United States Solid Waste and
Environmental Protection Emergency Response
Agency
Superfund
&EPA Reporting Requirements for
Continuous Releases of
Hazardous Substances
A Guide for Facilities on Compliance
EPA 540-R-97--047-
OSWER 3360.7-01 A
PB97-963314
December 1997
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United States Office of Emergency and
Environmental Protection Agency Remedial Response
Washington, DC 20460
Superfund
E PA Reporting Requirements for
Continuous Releases of
Hazardous Substances
A Guide for Facilities on
Compliance
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CR-ERNS REGIONAL CONTACTS
EPA Regional Office
State that Reporting Facility
is Located
Contact(s)/Mail Code
E-Mail Address
U.S. Environmental Protection Agency
New England Region 1
5 Post Office Sq., Suite 100
Boston, MA 02109-3912
Connecticut, Maine,
Massachusetts, New
Hampshire, Rhode Island,
and Vermont
Mike Barry/OSRR02-2
barrv.michael(3),epa. gov
U.S. Environmental Protection Agency
Region 2
290 Broadway
New York, NY 10007-1866
New Jersey, New York,
Puerto Rico and the U.S.
Virgin Islands
Neil Norrell/MS211
(needs updating)
norrell.neilfa), eoa.gov
U.S. Environmental Protection Agency
Region 3
1650 Arch Street
Philadelphia, PA 19103-2029
Delaware, Maryland,
Pennsylvania, Virginia, West
Virginia, and the District of
Columbia
Jim Kilpatrick/3HS61
Kilpatrick.Jamesfa),epa.gov
U.S. Environmental Protection Agency
Region 4
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA 30303-3104
Alabama, Florida, Georgia,
Kentucky, Mississippi, North
Carolina, South Carolina, and
Tennessee
Karl Wilson
Wilson.Karlfa),eoa.gov
U.S. Environmental Protection Agency
Region 5
77 West Jackson Boulevard
Chicago, IL 60604-3507
Illinois, Indiana, Michigan,
Minnesota, Ohio, and
Wisconsin
Joseph Solt/SM-5J
Ruth McNamara
solt.i oseohfoieDa. gov
mcnamara.ruth(a),epa. gov
Last update: 09-18-2013
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EPA Regional Office
State that Reporting Facility
is Located
Contact(s)/Mail Code
E-Mail Address
U.S. Environmental Protection Agency
Region 6
Fountain Place 12th Floor, Suite 1200
1445 Ross Avenue
Dallas, TX 75202-2733
Arkansas, Louisiana, New
Mexico, Oklahoma, and
Texas
Steve Mason 6SF-PE
mason. steve(3),epa. gov
U.S. Environmental Protection Agency
Region 7
901 North 5th Street
Kansas City, KS 66101
Iowa, Kansas, Missouri, and
Nebraska
Patricia Reitz
AWMD/CRIB
reitz.Datricia(a),eDa. gov
U.S. Environmental Protection Agency
Region 8
1595 Wynkoop St.
Denver, CO 80202
Colorado, Montana, North
Dakota, South Dakota, Utah,
and Wyoming
Joe Byron
Bvron.i oseDh(a),eDa. gov
U.S. Environmental Protection Agency
Region 9
75 Hawthorne Street
San Francisco, CA 94105
Arizona, California, Hawaii,
Nevada, and the territories of
Guam and American Samoa
Mary Wesling/SFD-9-3
wesling.marv(S),eDa. gov
Suzanne E. Powers
U.S. Environmental Protection Agency
Washington Operations Office
300 Desmond Dr. S.E. Suite 102
Lacey, Washington 98503
Alaska, Idaho, Oregon, and
Washington
Suzanne Powers
Powers. Suzanne®, eoa. gov
Last update: 09-18-2013
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The policies and procedures set forth here are intended as guidance to facilities.
They may not be relied on to create a substantive or procedural right enforceable
by any other person. The Government may take action that is at variance with the
policies and procedures in this manual. This 1997 revised edition of "Assessing
Reports of Continuous Releases of Hazardous Substances - A Guide for Facilities
on Compliance" replaces and updates the October 1990 edition.
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TABLE OF CONTENTS
Pace
BACKGROUND . iv
PART 1: REPORTING REQUIREMENTS FOR CONTINUOUS RELEASES
OF HAZARDOUS SUBSTANCES . 1
1.0 Introduction 1
1.1 CERCLA and EPCRA Release Reporting Requirements 1
1.2 Continuous Releases 3
1.3 Reporting Continuous Releases 6
1.4 Recordkeeping Requirements 9
1.5 EPA's Role in the Continuous Release Reporting Process 12
1.6 Additional Questions 13
1.7 Where to Submit Written Reports 13
1.8 Sources for Further Information 15
PART 2: INSTRUCTIONS AND PROCEDURES FOR CONTINUOUS
RELEASE REPORTING 16
2.0 Introduction 16
2.1 General Overview of How to Report a Continuous Release 16
2.2 Initial Telephone Notification 17
2.3 Initial Written Report and Follow-up Reports 18
2.4 Notifications of Statistically Significant Increases 28
2.5 Reports of Changed Releases 29
2.6 Summary 30
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APPENDICES
Appendix A: Acronyms
Appendix B: Suggested Continuous Release Reporting Format (Blank)
Appendix C: Suggested CR-ERNS Reporting Format—Addendum to TRI Form R (Blank)
Appendix D: Completed Suggested Continuous Release Reporting Format
Appendix E: Completed Suggested CR-ERNS Reporting Format — Addendum to TRI Form R
ii
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LIST OF EXHIBITS
EXHIBITS Page
Exhibit 1-1: Reporting Requirements Under CERCLA Section 103 and EPCRA Section 304 2
Exhibit 1-2: Definitions 4
Exhibit 1-3: Standard Reporting Requirements 6
Exhibit 1-4: Circumstantial Reporting Requirements 8
Exhibit 1 -5: Where to Submit Continuous Release Reports for Releases of
CERCLA Hazardous Substances 10
Exhibit 1-6: Where to Submit Continuous Release Reports for Releases of
Non-CERCLA EHSs 11
Exhibit 1-7: EPA Regional Superfund Offices 14
Exhibit 2-1: Checklist of Information Required in the Initial and Follow-up Written Reports 19
Exhibit 2-2: Sources of Information for Identifying the Location of
Your Facility 20
Exhibit 2-3: Definitions 21
Exhibit 2-4: Estimated Average Stream Flow Rates 24
Exhibit 2-5: Sources of Information for Estimating Average Lake Depth 24
Exhibit 2-6: Normal Range 24
Exhibit 2-7: Examples of Reporting Single Hazardous Substances 25
Exhibit 2-8: Example of Reporting a Mixture 26
Exhibit 2-9: Calculation of the SSI Trigger for a Hazardous Substance 27
iii
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BACKGROUND
The purpose of this document, "Reporting
Requirements for Continuous Releases of Hazardous
Substances - A Guide for Facilities on Compliance"
(Guide), is to help you understand the definitions and
requirements contained in the U.S. Environmental
Protection Agency's (EPA's) Final Rule on "Reporting
Continuous Releases of Hazardous Substances" (55
Federal Register 30166) published on July 24, 1990,
which amended 40 Code of Federal Regulations Parts
302 and 355. The Continuous Release Rule provides a
reduced reporting option for facilities that release
hazardous substances in a manner that is continuous,
and stable in quantity and rate. This Guide has been
designed to provide facilities who choose this reduced
reporting option with the information necessary to
successfully comply with the continuous release
reporting.
The Guide is divided into two pats. Part 1 provides
general information in a question and answer format
regarding the Continuous Release Rule and the
responsibility of the person in charge of a facility to
report releases of hazardous substances. Part 2 contains
detailed instructions on how to prepare continuous
release reports that include all of the information
required to qualify for reduced reporting under the
Rule. Although the Rule applies to both facilities and
vessels, because the reporting elements from vessels are
somewhat different from those of facilities (e.g., vessels
by their nature do not have a set location), this Guide
will only address the reporting requirements for
facilities. Much of the information in this Guide is
applicable to vessels, however, persons in charge of
vessels who wish to report under the Continuous
Release Rule should contact EPA to discuss vessel-
specific requirements in detail.
IV
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PART 1: REPORTING REQUIREMENTS FOR CONTINUOUS RELEASES
OF HAZARDOUS SUBSTANCES
1.0 Introduction
Part 1 of the Reporting Requirements for
Continuous Releases of Hazardous Substances - A
Guide for Facilities on Compliance (Guide) explains the
general reporting (notification) requirements of the
Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA)
and the Emergency Planning and Community Right-to-
Know Act (EPCRA) for hazardous substances, as well
as a number of relevant terms. In addition, it provides
information on what qualifies as a continuous release
under the Rule, and describes the continuous release
reduced reporting requirements in detail, including
how, when, and to whom such releases must be
reported.
1,1 CERCLA and EPCRA Release
Reporting Requirements
Section 103(a) of CERCLA "as amended" and
EPA's implementing regulations (40 Code of Federal
Regulations (CFR) 302.8) require the person in charge
of a facility to immediately notify the Federal
government (the National Response Center or NRC)
whenever a reportable quantity (RQ) or more of a
CERCLA hazardous substance is released unless the
release is federally permitted. The purpose of this
requirement is to notify officials of potentially
dangerous releases so that they can evaluate the need
for a response action. CERCLA hazardous substances
are defined in Section 101(14) of CERCLA and
include over 800 specific CERCLA listed substances
(40 CFR 302.4), as well as, hazardous substances that
have been defined under other statutes.
Likewise, Section 304 of EPCRA (also known as
Title III of the Superfiind Amendments and
Reauthorization Act (SARA)) and EPA's implementing
regulations (40 CFR 355.40) require the owner or
operator of a facility to immediately notify state and
local officials whenever an RQ or more of a CERCLA
hazardous substance is released. These same Sections
also require the owner or operator of a facility to
immediately notify state and local authorities whenever
there is a release of an RQ or more of any of the 356
listed Extremely Hazardous Substances (EHSs);
approximately 222 of these EHSs are not CERCLA
hazardous substances, but are non-CERCLA EHSs.
Notifications under Section 304 of EPCRA must be
given both to the local emergency planning committee
(LEPC) of any area likely to be affected by the release
and to the state emergency response commission
(SERC) of any state likely to be affected by the release.
If the release is located on Tribal lands and a Tribal
Emergency Response Commission (TERC) exists,
notification must be given to the appropriate TERC.
For the purposes of this Guide, all references to
requirements for reporting to SERCs and LEPCs under
EPCRA should be construed to include the same
requirements for reporting to TERCs, if appropriate.
The reporting requirements between CERCLA
and EPCRA are slightly different. These differences
are outlined in Exhibit 1-1 and are reviewed in the
following sections.
What is a facility?
A "facility" is defined under CERCLA to include
any building, structure, installation, equipment, pipe or
pipeline, well, pit, pond, lagoon, impoundment, ditch,
landfill, storage container, motor vehicle, rolling stock,
or aircraft or any site or area where a hazardous
substance has been deposited, stored, disposed of or
placed, or otherwise come to be located. There may be
one or more facilities at a particular site. For example,
a site may be comprised of four facilities including one
building, one lagoon, and two storage containers.
The definition of the term "facility" under
EPCRA differs from the CERCLA definition. Under
Section 329(4) of EPCRA, a facility is defined as aU
buildings, equipment, structures, and other stationary
items that are located on a single site or on contiguous
or adjacent sites that are owned and controlled by the
same person. For emergency release reporting, the
EPCRA definition of facility also includes motor
vehicles, rolling stock, and aircraft.
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EXHIBIT 1-1:
REPORTING REQUIREMENTS UNDER CERCLA SECTION 103 AND EPCRA SECTION 304
CERCLA Section 103
EPCRA Section 304
DeGnition of
a Facility
Defined in Section 101(9) of CERCLA as
including any building, structure, installation,
equipment, pipe or pipeline, well, pit, pond,
lagoon, impoundment, ditch, landfill, storage
container, motor vehicle, rolling stock, or
aircraft on any site or area where a hazardous
substance has been deposited, stored, disposed
of or placed, or otherwise come to be located.
A facility is defined in Section 329(4) of EPCRA
as all buildings, equipment, structures, and other
stationary items that are located on a single site
or on contiguous or adjacent sites that are owned
and controlled by the same person.
Relevant
Chemical List
CERCLA hazardous substances
(40 CFR 302.4)
CERCLA hazardous substances (40 CFR 302.4)
and 356 EPCRA Section 302 EHSs (Appendix A
to 40 CFR 355)
NotiGcation
Requirements
National Response Center (NRC)
SERC(s), LEPC(s), and TERC(s)
Constituents
of a Release
Any release at or above a specified Reportable
Quantity (RQ) into the environment (on-site or
off-site)
Any release at or above a specified Reportable
Quantity (RQ) with exposure to off-site
environment
When does a hazardous substance release occur?
Under CERCLA, a "release" occurs when a
hazardous substance enters the environment. A key
element of the definition of release is the phrase "into
the environment" The environment includes all media:
air, land (surface or subsurface strata), surface water,
and ground water (including drinking water supply).
Examples of hazardous substances released into the
environment include: releases from pipes onto the
ground; releases from stacks into the air; or other
uncontained discharges. If such a release of a
CERCLA hazardous substance occurs in a quantity that
equals or exceeds an RQ in a 24-hour period, it must be
reported immediately to the NRC.
