1998 EPCRA 313 Q&A, Question # 8

8. A company houses all of its operations including its manufacturing processes in a leased warehouse that is neither contiguous nor adjacent to the facility. In June, it bought a different warehouse and moved the manufacturing operations there. These two locations are neither adjacent nor contiguous. The company did not shut down or close during this time. How should the company make threshold determinations and report for Section 313?
Because the operations were carried out at two distinctly separate, physical sites, the company operated two separate facilities. The owner/operator of the company, therefore, must make threshold determinations and release and other waste management calculations individually for each facility. The company need only file Form Rs for the facility(ies) that exceeded the reporting thresholds during the reporting year. If independently both facilities meet the reporting criteria, the company must submit the appropriate forms for each facility.

Additional Details

Question # 8 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-008 Status Archived
Category 1. Determining Whether or Not to Report: Facility Subcategory 1.A. Types of Facilities That Must Report
Keyword(s) Contiguous/Adjacent, Definition of Facility
Updated Q&A Question Number 32
Prior Q&A [Archived] Question Number 7, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 7, 1997 EPCRA 313 Q&A: Contiguous/Adjacent; Facility-Definition of. 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.