Question # 123

123. A DOE facility has three establishments (“distinct and separate economic activities [e.g., separate NAICS codes][that] are performed at a single location”). The three establishments are considered one facility for threshold determinations, but are submitting separate Form R reports to report their releases and other waste management activities. A waste containing tetrachloroethylene (TCE) is produced at Establishment A and transferred to Establishment B for waste treatment in a TSCA incinerator. Establishment A has only air releases of TCE. Except for the amount received from Establishment A, Establishment B does not use TCE. How should the tetrachloroethylene be reported if two Form Rs are submitted?
Establishment A should report all releases and other waste management of the TCE up to the point at which the waste TCE was transferred to Establishment B. It would not, however, report the transfer of the TCE to Establishment B. Since there are only air releases of TCE from Establishment A, this establishment would report the amount of air releases in Part II, Section 5 and 8.1 of the Form R. Establishment B should report all releases and other waste management (including incineration) once the TCE is received from Establishment A. Establishment B would report any releases or other waste management in Part II, Sections 5, 6 and 8 of the Form R. The on-site incineration would be reported in Part II, Section 8.6 of Establishment B’s Form R.