The definition of a release is similar under
EPCRA, however generally EPCRA reporting
requirements do not apply if the release results in
exposure to persons solely within the facility (i.e., site)
boundaries. Releases of CERCLA hazardous
substances and EHSs in quantities that equal or exceed
an RQ must also be reported to the SERC and LEPC.
What is a reportable quantity?
Each CERCLA hazardous substance is assigned
an RQ. When an RQ or more of a CERCLA hazardous
substance is released from a facility during a 24-hour
period, it triggers the reporting requirements of Section
103 of CERCLA. An RQ is not an absolute measure of
the risk associated with the hazardous substance; the
purpose of an RQ is to trigger the reporting of a
hazardous substance release. The actual risk posed to
human health and the environment will vary with the
circumstances of the particular release; many factors
other than the size of the release may influence the risk
and thus the need for a government response. Except
for radionuclides (which are expressed in curies), the
RQ is expressed in pounds (i.e., 1 lb, 10 lbs, 100 lbs,
1000 lbs, 5000 lbs). You can find a list of hazardous
substances and their associated RQs in the CFR in
Table 302.4 at 40 CFR Part 302.
EHSs that are not CERCLA hazardous substances
(i.e., non-CERCLA EHSs) are assigned repotting
triggers (RQs) under Section 304 of EPCRA, RQs for
non-CERCLA EHSs were adjusted on May 7, 1996 at
61 FR 20473 and are in 40 CFR Part 355. EPCRA
2
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Section 304 requires that any release of an EHS that
equals or exceeds an RQ established under either
CERCLA or EPCRA be reported immediately to the
appropriate SERC and LEPC.
How are releases of CERCLA hazardous substances
reported?
Generally, CERCLA Section 103(a) requires the
person in charge of a facility to notify the NRC
immediately if that person has knowledge that an RQ
or more of a hazardous substance has been released
from the facility within a 24-hour period. To determine
whether an RQ or more of a specific CERCLA
hazardous substance has been released within a 24-hour
period, the person in charge must consider the amount
released from all sources at the facility and determine
if together the release of the hazardous substance
equals or exceeds an RQ, For example, if a facility has
three sources, each releasing 1/3 of an RQ of a
CERCLA hazardous substance X over the same 24-
hour period, and the release of hazardous substance X
is not federally permitted, the person in charge must
report that release to the NRC. (The NRC's telephone
number is listed on page 15 of this Guide).
The EPCRA Section 304 reporting requirements
parallel the CERCLA notification requirements, but
apply to the owner or operator of a facility, and are
intended to make release information available
immediately to state and local authorities. For the
purposes of EPCRA, to determine whether an RQ or
more of a CERCLA hazardous substance or EHS has
been released over a 24-hour period, the owner or
operator must consider the amount released from all
sources at the facility and determine if together the
release of the hazardous substance equals or exceeds an
RQ. For example, if a facility has three sources, each
releasing 1/3 of an RQ of a CERCLA hazardous
substance or non-CERCLA EHS X over the same 24-
hour period, and the release of hazardous substance X
is not federally permitted, the person in charge must
report that release to the appropriate SERC and LEPC.
You can obtain the telephone numbers for appropriate
state authorities (SERC) and local authorities (LEPC)
by calling the RCRA/Superfund/EPCRA Hotline. See
page 15 of this Guide for telephone numbers.
The primary reason for these notification
requirements is to alert government officials to releases
of CERCLA hazardous substances and EHSs that may
require a timely response action to prevent or mitigate
damage to public health or welfare or the environment.
1.2 Continuous Releases
What is the continuous release reduced reporting
option?
CERCLA Section 103(f)(2) and EPA's
implementing regulations at 40 CFR Parts 302 and 355,
provide a special reduced reporting option for
"continuous" releases of CERCLA hazardous
substances and EHSs. This CERCLA and EPCRA
reporting relief applies to facilities that release
CERCLA hazardous substances or EHSs that are
"continuous" and "stable in quantity and rate" under the
regulatory definition of 40 CFR 302.8(b). For these
types of releases, reporting facilities can choose either
to: 1) report on a per occurrence basis, or 2) report as
a "continuous" release in accordance with the
Continuous Release Rule, "Reporting Continuous
Releases of Hazardous Substances" (55 FR 30166)
published on July 24, 1990, which amended 40 CFR
Parts 302 and 355.
The purpose of CERCLA Section 103(f)(2) is to
reduce reporting of predicable release notifications.
CERCLA Section 103(f)(2), however, does not
eliminate the requirement to report. Government
response officials need to receive some notification of
each hazardous substance release that equals or exceeds
an RQ on a continuous basis, so that the release can be
evaluated and if necessary, a response action can be
taken.
What is a continuous release?
A "continuous release" is a release of a hazardous
substance that is "continuous" and "stable in quantity
and rate" under the regulatory definitions of these terms
listed in Exhibit 1-2. A continuous release may be a
release that occurs 24 hours a day (e.g., a radon release
from a stockpile) or a release that occurs during a
certain process (e.g., benzene released during the
production of polymers) or a release that occurs
intermittently (e.g., the release of a hazardous
substance from a tank vent each time the tank is filled).
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EXHIBIT 1-2: DEFINITIONS
Continuous. A continuous release is a release
that occurs without interruption or abatement, or
that is routine (i.e., occurs during normal
operating procedures or processes), anticipated,
intermittent, and incidental to normal operations.
Stable in quantity and rate. A release that is
stable in quantity and rate is a release that is
predictable and regular in the amount and rate of
emission.
Some releases resulting from malfunctions may
also qualify for reduced reporting as continuous
releases under Section 103(f)(2) if they are incidental
to normal plant operations or treatment processes, are
stable in quantity and rate, and either (1) occur without
interruption or abatement or (2) are routine, anticipated,
and intermittent. For example, fugitive emissions from
valves that occur at different rates over the course of a
production cycle may be a malfunction that qualifies
for reduced reporting. The determinative question of
whether any release, including a malfunction, qualifies
for reporting under Section 103(f)(2) is whether the
release satisfies the definitions of "continuous" and
"stable in quantity and rate."
Releases must be sufficiently predictable and
regular so that the person in charge, or the owner or
operator of the facility can provide a full description of
the release to government authorities. Upon receipt of
continuous release information, government officials
will evaluate the risk associated with the release and
determine the need for a response action.
Do releases that result from unanticipated events
qualify for reduced reporting as continuous
releases?
Releases of CERCLA hazardous substances that
are the result of unanticipated incidents do not qualify
for reduced reporting under Section 103(f)(2). Such
episodic incidents include spills, equipment failures, or
the emergency shutdown of equipment. Also included
are releases from malfunctions that are not continuous
or stable, such as pipe ruptures. Although these
releases may occur with some regular statistical
frequency, unanticipated incidents by their nature do
not produce releases that are continuous or sufficiently
regular or predictable in quantity and rate to satisfy the
requirements for reporting them as continuous releases.
If you are aware that such an episodic release of a
CERCLA hazardous substance has occurred in a
quantity equal to or greater than an RQ, you must
report the release immediately to the NRC, SERC, and
LEPC.
How do you handle simultaneous continuous
releases from several sources and determine
whether such releases must be reported?
To determine whether a hazardous substance
release is reportable under CERCLA, you must identify
whether the release equals or exceeds an RQ. If your
facility is releasing a hazardous substance from several
sources simultaneously, you must aggregate the
releases of the hazardous substance across all of the
facility's sources to determine whether an RQ or more
of a hazardous substance has been released from your
facility.
If you release an RQ or more of the same
CERCLA hazardous substance from more than one
facility (e.g., building, surface impoundment, or
lagoon), the Continuous Release Rule (40 CFR
302.8(1)) provides you with two reporting options
under CERCLA. To meet the requirements of
CERCLA, you may either: 1) aggregate multiple
concurrent releases of the same hazardous substance
from contiguous or adjacent facilities and report them
in a single notification; or 2) consider releases from
each facility separately and submit separate reports on
a facility-specific basis. Under EPCRA the definition
of facility includes all "buildings, equipment,
structures, and other stationary items that are located on
a single site or on contiguous or adjacent sites that are
owned and controlled by the same person" therefore,
all releases from contiguous or adjacent facilities are,
by definition, aggregated. For the purposes of EPCRA,
these items must be reported as one facility.
Although under CERCLA you may select either
option for reporting continuous releases, whichever
option you select must be used for all continuous
release reporting. For example, if you report releases
on a facility-specific basis, statistically significant
increases (SSIs) in the release must also be reported on
a facility-specific basis. If you select the option of
aggregating releases from contiguous or adjacent
facilities and reporting them in a single notification,
you may have a single SSI trigger for all the releases.
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How do you establish a basis for reporting releases
as continuous?
To qualify a release for reporting as a continuous
release, you must establish a basis for asserting that the
release is continuous and stable in quantity and rate.
The Continuous Release Rule provides you with
flexibility in establishing this basis. You may report
the release to either the NRC (for CERCLA hazardous
substances) or the appropriate SERC and LEPC (for
CERCLA hazardous substances and non-CERCLA
EHSs) on a per-occurrence basis for the period of time
necessary to establish that the pattern of the release is
continuous and stable. However, if you have a
sufficient basis for establishing the continuity, quantity,
and regularity of a release, multiple reports are not
necessary. A one-time telephone call to each of the
appropriate authorities (the NRC, SERC, and LEPC for
CERCLA hazardous substances, or only the SERC and
LEPC for non-CERCLA EHSs) will alert them to your
intent to report the release as a continuous release.
You may establish the pattern of the release by
relying on past release data, engineering estimates,
your knowledge of the facility's operations and release
history, or your best professional judgment.
Monitoring data are not required. Regardless of which
method is used, however, all estimates reported for a
particular release must have a sound technical basis.
The basis for asserting that the release is continuous
and stable in quantity and rate will be included in your
written report.
Are the reporting requirements different under
CERCLA and EPRCA?
The reporting requirements for CERCLA and
EPCRA are slightly different. CERCLA covers only
CERCLA hazardous substances. EPCRA covers both
CERCLA hazardous substances, and EPCRA EHSs
(EPCRA EHSs are made up of some CERCLA
hazardous substances and some non-CERCLA
hazardous substances).
CERCLA hazardous substances must be reported:
1) in accordance with CERCLA, to the NRC; 2) in
accordance with EPCRA, to the appropriate SERC and
LEPC. Those listed EHSs which are also CERCLA
hazardous substances fall under both CERCLA and
EPCRA and must also be reported to the NRC, SERC,
and LEPC.
Non-CERCLA EHSs (those EHSs which are not
covered under CERCLA) are governed by EPCRA and
so must only be reported to the appropriate SERC and
LEPC. The remainder of this Guide will discuss
reporting requirements to the NRC, SERC, and LEPC
in detail, and these requirements will also be illustrated
in several exhibits. However, it is important to
remember that in all cases non-CERCLA EHSs need
not be reported to the NRC.
Exhibit 1-1, on page 2, explains the different
reporting requirements under CERCLA and EPCRA,
including the definition of facility, the relevant
chemical list, notification requirements, and
constituents of a release.
What reporting is required for continuous releases
of CERCLA hazardous substances?
Although Section 103(f)(2) provides for reduced
reporting of continuous releases, it does not eliminate
the need to report such releases. The continuous
release reporting requirements for CERCLA hazardous
substances are described in detail in Section 1.2 -
Reporting Continuous Releases. The different types of
continuous release telephone notification and written
reports are explained more fully on the following
pages. There are three standard reporting
requirements: the initial telephone notification; the
initial written report; and the written first anniversary
follow-up report. In all cases, each facility must submit
these reports. These main reporting requirements are
outlined in Exhibit 1-3 on page 6. In addition to the
standard reporting requirements, there are three
additional reports for special circumstances: a report of
an SSI and two types of reports of changes in
previously submitted continuous release information.
These special reports will only be submitted by those
facilities that encounter these particular situations. The
additional circumstantial reporting requirements are
outlined in Exhibit 1-4 on page 8. Exhibit 1-5, on
page 10, outlines where to submit continuous release
reports for release of CERCLA hazardous substances.
In addition, to help you understand the reporting
requirements of the Rule, Part 2 of this Guide contains
specific procedures and instructions for complying with
the requirements for CERCLA hazardous substances.
What reporting is required for non-CERCLA
EHSs?
Releases of non-CERCLA EHSs may qualify as
continuous releases as long as they satisfy the
regulatory definitions in the Continuous Release Rule.
Therefore, continuous releases of non-CERCLA EHSs
are entitled to reduced reporting requirements under
EPCRA. The continuous release notification
requirements for such releases are slightly different
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EXHIBIT 1-3:
STANDARD REPORTING REQUIREMENTS
The reporting requirements for continuous
releases of CERCLA hazardous substances are:
Step 1 Initial telephone notification to
the NRC, SERC, and LEPC; I
Step 2 Initial written report to the
EPA Regional Office, SERC, and
LEPC; and
Step 3 A one-time first anniversary follow-up
report to the EPA Regional Office.
from the requirements for releases of CERCLA
hazardous substances as described below.
If your facility has a continuous release of a non-
CERCLA EHS, you must establish the release as
continuous and stable in quantity and rate by making an
initial telephone call to the appropriate SERC and
LEPC, and by submitting an initial written report to the
SERC and LEPC. These notifications will provide
state and local response officials with sufficient
information to assess the release and to determine
whether it qualifies for reduced reporting.
Additional circumstantial reporting requirements
for non-CERCLA EHSs that are continuous and stable
in quantity and rate include immediate reporting of
SSIs and reporting changes in the source or
composition of the release. Under the requirements of
EPCRA Section 304, you must submit a written follow-
up notice to the SERC and LEPC within 30 days of a
report of an SSI.
