Question # 337

337. Do we have to count the chlorine in the city water we use? Are water treatment chemicals such as chlorine covered?
You are not required to account for amounts of a listed toxic chemical present in water that you draw into your facility from the environment or municipal sources (40 CFR Section 372.38(c)(5)). For example, chlorine present in water taken from municipal sources does not have to be considered for threshold determinations and release and other waste management estimates. Any chlorine you use to treat process water used in your facility, however, counts toward the otherwise use threshold determination. However, if you use the chlorine to treat drinking water for personal use at the facility the chlorine is exempt under the personal use exemption from threshold and release and other waste management calculations (40 CFR Section 372.38(c)(3)).