8. Two covered bulk petroleum stations owned by the same parent company are connected to each other by a pipeline some distance apart from each other. The parent company controls the easement of the pipeline but the land on which the pipeline rests is not owned by the parent company. 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, even though the parent company controls the easement on which the pipeline is located (see Q#6 and Q#48 of the EPCRA section 313 Questions and Answers Document: Revised 1997 version).