Exhibit 1-6, on page 11, illustrates to whom you
must submit each type of continuous release report for
releases of non-CERCLA EHSs. For a summary of the
information required in the reports you must submit for
continuous releases, please refer to Part 2.
1.3 Reporting Continuous Releases
What are the standard requirements for reporting
a continuous release of a hazardous substance?
There are three steps in the standard continuous
release reporting process. Each step in the process
involves a different type of continuous release
notification. The three types of notification required to
report a CERCLA hazardous substance are summarized
in Exhibit 1-3. The reporting requirements for non-
CERCLA EHSs are slightly different and will be
addressed in detail in the following sections.
To begin the reporting process for continuous
releases, you must have a sufficient basis for
establishing that the release is continuous and stable in
quantity and rate. Once such a basis has been
established, the initial telephone notification should be
made.
Step 1: Initial Telephone Notification
For CERCLA hazardous substances, you must
make an initial telephone call to three separate
government authorities: the NRC, the appropriate
SERC, and the appropriate LEPC. For non-CERCLA
EHSs, you need only call the appropriate SERC and
LEPC. In either case, the initial telephone calls will
alert authorities to your intent to report a release as a
continuous release. When calling, please be certain
that your intent is clear to those receiving your
telephone call. See Part 2 of this Guide for a summary
of the information that must be provided to government
officials in the initial telephone call.
How will EPA identify continuous release reports?
If you are reporting a release of a CERCLA
hazardous substance, when you make the initial
telephone notification, the NRC will assign a case
number to your release report. This case number will
become EPA's identifier for your facility. EPA calls
this number your facility's CR-ERNS number. You
must use this CR-ERNS number on all future release
reports or correspondence related to continuous
releases from your facility. The CR-ERNS number will
identify your facility and will enable EPA to link all
reports about releases from your facility. If you
misplace your CR-ERNS number, contact the
appropriate EPA Regional Office and provide
information identifying your facility.
6
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Since your facility has only one overall
"continuous release" (which may be made up of a
number of individual continuous releases of hazardous
substances from a number of sources) your facility
should have only one CR-ERNS number. Once
assigned to your facility, the CR-ERNS number will
not change with different release reports such as the
follow-up report, statistically significant increase
reports, and changed release reports.
If you are reporting a release of a non-CERCLA
EHS, since you do not report to the Federal authorities
you will not receive a CR-ERNS number. CR-ERNS
numbers are only used by EPA to track your
continuous release. Since a release of a non-CERCLA
EHS will not be reported to EPA, and since your SERC
and LEPC will use their own methods to track your
release, no CR-ERNS number is required for a release
of a non-CERCLA EHS.
If you elect to aggregate multiple concurrent
releases of CERCLA hazardous substances from
adjacent or contiguous facilities for purposes of
reporting continuous releases, you will be assigned
only one CR-ERNS number for your aggregated
release in your initial telephone call. This number will
be the CR-ERNS number for the entire site and should
be used on all subsequent release reports and
correspondence.
If you misplace your CR-ERNS number, contact
your EPA Regional Office (see pages 14 and 15 for
telephone numbers), provide information identifying
your facility, and the EPA Regional Office will provide
you with your CR-ERNS number.
Step 2: Initial Written Report
Within 30 days of the initial telephone
notification, you are required to submit an initial
written report to the appropriate EPA Regional Office,
SERC, and LEPC (for releases of CERCLA hazardous
substances) and to only the appropriate SERC and
LEPC (for releases of non-CERCLA EHSs). (See
pages 14 and 15 for a listing of the addresses of the
EPA Regional Offices.) The purpose of this report is
to confirm your intent to report your release as a
continuous release under Section 103(f)(2), and to
provide government response officials with sufficient
information about your release to enable them to
determine if the release qualifies as a continuous
release. The information will also allow government
officials to identify the potential risks associated with
the release.
The initial written report must include specific
information about each source of the continuous
release. This information should include: a brief
statement describing the basis for asserting that the
release is continuous and stable in quantity and rate;
hazardous substance information; the environmental
medium affected (i.e., air, surface water, soil, or ground
water); and certain ecological and population density
information. A detailed discussion of the requirements
of the initial written report is provided in Part 2 of this
Guide.
To assist you in preparing both the initial written
report and the one-time first anniversary follow-up
report discussed below, EPA has included a Suggested
Continuous Release Reporting Format as Appendix
B of this Guide. Using the format will ensure that you
have provided EPA with all the information required to
properly assess your continuous release report. This
format is also available electronically for EPA Regional
Offices. An example of a properly Completed
Suggested Continuous Release Reporting Format
can be found in Appendix D.
Step 3: First Anniversary Follow-up Report
For reports of releases of CERCLA hazardous
substances, within 30 days of the first anniversary of
your initial written report, you are required to reassess
your initial continuous release report and gather the
information on all of the reported substances being
released. After doing this, you must submit a one-time,
written first anniversary follow-up report to the
appropriate EPA Regional Office. Please note that the
first anniversary follow-up report must be sent to the
appropriate EPA Regional Office for all reports of
CERCLA hazardous substances, but is not required for
reports of non-CERCLA EHSs.
The information required in the written follow-up
report is identical to that required in the initial written
report, but it should be based on release data gathered
over the year (i.e., during the period since the
submission of the initial written report). The principal
purpose of the follow-up report is to update and
confirm the information submitted in the initial written
report, thereby providing government authorities with
a more accurate baseline against which to evaluate the
risks associated with the continuous release. After you
have submitted the follow-up report to the EPA
7
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Regional Office, you are responsible for reassessing the
release annually, but you are not required to notify EPA
of each reassessment unless there is a change in the
information previously submitted to EPA.
Are there additional continuous release reporting
requirements?
There are two additional types of continuous
release reporting requirements: a requirement for
notification of an SSI and requirements for notification
of changes to previously submitted continuous release
information. These reports are used during specific
circumstances and are illustrated in Exhibit 1-4.
EXHIBIT 1-4: CIRCUMSTANTIAL
REPORTING REQUIREMENTS
There are two types of additional
reporting requirements for continuous
releases of CERCLA hazardous
substances that are only used during
specific circumstances. These
requirements are:
(1) Notification of an SSI:
- Immediate notification of an
SSI to the NRC, SERC, and
LEPC.
(2) Notification of a change in
previously submitted release
information. Either:
- Notification of a change in
source or composition,
which is treated as if it were
a new release (i.e., with a
telephone call to the NRC,
SERC, and LEPC, followed
by a written report and a
first anniversary follow-up
report); or
- For CERCLA substances
only, notification of any
other type of change (e.g., a
change in facility
ownership) in a written
letter to only the EPA
Region.
Statistically Significant Increase Notifications
An SSI is any episodic release of a hazardous
substance that exceeds the release quantity delineated
in the upper bound of the normal range of the facility's
continuous release report. The normal range is defined
to include all the releases of a hazardous substance
(from all sources) occurring over any 24-hour period
under normal operating conditions during the preceding
year. Only those releases that are both continuous and
stable in quantity and rate may be included in the
normal range. The aggregated upper bounds of the
normal range of each hazardous substance is referred
to throughout this Guide as the "SSI trigger." A
detailed explanation of the SSI trigger and instructions
for calculating the trigger are included in Part 2 of this
Guide,
An SSI in a continuous release of a CERCLA
hazardous substance must be reported to the NRC,
SERC, and LEPC as soon as the person in charge is
aware that the release exceeds the SSI trigger. SSIs in
a continuous release of a non-CERCLA EHS must be
reported to the appropriate SERC and LEPC. Because
an SSI is a type of episodic release, it is treated as such
by the NRC.
The NRC may provide you with an SSI number.
This number is not to be confused with your facility's
CR-ERNS number. When reporting an SSI, the caller
should anticipate that the NRC will ask for information
that is similar to what is asked when a person reports
any other episodic release incident. SSI reports to the
NRC must include the CR-ERNS number assigned to
the facility by the NRC during the original initial
telephone notification.
Please note that, it may be possible to adjust the
SSI trigger (i.e., change the normal range of the release)
if a particular continuous release frequently exceeds the
upper bound of the normal range. Specific procedures
for modifying the SSI trigger for a hazardous substance
are contained in Part 2.
-------
Changes in Previously Submitted Release
Information
There are two types of reports of changes in
previously submitted release information: reports of a
change in source or composition; and reports of
changes in other information.
How do you report changes in source or
composition?
If there is a change in the source or composition
of your continuous release of a CERCLA hazardous
substance, the release is considered a "new" release. A
change in the source or composition of a release may
be caused by such factors as equipment modifications
or process changes. To continue reporting the release
under CERCLA Section 103(f)(2), you must establish
the new release as continuous and stable in quantity
and rate, with an initial telephone call to the NRC,
SERC, and LEPC and, within 30 days, submit an initial
written report to the appropriate EPA Regional Office,
SERC, and LEPC. When telephoning the NRC, clearly
identify the release as a change in the source or
composition of a previously reported release and for
reports of releases of CERCLA hazardous substances,
provide the CR-ERNS number assigned by the NRC in
your original initial telephone call. As with your
original continuous release report, you must submit a
first anniversary follow-up report to the EPA Region
for any changes in source or composition of CERCLA
hazardous substances.
If there is a change in source or composition of
your continuous release of a non-CERCLA EHS, it is
also considered a new release. An initial telephone call
must be made to the appropriate SERC and LEPC,
followed by an initial written report.
How do you report changes in other information?
For all other changes (i.e., changes other than in
the source or composition) in the information submitted
in any initial written or follow-up report for releases of
CERCLA hazardous substances, you must notify the
EPA Regional Office by letter within 30 days of
determining that the information previously submitted
is no longer accurate. Although notification of the
SERCs and LEPCs for either CERCLA hazardous
substances or non-CERCLA EHSs is not required by
the Continuous Release Rule, SERCs and LEPCs
should be notified of these changes to properly update
the facility's file.
Examples of changes in other information
include: changes in the facility ownership; changes in
the identity of the person in charge of the facility; or
changes in the sensitive populations and ecosystems.
All notifications of changes in releases of CERCLA
hazardous substances must include the original CR-
ERNS number assigned to the facility by the NRC in
the initial telephone notification. You must also
include a signed statement with the notification
verifying that all reported information on the release
submitted to date is accurate and current. A similar
signed statement is required in all written
correspondence pertaining to the continuous release.
For an example of the statement required under the
Rule, see Part 2 of this Guide.
1.4 Recordkeeping Requirements
What are my recordkeeping responsibilities as a
person in charge of a facility?
To satisfy the specific requirements for reporting
continuous releases, you are responsible for estimating
or calculating the quantities of all continuous releases
that you report by whatever methods are appropriate.
As stated above, this may involve reliance upon past
release data, engineering estimates, knowledge of plant
operations and release history, your best professional
judgment, or any other method that has a sound
technical basis. All estimates, however, must have a
sound technical basis.
In addition, you must keep the information
substantiating the estimates you have reported on file at
your facility. Supporting materials must be kept on file
for a period of one year and should substantiate the
normal range of the release, the basis for asserting that
the release is continuous and stable in quantity and rate,
and the other information included in the initial written
report, the follow-up report, or the most recent annual
evaluation. EPA may question the basis for your
determination that a release is continuous and stable or
any other submitted information, and may ask to
review the substantiating information. It is important,
therefore, to keep an accurate account of the history of
all continuous releases at your facility and evaluate
these releases carefully for changes, and for SSIs as
well.
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EXHIBIT 1-5
WHERE TO SUBMIT CONTINUOUS RELEASE REPORTS FOR RELEASES OF
CERCLA HAZARDOUS SUBSTANCES
Continuous Release
Reporting Requirements
National
Response
Center
(NRC)
State Emergency
Response
Commission
(SERC)
Local Emergency
Planning
Committee
(LEPC)
Environmental
Protection Agency
(EPA)
Regional Office
Standard
Reporting
Requirements
Initial Telephone
Notification
/
/
/
Initial Written Report
/
/
/
Follow-up Report
/
Circumstantial
Reporting
Requirements
SSI Telephone
Notification
/
/
/
Change of Release
Information1
(New Release)
/
/
/
/
Change in Other
Information2 (Letter)
/
1. A change of previously submitted release information (i.e., source or composition) is treated like a "new release". Therefore, for reports of CERCLA hazardous
substances, the person in charge of the facility must first make an initial telephone notification to the NRC, SERC, and LEPC to report the change. The facility must
then send a written report to the SERC, LEPC, and appropriate EPA Regional Office. Within 30 days of the first anniversary of the Initial Report, for reports of releases
of CERCLA hazardous substances, the facility must send a follow-up report to the appropriate EPA Regional Office.
2. A change in other information is usually a change in general information regarding the facility (i.e., a change in the person in charge of the facility or sensitive
population). According to the Rule, a facility is only required to submit a letter to the appropriate EPA Regional Office stating these changes. Although a facility is not
required to submit the changes to the SERC and LEPC, it is recommended that a reporting facility do so in order to properly update the facility's files.
10
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EXHIBIT 1-6
WHERE TO SUBMIT CONTINUOUS RELEASE REPORTS FOR RELEASES OF NON-CERCLA EHSs
Continuous Release
Reporting Requirements
National
Response
Center
(NRC)
State Emergency
Response
Commission
(SERC)
Local Emergency
Planning
Committee
(LEPC)
Environmental
Protection Agency
(EPA)
Regional Office
Standard
Reporting
Requirements
Initial Telephone
Notification
/
/
Initial Written Report
/
/
Follow-up Report
Circumstantial
Reporting
Requirements
SSI Telephone
Notification
/
/
Change of Release
Information1
(New Release)
/
/
Change in Other
Information2 (Letter)
1. A change of previously submitted release information (i.e., source or composition) is treated like a "new release". Therefore, for reports of non-CERCLA EHSs, the
owner or operator of the facility must first make an initial telephone notification to the appropriate SERC and LEPC to report the change. The facility must then send a
written report to the SERC and LEPC.
