Handling Pamphlet 155Ed2-January 2008
Chlorine Handling Pamphlet 155Ed2-January 2008
Chlorine Handling Pamphlet 155Ed2-January 2008
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Table of Contents
1. INTRODUCTION...............................................................................................................1
3. CHLORINE CONTAINERS...............................................................................................7
3.1 General..................................................................................................................7
3.2 Cylinders ...............................................................................................................8
3.3 Ton Containers ......................................................................................................9
3.4 Cargo Tanks (Trailers) ........................................................................................11
3.5 Tank Cars (Rail) ..................................................................................................11
3.6 Stationary Storage Tanks ....................................................................................11
i
7. BUILDING/STRUCTURE CONCERNS ..........................................................................26
8. SECURITY ......................................................................................................................28
12.1 Inhalation.............................................................................................................40
12.2 Contact with Skin.................................................................................................42
12.3 Contact with The Eyes ........................................................................................42
13. REFERENCES................................................................................................................43
ii
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 1
1. INTRODUCTION
1.1 SCOPE
Chlorine is the most widely used disinfectant in water and wastewater treatment plants in
the world. Although sodium and calcium hypochlorites are also used in water and
wastewater treatment, this document deals only with elemental chlorine.
This manual is intended to provide basic information on chlorine safety for treatment plant
personnel. Throughout this text, the reader is referred to other Chlorine Institute (CI)
publications for technical topics requiring detailed explanations of the subject matter or for
subjects of specific interest.
The Chlorine Institute, Inc. (CI) exists to support the chlor-alkali industry and serve the
public by fostering continuous improvements to safety and the protection of human health
and the environment connected with the production, distribution and use of chlorine, sodium
and potassium hydroxides, and sodium hypochlorite; and the distribution and use of
hydrogen chloride. This support extends to giving continued attention to the security of
chlorine handling operations.
Chlorine Institute members are committed to adopting CI safety and stewardship initiatives,
including pamphlets, checklists, and incident sharing, that will assist members in achieving
measurable improvement. For more information on the Institutes stewardship program,
visit the CI website at www.chlorineinstitute.org.
1.4 DISCLAIMER
The information in this pamphlet is drawn from sources believed to be reliable. The Institute
and its members, jointly and severally, make no guarantee, and assume no liability, in
connection with any of this information. Moreover, it should not be assumed that every
acceptable procedure is included, or that special circumstances may not warrant modified or
additional procedures. The user should be aware that changing technology or regulations
may require changes in the recommendations contained herein. Appropriate steps should
be taken to ensure that the information is current, when used. These recommendations
should not be confused with federal, state, provincial, municipal, or insurance requirements,
or with national safety codes.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 3
1.5 APPROVAL
The Institutes Customer Stewardship Issue Team approved Edition 2 of this pamphlet on
January 3, 2008.
1.6 REVISIONS
1.7 REPRODUCTION
The contents of this pamphlet are not to be copied for publication, in whole or in part,
without prior Institute permission.
2.1 USAGE
Chlorine's primary use in wastewater treatment is to disinfect the effluent to protect the
receiving waters. Other wastewater uses include the destruction of hydrogen sulfide, control
of odors, removal of ammonia and ammonia compounds, control of filamentous biomass,
oxidation of organics, and control of filter flies.
The chemical symbol for elemental chlorine is Cl. Chlorine exists as a molecule containing
two atoms, shown chemically as Cl2. Chlorine has an atomic weight of 35.453, a molecular
weight of 70.906, and an atomic number of 17. Some of the physical properties of chlorine
are given in Table 1. While it is not explosive or flammable, as a liquid or gas it can react
violently with many substances. Chlorine is only slightly soluble in water (0.3 to 0.7% by
weight.)
Chlorine gas has a greenish-yellow color. It has a characteristic disagreeable and pungent
odor, similar to chlorine-based laundry bleaches, and is detectable by smell at
concentrations as low as 0.2 to 0.4 ppm. It is about two and a half times as heavy as air.
Consequently, if chlorine gas escapes from a container or system, it will seek the lowest
level in the building or area.
Liquid chlorine is amber in color and is about one and a half times as heavy as water.
Chlorine is seldom seen as a liquid because it boils (converts to a gas) at about -29oF (-
34oC) at atmospheric pressure.
The term dry chlorine does not refer to dry chlorinating chemicals such as calcium
hypochlorite. It refers to liquid or gaseous elemental chlorine with a very low water content
(see CI Pamphlet 100). While dry chlorine reacts violently with some metals, it is not
corrosive to metals such as copper or carbon steel. However, wet chlorine is highly
corrosive to most metals (Section 2.3.5). Chlorine shipped in rail cars, cargo tanks,
cylinders, and ton containers is dry chlorine.
4 PAMPHLET 155
Problems attributable to wet chlorine are usually due to moisture in a system and can result
from poor operating practices at the water or wastewater plant.
Vapor pressures:
at 32F (0C) 53.51 psi (368.9 kPa)
at 77F (25C) 112.95 psi (778.8 kPa)
at 129F (48.9C) 191.01 psi (1,316.8kPa)
Chlorine gas reacts with water to form both hypochlorous and hydrochloric acids (Eq. 1):
Hypochlorous acid dissociates in water to form the hydrogen and hypochlorite ions (Eq. 2):
Hypochlorous acid is the dominant form of chlorine in water up to pH 7.8. A significant percentage
of the chlorine is still in the form of hypochlorous acid even between pH 8 and pH 9 (Table 2). Each
plant must determine the dose and residual needed to achieve disinfection. Hypochlorous acid is
the predominant form of chlorine for disinfection.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 5
pH %HOCL %OCL
One volume of liquid chlorine yields about 460 volumes of chlorine gas. For example, 1
pound or about 11 fluid ounces of liquid chlorine yields approximately 5.4 cubic feet of 100%
chlorine gas when vaporized at normal temperature [70F (21.1C)] and atmospheric
pressure. Therefore, one 150-lb cylinder would completely fill a 10 x 10 x 8-foot room with
100% chlorine gas.
The vaporization of liquid chlorine on skin or clothing may reduce the temperature enough
to cause frostbite (even through high-quality protective clothing), cause the fogging of
protective face masks, or the freezing of footgear to the ground. It is essential to wear the
proper PPE during all routine operations.
Chlorine is an irritant to the eyes, skin, mucous membranes, and the respiratory system.
The primary concern with exposure to chlorine is the respiratory system followed by the
eyes. The impact of exposure to chlorine is both concentration and time dependent. People
with respiratory conditions should inform their doctor that they work around chlorine. Extra
precautions may be necessary. Table 3 summarizes exposure levels and effects on
humans.
6 PAMPHLET 155
As the duration of exposure or the concentration increases, the affected individual may
become apprehensive and restless, with coughing accompanied by throat irritation,
sneezing, and excess salivation. At higher levels, vomiting associated with labored
breathing can occur. In extreme cases, difficulty in breathing can progress to the point of
death through suffocation. An exposed person with a preexisting medical or cardiovascular
condition can have an exaggerated response. Anyone exhibiting these symptoms
should see a qualified healthcare provider immediately as his or her condition is
likely to deteriorate over the next few hours.
Chlorine is only slightly soluble in water, in which it forms a weak solution of hydrochloric
and hypochlorous acids (Eq. 1). Chlorine hydrate, a greenish ice-like substance (Cl2.
8H2O), may form as crystals below 49.3F (9.6C) at atmospheric pressure.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 7
Chlorine hydrate can also form at higher temperatures if the chlorine is at an increased
pressure. These crystals can interfere with the proper operation of chlorination systems.
Below 250F (121C) iron, copper, steel, lead, nickel, platinum, silver, and tantalum are
resistant to dry chlorine (gas or liquid state). At ordinary temperatures dry chlorine reacts
(often violently) with aluminum, arsenic, gold, mercury, selenium, tellurium, tin, and titanium.
Carbon steel ignites at 483F (251C) in a chlorine atmosphere (See CI Pamphlet 164).
Wet chlorine forms acids and is very corrosive to most common metals. Platinum, silver,
and tantalum are resistant to both wet and dry chlorine. Titanium is unique because it is
resistant to wet chlorine but cannot be used in contact with dry chlorine. Experts should be
consulted when dealing with systems using wet chlorine.
Chlorine reacts with many organic compounds. Some of these reactions can be violent or
explosive, including those with oils, greases, solvents, coolants, and other hydrocarbons.
The separation of these materials during storage and use is essential to safety. This is
especially important when new components including piping are added to the chlorine
system. Even thin layers of oils and greases can react violently (See CI Pamphlets 6 and
164).
3. CHLORINE CONTAINERS
3.1 GENERAL
Chlorine is shipped and stored in pressure vessels as a liquefied gas under pressure. While
on-site stationary tanks are used solely for storage, chlorine is commonly transported in
cylinders, ton containers, cargo tanks, and rail tank cars. Cylinders and ton containers have
many handling similarities, but different equipment is needed to deal with emergencies
involving each type of container. Chlorine Institute Emergency Kit and cylinder recovery
vessels are designed to contain most container leaks. These include:
Confusion can be avoided if the term "ton containers" is used and not "ton cylinders".
Chlorine ton containers and cylinders must always be handled with care and should not be
dropped or struck. During transport, containers must be secured to prevent them from
moving. A loading dock or a hydraulic tailgate on the truck should be used when unloading.
