A water treatment plant has a chlorine room with two 1-ton (2,000-lb) containers connected to a common manifold and one full 1-ton container stored beside them in the same room, located so that it could be involved in a release from the connected containers. A separate pool-disinfection system in a building one-half mile away holds four 150-lb chlorine cylinders. The 40 CFR 68.130 threshold quantity for chlorine is 2,500 lb. What is the largest quantity of chlorine in a single process that must be compared with the threshold quantity?
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Answer: C
- Process definition (68.3): interconnected vessels, plus separate vessels located so they could be involved in a potential release, are one process.
- Chlorine room: 2 manifolded containers × 2,000 lb = 4,000 lb; stored full container in the same room = 2,000 lb → 6,000 lb.
- Pool building, one-half mile away: 4 × 150 lb = 600 lb, a separate process (also below 2,500 lb on its own).
- Compare: 6,000 lb > 2,500 lb TQ → the chlorine room process is covered by the RMP rule.
2,000 lb: Treats each container as its own process; interconnected vessels and nearby containers that could be involved in a release form one process.
4,000 lb: Counts only the manifolded containers and omits the full container stored in the same room.
6,000 lb: Correct. The two connected containers and the co-located full container are one process: 3 × 2,000 = 6,000 lb, which exceeds 2,500 lb (40 CFR 68.3, 68.115(a)).
6,600 lb: Adds the pool cylinders half a mile away, which are a separate process that could not be involved in the same release.
RMP applicability is decided process by process: sum the maximum quantity in all interconnected and co-located vessels and compare it with the 68.130 threshold quantity.