2. A change in other information is usually a change in general information regarding the facility (i.e., a change in the person in charge of the facility or sensitive
population). According to the Rule, a facility is not required to submit the changes to the SERC and LEPC, but it is recommended that a reporting facility do so in order
to properly update the facility's files.
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1.5 EPA's Role in the Continuous
Release Reporting Process
How will continuous release information be
processed?
When EPA receives the CERCLA hazardous
substance continuous release information, the Agency
will create a file for your facility. The information you
submit in the initial written and first anniversary
follow-up report will be entered into the Continuous
Release - Emergency Response Notification System
(CR-ERNS) database. EPA will also enter any reports
of changes in the release into CR-ERNS. CR-ERNS is
a central depository for all continuous release
information received by the NRC and the EPA
Regions. Information in CR-ERNS will be stored in a
national database at the John A. Volpe National
Transportation Systems Center (VNTSC) in
Cambridge, MA.
How will EPA evaluate the potential threat posed by
a continuous release?
The potential threat posed by a continuous release
of a hazardous substance is determined by assessing its
toxicity, the quantity and frequency of the release, and
the proximity and nature of the potentially exposed
population and environment. EPA will evaluate the
health and environmental risks posed by continuous
releases. Information from written reports will be
combined with toxicity information on the hazardous
substance(s) released to generate risk estimates for each
release. It is important, therefore, that the information
you report is as accurate as possible. If data elements
are missing, EPA will be forced to use conservative
estimates.
What assistance will be provided by EPA
throughout the reporting process?
EPA has included a Suggested Continuous
Release Reporting Format for written reports located
in Appendix B of this Guide. This suggested Format
is designed to assist you in completing the written
reports and ensuring that all of the required information
is included in your written reports.
In addition, on page 19 of this Guide, you can
find Exhibit 2-1, a checklist of the information
required in the initial written report and first
anniversary follow-up reports. This checklist provides
an overview of the information required and is another
means that you can use to verify that all required
information has been collected and submitted.
In addition to the detailed explanation of the
specific continuous release reporting requirements
contained in this Guide, your EPA Region or the
RCRA/Superfund/EPCRA Hotline (telephone numbers
are provided on pages 14 and 15) can also provide
assistance in understanding and complying with all
reporting requirements.
What actions may EPA take in response to
continuous release reports?
Under CERCLA, EPA has authority to evaluate
and respond to releases of hazardous substances. EPA
can rely on the broad response authority available
under CERCLA Sections 104, 106, and 107 to respond
to continuous releases, as well as episodic releases.
The actions EPA may choose to take include, but are
not limited to, the following:
• If EPA has doubts or questions about any portion
of your report or about the basis reported for
establishing a release as continuous, you may be
asked to clarify your report or to submit
additional information;
• If you have not already done so, EPA may
request that you establish a release as continuous
and stable by reporting it for some period of time
on a per-occurrence basis under CERCLA
Section 103(a);
• EPA may alert a permit program office or other
office that a release from your facility merits
further evaluation and possible response action;
or
• EPA may decide to perform a site inspection or
field response at your facility.
If tjie person in charge of a facility does not receive
comments from EPA regarding a continuous release
report, should it be assumed that the report is
approved?
EPA's receipt of a continuous release report
without comment does not indicate approval of the
report or the information it contains. EPA, SERCs, and
LEPCs may re-evaluate the information submitted in
any continuous release report at any time, and may
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contact the person in charge of the facility to review
the basis for reporting the release as a continuous
release under Section 103(f)(2). There is no time limit
for EPA's review.
1.6 Additional Questions
Can the Toxic Release Inventory form be used to
satisfy continuous release reporting requirements?
To minimize any possible duplication in the
reporting process, the Continuous Release Rule allows
you to submit the EPCRA Section 313 Toxic Release
Inventory (TRI) Form R as a substitute for the written
initial or follow-up report, provided that you include
certain additional required continuous release
information. This additional information will provide
EPA with details about the continuous release that are
not available from the EPCRA Section 313 report
(Form R), but that are required to evaluate the risks
associated with the release properly.
This additional information should be reported on
a special CR-ERNS format for TRI reporters called
Suggested CR-ERNS Reporting Format --
Addendum to TRI Form R. This special format
appears as Appendix C to this Guide. The format
includes all elements of information needed to
complement the TRI Form R information in order to
comply with the Continuous Release Rule. Appendix
E is an example of a properly Completed CR-ERNS
Reporting Format ~ Addendum to TRI Form R.
1.7 Where to Submit Written Reports
Your continuous release report and any written
follow-up reports or changes should be submitted to
your EPA Regional Office. Exhibit 1-7 provides the
addresses of each Regional office and shows the
location of all of the EPA Regions.
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EXHIBIT 1-7
EPA REGIONAL SUPERFUND OFFICES
EPA Regional Offices
EPA, Region 1
CR-ERNS Coordinator
Emergency Response Section
JFK Building
Boston, MA 02203-2211
(617) 573-9682
EPA, Region 2 - Building 209
CR-ERNS Coordinator
Response & Prevention Branch
2890 Woodbridge Avenue
Edison, NJ 08837-3697
(908) 321-4357
- EPA, Region 3 (3HW-30)
CR-ERNS Coordinator
Superfund Removal Branch
841 Chestnut Building
Philadelphia, PA 19107
(215) 566-3293
EPA, Region 4
CR-ERNS Coordinator
Title III Section
61 Forsyth Street
Atlanta, GA 30303
(404)562-8718
EPA, Region 5
CR-ERNS Coordinator
Emergency & Remedial Response Sec,
77 West Jackson Street
Chicago, IL 60604
(312) 886-6028
EPA, Region 6
CR-ERNS Coordinator
Chief, Emergency Response Branch
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
(214) 665-2292
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EPA, Region 7
CR-ERNS Coordinator
Emergency Response & Spill Branch
726 Minnesota Ave.
Kansas City, KS 66101
(913) 551-7118
EPA, Region 8
CR-ERNS Coordinator
999 18th Street, Suite 500
Denver, CO 80202-2466
(303)312-6239
EPA, Region 9
CR-ERNS Coordinator
Field Operations Branch
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-2339
- EPA, Region 10
CR-ERNS Coordinator
Superfund Response and
Investigation Section
1200 6th Avenue
Seattle, WA 98101
(206)553-1673
SERCs and LEPCs.
Call the RCRA/Superfund/EPCRA Hotline
for the addresses and telephone numbers of
local SERCs and LEPCs.
1.8 Sources for Further Information
• National Response Center (NRC). 24 hour toll-
free telephone number for reporting spills only
(not an information hotline): 1-800-424-8802;
Washington, DC area: 202-267-2675.
RCRA/Superfund/EPCRA Hotline. Toll-free
telephone number: 1-800-424-9346: .Washington,
DC area: 1-703-412-9810.
The Telecommunications Device for the
Deaf (TDD) Hotline number is toll-free:
1-800-553-7672; the Washington, DC area:
703-486-3323.
The RCRA/Superfund/EPCRA Hotline is
open from 8:30 a.m. to 7:30 p.m. (EST)
Monday through Friday, excluding federal
holidays.
• National Technical Information Service (NTIS).
Open 8:30 a.m. to 5 p.m. (EST) Monday
through Friday. General telephone number:
703-487-4600.
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PART 2: INSTRUCTIONS AND PROCEDURES FOR
CONTINUOUS RELEASE REPORTING
2.0 Introduction
2.1 General Overview of How to
Report a Continuous Release
This part of the Guide includes detailed
instructions and procedures for complying with the
reporting requirements for continuous releases. These
instructions are intended to assist you in supplying the
information required by the implementing regulations
"Reporting Continuous Releases of Hazardous
Substances Final Rule" (40 CFR Parts 302.8 and
355.40). The instructions below cover both the
standard reporting requirements and the reporting
requirements for special circumstances. The standard
reporting requirements include the initial telephone
notification, the initial written report, and the one-time
first anniversary follow-up report. Reporting
requirements for special circumstances include reports
of SSIs, as well as reports of any changes in the release
that make the information submitted in the initial
written or follow-up reports inaccurate or out-of-date.
Part 2 of the Guide is organized into six sections.
Section 2.1 provides a general overview of how to
report continuous releases. Sections 2.2 through 2.5
explain each type of required notification. Within each
of these sections are detailed instructions on when and
where to submit each required report, as well as
instructions on what information to include in the
report. Section 2.6 provides a summary of the
information that must be provided by reviewing the key
elements of the Suggested Continuous Release
Reporting Format included in Appendix B of this
Guide. You are strongly encouraged to use this
suggested reporting format when completing your
written initial and follow-up reports to ensure that you
include all of the information required by the Rule.
This part of the Guide also provides other
materials to assist you in completing your written
reports including Exhibit 2-1, the checklist of the
information required in the initial written and follow-up
reports, which appears on page 19. This checklist is
another method that can be used to verify that all
required information has been collected and submitted.
If you have established that your release is
continuous and stable in quantity and rate, you may
begin reporting under CERCLA Section 103(f)(2). As
discussed in Part 1 of this Guide, the continuous release
reporting regulation provides you with two options for
reporting continuous releases of CERCLA hazardous
substances. You may aggregate multiple concurrent
releases of the same hazardous substance from
contiguous or adjacent facilities and report them in a
single notification, or you may consider each facility
separately and submit reports on a per facility basis.
Although you may elect either option for notification of
continuous releases, whichever option you elect must
also be used for reporting statistically significant
increases (SSIs) in the release and reporting changes in
information previously submitted.
To report a continuous release from your facility,
you must comply with the standard reporting
requirements under the Rule which require you to make
an initial telephone notification, an initial written
report, and a one-time, first anniversary follow-up
report. In the written reports (i.e., the initial written
report and the follow-up report), you must provide
specific information that describes your continuous
release. This information includes identifying the
facility and providing certain ecological and
population-density information on the surrounding
area, as well as information on the source of the
release. You must identify aU sources of continuous
release from your facility (e.g., smoke stacks, waste
piles, valves) whenever those facility-wide releases
equal or exceed an RQ. You must also provide
substance-specific information on each hazardous
substance released from each identified source (40 CFR
302.8(e)).
In addition to the standard reporting requirements
of the initial telephone notification and the written
reports, under certain circumstances you must make
additional reports. You must report any SSIs in the
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release, as well as any changes in the release that make
the information submitted in the initial written or
follow-up reports inaccurate or out-of-date. The
specific information required in each of these types of
continuous release reports is outlined in the sections
below. The instructions for reporting continuous
releases contained in this part of the Guide are written
for those who elect to report each facility separately
and therefore they refer to "facilities" rather than
"sites." The instructions for reporting releases from
sites are the same as those described for facilities
below.
2.2 Initial Telephone Notification
When should you notify?
The continuous release reporting regulation
requires that an initial telephone notification be made
as soon as you have a sufficient basis for establishing
that the release is continuous and stable in quantity and
rate. You may rely on release data, engineering
estimates, knowledge of the plant's operations and
release history, professional judgment, or any other
method that has a strong technical basis to establish the
basis for asserting that the release is continuous and
stable in quantity or rate, or you may report the release
(to the NRC for CERCLA hazardous substances or to
the SERC and LEPC for non-CERCLA EHSs) for a
period sufficient to establish the continuity and stability
of the release; (for further information on how to
establish a release as continuous and stable in quantity
and rate, refer to pages 3 and 4 of this Guide).
If a sufficient basis for establishing the release as
continuous exists for a CERCLA hazardous substance,
a minimum of one telephone call may be made to the
NRC, SERC, and LEPC. For non-CERCLA EHSs,
only the appropriate SERC and LEPC need be notified.
In either case, you may report all continuous releases of
hazardous substances at your facility in one telephone
report to each authority.
Who must be notified?
If you are the person in charge, owner or
operator, of the facility from which a continuous
release of a hazardous substance occurs, you must
telephone the following organizations:
* For CERCLA hazardous substances:
National Response Center (NRC)
Toll-free telephone number:
1-800-424-8802;
Washington, DC area: 1-202-267-2675;
• For CERCLA hazardous substances and non-
CERCLA EHSs:
The State Emergency Response
Commission (SERC) of any state likely to
be affected by the release; and
The Local Emergency Planning Committee
(LEPC) of any area likely to be affected
by the release.
Required information
The person in charge (for CERCLA hazardous
substances) or the owner or operator (for non-CERCLA
EHSs) is required to provide the information listed
below to government authorities in the initial telephone
notification.
1. Identify your report as a report of a continuous
release under CERCLA Section 103(f)(2). It is
very important for tracking purposes that the
person at the NRC, SERC, and LEPC to whom
you speak understands that you are giving the
initial telephone notification of a continuous
release (rather than an episodic report).
2. Identify the name and location of the facility
responsible for the release and provide the
corporate affiliation and address.
3. Identify each hazardous substance released.
4. Provide your name and telephone number and, if
different, the name and telephone number of the
person in charge of the facility.
If you are reporting a release of a CERCLA
hazardous substance, when you make this initial
telephone call to the NRC, you will be assigned a CR-
ERNS number. This CR-ERNS number will become
the identifier for your facility. Your CR-ERNS
number will never change; it is the number that
identifies you in the CR-ERNS database.
