Question # 24

24. In Alaska several fish processors have factories on ships. They use ammonia and chlorine in their fish processing operations. Is each ship a covered facility under Section 313 or is the whole group of ships (all of which belong to one company) a covered facility?
A facility is defined as all buildings, equipment, structures, and other stationary items which are located on a single site or adjacent or contiguous sites owned or operated by the same person (40 CFR Section 372.3). A ship is not a facility as defined under the Section 313 regulations. It is not stationary and it is not located on a single site (if it moves to other locations). Therefore, the ships should not report even if they are in a covered NAICS code.

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