Question # 121

121. Each establishment of a multi-establishment federal facility files its own Form R for an EPCRA section 313 chemical. The waste that this multi-operation site ships off-site for further waste management is inventoried on an entire facility basis. To report this waste, does each establishment estimate their percentage of the total waste or can one operation report the entire waste?
If individual establishments report separately for one chemical, they must report separately all releases of that chemical. Therefore, in the case cited above, one establishment cannot report the amount transferred off-site for further waste management from the entire facility. Each operation would have to report their percentage of the amount transferred off-site.