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If you are reporting a non-CERCLA EHS to the
appropriate SERC or LEPC you will not receive a CR-
ERNS number as your SERC and LEPC will use their
own methods to track your continuous release.
2.3 Initial Written and Follow-Up
Reports
Where and when to submit initial written and
follow-up reports?
Within 30 days of your initial telephone call to
the NRC, SERC, and LEPC, the initial written report of
CERCLA hazardous substances must be submitted to
the appropriate government authorities. You must send
one copy of the completed initial written report
containing the information described in this Section to
each of the following organizations:
• The EPA Regional Office for the
geographical region in which your facility
is located;
• The SERC of any state likely to be affected
by the release; and
• The LEPC of any area likely to be affected
by the release.
For reports of CERCLA hazardous substances,
the one-time, first anniversary follow-up report must be
submitted within 30 days of the first anniversary date
of the initial written report to the EPA Regional Office.
The first anniversary follow-up report must be
submitted to the EPA Regional Office only. You are
not required to submit the one-time first anniversary
follow-up report to the SERC and LEPC.
Reports of releases of non-CERCLA EHSs must
be reported only to the SERC and LEPC. No
notification of Federal authorities is required.
What information is required?
The information that you are required to submit
for all initial written and follow-up reports can be
divided into three primary sections: general
information: source information: and hazardous
substance information. These sections are described
briefly below and the specific information to be
included in each of these sections is described more
fully in the following pages.
* Section I - General Information. This section
includes identifying information about your
facility, as well as information concerning the
area surrounding your facility.
* Section II - Source Information. This section
includes information on each source of the
release including: the identity of each source; the
basis for stating that the release from a source
qualifies as continuous and stable in quantity and
rate; the environmental medium affected by the
release; the names and quantities of the CERCLA
hazardous substances or EHSs released from the
source; and the normal range and frequency of
the release. This information must be provided
separately for each source of the continuous
release.
* Section III - Hazardous Substance Information.
This section includes the upper bound of the
normal range for each hazardous substance
released across ail sources at a facility. This
number is also known as the SSI trigger. Section
II should be completed for each release source
before you calculate the upper bound of the
normal range of the release for each CERCLA
hazardous substance or EHSs across all sources at
the facility.
Section I: General Information
The information required in Section I of the initial
written report and follow-up reports includes general
information identifying your facility, as well as
information regarding the area in which your facility is
located. This general information is important because
it provides a better understanding of the potential risks
resulting from exposure from the facility's release. A
signed statement asserting that the continuous release
is continuous and stable in quantity and rate, and that
the information supplied is accurate and current to the
best of your knowledge, is also required in Section I.
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EXHIBIT 2-1
CHECKLIST OF INFORMATION REQUIRED IN INITIAL AND FOLLOW-UP WRITTEN REPORTS
Section I: General Information
A. Facility Identification
0 The CR-ERNS number assigned to the facility by the NRC when you made the initial
telephone notification;
~ The name of your facility, including the full address (street address, city, county, state,
zip code), and its longitude and latitude; and
~ The name, position, telephone number, and alternate telephone number of the person in
charge of your facility.
B. Population Information
~ The population density within a one-mile radius of your facility; and
O The identity of sensitive populations and ecosystems, including distance and direction
from the facility, within a one-mile radius.
Section II: Source Information
A. Basis for Asserting that the Release is Continuous and Stable in Quantity and Rate
~ A brief statement describing the basis for stating that the release is continuous
and stable in quantity and rate.
B. Information on the Source
~ The identity of each source of the release; and
E The environmental medium affected by the release.
C. Identify and Quantity of Each Hazardous Substance or Mixture Released
~ The name/identity of the hazardous substances;
E The Chemical Abstracts Service Registry Number (CASRN) for the substance;
^ if the release is a mixture, the components of the mixture and their approximate
concentrations and quantities by weight;
~ The upper and lower bounds of the normal range of the hazardous substance/mixture
release over the previous year;
n An estimate of the total amount of the hazardous substance released in the previous year;
^ The frequency of the release; and
The months during which the release occurs.
Section III: Hazardous Substance Information
O The aggregated upper bounds of the normal range of the hazardous substance released
from all source at the facility.
Statement Signed
~ "I certify that the hazardous substance releases described herein are continuous and stable
in quantity and rate under the definitions in 40 CFR 302.8(a) or 355.4(a)(2)(iii) and that
all submitted information is accurate and current to the best of my knowledge."
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In addition to the information required on the
following pages. Section I must clearly identify the
type of written report that you are submitting (i.e., an
initial written report, a first anniversary follow-up
report, or a written report of the change in source or
composition of a previously reported release). You
must also include information on the initial notification
of the release, such as the date of the release and the
date of the initial call. For CERCLA hazardous
substances, the CR-ERNS number assigned to you by
the NRC will also be required.
Section I: General Information
Part A: Facility Information
In Part A, provide the following information:
1. The complete name of your facility (and
company identifier where appropriate). If
multiple facilities are included in your written
report, provide the plant site name with the name
of the facility.
2. The full address of your facility, including the
street address or highway marker, city, county,
state, and zip code. A post office box number
should not be used as the facility address. The
address provided should be the location of the
facility where the hazardous substance release
occurs.
3. The location of your facility by its latitude and
longitude in units of degrees, minutes, and
seconds. Exhibit 2-2 includes helpful hints on
how to obtain the latitude and longitude
coordinates of your facility.
4. The nine digit number assigned by Dun and
Bradstreet (D&B) to your facility. This number
can be obtained via telephone by an officer of
your company from the national office of Dun
and Bradstreet (at 1-800-234-3867), If your
facility has not been assigned a D&B number,
please specify that the information is not
applicable.
5. For reports of CERCLA hazardous substances,
the CR-ERNS number assigned by the NRC
when you made the initial telephone report. Be
certain to include the CR-ERNS number on each
page of your report
6. The name, telephone number (including area
code), and an alternate telephone number for the
person in charge of your facility.
mmmmmmmmmtmmmmmammmmmmmmmmmmt
EXHIBIT 2-2
SOURCES OF INFORMATION FOR
IDENTIFYING THE LOCATION OF YOUR
FACILITY
Sources of data on latitude and longitude
coordinates of your facility include EPA
permits (e.g., NPDES permits), county
property records, facility blueprints, and site
plans.
In addition, information on the latitude and
longitude of your facility may be obtained
from a United States Geological Survey
(USGS) topographical map. These maps are
available in both the 7.5 minute and 15
minute series. These maps may be obtained
from the USGS distribution center at your
local public library. If you would like to
order a map from USGS, contact:
U.S. Geological Survey
Branch of Distribution
Box 25286 Federal Center
Denver, CO 80225
If you are not certain on which map your site
is located, consult the index of topographic
maps for your state, which may be obtained
from USGS free of charge. USGS maps are
also available at commercial dealers such as
surveyors or outdoor recreation equipment
dealers.
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Section I: General Information
Part B. Population Information
In Part B, provide the following information:
1. Choose the range listed below that most
accurately describes the population density within
a one-mile radius of your facility:
0-50 person(s)
51-100 persons
101-500 persons
501-1000 persons
more than 1000 persons.
2. Identify and describe the location of any sensitive
populations or ecosystems (see Exhibit 2-3 for
definitions and examples) within a one-mile
radius of your facility. If possible, describe the
location of the populations or ecosystems in
terms of distance and direction from your facility
(e.g., located V* mile northwest of the facility).
Exact addresses are not required.
EXHIBIT 2-3
DEFINITIONS
Sensitive populations are populations likely to be
more susceptible than average individuals to the
effects of exposure to a hazardous substance.
Examples of sensitive populations are elementary
school children, retirement communities, or
hospitals.
Sensitive ecosystems are environments likely to
be more susceptible than average environments to
the effects of exposure to a hazardous substance,
or ecosystems that have been designated for
special protection by Federal or state
governments. Examples ot sensitive ecosystems
include wetlands, wildlife refuges, tidal basins, or
endangered species habitats.
Section II: Source Information
General overview
When completing your written reports, you must
take into consideration all sources of the release from
your facility. For example, if the aggregate amount of
a particular hazardous substance released within 24
hours from your facility equals or exceeds an RQ, then
each source of the particular release must be identified,
even if some release amounts from individual sources
do not equal or exceed the RQ. The purpose of
requiring information on the source(s) of the release is
to provide EPA with sufficient information to evaluate
the risk associated with the continuous release.
Providing this information accurately in the initial
written and first anniversary follow-up report will
minimize future requests by EPA for additional
information or clarification.
In this section of the written report, you should
identify and describe separately each continuous
release source. If the continuous release of the same
hazardous substance comes from two or more sources
(e.g., two stacks), then information should be reported
separately for each of the sources. For example, if a
stack is one of several sources of a hazardous substance
release at your facility, you must provide information
on that stack including: the stack height; the identity of
the hazardous substance(s) being released from the
stack; the quantity released; and the frequency of the
release from the stack. If you have a release of a
particular hazardous substance from three stacks, you
should report each stack separately and provide the
required information specified for each stack.
Although the continuous release reporting
regulation allows multiple concurrent releases of the
same CERCLA hazardous substance to be considered
as if they were one continuous release, aggregate
reporting of such releases from different sources
complicates risk analyses. Area sources are most
readily aggregated for purposes of continuous release
reporting and risk evaluation when the frequency of the
release from each source is the same. Similarly,
aggregated stack releases are most readily evaluated if
the frequency of the release from each stack is the same
and the stack configurations (e.g., stack height,
diameter, throughput) are the same. If you elect to
aggregate releases across facilities, be certain to
identify information about each source of the release
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from all of your facilities. Also, note that if you
aggregate your releases, EPA may request clarifying
information about the releases from each of the
individual sources.
Identification of sources
In Section II, you must identify (i.e., name) and
describe each continuous release source. There are
several ways to name release sources. It is important
to: (1) provide a name that clearly identifies the source
(e.g., centrifugal processor A, rather than Unit A); and
(2) avoid giving two or more sources the same name.
Jt is also important to remember when naming your
sources that EPA, at any time, may contact you with
questions regarding releases from one of your named
sources. It would be prudent, therefore, to name the
sources at your facility in a manner that will be easy for
you and other employees to identify them. For
example, if your plant has four stacks, two wastepiles,
and twenty-four valves, you may name the sources as
follows: Stack #1; Stack #2; Stack #3; Stack #4;
Wastepile #1; Wastepile #2; and Valves in Building #2.
Note that the "Valves in Building #2" are aggregated in
this example and reported as a single source.
Required information
Section II, Source Information, contains three
Parts: Part A, Part B, and Part C. You must provide
the information required in each of these Parts for each
continuous release source. Be sure to place the name
of the source on all pages associated with that specific
source. A summary of the type of information required
in each Part is provided below.
Part A - Requests information on the basis for
asserting that the release from each identified
source is continuous and stable in quantity and
rate.
Part B - Requires specific information on the
environmental medium affected by the hazardous
substance release from each identified source.
Part C - Requires information on the hazardous
substance(s) and mixture(s) released from the
identified source, such as the upper bound of the
normal range of the hazardous substance.
The information required in Parts A, B, and C is
described more fully below and is used to assist EPA
and other government authorities in evaluating the risks
associated with the continuous release. It is important
to remember when completing your format to include
for each source all of the information required in each
part of Section II.
There is one exception to this rule. If the release
from any individual source will affect more than one
environmental medium (e.g., a wastepile releasing to
air and ground water) it must be modeled separately.
Therefore, any source that affects two different media
should be treated as two separate sources for purposes
of reporting. This is desirable because EPA must
analyze each release pathway separately to properly
evaluate the risks posed by the continuous release. In
addition, because the hazardous substance releases to
each medium may differ in frequency and quantity, it
is useful to distinguish the releases for purposes of risk
evaluation.
Section II: Source Information
Part A: Basis for Asserting the Release is
Continuous and Stable in Quantity and
Rate
In Part A of Section II, you must first identify the
source of the release (include the name of the source in
all subsequent parts), then briefly describe the basis for
stating that the release is continuous and stable in
quantity and rate. Your description of the basis for
stating that the hazardous substance release is
continuous and stable in quantity and rate should
include whether the release is continuous without
interruption, or is a routine, anticipated, intermittent
release. It should also include information on when the
release is expected to occur (i.e., evidence of
predictability of the release). One example of a release
that may be predictable and regular is fugitive
emissions from valves that occur at different rates over
the course of a production cycle as the pressure inside
the system changes. Although the rate of such fugitive
emissions may not be strictly uniform, it may be
predictable in the sense that the rate and amount of the
release vary in a similar manner each time the process
is operated or decompression occurs.
Your description should also identify the activity
that results in the release (e.g., batch process, operating
procedure, loading/unloading, maintenance activity,
filling of storage tanks). If the release occurs because
of a malfunction, this should be explained fully. Note
that only certain releases due to malfunctions can
22
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qualify as a continuous release. Please refer to the
discussion in the preamble of the continuous release
Final Rule at 55 FR 30171 or the discussion on page 4
of this Guide to determine whether a malfunction can
qualify as a continuous release.
Finally, your description should include
information on how you established the pattern of the
release and calculated release estimates (e.g.,
engineering estimates, your best professional judgment,
past release data).
In sum, when identifying your sources, refer to
the directions above on how to name sources. For each
source identified, provide the following information.
1. Indicate whether the release is continuous without
interruption or abatement or routine, anticipated,
and intermittent.
2. Identify the activity or activities that cause the
release from the source.
