1998 EPCRA 313 Q&A, Question # 71

71. If a company has a plant in New Jersey, which processes 15,000 pounds of methanol, and a plant in Texas, which processes the same amount of methanol, do both plants have to report as establishments of a facility?
No. The two processing plants are separate facilities because they are not located within the same, or adjacent, or contiguous physical boundary. Thus, their activities are not additive and neither would report for methanol because the processing threshold of 25,000 pounds has not been met by either facility.

Additional Details

Question # 71 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-071 Status Archived
Category 1. Determining Whether or Not to Report: Facility Subcategory 1.D. Multi-Establishment Facilities
Keyword(s) Facility, Multi-Establishment
Updated Q&A Question Number 111
Prior Q&A [Archived] Question Number 43, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 43, 1997 EPCRA 313 Q&A: Facility; Multi-Establishment. 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.