A container valve's protective housing and valve outlet cap should be in place when the
container is not in use.
8 PAMPHLET 155
3.2 CYLINDERS
Cylinder valves are equipped with a pressure relief device consisting of a fusible metal plug
in the valve body, located below the valve seat. The fusible metal is designed to melt
between 158F and 165F (70C and 74C) to relieve pressure and prevent rupture of the
cylinder in case of exposure to high temperatures.
Cylinders should always be stored upright. They are stamped near the neck ring area with
the tare weight and the date of the last hydrostatic test. According to U.S. Department of
Transportation [DOT] or Canadian Transportation of Dangerous Goods Regulations,
cylinders must be hydrostatically tested every five years. DOT regulations prohibit the
marring or defacing of these markings. Cylinders must be designed for use with CI Chlorine
Emergency Kit A for Cylinders.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 9
*Heights are to the top of the valve protection housing. The height to the center of the valve outlet is
about 3.5 in. (89 mm) less.
Figure 2 - One Typical Style of a Cylinder Valve (Other Designs May Also be in Use)
Ton containers (Figure 3) are welded steel tanks with a chlorine capacity of 2,000 lb (907
kg) and a loaded weight of as much as 3,650 lb (1,659 kg). They are stamped with a serial
number, the tare weight, and the date of the most recent hydrostatic test. Refer to Table 4
for dimensions and weights.
10 PAMPHLET 155
The heads are either concave or convex and welded to the barrels. The chimes (the steel
wall that extends beyond each head) provide a substantial grip for lifting beams. The
container valves are protected by a removable steel valve protective housing. Ton
containers have two valves and can supply either liquid or gas. When the valves are
properly aligned in a vertical position, the upper valve feeds chlorine gas while the lower
valve feeds liquid chlorine. The container has three fusible plugs in each end that are
designed to melt between 158F and 165F (70C and 74C) to relieve internal pressure.
The CI has developed recommended criteria for ton container valves. This can be found in
an appendix to CI Pamphlet 17. The valve outlet threads are not standard pipe threads. All
ton containers must be able to accommodate the use of the devices in CI Emergency Kit B.
Figure 4 - One Style of a Chlorine Ton Container Valve (Other Designs May Also be in Use)
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 11
Cargo tanks are used to transport chlorine over roads and highways. They have a capacity
of 15-22 tons (13,600 kg-20,000 kg.) Cargo tanks use the same man way and valve
arrangements as rail tank cars (Section 3.5) and are required to have excess flow check
valves under both the liquid and gas angle valves (CI Pamphlet 49).
All chlorine cargo tanks have four angle valves. They also have one safety relief valve
designed to release excess pressure buildup within the tank. They are designed to relieve
pressure at 225 psi (1,551 kPA.) Two of the angle valves are located on the longitudinal
center of the tank. These valves are connected to eduction pipes that run to the bottom of
the tank and are used to unload liquid chlorine. Two angle valves are located on a line
perpendicular to the tank=s length and are connected to the vapor phase. These valves
should never be used for gas withdrawal, but can be used to pressurize the car when
needed to increase the rate of liquid withdrawal. All four valves are equipped with excess
flow valves designed to close at a flow rate of 7,000 lb/hr (3,200 kg/hr).
CI Emergency Kit C is designed for stopping leaks on chlorine cargo tanks and tank cars (CI
Pamphlet 49).
Tank cars for transporting chlorine via railroad have capacities of 55, 85, or 90 tons, and
they may not be loaded in excess of these nominal loading weights. The only opening into
tank cars is through a manway on top, where the valves are enclosed with a steel cover.
All chlorine tank cars have four angle valves. They also have one safety relief valve
designed to release excess pressure buildup within the tank. Two of the angle valves are
located on the longitudinal center of the car. These valves are connected to eduction pipes
that run to the bottom of the tank and are used to unload liquid chlorine. Two angle valves
are located on a line perpendicular to the car's length and are connected to the vapor
phase. These valves should never be used for gas withdrawal, but can be used to
pressurize the car when needed to increase the rate of liquid withdrawal. The liquid valves
are equipped with excess flow valves designed to close at flow rates of 7,000, 15,000 or
32,000 lb per hour. The flow rate is usually stenciled on the side of the car. Unstenciled
cars have 7,000-lb-per-hour valves.
CI Emergency Kit C is designed for stopping leaks on chlorine tank cars and cargo tanks.
For additional recommendations, see CI Pamphlet 66.
For additional guidelines, recommended practices, and other useful information concerning
chlorine tank cars, refer to CI Pamphlets 1, 4, 24 and 66.
Stationary chlorine storage tanks may be found at large capacity treatment facilities. Such
tanks should be designed in accordance with CI Pamphlet 5, which includes a standard tank
car dome assembly (Section 3.5). Local codes should also be consulted.
12 PAMPHLET 155
The U.S. DOT regulates the transportation of hazardous materials, including chlorine.
Applicable DOT regulations appear in Title 49 of the Code of Federal Regulations (49 CFR),
and requires special HazMat and safety permits as of January 1, 2005. In most
circumstances it is preferable to let the chlorine supplier transport the chlorine to each use
site. If this arrangement is not possible, CI Pamphlet 76 contains recommendations on how
to safely transport packaged chlorine. Placards are required for the transportation of any
amount of chlorine. Proper labeling of the container is essential and the correct shipping
papers must be on the vehicle. These requirements, including the correct wording of the
paperwork and labeling, change frequently (Contact the supplier and review 49 CFR to
remain current).
In Canada, you must follow the requirements of the Transportation of Dangerous Goods
Regulations by Transport Canada, covering High Consequence Dangerous Goods.
The DOT and CTDG have specific training requirements for all personnel involved in the
transportation of hazardous materials, from those preparing the paperwork to those loading
and driving the truck (See CI Pamphlet 76).
4.2.1 Cylinders
Ton containers may be lifted by using a hoist of sufficient capacity for the load in conjunction
with a ton container lifting beam (Figure 5). A forklift of sufficient capacity can also be used.
Whether full or empty, ton containers must always be secured to prevent them from rolling.
Warning: An empty ton container may weigh as much as 1,650 lb and can cause severe
injury if not secured (See CI Pamphlet 76).
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 13
The chlorine in cargo tanks can either be unloaded into a permanent storage tank or fed
directly into the process. The storage tank must be on a scale or load cell to make certain
that it can accommodate the entire shipment. A trained driver or operator should make the
connections and monitor the unloading process (See CI Pamphlets 5, 49, and 57).
Tank cars should be inspected to make certain they are properly placarded and stenciled
with UN 1017. The tank car number and arrival dates should be noted in records kept at the
receiving facility. Cars should be used in the order received. They should not be connected
to a system until unloading time.
Specific DOT rules and CTDG Regulations must be met for placing warning signs, derails,
chocks, and bumpers, as well as for monitoring the unloading. Tank car suppliers should
provide the latest DOT requirements in addition to periodic training on connecting,
unloading, and disconnecting chlorine cars. Extensive training is needed by employees
who work with chlorine tank cars. Automatic or remotely activated valves located on both
sides of the flexible hose or copper loop should be considered to allow operators to quickly
shut off the flow of chlorine in case of a leak (See CI Pamphlets 57 and 66).
When a leak is suspected, it is recommended that ammonia vapors be used to find the
source. When ammonia vapor is directed at a leak, a white cloud will form. To produce
ammonia vapor, a plastic squeeze bottle containing commercial, 26 degree Baume or
stronger, aqua ammonia (ammonium hydroxide solution) should be used. A weaker
solution such as household ammonia may not be concentrated enough to detect minor
leaks. If a wash bottle is used, the dip tube inside the bottle should be cut off so that
squeezing the bottle directs only the vapor, and not liquid, from the nozzle. To prevent
corrosion, liquid aqua ammonia should not come into contact with any metal parts.
14 PAMPHLET 155
Self-contained breathing apparatus (SCBA) and appropriate protective suits are required
(the on-site coordinator decides what level of protection is needed). If chlorine is escaping
as a liquid from a cylinder or a ton container, align the tank so that the leaking side is up. In
this position the chlorine will escape only as a gas, greatly minimizing the leak.
If a chlorine valve is leaking through the valve outlet, install an outlet cap with gasket and
open and close the valve. Sometimes this will clean the stem seat and stop the leak. After
closing the valve, remove the outlet cap and check for leaks. If the leak will not stop, put the
outlet cap back on and notify the chlorine supplier.
When the packing gland is the source of the leak, first close the valve and then tighten the
packing nut. If it still leaks, make sure the valve is closed and retighten the packing gland.
Care must be taken when tightening the packing gland. Over tightening may bind the valve
or strip the threads and it will not close or open. Testing for leakage must be repeated after
every attempt to stop the leak. Fifty foot-pounds of torque on the packing nut should stop
most leaks.
If the source of the leak is at the valve threads, use a crowfoot wrench from the appropriate
Chlorine Emergency Kit to tighten the valve into the container. Care should be taken to
avoid stripping the threads. Do not tighten the valve if its integrity is in question. Application
of other suitable devices from Chlorine Institute Emergency Kits to cap leaks or use of a
cylinder containment vessel may be necessary.