3. If the release results from a malfunction, describe
the malfunction and explain why the release
should be considered continuous and stable in
quantity and rate.
4. Identify how you established the pattern of the
release and calculated release estimates.
Section II: Source Information
Part B. Specific Information on the Source
In Part B of Section II of your written report, you
must identify the environmental medium (i.e., air,
surface water, soil, or ground water) affected by the
hazardous substance release from each source
identified in Section II, Pat A. In addition, you must
provide specific information on the source and its
affected environment. It is important to remember that
if you have a release from a single source that affects
two different media (e.g., gypsum stack releasing radon
to air and radionuclides to ground water), you should
treat the release to each medium as separate source for
purposes of reporting. Another important point to
remember when completing all sections of the written
report is to include the appropriate units, such as
kilograms, meters, or curies.
For each source identified in Part B, provide the
following information.
Environmental medium
Identify the environmental medium (i.e., air,
surface water, soil, or ground water) that is affected by
the release from the identified source.
1. Air
If the medium affected is air, provide the
following information:
(a) Indicate whether the source is a stack or
ground-based area source.
(b) If the source is a stack, provide the stack
height in feet or meters. The stack height is
the distance from the ground to the top of
the stack.
(c) If the source is an area source (e.g., a waste
pile, surface impoundment, landfill, valve,
pump seal, or storage tank vent), provide an
estimate of the surface area or area of the
release source including the appropriate
unit such as square feet, square meters, or
acres.
2. Surface Water
If the medium affected is surface water, provide
the following information:
(a) If the release affects any surface water
body, give the name of die water body.
(b) If the release affects a stream, give the
"stream order" or the average flow rate (in
cubic feet per second). This information
can be obtained from your state water
resource division of USGS. If you cannot
locate this information, use the chart in
Exhibit 2-4 to estimate the flow rate
according to the velocity of the stream. If
the velocity of the stream fluctuates during
the year, use the average velocity when
calculating average flow rate.
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EXHIBIT 2-4
ESTIMATED AVERAGE STREAM
FLOW RATES
Mean
Stream
Mean Flow
Velocity
Order
(CFS)
(feet/sec!
1
0.65
1.0
2
3.10
1.3
3
15.00
1.5
4
71.00
1.8
5
340.00
2.3
6
1,600.00
2.7
7
7,600.00
3.3
8
56,000.00
3.9
9
171,000.00
5.6
10
810,000.00
5.9
CFS = Cubic Feet/Second
regarding the location of public water
supply wells may be available through the
county office that issues permits for wells.
Optional information
The following information is not required in the
Continuous Release Rule; however, such information
will assist EPA in evaluating the risks associated with
a continuous release. If the information below is not
provided, conservative values will be used to evaluate
the risks associated with the continuous release.
1. If the source is a stack release to air, provide
the: (a) inside diameter of the stack; (b) gas exit
velocity; and (c) gas temperature.
2. If the release affects surface water, provide the
average velocity of the surface water.
(c) If the release affects a lake, or other large surface
water body (e.g., a bay) give the surface area of
the lake (in acres) and the average depth (in feet
or meters). Exhibit 2-5 includes sources of
information on how to determine the average
depth of a lake.
EXHIBIT 2-5
SOURCES OF INFORMATION FOR
ESTIMATING AVERAGE LAKE DEPTH
If the lake is large enough to be navigable, your
local Coast Guard office will have a navigation
chart that will provide the average depth of the
lake. For smaller lakes, you may estimate the
average depth of the lake by relying on your
knowledge of the use of the lake and the
surrounding area, and your best professional
judgment
3. Soil or Ground Water
If the medium affected is soil or ground water,
provide the following information:
(a) If the release is on or under ground, indicate
the distance to the closest water well within
a two-mile radius of the site. Information
Section II: Source Information
Part C. Identity and Quantity of Each Hazardous
Substance or Mixture Released
For each source, you must report information
about the identity and quantity of the hazardous
substances released from the source. In particular, you
must identify the normal range of each release and the
total annual quantity released during the previous year
from each source. The regulatory definition of the
"normal range" of a continuous release is provided in
Exhibit 2-6.
¦¦¦¦¦¦¦¦¦¦¦¦¦¦¦¦¦¦¦¦¦
EXHIBIT 2-6
NORMAL RANGE
The normal ranee of a continuous release
includes all releases of a hazardous substance (in
pounds or kilograms) reported or occurring during
any 24-hour period under normal operating
conditions during the previous year. Only
releases that are both continuous and stable in
quantity and rate may be included in the normal
range.
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EXHIBIT 2-7: EXAMPLES OF REPORTING SINGLE HAZARDOUS SUBSTANCES
In this example, your facility has a release which may qualify for reduced reporting as a continuous release.
The hazardous substances released from the identified source (Stack A) are nitrogen dioxide (10102440) and
nitric oxide (10102439).
The volume of nitrogen dioxide (NO,) released in a 24-hour period is between 0 and 120 lbs. During the
previous year, 960 lbs of N02 was released. The release occurs once per week in February and June for a total
of 8 days per year. The amount of nitric oxide (NO) released is between 1 and 115 lbs. The release of NO
occurs approximately 120 days each year. A total amount released last year was 13,800 lbs.
For these releases from the specific source, you must provide the information outlined below.
Name of
Hazardous
Substance
Nitrogen
dioxide (N02)
CASRN#
10102440
Normal Range
(specify lbs. or kg)
Upper Lower
Bound Bound
120 lbs 0 lbs
Total Annual
Amount Released
(specify lbs, or kg)
960 lbs.
Number of
Days Release
Occurs
(Per year)
8
Months of
the
Release
February; June
Nitric
oxide (NO)
10102439
115 lbs 1 lb
13,800 lbs.
120
All 12 months
You are not necessarily required to monitor
releases to determine the normal range of the release.
You may establish the normal range by using
engineering estimates of releases under various
operating conditions, knowledge of the operating
history of the facility, experience with operating
processes, professional judgment, or any other method
that has a sound technical basis. EPA will use the
upper bound of the normal range to estimate the risks
to human health and the environment posed by the
hazardous substance release.
To provide the required information regarding the
quantity of the hazardous substance released from each
identified source, you should begin by determining
whether the release is a single hazardous substance or
a mixture of hazardous substances. If the release is of
one or more single hazardous substances, follow the
directions provided below in Example A. If the release
is a mixture of hazardous substances, you have two
options. For a mixture you may complete Part C either:
1) by reporing each hazardous substance as if it were a
discrete and separate release (as in Example A); or 2)
by reporting the release as a mixture and identifying the
hazardous substance components of the mixture along
with information on the weighted contribution of each
component in the mixture (as in Example B).
Example A: Single hazardous substances
For each source, follow the directions below to
report each hazardous substance released from the
source that is a single hazardous substance or a
component of a mixture that you wish to report
separately. Exhibit 2-7 provides an example of how to
report releases of single hazardous substances.
1. Identify the hazardous substance released by
name and by Chemical Abstracts Service
Registry Number (CASRN). The CASRN for a
hazardous substance can be located in any
material safety data sheet or in most chemical
supplier company catalogues.
2. Provide the upper and lower bounds of the
normal range of the release from the identified
source (i.e., quantity in pounds, kilograms, or
curies) during the previous year.
3. Estimate the total annual amount (in pounds,
kilograms, or curies) of the hazardous substance
released from the identified source during the
previous year.
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TABLE 2-8: EXAMPLE OF REPORTING A MIXTURE
In this example, if your facility wants to report the release of a mixture of hazardous substances, you must list
each component of the mixture by hazardous substance and include its percentage by weight. For example, for
the release of mixture Z, you must provide the following information about its components, ethylene oxide,
acrolein, and 2,3,5-tri-chlorophenol:
Name of
Hazardous
Name of Suhstance
Weight
Normal Range of Normal Range of
Components Mixture
Upper Lower Upper Lower
Mixture Components CASRN# Percentage Bound Bound Bound Bound
Z (components listed below)
Z Ethylene 75218 10% 10 lbs Olbs
oxide
Z Acrolein 107028 15% 15 lbs Olbs
Z 2,3,5-tri-
chlorophenol 933788 20% 20 lbs 0 lbs
100lbs Olbs
Number of Total Quantity
Days Release of Mixture
Occurs
(Per year)
365
Released in
Previous Year
Months
Of the
Release
79,500 lbs All 12
Months
4. Specify the frequency of the release by indicating
the number of days the release occurs per year
from the identified source. Stating "continuous"
is not sufficient, as one source may be
continuously operating 365 days a year, while
another source may be continuously operating on
weekdays, 261 days a year.
5. Indicate the actual months the release occurs.
Example B: Mixture
For each source, follow the directions below to report
each mixture released from the source. Exhibit 2-8
provides an example on how to report a mixture.
1. Identify the mixture by name (e.g., Blue Pigment
#25).
2. Identify each hazardous substance component of
the mixture by name and CASRN,
3. Estimate the percentage by weight of each
hazardous substance component of the mixture.
4. Provide the upper and lower bounds (i.e.,
quantity in pounds, kilograms, or curies) of the
normal range of each hazardous substance
component of the mixture that was released from
this source. To calculate the upper bound of the
I
normal range of each hazardous substance
component, multiply the weight percentage of
each component by the upper bound quantity of
the mixture.
5. Provide the upper and lower bounds (i.e.,
quantity in pounds, kilograms, or curies) of the
normal range of the mixture that was released
from the identified source during the previous
year.
6. Specify the frequency of the release by indicating
the number of days the release occurs per year
from the identified source. Stating "continuous"
is not sufficient, as one source may be
continuously operating 365 days a year, while
another source may be continuously operating on
weekdays, 261 days a year.
7. Estimate the total annual quantity (in pounds,
kilograms, or curies) of the mixture that was
released from the identified source during the
previous year.
8. Indicate the actual months the release occurs.
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Section III: Hazardous Substance Information
XHIBIT 2-9: CALCULATION OF THE
SSI TRIGGER FOR A
HAZARDOUS SUBSTANCE
Hazardous
Substance
Source
Upper
Bound
Ammonia
Tank Vents
in Building #1
120 lbs.
Valves in
Building #5
115 lbs.
Upper Bound for Ammonia
235 lbs.'
* For purposes of this example, it is assumed that
the only sources of the ammonia release at the
facility are the Tank Vents in Building #1 and the
Valves in Building #5.
After you provide the required information for all
sources of continuous releases from your facility, you
must aggregate information of a hazardous substance
release from all sources to determine the SSI trigger
(upper bound of the normal range) for each hazardous
substance released at your facility.
The SSI trigger of a particular hazardous
substance is calculated by aggregating the upper
bounds of the hazardous substance released across all
sources at a facility.
If you are aggregating CERCLA hazardous
substance releases from separate, contiguous, or
adjacent facilities and reporting them in a single report,
aggregate the upper bound of the normal range of the
hazardous substance released from all sources at the
site to determine the SSI trigger. If you aggregate your
releases across facilities, the SSI trigger must also be
site-specific, not facility-specific. Aggregating releases
across facilities at the same site may reduce your
reporting burden; however, EPA will evaluate the risks
associated with the releases as if the releases were from
one facility.
To calculate the SSI trigger for each hazardous
substance you should:
1. List each specific source name and enter the
upper bound of the normal range of the release
from that source. If the identified hazardous
substance is a component of a mixture, enter the
upper bound of the normal range for that
component of the mixture (as determined in
Section II, Part C).
2. Aggregate the upper bound quantities from each
source of the release. Report these totals as the
SSI trigger for the hazardous substance. The
example that is provided in Exhibit 2-9 illustrates
the calculation of the SSI trigger for a release of
ammonia.
The above method for calculating the SSI trigger
of a hazardous substance assumes that all releases of
the same hazardous substance occur simultaneously
(i.e., over the same 24-hour period). To the extent that
the frequency of the release differs, you may adjust the
SSI trigger so that it more accurately reflects the.
frequency and quantity of the hazardous substance
released from all sources over a 24-hour period. The
SSI trigger in the final analysis must reflect the upper
bound of the normal range of the release, taking into
consideration all sources of the release at the facility.
The normal range of the release includes all continuous
releases previously reported or occurring over a 24-
hour period during the previous year.
Signed statement
After providing the information required in
Sections I through III, as described above, the person in
charge of the facility must sign a statement asserting
that the information provided is accurate and current to
the best of his or her knowledge. This statement must
be similar to the following:
"I certify that the hazardous substance releases
described herein are continuous and stable in quantity
and rate under the definitions in 40 CFR 302.8(a) or
355.4(a)(2)(iii) and that all submitted information is
accurate and current to the best of my knowledge."
In addition, the person in charge of the facility
must print clearly his/her name and position and date
the certification statement.
27
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2.4 Notifications of Statistically
Significant Increases
When do you submit SSI reports?
An SSI is an episodic release that must be
reported whenever the hazardous substance release
exceeds the continuous release SSI trigger (i.e., the
upper bound of the normal range of the release) within
a 24-hour period. The determination of whether a
release is an SSI should be based upon calculations or
estimation procedures that identify the release as
exceeding the upper bound of the reported normal
range of the continuous release. The person in charge
of a facility must report an SSI of a CERCLA
hazardous substance to the NRC, SERC, and LEPC,
and the owner or operator of a facility must report an
SSI of a non-CERCLA EHS to the SERC and LEPC, as
soon as the facility is aware that the release has
occurred.
Who must be notified?
