1998 EPCRA 313 Q&A, Question # 7

7. Two covered bulk petroleum stations owned by the same parent company, but a considerable distance apart from each other, are connected to each other by a pipeline. The parent company has an easement to access the pipeline but the land on which the pipeline rests is not owned by the parent company. The easement only allows the parent company to conduct repairs on a sporadic basis. The parent company has no other rights to the land and does not exert any other control over the land. For the purposes of reporting on the Form R, are the two stations considered two separate facilities?
Yes. Since the two bulk petroleum stations are not contiguous or adjacent properties and are connected only by a pipeline, the two stations are considered two separate facilities with the same owner. The parent company has an easement on which the pipeline is located, but does not control, operate, or own the land on which the pipeline rests to an appropriate degree.

Additional Details

Question # 7 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-007 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 29
Prior Q&A [Archived] Question Number 8, 1998 Newly Added Industries
Prior Source: [Archived] Question Number 8, 1998 Newly Added Industries: Form R; Parent Company. Addendum means that the source of the 1998 Q " A is the Addendum to the Guidance Documents for the Newly Added Industries (EPA 745-B-98-001). 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.