Regular training with an SCBA and the use of appropriate Emergency Kits or cylinder
containment vessels is essential. Comply with all applicable local, state, and federal
regulations relating to both training and response requirements.
Responding to leaks involving tank cars and cargo tanks requires more extensive training
than that needed for cylinder and ton container leaks. Personnel dealing with tank car and
cargo tank leaks must be highly trained and familiar with the various features of these
containers as well as with CI Pamphlets 49 and 66 and the Emergency Kit C. Coverage of
the specific training required is beyond the scope of this pamphlet.
If a leak is found in the pressurized piping system, the chlorine supply to that section of
piping must be shut off, the pressure relieved, and the system purged of all chlorine before
the necessary repairs are made. The system must be purged with a dry, non-reactive gas
before any welding is done. Welding should comply with all applicable codes. Never weld
on or to any chlorine container (See CI Pamphlet 6).
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 15
Chlorine may be stored safely indoors. If stored outdoors, shading from direct sunlight in
warm climates is recommended. Containers should not be stored where they can be
dropped, where heavy objects can fall on them, or where vehicles can strike them. They
should not be stored near elevators, heating, ventilating, or air conditioning systems
because dangerous concentrations of gas may spread rapidly if a leak occurs. Easy access
to containers is important in the event of a leak. Below ground storage must be avoided
because chlorine vapors are heavier than air and will not readily dissipate from low areas in
the event of a leak.
The chlorine storage area must be posted properly with signs in accordance with local
codes and state and federal laws and regulations. Access to storage areas by unauthorized
personnel should be restricted.
Local fire and building codes may dictate the legal requirements for buildings used to store
chlorine. Consult with the local government to determine which code is in effect in the
community where the plant is located and review the code. Any building that will house
chlorine containers or equipment should be designed and constructed to protect all
elements of the chlorine system from fire hazards. Fire-resistant construction is
recommended. Chlorine containers should be segregated from flammable and oxidizing
materials and from materials such as ammonia, sulfur dioxide, hydrocarbons, certain
refrigerants and other materials that are reactive with chlorine. Chlorine cylinders should be
segregated from other compressed or liquefied gases. However, if flammable materials are
stored or processed in the same building, a fire wall that meets the applicable fire and
building code standards should be in place.
Local fire codes and building codes as well as intended use may dictate the legal
requirements for the outside storage of chlorine. Consult with the local government to
determine which code and code year are in effect in the community where the plant is
located and review the code. An outdoor storage area should be clear of trash and debris
so as not to present a fire hazard. In general, it is recommended that overhead shading
from the sun be provided in warm climates. Containers must not be stored in standing
water.
Installations, manned or unmanned, where chlorine is stored or used should have gas
detection equipment to monitor for chlorine releases. Chlorine detectors must be designed
and adequately maintained to warn personnel or to signal a remote, manned location in
case of a leak. Proper maintenance includes a written plan for a regular calibration of the
monitoring equipment, including written documentation of periodic testing.
16 PAMPHLET 155
Chlorine containers should be segregated from flammable and oxidizing materials and from
materials such as ammonia, sulfur dioxide, hydrocarbons, certain refrigerants and other
materials that are reactive with chlorine. Chlorine cylinders should be segregated from
other compressed or liquefied gases.
5. PIPING/FEED SYSTEMS
All chlorine is shipped and stored in pressure vessels as a liquefied gas under pressure,
resulting in the presence of both liquid and gas phases in the containers. Cylinders are
nearly always used to feed chlorine as a gas. Ton containers have two valves and can
supply either liquid or gas. When the valves are properly aligned in a vertical position, the
upper valve feeds chlorine gas while the lower valve feeds chlorine as a liquid (Figure 6).
Cargo tanks and tank cars should only be used to feed liquid chlorine.
In water and wastewater treatment operations, the removal of gaseous chlorine from a
cylinder or ton container is usually controlled by the use of a vacuum-operated, gas feed
chlorinator. A chlorinator is a piece of equipment used to feed chlorine gas into water. The
vacuum is produced by a water-operated venturi that mixes the chlorine with the water and
produces a high-strength chlorine solution. This solution is piped and diffused into the water
or wastewater to provide the required chlorine dosage.
If liquid chlorine is being withdrawn from a ton container, the liquid chlorine must be
converted to a gas by passing through a vaporizer and the resulting gas is fed into the
chlorination system. Chlorinators are designed to handle gaseous chlorine. Liquid chlorine
may damage gas chlorinators.
There are a few major areas of concern for the operation of a gas chlorinator, including the
cleanliness of the chlorine supplied and the safety of the piping system. The quality of the
chlorine is important because the chlorinator feeding the gas has small orifices and fine
control valves that can be clogged or plugged. The operator should make every effort to
ensure that the entire chlorine delivery system is as clean as possible. A chlorinator has a
filter at the inlet of the unit that requires periodic inspection and replacement to maintain
system integrity. The appearance of a film on the gas metering tube is usually an indication
of a problem. If the film is reddish in color, the piping system from the chlorine container to
the chlorinator or the container may contain ferric chloride. This substance forms when
moisture reacts with chlorine inside of a steel piping system.
The container outlet valve is supplied with a valve cap. When the valve cap is removed,
plant personnel should inspect the outlet and remove any foreign material before placing it
in service.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 17
The gas chlorinator is designed to operate only with chlorine gas. Most current gas
chlorinator installations mount directly on the container valve to feed gas from the container.
When installed in this fashion, there is minimal chance of liquid carryover from the
container to the gas chlorinator.
When chlorine containers discharge into a pressure manifold, the gas chlorinator is
connected to the manifold and additional concerns arise. The pressure piping must be
installed so that no liquid chlorine or chlorine liquid droplets can enter the gas chlorinator.
Any liquid chlorine, including droplets, will eventually damage the chlorinator and could
cause serious safety problems. The following are recommendations that will help prevent
this from happening:
1. The container storage room and pressure piping manifold should be kept at a
temperature that will allow the feed rates desired.
2. All gas piping under pressure must be protected from cold drafts (windows, doors,
cellars, etc.) that can cause reliquification, because any liquid chlorine formed will be
carried by the gas stream to the chlorinator.
3. Facilities may need to consider low-level heat tracing for gas pressure piping made
of steel. This may be needed to maintain the temperature above the reliquification
point (See Figure 7). Do not apply other sources of heat to chlorine lines. This
procedure should be reviewed with a person trained in designing or operating
chlorine systems.
4. The addition of drip legs at points of pipeline direction change may be required. The
drip legs, equipped with small pad heaters, can aid in the removal of any liquid
carryover.
18 PAMPHLET 155
6. Slope the gas pressure line downward from the feed equipment toward the chlorine
container.
8. Check for external corrosion of equipment (valves, piping, fittings, etc.), which may
be an indication of internal corrosion.
This section provides basic information about dry chlorine liquid or gas piping systems. (See
CI Pamphlet 6.)
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 19
Dry chlorine is either gaseous or liquefied elemental chlorine with a very low water content.
All chlorine commercially available in cylinders, ton containers, cargo tanks, and railroad
tank cars is shipped as dry chlorine.
In general, ASTM A106 Grade B Schedule 80 seamless carbon steel piping is used when
the process temperature range is -20F to 300F (-29C to 149C). Threaded or socket-
welded construction can be used for pipe diameters of 1 inches or less. Butt-welded and
flanged joints can be used for all sizes of piping. Consult all applicable fire and building
codes regarding the use of welded or flanged joints.
Certain metal piping materials, including titanium, aluminum, gold, and tin, MUST NOT be
used with dry chlorine. Stainless steels are subject to chloride stress corrosion and should
not be used in chlorine service. Even metals considered compatible with chlorine should
never be heated when exposed to or containing chlorine. Many of these metals can burn in
a chlorine atmosphere, releasing heat and metal chloride gases. (Note: iron and steel ignite
with chlorine at about 483F [226C]). In addition, the corrosion rate of steel in a chlorine
atmosphere increases significantly at temperatures above 250F (121C).
Piping systems must be thoroughly cleaned and dried before use (See CI Pamphlet 6).
Information on fittings, flanges, valves, nuts, bolts, flexible connectors, pipe dope and other
fittings used in pressure piping can be found in Pamphlet 6. Lead and asbestos gaskets
have been used. Further information on acceptable gasket materials is in Pamphlet 95.
Refer to Pamphlet 164 for materials compatibility.
Plastic piping must never be used to transport liquid chlorine at treatment plants. Plastic
piping is used only under specific conditions for gaseous chlorine and chlorine/water
solutions after chlorine is injected from the chlorinator, or when the possibility exists for
moisture to enter a system as in a gas chlorinator operation. Treatment plants use plastic
piping primarily for the vacuum piping between the vacuum regulator and the ejector
(injector) or for chlorine/water solution lines from the injector to the feed point. Where
structural considerations are of concern, plastic-lined steel pipe may be required. Unlined
steel cannot be used in a chlorine solution line.
Most fluorocarbon plastic piping is also suitable for use with gaseous chlorine, but it should
be used only under the same conditions as for other types of plastic pipes. Suitable
fluorocarbon plastics include polytetrafluoroethylene (PTFE), perfluoroalkoxy (PFA),
polyvinylidene fluoride (PVDF), and ethylene chlorotrifluoroethylene.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 21
Vacuum chlorinator systems operate under a vacuum that is created by water passing
through a venturi. Many of the chlorinators that mount directly to cylinder and ton container
valves are designed to close and stop the release of chlorine if vacuum is lost. This design
can be a significant safety feature since any loss of vacuum, including a piping leak, will
shut off the gas flow.