If you are the person in charge, or owner or
operator, of the facility from which an SSI in a
continuous release occurs, you must telephone the
following government organizations:
• For CERCLA hazardous substances:
NRC
Toll-free telephone number:
1-800-424-8802;
Washington, DC area: 1-202-267-2675;
• For CERCLA hazardous substances and non-
CERCLA EHSs:
The SERC of any state likely to
be affected by the release; and
The LEPC of any area likely to be affected
by the release.
In addition to these notifications, under the
requirements of SARA Title III Section 304, you must
submit a written follow-up notice to the SERC and
LEPC. For information on the addresses and telephone
numbers of SERCs and LEPCs, contact the
RCRA/Superfund/EPCRA Hotline toll free at
1-800-424-9346. (See Exhibit 1-7 on page 14)
What type of information is required in SSI
reports?
In the telephone notification, the release should
be identified as an SSL For reports of releases of
CERCLA hazardous substances, the person in charge
of the facility should also provide the original CR-
ERNS number assigned by the NRC. This will ensure
that the SSI report is recorded correctly and evaluated
properly.
The person in charge will be asked to provide all
of the information required in an episodic release report
under CERCLA Section 103(a). An SSI is a type of
episodic release. It represents a release of a hazardous
substance above an RQ that has never been evaluated
or considered.
What are that requirements for modifying the SSI
trigger?
In the event that a particular continuous release at
a facility frequently exceeds the upper bound of the
normal range, the person in charge may want to modify
the previously established upper bound(s) of the
relevant hazardous substances as an alternative to
reporting successive SSIs.
To modify the SSI digger, you must report at
least one release as an SSI (to facilitate immediate
evaluation). During such a report, you may also notify
the government authorities of the new upper bound of
the release. For reports of CERCLA hazardous
substances, within 30 days of the telephone
notification, you must submit a written notification to
the EPA Regional Office in your geographical area,
describing the new normal range, the reason for the
change, and the basis for certifying that the release is
continuous and stable at the higher amount. A
modification of the SSI trigger is a type of change in
source or composition and therefore is reported as a
new release under the "old" CR-ERNS number.
Although it is not required, it is also advised that you
notify the appropriate SERC and LEPC.
28
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2.5 Reports of Changed Releases
Where and when do you submit reports of changed
releases?
The person in charge of the facility must notify
the appropriate government authorities if there are any
of the following changes in a continuous release.
Change in Source or Composition
If there is a ;ange in the source(s) or
composition of a continuous release, the release is
considered a "new" release. A change in the source(s)
or composition of a release may be caused by factors
such as equipment modifications or process changes.
The new release may pose a hazard that warrants
timely evaluation and, therefore, to report this new
release under CERCLA Section 103(f)(2), you must
establish the new release as continuous and stable in
quantity and rate (i.e., for CERCLA hazardous
substances, call the NRC, SERC, and LEPC; for non-
CERCLA EHSs, call the SERC or LEPC; and in both
cases, submit a new initial written report and follow-up
report).
For CERCLA hazardous substances, when you
make the initial telephone call to the NRC, provide
your original CR-ERNS number. When submitting
your new written initial report to the EPA Regional
Office, SERC, and LEPC (for a report of a release of a
CERCLA hazardous substance), or only the SERC and
LEPC (for a report of a release of a non-CERCLA
EHS), be certain to specify whether you are adding a
new source(s), deleting a source(s), or modifying the
list of hazardous substances previously reported. In
addition, if your change report includes information
that has already been submitted, please clearly
differentiate between the new or changed information
and the previously reported information by either
placing a check mark in the left hand margin,
highlighting the information, or using any other means
to identify the changed or new information. It is
important to clearly identify new or changed
information.
Please note that each time you submit a written
report of a change in the source or composition of a
release, you must recalculate the upper bound of the
normal range for each affected hazardous substance.
For example, if you add a source from which two
single hazardous substances (i.e., HS #1 and HS #2) are
released and you have previously reported releases of
these same substances from other sources, you must
recalculate, in Section III of the reporting format, the
upper bound of the normal range for both HS #1 and
HS #2. To obtain the new upper bound for HS #1, you
must add the upper bound of HS #1 released from the
new source to the upper bound of HS #1 released from
all other sources at your facility. The new upper bound
for HS #2 should be calculated in a similar manner.
Other Changes
If there is a change in the information submitted
in the initial written or follow-up reports of a release of
a CERCLA hazardous substance (other than a change
in the source or composition of the release) the person
in charge must notify the EPA Regional Office in
writing within 30 days of determining that the
information submitted previously is no longer valid.
One example of a change in the information submitted
previously, other than a change in the source or
composition of the release, is a change in ownership in
the facility.
AH notifications of changes in releases of
CERCLA hazardous substances must include the CR-
ERNS number assigned by the NRC in your initial
telephone notification that identifies the facility. You
must also include a signed statement (see page 27 of
this Guide) certifying that the release is continuous and
stable in quantity and rate, and that all the reported
information on the release is accurate and current.
Although not required, it is advised that the
appropriate SERC and LEPC be notified of any
changes in other information regarding release of either
CERCLA hazardous substances or non-CERCLA
EHSs.
29
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2.6 Summary
Prior to sending your report to the appropriate
government authorities, ensure that you have:
1. Included the original CR-ERNS number
identifying your facility on each page of the
report, if applicable;
2. Completed all information requested in Sections
1,11, and III;
3. Included supplementary pages, if needed. (It
would be helpful to number the additional pages
of information submitted sequentially in
accordance with the sections and subsections of
the reporting format (e.g., Section II, Part A, page
2).)
4. Indicated the appropriate units (e.g., meters,
kilograms, or curies), in all sections;
5. Provided a unique name for each source
identified and have indicated the source name on
Parts A, B, and C of Section II;
6. Included the certification statement and signed
the report; and
7. Made sufficient copies of the report for your files.
-------
APPENDIX A
ACRONYMS
-------
CASRN
CERCLA
CFR
CR-ERNS
EHS
EPA
EPCRA
FR
LEPC
NRC
RQ
SARA
SERC
SSI
TERC
TRI
VNTSC
ACRONYMS
Chemical Abstracts Service Registry Number
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
Code of Federal Regulations
Continuous Release Emergency Response Notification System
Extremely Hazardous Substance
Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act
Federal Register
Local Emergency Planning Committee
National Response Center
Reportable Quantity
Superfund Amendments and Reauthorization Act of 1986
State Emergency Response Commission
Statistically Significant Increase
Tribal Emergency Response Commission
Toxic Release Inventory
John A. Volpe National Transportation Center
-------
APPENDIX B
SUGGESTED CONTINUOUS RELEASE REPORTING FORMAT (BLANK)
-------
SECTION I: GENERAL
INFORMATION
CR-ERNS Number:
Date of Initial Release:
Date of Initial Call to NRC:
T^pe of Report: Indicate below the type of report y
First Anniversary
| | Initial Written Notification Follow-up
Report
ou are submitting.
Written Notification Written Notification
of a Change to of a Change to
initial Notification Follow-up Report
Signed Statement: I certify that the hazardous substances releases described herein are continuous and stable in
quantity and rate under the definitions in 40 CFR 302.8(a) or 355.4(a)(2)(iii) and that all submitted information is
accurate and current to the best of my knowledge.
Name and Position
Date
Signature
Part A. Facility or Vessel Information
Name of Facility or Vessel
Person
in Charge
of Facility
or Vessel
Facility
Address or
Vessel
Port of
Registration
Name of Person in Charge
Position
Telephone No. ( )
Alternate Telephone No. ( )
Street
City
County
State
Zip Code
¦¦
Dun and Bradstreet Number for Facility I
Imi
Facility/Vessel
Location
PartB. Popu
Latitude
Longitude
Deg
Deg
Min
Min
Sec
Sec
Vessel LORAN Coordinates
ation Information
Population
Density
Sensitive
Populations
and
Ecosystems
Within One
Mile Radius
Choose the range that describes the population density within a one-mile radius of your facility or vessel
(Indicate by placing an "X" in the appropriate blank below).
0-50 persons 101 - 500 persons more than 1000 persons
51-100 persons 501 - 1000 persons
Sensitive Populations or Ecosystems
(e.g., schools, hospitals, wetlands, wildlife preserves, etc.)
Distance and direction from facility
-------
SECTION II: SOURCE
INFORMATION
CR-ERNS Number:
Part A: Basis for Asserting the Release is Continuous and Stable In Quantity and Rate.
For EACH source of a release of a hazardous substance or mixture from your facility or
vessel, provide the following information on a SEPARATE sheet. Photocopy this page if
necessary.
Name of Source:
1. Indicate whether the release from this source is either:
continuous without interruption OR routine, anticipated, intermittent
2. Identify the activity(ies) that results in the release from this source (e.g., batch process, filling of a storage tank).
If malfunction, describe the malfunction and explain why the release from the malfunction should be considered
continuous and stable in quantity and rate.*
3. Identify below how you established the pattern of release and calculated release estimates.
Past release data Knowledge of the facility/vessel's Engineering estimate
operations and release history
AP-42 Best professional judgment Other (explain)
* Note that unanticipated events, such as spills, pipe ruptures, equipment failures, emergency shutdowns, or accidents,
do not qualify for reduced reporting under CERCLA section 103(f)(2). Unanticipated events are not incidental to
normal operations and, by definition, are not continuous or anticipated, and are not sufficiently predictable or regular
to be considered stable in quantity and rate.
-------
SECTION II:
SOURCE
INFORMATION
(continued)
Name of Source:
Part B: Specific Information on the Source
For the source identified above, provide the following information. Please provide a SEPARATE
sheet for EACH source. Photocopy this page if necessary.
AFFECTED MEDIUM, Identify the environmental medium (i.e., air, surface water, soil, or ground water) that is
affected by the release from this source. If your source releases hazardous substances to more than one medium (e.g., a
wastepile releasing to air and ground water), treat the release to EACH medium as a separate source and complete
Section II, Parts A, B, and C, of this format for EACH medium affected.
O AIR (stack or area ) If the medium affected is air, please also specify whether the
source is a stack or a ground-based area source.
If identified source is a stack, indicate stack height: feet or meters; OR
If identified source is an area source (e.g., waste pile, landfill, valves, tank vents, pump seals, fugitive
emissions), indicate surface area: square feet or square meters.
O SURFACE WATER (stream , lake , or other )
If the release affects any surface water body, give the name of the water body.
If the release affects a stream, give the stream order or average flow rate, in cubic feet per second,
stream order: or average flow rate: cubic feet/second; OR
If the release affects a lake, give the surface area of the lake in acres and the average depth in meters,
surface area of lake: acres and average depth of lake: meters.
O SOIL OR GROUND WATER
If the release is on or under ground, indicate the distance to the closest water well.
Optional Information
The following information is not required in the final rule; however, such information will assist EPA in
evaluating the risks associated with the continuous release. If this information is not provided, EPA will
make conservative assumptions about the appropriate values. Please note that the units specified below
are suggested units. You may use other units; however, be certain that the units are clearly identified.
For a stack release to air, provide the following
information, if available:
Inside diameter feet or meters
Gas Exit Velocitv feet/second or
meters/second
Gas Temperature decrees Fahrenheit.
Kelvin, or Celsius
For a release to surface water, provide the
following information, if available:
Average Velocitv feet/second
of Surface Water
-------
SECTION II: SOURCE INFORMATION
(continued)
CRERNS Number:
Part C. Identity and Quantity of Each Hazardous Substance or Mixture Released From Each Source
Please provide a SEPARATE sheet for EACH source. Photocopy this page if necessary.
Name of Source:
List each hazardous substance released from the source identified above and provide the following information. (For an example, see Table 1 of
Reporting Requirements for Continuous Releases of Hazardous Substances - A Guide for Facilities and Vessels on Compliance.)
Normal Range Number of Days Total Quantity
(in lbs. or kg per day)* Release Occurs Released in Previous Year Months of the
Name of Hazardous Substance CASRN # Upper Bound Lower Bound (per veart fin lbs, or kg)* Release
List each mixture released from the source identified above and provide the following information. (For an example, see Table 2 of Reporting
Requirements for Continuous Releases of Hazardous Substances - A Guide for Facilities and Vessels on Compliance.)
Name of Mixture
Name of
Hazardous
Substance
Components
CASRN#
Normal Range of
Components
(in lbs. or kg per day)*
Weight Upper Lower
Percentage Bound Bound
Normal Range of
Mixture
(in lbs. or kg per day)*
Upper Lower
Bound Bound
Number of Total Quantity of
Days Release Mixture Released Months
Occurs in Previous Year of the
(per year) fin lbs, or kg) Release
* Please be sure to include units where appropriate. Also, if the release is a radionuclide, units of curies (CI) are appropriate.
-------
SECTION III: SUBSTANCE
INFORMATION
CR-ERNS Number:
Calculation of the SSI Trigger
For EACH hazardous substance or hazardous substance component of a mixture indicated in
Section II, Part C, list the names of the releasing sources and their upper bounds. Please use a
SEPARATE sheet for EACH hazardous substance. Photocopy this page if necessary.
Name of Hazardous Substance:
To calculate the SSI trigger (i.e., the upper bound of the normal range of a release) for the hazardous substance
identified above, aggregate the upper bounds of the normal range of the identified hazardous substance across all
sources identified in Section II, Part C. If the hazardous substance is also a component of a mixture, be certain to
include the upper bound of the component as calculated in Section II, Part C, in your calculation of the SSI trigger.
