Question # 122

122. A facility consists of many establishments and the operators have chosen to file Form Rs by establishment rather than as a facility. Establishment 1 has a manufacturing process that otherwise uses over 10,000 pounds of a listed toxic chemical. Establishment 1 sends its wastewater to establishment 2, where it is treated. Establishment 2 just treats the toxic chemical and does not use it anywhere else. Since a Form R has to be filed because of establishment 1’s activities, how should the operator of establishment 2 fill out the Form R? Specifically, how should establishment 2 address Part II Section 3 for activities and uses at the facility? How should establishment 2 reflect the releases resulting from the waste treatment?
Since the facility has chosen to report separately as two establishments, rather than not answering that Section of the Form R, EPA recommends that establishment 2 check the block 3.3(c) for otherwise use as an ancillary use. The rest of the Form R can be filled out as if that second establishment had triggered reporting itself. If any further questions were to arise about activities at establishment 2, its required record keeping should indicate that the Form R is for treatment only and reflects releases and other waste management activities transferred to establishment 2 by other establishments.