Vaporizers (evaporators) are designed to convert liquid elemental chlorine into chlorine gas.
Steam or hot water jackets are used to provide the heat needed for vaporization.
Temperature control is critical. Pressure relief through the use of a safety valve with a
rupture disk is required for vaporizers. Periodic cleaning is necessary and the
manufacturer's recommendations should be followed (See CI Pamphlet 9).
Chlorine systems require an extensive initial test before being placed in service, as well as
periodic pressure testing throughout their service life. Vaporizers and chlorinators should
be tested according to their manufacturers' recommendations. Piping systems should be
tested according to the recommendations in CI Pamphlet 6. Flexible hoses, connectors, or
pigtails should be visually inspected, pressure tested, and replaced according to the
manufacturers' recommendations. Periodic inspection should be part of a preventive plant
maintenance program. Replacement of flexible connectors is recommended annually as a
minimum.
The use of automatic shut-off devices should be considered. These include actuators that
close the container valves as well as separate valves adjacent to or near the container
valves. They can be operated both remotely and by the use of pressure-sensing switches
or chlorine detectors. Such devices exist for all types of North American containers.
The supplier of chlorine and/or the supplier of your chlorination equipment can often help
with understanding the safe operation, service, and maintenance of chlorine gas feed
equipment (chlorinator) at water and wastewater treatment plants. The chemical supplier
may often be a plant operator's first contact when assistance is needed.
22 PAMPHLET 155
6.1.1 Cylinders
Cylinders discharge gas when upright. When connected to the unloading system, the
cylinder must be secured to prevent movement or falling. The use of load cells or scales is
recommended to monitor the contents of the container during unloading.
A yoke and adaptor for use with CGA Connection 820 or 820C (either open or closed yoke)
is the standard connection to the cylinder valve outlet. (See Figure 8) A gasket on the face
of the valve is part of the connection, and a new gasket must be used each time a
connection is made. The CGA Connection 660, which utilizes a threaded union that threads
to the valve outlet, is not recommended for connecting to the cylinder valve.
Valve outlet threads are not standard tapered pipe threads and, therefore, are not suitable
for use with standard pipe fittings.
A flexible connection should be used between the cylinder and piping system. Annealed
copper tubing suitable for brazing is recommended. ASTM Specification B-88 is
recommended provided the material furnished is of the proper dimensions. As an
alternative, certain types of nonmetallic and metallic hoses are acceptable. The connection
should be regularly inspected and replaced when deterioration is evident. It is very
important to follow the recommendations on flexible hoses found in CI Pamphlet 6.
Chlorine may be discharged as a liquid or a gas from ton containers. Ton containers are
unloaded from a horizontal position, with the two discharge valves aligned vertically. The
upper valve discharges gas and the lower valve discharges liquid chlorine. Containers
should be held in a cradle or firmly secured to prevent rolling. A cradle with rollers makes it
easy to rotate the container so that the two discharge valves are aligned vertically.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 23
Ton containers use a valve similar to the cylinder valve. The major difference is the lack of a
fusible plug in the valve body. The Institute recommends the use of the yoke and adaptor
(CGA Connection 820 or 820C) as the standard connection to the container valve outlet. A
gasket on the face of the valve is part of the connection, and a new gasket must be used
each time a connection is made. The union threaded connection (CGA Connection 660) is
not recommended for connecting to the unloading valve. Valve outlet threads are not
standard tapered pipe threads. A flexible connection must be used between the ton
container and piping system (Section 6.1.1).
For vacuum regulators mounted to cylinders or ton containers, follow the manufacturers
procedures for connecting and disconnecting to the system. Otherwise, proceed according
to the following subsection:
The cylinder or ton container must be secured properly. When connecting to the cylinder or
ton container valve, the following precautions should be taken:
Wear or equip yourself with the proper personal protective equipment (Section 8.2).
Make certain that the packing nut is at least hand tight; if it is not, contact your
supplier for advice.
Make certain that the valve is closed before removing the outlet cap.
Remove the valve outlet cap. Note that for ton containers with valves vertically
aligned, the upper valves dispense gas and the lower valves dispense liquid.
Use a new appropriate ring gasket to connect the yoke and the yoke adaptor to the
valve. Never reuse gaskets.
Using a wrench (50 ft/lbs maximum torque)/no longer than 8 inches, open the
container valve to briefly introduce chlorine into the system and then close the valve.
Never use an extension (cheater) bar on the wrench.
Using only vapor from a 26 degree Baume or greater, aqua ammonia (ammonium
hydroxide) solution (Section 4.3.1), test the yoke adaptor interface and the packing
gland area for leaks. If any leaks are found, they must be remedied before
proceeding (Subsection 4.3.1.1). Repeat this step if a leak was found.
Using a wrench no longer than 8 inches, open the valve one complete turn. This is
all that is required to achieve maximum gas flow rates.
24 PAMPHLET 155
Check again for leaks using only the vapors from an ammonia solution.
Extreme caution must be exercised when disconnecting cylinders or ton containers that are
not empty (If systems are equipped with automatic switch-over vacuum regulators, consult
the manufacturers literature for connection and disconnection procedures). This is
especially critical in systems feeding liquid chlorine. Proceed with care as follows:
Wear or equip yourself with the proper personal protection equipment (Section 9.2).
Using a torque wrench, close the cylinder or ton container valve to a torque of 25 to
30 foot pounds.
Let the pressure in the system drop to 0 psig by using the gas feed equipment to
consume any residual chlorine, and apply a vacuum as appropriate for your systems
design. When gauges indicate 0 psig or a vacuum, the appropriate piping system
valve can be closed.
If any leaks exist (the pressure increases in the line by the container), increase the
torque to 40 foot pounds and retest for leaks. If the leak persists, use a maximum of
50 foot pounds of torque on the stem and repeat the above procedure.
If the valve still leaks at 50 foot pounds, contact your supplier for advice.
If the pressure in the line connected to the cylinder or ton valve remains constant at
or below 0 psig, the yoke can be loosened and disconnected.
Verify that an outlet gasket is in place and replace the valve outlet cap.
Protect the yoke adaptor and chlorine line from the intrusion of moisture and moist
air.
Place a valve hood or bonnet on the cylinder or ton container as appropriate and
mark as empty.
Place the cylinder or ton container in an appropriate location for empty containers.
Chlorine tank cars must never be connected or unloaded by anyone not thoroughly trained
about chlorine, the design of the car, and the unloading system. Each organization should
have its own training program that covers these items. Pertinent details are beyond the
scope of this document. See CI pamphlets 49 and 66. The chlorine supplier also can
provide help with the training of personnel responsible for connecting to and unloading
chlorine from a tank car or a cargo tank.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 25
Opening the angle valve too quickly or allowing unusually high flow rates will cause the
excess-flow valve to close. If this occurs, the angle valve should be closed and left closed
until the metal ball in the excess-flow valve drops back into place with an audible click. If the
ball does not fall into place, contact your chlorine supplier for advice. When unloading
chlorine, the angle valve should be completely open and never used to control flow rate.
Automatic shut-off systems should be considered and may be required by local codes and
regulations (CI Pamphlet 57).
A graph that shows the relationship between the chlorine vapor pressure and the
temperature of the liquid chlorine is illustrated in Figure 7. From this figure it can be seen
that the vapor pressure increases significantly as the chlorine temperature rises.
Consequently, chlorine flow rates also can vary greatly depending on the temperature of the
liquid chlorine.
It is possible that at very low temperatures a pressure gauge might read zero PSIG and
indicate that a chlorine vessel is empty when, in fact, the chlorine vapor pressure is low due
to the low temperature of the residual liquid chlorine in the container. A similar situation can
occur if chlorine gas is withdrawn too quickly from cylinders and ton containers.
The remaining liquid chlorine can be cooled by the evaporating gas and result in reduced
vapor pressure.
Tank cars and cargo tanks may need to be padded (CI Pamphlets 49 or 66) with oil-free dry
air or nitrogen with -40F (-40C) dew point or lower to maintain acceptable unloading rates.
If a tank car is padded and the liquid is piped to a vaporizer (evaporator), care should be
taken in the vaporizing operation. This false high pressure will require more heat to raise the
liquid temperature to the boiling (vaporizing) point. Liquid carryover could result. Warning:
Air padding is not an acceptable practice for unloading cylinders and ton containers.
Chlorinator manufacturers use the approximation that cylinders of chlorine can be unloaded
as a gas to a vacuum system at a continuous rate of 1 to 1.5 lb/day/F of ambient
temperature. For example, a vacuum system at 70F (21C) ambient temperature can
achieve a feed a rate of 70 to 105 lb (32 to 48 Kg) per 24 hours. Higher rates can be
achieved for short periods of time, but the rate decreases as the vaporization cools the
remaining liquid chlorine.
The dependable continuous discharge rate of liquid chlorine is at least 400 lb/hr (181 kg/hr)
at 70F (21C) and against a discharge line pressure of 35 psi gauge (241 kPa).
