1998 EPCRA 313 Q&A, Question # 6

6. A covered petroleum company sends its hazardous waste containing a Section 313 toxic chemical to a land treatment unit by underground pipeline. The petroleum company and the land treatment unit are owned and operated by the same individual. The land treatment unit is not adjacent nor contiguous to the petroleum company, but the petroleum company maintains a 'right-of-way' of the pipe-line. Are these two facilities under EPCRA Section 313?
Since the land treatment unit is not adjacent nor contiguous to the petroleum company and they are connected only by a pipeline, the two are considered two separate facilities with the same owner/operator, even though the petroleum facility controls 'right of way' of the pipeline. However, releases and other waste management activities associated with loading or unloading activities or leaks from a pipeline within either facility would be covered.

Additional Details

Question # 6 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-006 Status Archived
Category 1. Determining Whether or Not to Report: Facility Subcategory 1.A. Types of Facilities That Must Report
Keyword(s) Definition of Facility, Pipeline
Updated Q&A Question Number 27
Prior Q&A [Archived] Question Number 6, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 6, 1997 EPCRA 313 Q&A: Facility; Pipeline. Type of Change: Minor - Minor edits are those edits which only involve non-substantive additions or deletions of words to provide clarity in the Question and Answer. Description of Substantive Edits: NA - NA indicates no substantive edits were made to the original Question and Answer.