Must the amount of chlorine present in sodium hypochlorite be considered when determining whether a process is subject to the Risk Management Program regulations in 40 CFR Part 68?
No. The risk management program regulations apply only to processes that contain more than a threshold quantity of one of the specifically listed regulated substances in 40 CFR §68.130. Sodium hypochlorite (CAS # 7681-52-9) is not a listed regulated substance. Elemental chlorine (CAS # 7782-50-5) is a regulated substance. If elemental chlorine (or any other regulated substance) is present in a process, the amount of that substance must be considered when determining whether the process is covered. Sodium hypochlorite does not contain elemental chlorine; rather it is a chemical compound comprised of a chlorine ion bonded to an oxygen atom. Therefore, the amount of the chlorine ion present in sodium hypochlorite should not be considered when determining whether a threshold amount of chlorine is present in a process.