The maximum flow for unloading cargo tanks and tank cars is determined by the rating of
the excess flow valves. Cargo tanks are equipped with excess flow valves under all four
angle valves. The liquid excess flow valves are rated at 7,000 lb/hr (3,200 kg/hr). Any
instantaneous rate exceeding this value will seat the excess flow valve and stop the flow.
(CI Pamphlet 49).
Tank cars are equipped with excess flow valves under the two liquid angle valves located
on the longitudinal center of the car. They can be rated at either 7,000 lb/hr (3,200 kg/hr) or
15,000 lb/hr (6,800 kg/hr). While large-scale users may need to connect to both liquid
valves for unloading, it is unlikely that a treatment plant would need to do this (CI Pamphlet
66).
7. BUILDING/STRUCTURE CONCERNS
Local fire and building codes may dictate the legal requirements for buildings or other
structures used to store or feed chlorine. Consultation with local government officials to
determine what code and code year applies is essential. Buildings in which chlorine is
stored should be made of noncombustible materials and should be free of flammable
materials. Any building housing chlorine equipment or containers should be designed and
constructed to protect all elements of the chlorine system from fire hazards.
If flammable materials are stored or processed in the same building, a fire wall should be
erected to separate the chlorine from the flammables. Fire-resistant construction is
recommended.
Chlorine is not classified as a flammable gas; therefore, no special code requirements exist
with regard to electrical systems. However, chlorine gas is extremely corrosive and, in the
event of a leak, the electrical system at a chlorine facility could be damaged by corrosion.
7.3.1 Ventilation
Safeguards should be in place to ensure that personnel without the appropriate personal
protective equipment do not enter or remain in buildings where chlorine is present due to
the potential of a leak or equipment failures.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 27
Chlorine gas is heavier than air and will collect at floor level. The exhaust air intake should
be located at or near floor level. The exhaust air discharge should be at a safe location. An
elevated fresh-air inlet must be provided and should be positioned for adequate cross
ventilation. Multiple fresh-air inlets and fans may be necessary to facilitate adequate
ventilation. Fans, if used, should be operable from a safe remote location.
7.4 HEATING
Rooms in which chlorine containers are stored should be maintained at a normal indoor
temperature of 60 to 70F (15 to 20C) to facilitate gas discharge rates from the
containers. The chlorination equipment should be housed in a room at the same or higher
temperature. However, the temperature in chlorine use and storage areas must never
exceed 130F (54C).
Local fire and building codes should be consulted to determine if scrubber systems are
required. Scrubbers are devices that remove chlorine from the air, and they are effective for
containing chlorine releases.
Automatic actuators or valves can be located on or next to the cylinder or ton container
valve. They can be activated by a chlorine detector, fire alarm, seismic detector, or by a
remote switch. Automatic closure devices are now cited in I.C.C. and NFPA Fire and
Building Codes.
The Chlorine Institute does not recommend sprinklers for chlorine storage or use areas that
are constructed of noncombustible materials and that are always free of flammable
materials; however, some fire and building codes may still require them. If sprinklers are
installed, they should be used only to suppress fires or to cool containers threatened by fire.
Sprinklers are not effective in mitigating a chlorine leak or in serving as scrubbers. The
presence of water (moisture) and chlorine can cause corrosion and exacerbate a leak.
Exits should be clearly marked. All exit doors should open outward to the outdoors and
should be equipped with anti-panic hardware that allows for easy opening. Internal exit
doors are not recommended. Each room should contain at least one window so the interior
can be viewed without entering the building. All windows should be made of fire-resistant,
non-shattering material. Local fire and building codes also should be reviewed.
28 PAMPHLET 155
Installations using or storing chlorine should have gas detection equipment in place to
monitor for chlorine releases. Such equipment is particularly important when the facility is
not staffed twenty-four hours a day. Chlorine detectors must be designed and adequately
maintained to warn on-site personnel or to alert responders at a remote location of a
release.
If the monitors are being used for leak detection as opposed to monitoring for Occupational
Safety and Health Administration (OSHA) exposure limits (CI Pamphlets 1 or 65), different
alarm settings may be required. Pertinent information should be available from the
manufacturer of the detection equipment (CI Pamphlet 73).
8. SECURITY
9.1.1 General
It is the responsibility of employees to carry out correct operating procedures safely and to
properly use the safety equipment provided. The Chlorine Institute maintains numerous
publications and other materials to aid end users in the development of meaningful training
programs. See the Chlorine Institute Catalog for a complete listing.
OSHA regulations define the training requirements for emergency response personnel. The
regulation identifies several training levels according to the emergency response task, each
having minimum training requirements (See 29 CFR, 1910.120).
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 29
In addition to the OSHA training, at a minimum, chlorine employee training should include
the following subjects:
Suppliers are responsible for providing material safety data sheets (MSDS) that contain a
detailed assessment of chemical characteristics, hazards, and other information relative to
health, safety, and the environment. These sheets provide the following information:
Physical data on boiling, freezing, and melting points, specific gravity, solubility, and
vapor pressure.
Work practices, such as handling and storage procedures, normal cleanup, and
waste disposal methods.
Emergency procedures for handling spills, fires, and explosions, as well as first-aid
procedures.
30 PAMPHLET 155
Such basic vital information must be readily accessible to all employees as a reference
source.
Some chlorine suppliers have technical expertise and equipment that can be made
available to a customer during an emergency. The availability of such emergency
assistance should be ascertained before you begin handling chlorine. If additional help is
needed contact Chemtrec at 1-800-424-9300 (see Table 5 for Canada, Alaska and Hawaii.)
Chemtrec will activate CHLOREP if needed.
The Chlorine Institute maintains training materials and other publications that may be found
in the Chlorine Institute Catalog, which organizes subjects into industry specific sub-
categories such as the Water and Wastewater industry (See Section 13.1.).
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 31
Employees with respiratory diseases or reduced respiratory capacity should avoid working
in situations where chlorine exposure is possible. Chlorine users should adopt a medical
surveillance program suitable to their needs (See CI Pamphlet 63).
32 PAMPHLET 155
9.2.1.1 Clothing
All personnel entering areas where chlorine is stored or handled should carry or have
immediately available an escape-type respirator. Chemical cartridge or full-face canister gas
masks offer adequate temporary protection provided the oxygen content in the air is greater
than 19.5% and the chlorine concentration does not exceed the rated capacity of the
respirator. The need to protect the eyes from chlorine should be part of the evaluation of
appropriate respiratory equipment.
Fit testing and regular maintenance programs for respirator equipment are required and
must be documented (29 CFR 1910.134(f) and Appendix A, (h) and (m)) (See CI Pamphlet
65).
This section addresses only the need for personal protective equipment (PPE) in connection
with initial line breaks and the routine operations of unloading containers performed by
treatment plant personnel. Emergency response operations are covered in Section 9.
It is assumed that the facility has performed a detailed job safety analysis of the specific
task being performed. If an analysis concludes that a lower level of PPE is adequate for the
employee(s) performing the operations, such lower level PPE must be fully compatible with
these recommendations.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 33
A line break is defined as the opening of a line, section of a line, a vessel, or other
equipment that contains or previously contained chlorine and includes equipment that was
returned to chlorine service and is reopened to the atmosphere. An initial line break is
considered a maintenance activity and does not include the act of connecting or
disconnecting containers for loading and/or unloading purposes or material sampling
activities.
For line breaks that have been routinely performed in the past, and have demonstrated that
the evacuation techniques and maintenance procedures utilized do not result in chlorine
concentrations that exceed either the OSHA ceiling limit or the safety rating of the
respirator, then the following PPE recommendations apply (See CI Pamphlet 65):
If testing or evaluation work has not been performed, or if performed with results that show
chlorine levels exceeded the safety rating of the respirator, then these recommendations
apply (See CI Pamphlet 65):
An emergency eyewash and a deluge shower should be located near the potential exposure
site but not so close as to be unusable in an emergency. The path to the unit must remain
clear of all obstructions. There are OSHA standards that define eyewash/safety shower
parameters, i.e., flow rates and temperature along with other considerations such as
protection against freezing (29 CFR 1910.151(c)).
10.1 PLANNING
The presence and use of chlorine can be a potential hazard to both facility employees and
the surrounding community. In recognition of this potential, federal law and many state laws
require that written emergency plans be developed to prevent, mitigate, and guide response
to a chlorine release. There are at least two planning efforts required for each water or
wastewater treatment facility: one that addresses protecting the community from a chlorine
release and one for protecting employees.
Before an emergency plan is written, a risk assessment for the facility is recommended. A
risk assessment is the process of collecting and analyzing information in order to determine
what chemical hazards and process risks are present at a facility that could impact
employees or the public. Sites with more than 1,500 lb of chlorine in a single process are
required to do a risk assessment under the Process Safety Management (PSM) regulations
stipulated by OSHA in Section 1910.119 of 29 CFR (Appendix C). The Environmental
Protection Agency (EPA) requires a risk management plan (RMP) for sites where chlorine
exceeds 2,500 lb in a single process, as given in 40 CFR 68 (Appendix D).
At the time this document was published, there were two generic RMPs involving chlorine
that could provide information useful in preparing plans suited to specific facilities. One,
designed for treatment plants, was prepared by the EPA and the Research Foundation of
the American Water Works Association (AWWA), The Risk Assessment Methodology for
Water Utilities (2003). The other, available from the Chlorine Institute (CI Pamphlet 162),
applies to chlorine packaging plants and sodium hypochlorite manufacturers. These plans
can assist in preparing RMP plans for treatment plants.
