Question # 115

115. A covered facility with three establishments exceeds an activity threshold for a listed toxic chemical. The facility has the option to file one form to cover the activities at the entire facility or they may file forms for each of the establishments as long as the threshold determinations and release and other waste management calculations are based on all of the activities at the entire facility. The facility chooses to file separate Form R reports for each establishment. All three of the establishments conduct a threshold activity with the listed toxic chemical. However, one establishment does not release or perform any waste management activities with the listed toxic chemical. Must this establishment also file a Form R or can the facility submit only two Form R reports?
If individual establishments or groups of establishments report separately for one listed toxic chemical, they must report separately all covered activities, releases, and other quantities of the toxic chemical managed as waste. Therefore, if each establishment conducts a threshold activity with the toxic chemical, each establishment is also required to report separately for the toxic chemical even if the establishment had no releases or other waste management activities with the toxic chemical. Such establishments should make certain that they file a complete Form R including reporting the chemical activity information on Part I, Section 3 of the Form.