RMP planning must include consideration for monitoring, detection, and alarm equipment.
Selection of the appropriate emergency personnel, assignment of responsibilities, quantity
release estimate, mutual assistance (supplier, hazardous materials [HAZMAT] teams, fire
departments, etc.), necessary notification requirements (facility and off site), decision
making, first-aid needs, and containment should be covered in a set of procedures included
in the written plan.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 35
Emergency response procedures are concerned with the efforts of employees from outside
the immediate release area or by other designated responders in dealing with an
occurrence that results, or is likely to result, in an uncontrollable release of a hazardous
substance. Responses to incidental releases of hazardous substances where the substance
can be absorbed, neutralized, or otherwise controlled at the time of release by the
employees in the immediate release area or by maintenance personnel are not considered
to be emergency responses (29 CFR 1910.120).
The procedures established should outline the proper coordination and communication
between plant personnel, their plant management, and outside agencies. Community
response personnel must include fire department, police department, emergency medical
personnel, and HAZMAT teams at the least. State or local regulations may have additional
requirements.
Each treatment plant should develop its own emergency action checklist, which should be
readily available for facility personnel to aid in response. Table 5 lists typical key actions
that are to be taken in the event of a chlorine emergency. It should be considered as a
guide to aid the treatment plant operator. More detailed assistance is available from OSHA,
EPA, and state regulatory agencies.
Assistance and information during the planning process is available from your chlorine
suppliers and CI Pamphlet 64. In an emergency situation, responders should be called in
the order dictated in your emergency response plan (ERP). These may include the fire
service, your chlorine supplier, or another local emergency response team. If you cannot
obtain assistance during an emergency, you can contact Chemtrec by calling the toll-free
number on your shipping papers (see Table 5). Chemtrec is primarily designed to assist in
transportation emergencies and should be used in other situations only as a last resort.
10.3 TRAINING
Training programs and materials are available from a variety of sources, including chlorine
suppliers, state and local government agencies, and organizations such as the CI, AWWA,
WEF, and NFPA. The best starting point for identifying training resources is the local
emergency planning committee (LEPC) for your area (Contact your State Emergency
Response Commission for LEPC information) as well as your supplier. (See CI W-Video.)
36 PAMPHLET 155
Treatment plant employees should be trained in the emergency response plan, in safety
procedures for the handling and use of chlorine, and in the use of self-contained breathing
apparatus and other applicable equipment. The training requirements depend on the
specific employee's roles and responsibilities. Each plant should have a training program
customized to its specific needs depending on the type of facility, type and number of
chlorine containers, and number of employees. The site should keep written documentation
of all training.
Emergency responder training requirements are based on the response level (Table 6) and
type of job responsibility assigned to each responder. The following list includes the various
response levels of those who may be present at the site of an emergency, and brief
descriptions of their responsibilities:
First Responder, Awareness Level: Persons who, in the course of their normal
duties, may be first on the scene of an emergency involving a hazardous substance.
They are expected to notify the proper authorities as indicated in the plant's
emergency response plan and take no further action.
Hazardous Materials Specialist: Persons who respond with and provide support
to hazardous materials technicians. Their duties parallel those of the technicians but
require a more specific knowledge of the various substances they may be called on
to contain. The specialist also may act as the site liaison with federal, state, local,
and other government authorities regarding site activities.
On-Scene Incident Commander: The person who is responsible for directing and
coordinating all aspects of a hazardous incident.
Specialist Employees: Persons who, in the course of their regular job duties, work
with and train in the hazards of specific hazardous substances, and who may be
called on to provide technical advice or assistance.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 37
It is beyond the scope of this pamphlet to provide the details of a training program for
emergency responders; however, a summary of the training requirements is given in Table
6. Actual training requirements for each level of responder are given in 29 CFR 1910.120.
Because these regulations change, you should review 29 CFR periodically.
An effective way to determine the adequacy of a treatment plant emergency plan is to have
periodic audits and exercises. Audits should be performed with various facility response
personnel to test their knowledge of duties and equipment, along with periodic auditing on
actual use of the equipment. Exercises should be conducted to test the participants'
reactions and effectiveness in implementing the emergency plan as well as to test the actual
mechanics of the plan.
There are basically three types of exercises: the full-scale exercise, the in-plant exercise,
and the table-top exercise. Consideration should be given to conducting full-scale exercises
utilizing responders from the community at least once a year. Periodic in-plant exercises
should use different simulated events and involve as many of the various personnel as
possible. These exercises should be conducted similarly to full-scale exercises but would
not involve outside emergency personnel.
38 PAMPHLET 155
Table-top exercises should be conducted periodically to check the ability of the emergency
response crews to analyze an event, communicate effectively to outside emergency
response personnel, and respond to unfolding events. This type of exercise is usually
conducted with just the supervisors of key emergency response personnel, both in-plant
and from outside agencies.
Following any of the exercises, a critique should be made to assess the effectiveness of the
plan and to pinpoint any weaknesses in it or in the training and knowledge level of the
personnel involved. A written report of the exercise should be available for review and the
facility's emergency plan should be modified as needed.
11.1.1 General
Chlorine gas is primarily a respiratory irritant. At low concentrations chlorine gas has an
odor similar to household beach. As the concentrations increase from the level of detection
by smell, so does symptomatology in the exposed individual. At chlorine concentrations
above 5 ppm the gas is very irritating, and it is unlikely that any person would remain in
such an exposure for more than a very brief time unless the person is trapped or
unconscious. If the symptoms persist for more than a few hours, the effects of exposure to
chlorine may become more severe for several days after the incident. In such cases,
observation of exposed individuals should be a part of the medical response program (See
CI Pamphlet 63 for more detailed information).
The following list is a compilation of chlorine exposure thresholds and reported responses in
humans (with considerable variation among subjects):
0.2 0.4 Odor threshold (decrease in odor perception occurs over time)
1 3 ppm Mild mucous membrane irritation, tolerated up to 1 hour
5 15 ppm Moderate irritation of the respiratory tract. The gas is very irritating, and it is
unlikely that any person would remain in such an exposure for more than a
very brief time unless the person is trapped or unconscious
30 ppm Immediate chest pain, vomiting, dyspnea, cough
40 60 ppm Toxic pneumonitis and pulmonary edema
430 ppm Lethal over 30 minutes
1000 ppm Fatal within a few minutes.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 39
11.2.1 Respiratory/Cardiovascular
The toxic effects of chlorine are due to its corrosive properties. Chlorine is water soluble and
primarily removed by the upper airways. As indicated above, exposure to low
concentrations of chlorine gas may cause nasal irritation as well as irritation of the mucous
membranes of the respiratory tract. As concentrations increase, there is an increase in the
irritating effect on the upper and lower respiratory tract manifested as coughing with
eventual difficulty in breathing. Inhalation of chlorine gas (>15 ppm) may lead to respiratory
distress associated with airway constriction and accumulation of fluid in the lungs
(pulmonary edema).
As the duration of exposure and/or the concentration increase, the affected individual may
develop the immediate onset of rapid breathing, wheezing, rales, or hemoptysis.In extreme
cases difficulty in breathing can progress to the point of death through cardiovascular
collapse from respiratory failure. An exposed person with a pre-existing respiratory
condition can have an exaggerated response. Cases of Reactive Airways Dysfunction
Syndrome (RADS), a chemical irritant-induced type of asthma, have been reported.
11.2.2 Dermal
Liquid chlorine in contact with the skin will cause local chemical or thermal (frostbite) burns.
Gaseous chlorine in contact with the skin can dissolve in body moisture (i.e., perspiration)
to form hypochlorous and hydrochloric acids. At 3,500 ppm chlorine in air, the pH of
moisture on the skin would be approximately 4. A pH of 4 is comparable to carbonated
water. While a burning sensation and skin irritation can occur due to such exposure, a
review of the literature has provided no specific human data to determine the concentration
of chlorine required to produce such effects.
11.2.3 Eyes
Low concentrations of chlorine in the air can result in eye irritation, associated burning
discomfort, spasmodic blinking, redness, conjunctivitis and tearing. Exposure to higher
concentrations of gaseous chlorine may result in more serious injuries. Liquid chlorine in
contact with the eyes will result in serious thermal and/or chemical burns.
Most studies indicate no significant connection between adverse health effects and chronic
exposure to low concentrations of chlorine.
A health video, outlining the short term health effects is available from The Chlorine
Institute. (See H-VIDEO or H-DVD.)
40 PAMPHLET 155
First aid is the immediate temporary treatment given to an exposed individual. Prompt
action is essential. Reassurance to the individual will help to alleviate anxiety. When
indicated, medical assistance must be obtained as soon as possible. Never give anything
by mouth to an unconscious or convulsing person. If chlorine has saturated an exposed
individuals clothes and/or skin, decontamination should be done by removing affected
clothing and showering as appropriate. (See CI Pamphlet 63 for more detailed information.)
Responders should take the necessary precautions to protect themselves from any
exposure to chlorine while administering first aid and should move the victim from any
contaminated area as quickly as possible.
12.1 INHALATION
An individual with chlorine exposure should be evaluated for adequate airway, breathing
and circulation after the inhalation. If breathing has apparently ceased, the victim should be
given cardiopulmonary resuscitation (CPR) immediately. If breathing has not ceased, the
exposed individual should be placed in a comfortable position. The person should sit in an
upright position with the head and trunk elevated to a 45-60 degree position (unless there is
a medical contraindication). Slow, deep breathing should be encouraged. Vital signs
(respiratory rate, pulse, and blood pressure) and oxygen saturation should be obtained if
trained personnel and equipment are available.
Suitable equipment for the administration of oxygen should be available either on site or at a
nearby facility. Such equipment should be periodically tested.
Historically, oxygen therapy, specifically humidified oxygen, has been considered the
primary treatment for chlorine inhalations. Humidified oxygen is preferred since the humidity
soothes the irritation to the mucous membranes caused by the chlorine. Oxygen without
the humidity can have a drying effect, thus potentially aggravating the irritant symptoms.
However, if humidified oxygen is not available, oxygen without the humidity should not be
withheld if oxygen therapy is indicated. With the advance in technology, equipment (pulse
oximeter) is now available which can quickly measure the oxygen saturation in an individual.
This measurement may be helpful in deciding whether supplemental oxygen is needed after
a chlorine inhalation.
Oxygen therapy may not be necessary for all cases of chlorine inhalation. However, in any
case in which an individual with a chlorine inhalation continues to be symptomatic after
leaving the area of exposure, oxygen therapy is recommended unless it can be determined
that it is not needed. The circumstances in which oxygen therapy is not needed should
be defined in advance by a physician, based on the clinical findings and a case by
case determination made by first aid providers specifically trained in this area.
Oxygen should be administered by first aid providers trained in the use of the specific
oxygen equipment under the guidance of a licensed health care professional.
If a pulse oximeter is not available, oxygen therapy is recommended for any individual
who has inhaled chlorine and continues to be symptomatic after leaving the area of
exposure.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 41
If a pulse oximeter is available, the following findings comprise a base list of situations in
which oxygen therapy is generally indicated to be given by first aid providers after a chlorine
inhalation. Other criteria may be added to this list if specifically recommended by a
physician:
The individual is in obvious respiratory distress (including, but not limited to rapid
respirations, difficulty breathing, using accessory muscles for respiration, continuous
uncontrollable coughing, wheezing); or
Not all individuals who have inhaled chlorine require oxygen therapy. It is recommended
that the circumstances in which oxygen therapy is not needed should be defined in advance
by a physician and a case by case determination made by first aid providers specifically
trained in this area.
In situations where it has been determined that oxygen therapy is not needed, but the
individual with an inhalation exposure has irritant symptoms, humidified air may be provided
for symptomatic care. While breathing humidified air, the individual should be closely
monitored for 30 - 60 minutes. If the individual continues to show no signs or symptoms for
which oxygen would be indicated, the humidified air can be stopped. Observation should
continue for an additional 30 minutes while the individual is breathing room air so as to
insure that there is no deterioration of the individual's condition. Oxygen therapy should be
started at any time during the above process if symptoms worsen to the point that oxygen is
indicated. Further evaluation by a physician should be provided in any case in which
oxygen therapy is provided.
42 PAMPHLET 155
Other symptomatic care measures, such as cool compresses to the face and over-the-
counter medications, may help to minimize symptoms. Over-the-counter medications which
may be helpful include:
If liquid chlorine has contaminated the skin or clothing, an emergency shower should be
used immediately and contaminated clothing should be removed under the shower. Flush
contaminated skin with copious amounts of tepid water for 15 minutes or longer. Thermal
burns, due to the cold temperature of liquid chlorine, may be more damaging than any
chemical reaction of chlorine and the skin. Exposure to gaseous chlorine can irritate the
skin. Do not attempt chemical neutralization or apply any salves or ointments to damaged
skin. Refer to a qualified health care provider if irritation persists after irrigation or if skin is
broken or blistered.
If the eyes have been irritated due to exposure to chlorine, they should be flushed
immediately with copious quantities of tepid water for at least 15 minutes.
The eyelids should be held apart during this period to ensure contact of water with all
accessible tissue of the eyes and lids. Medical assistance must be obtained as soon as
possible. If such assistance is not immediately available, eye irrigation should be continued
for a second 15-minute period. Nothing but water should be applied unless ordered by a
qualified heath care provider.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 43
13. REFERENCES
13.1 CI PUBLICATIONS
* The Chlorine Manual, ed. 6; Pamphlet 1; The Chlorine Institute: Arlington, VA, 1997.
Bulk Storage of Liquid Chlorine, ed. 7; Pamphlet 5; The Chlorine Institute: Arlington, VA,
2005.
Piping Systems for Dry Chlorine, ed. 15; Pamphlet 6; The Chlorine Institute: Arlington, VA,
2005.
Chlorine Vaporizing Systems, ed. 6; Pamphlet 9; The Chlorine Institute: Arlington, VA,
2002.
Packaging Plant Safety and Operational Guidelines, ed. 3-R1; Pamphlet 17; The Chlorine
Institute: Arlington, VA, 2002.
Recommended Practices for Handling Chlorine Bulk Highway Transports, ed. 8; Pamphlet
49; The Chlorine Institute: Arlington, VA, 2001.
Emergency Shut-Off Systems for Bulk Transfer of Chlorine, ed. 4; Pamphlet 57; The
Chlorine Institute: Arlington, VA, 2003.
* First Aid, Medical Management / Surveillance and Occupational Hygiene Monitoring
Practices for Chlorine, ed. 7; Pamphlet 63; The Chlorine Institute: Arlington, VA, 2003.
Emergency Response Plans for Chlor-Alkali, Sodium Hypochlorite, and Hydrogen Chloride
Facilities, ed. 6; Pamphlet 64; The Chlorine Institute: Arlington, VA, 2006.
* Personal Protective Equipment for Chlor-Alkali Chemicals, ed. 4; Pamphlet 65; The
Chlorine Institute: Arlington, VA, 2001.
Recommended Practices for Handling Chlorine Tank Cars, ed. 4; Pamphlet 66; The
Chlorine Institute: Arlington, VA, 2007.
* Atmospheric Monitoring Equipment for Chlorine, ed. 7; Pamphlet 73; The Chlorine
Institute: Arlington, VA, 2003.
Guidance on Complying with EPA Requirements Under the Clean Air Act by Estimating the
Area Affected by a Chlorine Release, ed. 4-R1; Pamphlet 74; The Chlorine Institute:
Arlington, VA, 2006.
Guidelines for the Safe Motor Vehicular Transportation of Chlorine Cylinders and Ton
Containers, ed. 4; Pamphlet 76; The Chlorine Institute: Arlington, VA, 2007.
* Recommendations for Prevention of Personnel Injuries for Chlorine Producer and User
Facilities, ed. 4; Pamphlet 85; The Chlorine Institute: Arlington, VA, 2005.
Chlorine Scrubbing Systems, ed. 3; Pamphlet 89; The Chlorine Institute: Arlington, VA,
2006.
Gaskets for Chlorine Service, ed. 3; Pamphlet 95; The Chlorine Institute: Arlington, VA,
2003.
44 PAMPHLET 155
Dry Chlorine: Definitions and Analytical Issues, ed. 3; Pamphlet 100; The Chlorine Institute:
Arlington, VA, 2002.
Generic Risk Management Plan for Chlorine Pkg Plants & Sodium Hypochlorite Production
Facilities, ed. 2-R1; Pamphlet 162; The Chlorine Institute: Arlington, VA, 2004.
Reactivity and Compatibility of Chlorine and Sodium Hydroxide with Various Materials, ed.
2; Pamphlet 164; The Chlorine Institute: Arlington, VA, 2007.
Learning From Experience, ed. 1; Pamphlet 167; The Chlorine Institute: Arlington, VA,
2002.
Instruction Booklet: How to Use the Chlorine Institute Emergency Kit A for 100-lb, and
150-lb. Chlorine Cylinders, ed. 10; Pamphlet IB/AThe Chlorine Institute: Arlington, VA,
2003
How to Use the Chlorine Institute Emergency Kit A for 100-lb and 150-lb Chlorine
Cylinders, Video, ed. 2; A-VIDEO, A-DVD (Spanish: A-VIDEO-S, A-DVD-S); The
Chlorine Institute: Arlington, VA, 1996
Instruction Booklet: CI Recovery Vessel for 100-lb and 150-lb Chlorine Cylinders, ed. 1;
Pamphlet IB/RV; The Chlorine Institute: Arlington, VA, 1992
Instruction Booklet: Chlorine Institute Emergency Kit B for Chlorine Ton Containers, ed.
9; Pamphlet IB/B; The Chlorine Institute: Arlington, VA, 2003
How to Use the Chlorine Institute Emergency Kit B for Chlorine Ton Containers, ed.2; B-
VIDEO, B-DVD; The Chlorine Institute: Arlington, VA, 2006
Instruction Booklet: Chlorine Institute Emergency Kit C for Chlorine Tank Cars and Tank
Trucks, ed. 8-R1; IB/C; The Chlorine Institute: Arlington, VA, 2006
How to Use the Chlorine Institute Emergency Kit C for Chlorine Tank Cars and Tank
Trucks, ed. 1; C-VIDEO, C-DVD (Spanish: C-VIDEO-S, C-DVD-S); The Chlorine
Institute: Arlington, VA, 2005
Health Effects from Short-Term Chlorine Exposure, ed. 1; H-VIDEO, H-DVD; The
Chlorine Institute: Arlington, VA, 1994
Chlorine Safety for Water and Wastewater Operators, ed. 1; W-VIDEO, W-DVD
(Spanish: W-VIDEO-S, W-DVD-S); The Chlorine Institute: Arlington, VA, 1999
Chlorine Emergencies: An Overview for First Responders; DVD; The Chlorine Institute:
Arlington, VA, 2007
Wall Chart: Handling Chlorine Cylinders and Ton Containers (English and Spanish), ed.
2; WC-1; The Chlorine Institute: Arlington, VA, 2001
CI Security Management Plan for the Transportation and On-Site Storage and Use of
Chlorine Cylinders, Ton Containers and Cargo Tanks, August 15, 2003. [Contact CI
Staff]
* A Free Publication: These publications may be downloaded free from CIs website:
www.chlorineinstitute.org.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 45
APPENDIX A
The Emergency Planning and Community Right-to-Know Act (EPCRA) is also known as Title III of
the Superfund Amendments and Reauthorization Act (SARA) of 1986 (42 CFR). Five sections of
this act apply to water and wastewater treatment facilities. They are summarized as follows:
Section 302 requires that any facility having on its premises more than 100 lb of chlorine
must report this fact to the State Emergency Response Commission. This is a one-time
reporting requirement. Other extremely hazardous substances not typically found at
treatment facilities must also be reported.
Section 303 requires that any facility that has reported in accordance with section 302 must
provide to the local emergency planning committee (LEPC) the name of its facility
emergency coordinator who will participate with the LEPC in the emergency planning
process. The facility must also provide to the LEPC any information requested for plan
development and implementation.
Section 304 requires that any facility that releases 10 lb or more of chlorine into the
environment must immediately report the release to the community emergency coordinator,
the state, and the National Response Center. The initial contact of this notification must be
followed-up by a written notification to the same parties. The contents of the notification are
also stipulated in this section. The routine release of chlorine into water and wastewater for
treatment purposes does not have to be reported. Failure to report to the National
Response Center (800-424-8802) in a timely manner (as soon as an RQ is believed to be
exceeded and absolutely within a 24-hour time frame) can result in criminal and civil
penalties. (See CI Pamphlet 64.)
Section 311 requires that any facility having 100 lb of chlorine on its premises at any one
time must submit a material safety data sheet (MSDS) for chlorine, or a list of the hazardous
chemicals, including chlorine, that are on its premises, to the local fire department, the local
emergency planning committee, and the State Emergency Response Commission. If an
MSDS is submitted, it must be resubmitted whenever there is a significant change in it.
Section 312 requires that any facility having 100 lb of chlorine on its premises at any one
time during a calendar year must prepare and submit, before March 1 of the following year,
an Emergency and Hazardous Chemical Inventory Form (either Tier I or Tier II) to the State
Emergency Response Commission, the emergency planning committee, and the local fire
department. This is an annual requirement.
For further information on the EPCRA law, contact your local emergency planning committee of the
State Emergency Response Commission.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 47
APPENDIX B
The following sections of Title 29 of the Code of Federal Regulations (29 CFR) are pertinent to the
operation of facilities utilizing chlorine as part of the process.
Any facility having an extremely hazardous substance, such as chlorine, on its premises must
develop an emergency response plan and train its employees in the implementation of that plan.
Each employer shall develop an emergency response plan that shall address, at a minimum, the
following elements:
Pre-emergency planning and coordination with outside parties. Personnel roles, lines of
authority, training and communication. Emergency recognition and prevention.
Decontamination.
Employers shall provide employee training on the chemical hazards that may be encountered
on the job. The training program must contain the following items:
Information on the location of the facility's emergency response plan and what the employees'
responsibilities would be during an emergency.
Education as to the physical and health hazards of chlorine gas and any other hazardous
material that may be present in the employees' work place.
Procedures that employees can take to protect themselves from health hazards.
48 PAMPHLET 155
Information regarding actions taken by the employer to provide protection, such as emergency
procedures and personal protective equipment, and so on.
Compressed gases shall be stored, handled and used in accordance with generally accepted
standards.
Cylinders, pressure vessels or containers shall be identified as to the gas contained therein.
Compressed gas cylinders in storage or in service shall be secured to prevent falling or being
upset, and shall be protected against tampering by unauthorized persons.
Storage tanks and cylinders located in areas subjected to traffic shall be protected against
vehicle damage.
Compressed gas cylinders when not being used shall have their protective caps in place over
the valve assembly.
In addition to these sections from 29 CFR, you should review the following OSHA regulations
in 29 CFR concerning the specific topics indicated:
APPENDIX C
The Clean Air Act Amendments of 1990 mandated, under the OSHA act of 1970 that a chemical
process safety standard be set to prevent accidental releases of chemicals that pose a threat to
employees. It targets highly hazardous chemicals that have the potential to cause a catastrophic
incident both in the workplace and the surrounding community. As a result, "Process Safety
Management of Highly Hazardous Substances" (29 CFR) covers more than 3 million U.S. workers
at nearly 25,000 sites. Sites with 1,500 pounds or more of chlorine in a single process must comply
with PSM.
Process safety management is the proactive identification, evaluation, and mitigation or prevention
of chemical releases that could occur as a result of failures in process, procedures, or equipment.
The major objective of a chemical process safety program is to prevent unwanted releases of
hazardous chemicals, especially into locations that could expose employees and others to serious
hazards. An effective program requires a systematic approach to evaluating the entire process
including design, technology, operational and maintenance activities and procedures, non-routine
activities, and training programs. A complete process safety management program includes the
following elements:
To control hazards, employers need to develop the necessary expertise, judgment, and proactive
initiative within their workforce to properly implement and maintain an effective process safety
management program as envisioned by the OSHA standard.
The various lines of defense that have been incorporated into the design and operation of the
process to prevent or mitigate the release of hazardous chemicals need to be periodically evaluated
and strengthened to assure their effectiveness at each level.
50 PAMPHLET 155
APPENDIX D
You are covered by the Risk Management Program Rule (RMPR) if you operate a stationary source
and have more than 2,500 pounds of chlorine in a process.
The Environmental Protection Agency (EPA) defines stationary sources as buildings, structures,
equipment, installations, or substances emitting stationary activities that belong to the same
industrial group, which are located on one or more contiguous properties, which are under the
control of the same person (or persons under common control) and from which an accidental
release may occur (40 CFR). The term stationary source does not apply to transportation including
storage incident to transportation of any regulated substance, but it does include transportation
containers used for storage not incident to transportation and transportation containers connected
to equipment at a stationary source for loading or unloading.
This issue is not fully resolved because there is some confusion among several government
agencies over regulating and enforcement authority. However, it is the intent of the EPA to apply
the RMPR to chlorine tank cars and tank trucks unloading or feeding a process at a facility. In
addition, the amount of chlorine in transportation vehicles is an important factor in determining
worst-case and alternate scenarios and complying with other parts of the Rule.
The EPA defines process to mean any activity involving a regulated substance, including any use,
storage, manufacturing, handling, or on-site movement of such substances, or any combination of
these activities. Any group of vessels that are interconnected, or separate vessels that are located
in such a way that a regulated substance could be involved in a potential release, is considered a
single process. The EPA also says that the owner or operator of a facility must make a reasonable
determination as to whether two or more vessels may be involved in the same accident, or whether
a release from one vessel may be likely to lead to a release from another.
To our knowledge, neither the Occupational Safety and Health Administration (OSHA) nor the EPA
has issued guidelines further refining this definition of process. Each individual site must use the
guidelines that are given to determine the number of processes it has. Since the two agencies will
not issue additional guidelines, the Chlorine Institute cannot do so either.
If the RMPR applies to your facility, then you will be required to develop a formal risk management
program and to register and submit a risk management plan (RMP). The regulations apply to 77
toxic substances (including chlorine, anhydrous ammonia, and sulfur dioxide) and 63 substances
that are flammable when certain threshold amounts are met or exceeded in a process. Many of the
requirements are similar to Process Safety Management (PSM) rules developed by OSHA
(Appendix C), but there are important additional requirements.
WATER AND WASTEWATER OPERATORS CHLORINE HANDBOOK 51
The EPA regulations go beyond the PSM rules and require facilities to determine the effect potential
workplace chemical accidents may have in the surrounding community. Also, the EPA rules require
facilities to register and submit certain data about your risk management program to government
agencies and local emergency planning committees (LEPCs), as well as make it available to the
general public.
Note: In addition, the list of chemicals covered and the threshold amounts are different for the PSM
and RMP. It is technically possible to be covered by the PSM but not by the RMP except under the
general duty clause.
Compliance with both the OSHA standard and the EPAs RMP is required by the Clean Air Act
Amendments. Operators who incorporate the stipulations of both sets of requirements will be better
equipped to meet full compliance while enhancing their relationship with the local community.
The deadline for completing all of the elements in the Risk Management Program and for
registering and submitting the RMP is the day you first have a quantity over the threshold in a
process.
1300 Wilson Boulevard Suite 525 Arlington, VA 22209
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Email: pubs@CL2.com Website: www.chlorineinstitute.org
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