Name of Source(s) Upper Bound of the Normal Ranee of
the Release (specify lbs,, kg, or CD
TOTAL - SSI trigger for this hazardous substance release*
* This method for calculating the SSI trigger for the hazardous substance assumes that all releases of the
same hazardous substance or mixture occur simultaneously. To the extent that a hazardous substance is
released from your facility from different sources and at different frequencies, you may adjust the SSI
trigger as appropriate, so that it more accurately reflects the frequency and quantity of the release. The
SSI trigger in the final analysis must reflect the upper bound of the normal range of the release, taking
into consideration all sources of the release at the facility or vessel. The normal range of the release
includes all releases previously reported or occurring over a 24-hour period during the previous year.
-------
APPENDIX C
SUGGESTED CR-ERNS REPORTING FORMAT » ADDENDUM TO TRI FORM R (BLANK)
-------
CR-ERNS Report — Addendum to Form R
This Form serves as an addendum to EPCRA Section 313 Toxic Release Inventory (TRI)
Form R. This along with EPCRA 313 Form R will provide EPA with the required
information for reporting continuous releases.
Name of Facility:
CR-ERNS #:
Type of Report: Indicate below the type of report you are submitting,
First
Anniversary
Initial
Written
Report
Follow-up
Report
Written Notification
of a Change to Initial
Written Report
Written Notification
of a Change to
Follow-up Report
Signed Statement: I certify that the hazardous substances releases described herein are continuous
and stable in quantity and rate under the definitions in 40 CFR 302.8(a) or 355.4(a)(2)(iii) and that all
submtted information is accurate .and current to the best of my knowledge.
Name and Position
Date
Signature
Population Density: Choose the range that describes the population density within a one-mile radius of
your facility.
0-50 people
51-100 people
101 -500 people
501- 1000 people
Over 1000 people
Sensitive Populations and Ecosystems: Indicate all sensitive populations and ecosystems within a
one-mile radius include the distance and direction from the facility.
Sensitive Population or Ecosystems
Distance and direction from facility
Pace I 9/97
-------
CR-ERNS Report — Addendum to Form R
CR-ERNS #:
Source Information: For EACH source of a release from your facility, provide the following information
on a SEPARATE sheet.
Name of Source:
Indicate whether the release from this source is either:
continuous without interruption OR routine, anticipated, intermittent
Pattern of the Release: Identify below how you established the pattern of release and calculated
release estimates.
Past rftleasft Hat a
Knowledge of the facility's
F.ngineexing F.stimatps
operations and release history
AP-4?
Rest professional judgement
Other (explain)
Environmental Medium affected by the release from this source:
Air Surface Water
Soil or Ground Water
Air
Surface
Water
If release is to air, please indicate stack height OR surface area of the release.
Stack Height OR Surface Area
If release is to Surface Water, please indicate name, type and specific information
of the water body:
Name of water body .
If stream: Stream Order OR Average flow rate (ft3/sec)
If lake: Surface area (ac) AND Average Depth (m)
Soil or
Ground Water
Indicate distance of closest water well:
Hazardous Substance Information:
Name of Hazardous
Substance: CASRN*
Upper Lower
Bound Bound
(in lbs. or kg per day)
Number of
Days Release
Occurs (per year)
Months of
the Release
Page 2 9/97
-------
APPENDIX D
COMPLETED SUGGESTED CONTINUOUS RELEASE REPORTING FORMAT
-------
SECTION I: GENERAL INFORMATION
CR-ERNS Number:
900004
Date of Initial Release: JaIuar7 30' 1995
Date of Initial Call to NRC: January 3J;95
Type of Report: Indicate below the type of report you are submitting.
First Anniversary Written Notification
1 1 Initial Written Notification [_J Follow-up FH of a Change to X
Report Initial Notification
Written Notification
of a Change to
Follow-up Report
Signed Statement: I certify that the hazardous substances releases described herein are continuous and stable in
quantity and rate under the definitions in 40 CFR 302.8(a) or 355.4(a)(2)(iii) and that all submitted information is
accurate and current to the best of my knowledge.
CR-ERNS Reporter; Vice President
Name and Position
July 26, 1996
Date ¦ Signature
Part A. Facility or Vessel Information
Name of Facility or Vessel
Person
in Charge
of Facility
or Vessel
Facility
Address or
Vessel
Port of
Registration
Dun and Bradstreet Number for Facility
Delta Transport Co. / Railcar & Trucking Facility
Name of Person in Chaise CR- ERN S
Reporter
Position Vice president
Telephone No. (444)999-1234
Alternate Telephone No. &44 )999-i200
Street 1001 Truck - Sail Laae
County Culberson
City Transfer
State TK Zip Code 77252
04-123-4567
Facility/Vessel
Location
Latitude
Dee 31
Min
40
Sec 25
Vessel LORAN Coordinates
Longitude
Dee 104
Mia
07
Sec 57
Part B. Population Information
Population
Density
Sensitive
Populations
and
Ecosvstems
Within One
Mile Radius
Choose die range describes die population density within a one-mile radius of your facility or vessel
(Indicate by placing an "X" in the appropriate blank below).
" _ 0-50 persons 101 - 500 persons more than 1000 persons
SI -100 persons x 501 - 1000 persons
Sensitive Populations or Ecosystems
(e g., schools, hospitals, wetlands, wildlife preserves, etc.)
Distance and direction from facility
Cowboy State Park
Sunset Daycare Center
1/2 aile SW
3/4 mile N
-------
SECTION XI: SOURCE
INFORMATION
CR-ERNS Number
900004
Part A: Basis for Asserting the Release is Continuous and Stable in Quantity and Rate.
For EACH source of a release of a hazardous substance or mixture from your facility or
vessel, provide the following information on a SEPARATE sheet Photocopy this page if
necessary.
Name of Source? Fugitive Emissions - Truck Loading / Unloading
1. Indicate whether the release from this source is either
continuous without interruption OR routine, anticipated, intermittent
2. Identify the activity(ies) that results in the release from this source (e.g^ batch process, filling of a storage tank).
If malfunction, describe die malfunction and explain why the release from the malfunction should be considered
continuous and stable in quantity and rate.*
Emissions from valves, 0-rings, and seals.
3. Identify below how you established die pattern of release and calculated release estimates.
~
Past release data Knowledge of the facility/vessel's Engineering estimate
operations and release history
AP-42 x Best professional judgment Other (explain)
* Note that unanticipated events, such as spills, pipe ruptures, equipment ftzilures, emergency shutdowns, or accidents,
do not qualify for reduced reporting under CERCLA section 103(f)(2). Unanticipated events are not incidental to
normal operations and. by definition, are not continuous or anticipated, and are not sufficiently predictable or regular
to be considered stable in quantity and rate.
-------
SECTION II: SOURCE
INFORMATION
(continued)
CR-ERNS Number
900004
J Name of Source: fugitive Emissions
- Truck Loading / Unloading I
Part B: Specific Information on the Source
For the source identified above, provide the following information. Please provide a SEPARATE
sheet for EACH source. Photocopy this page if necessary.
AFFECTED MEDIUM Identify the environmental medium (i.e., air, surface water, soil, or ground water) that is
affected by rise release from this source. If your source releases hazardous substances to more one medium (e.g., a
wastepile releasing to air and ground water), treat the release to EACH medium as a separate source and complete
Section IL Parts A, B, and C, of this format for EACH medium affected.
O AIR y (stack or area x ) If the medium affected is air, please also specify- whether the
source is a stack or a ground-based area source.
~ If identified source is a stack, indicate stack height: feet or meters; OR
« If identified source is ail area source (e.g.. waste pile, landfill, vaives, tank vents, pump seals, fugitive
emissions), indicate surface area: 18 ^quarejegpor square meters.
® SURFACE WATER (stream .lake .or other )
• If the release affects any surface water body, give the name of the water body.
• If the release affects a stream, give the stream order or average flow rate, in cubic feet per second,
stream order or average flow rate: cubic feet/second; OR
• Iftfae release affects a lake, give the surface area ofthe lake in acres and the average depth in meters,
surface area of lake: acres and average depth of lake: meters.
© SOIL OR GROUND WATER
If the release is on or under ground, die distance to the closest water well.
Optional Information
The following information is not required in the final rule; however, such information will assist EPA in
evaluating the risks associated with tfae continuous release. If tins information is not provided, EPA will
make conservative assumptions about the appropriate values. Please note that the units specified below
are suggested units. You may use other units; however, be certain that the units are clearly identified.
For a stack release to air. provide the following
information, if available:
Inside diameter feet or meters
Gas Exit Velocitv feet/second or
meters/second
Gas Temperature degrees Fahrenheit,
Kelvin, or Celsius
• For a release to surface water, provide the
following information, if available:
Averaee \felocitv fees/second
of Surface Water
-------
CR-ERNS Number
900004
SECTION II: SOURCE INFORMATION
(continued)
Part C. Identity and Quantity of Each Hazardous Substance or Mixture Released From Each Source
Please provide a SEPARATE sheet for EA CH source. Photocopy this page if necessary.
Name of Source: Fugitive Emissions - Truck Loading / Unloading
List eacli mixture released from the source identified above and provide the following information. (For nn example, see Table 2 of Reporting
Requirements for Continuous Releases of Hazardous Substauces - A Guide for Facilities and Vessels on Compliance.)
Normal Range of Normal Range of
Name of Components Mixture
Hazardous (in lbs. or kg per day)* (in lbs. or kg per day)
Substance Weight Upper Lower Upper Lower
Name of Mixture Components CASRNff Percentage Bound Bound Bound Bound
Normal Range of
Components
(in lbs. or kg per day)'
Upper Lower
Total Quantity of
Number Mixture Released Months
of Releases iu Previous Year of the
(per year) (in lbs, or kp) Release
Name of Hazardous Substance CASRN H
Acetaldehyde
List each hazardous substance released from (lie source identified above and provide the following information. (For an example, see Table I of
Reporting Requirements for Continuous Releases of Hazardous Substances
Normal Range
(iirijjipbr kg per day)*
Upper Bound Lower Bound
75070 1,007.A 2.33
Benzene
71432
46.3
A Guide for Facilities and Vessels on Compliance.)
Number
of Rclcnses Released in^previous Year
(per year)
240
350
Total Quantity
16,200.90
Months of
the Release
Jnn, Feb, Apr,
May, June, Aug,
Sept, Nov
All
* Please be sure to include units where appropriate. Also, if the relet'::" is a radionuclide, units of curies (('I) are appropriate.
-------
SECTION II: SOURCE
INFORMATION
CR-ERNS Number
900004
Part A: Basis for Asserting the Release is Continuous and Stable in Quantity and Rate.
For EACH source of a release of a hazardous substance or mixture from your facility or
vessel* provide the following information on a SEPARATE sheet. Photocopy this page if
necessary.
Name Of Source: North Stack - Transfer Storage Shed
1. Indict* whether the release from source is either:
continuous without interruption X OR routine, anticipated, intermittent
2. Identify the activities) that results is the release from this source (e.g^ batch process, fining of a storage tank)
If maifimction, describe the malfunction and explain why the release from the malfunction should be considered
continuous and stable in quantity and rate *
The intermediate storage between transfer stations.
3. Identify bdow how you established the pattern of release calculated release estimates.
Past release
Knowledge of the facility/vessel's
y Engineering estimate
operations and release history
AP-42
X Best professional judgment
Other (explain)
• Note that unanticipated events. such as spills, pipe ruptures, equipment failures. emergency shutdowns, or accidents,
do not qualify for reduced reporting under CERCLA section 103(f)(2). Unanticipated events am not incidental to
normal operations and. by definition, an not continuous or anticipated, and are not sufficiently predictable or regular
to be considered stable m quantity and rate.
-------
SECTION II: SOURCE
INFORMATION
(coqitinued)
CR-ERNS Number
900004
Name of Source: North Stack - Transfer
Storage Shed
I
Part B: Specific Information on the Source
For the source identified above, provide the following information. Please provide a SEPARATE
sheet for EACH source. Photocopy this page if necessary.
AFFECTED MEDIUM. Identify the environmental medium (i.e., air, surface water, soil, or ground water) that is
affected by the release from this source. If your source releases hazardous substances to more than one medium (e.g.. a
wastepile releasing to air and ground water), treat the release to EACH medium as a separate source and complete
Section Q, Parts A. B, and C. of this format for EACH medium affected.
O AIR X (stack X or area ) If the medium affected is air, please also specify whether the
source is a stack or a ground-based area source.
• If identified source is a stack, indicate stack height: is meters; OR
• If identified source is an area source (e.g., waste pile, landfill, valves, tank vents, pump seals, fugitive
emissions), indicate surface area: square feet or square meters.
© SURFACE WATER (stream , lake , or other )
• If the release afiects any surface water body, give the name of the water body.
If the release afiects a stream, give the stream order or average flow rate, in cubic feet per second,
stream order or average flow rate: cubic feet/second; OR
If die release afiects a lake, give the surface area of die lake in acres and the average depth in meters,
surface area of lake: acres and average depth of lake: meters.
© SOIL OR GROUND WATER
If die release is on or under ground, indicate die distance to the closest water well.
Optional Information
The following infisnaticn is not required in die final rale; however, such information will assist EPA in
evaluating the risks associated with the continuous release. If tins information is not provided, EPA will
make conservative assumptions about the appropriate values. Please note that the units specified below
are suggested units. You may use other units; however, be certain that the units are clearly identified.
V
For a stack release to air. provide the following
information, if available:
Inside diameter -1-*7
Gas Exit Velocity
.degree^^Sieohe^)
Kelvin, w i-elstus
'second or
For a release to surface water, provide die
following information, if available:
Average Velocity' feetfcecond
of Surface Water
y
-------
Cll-KRNS Number
900004
SECTION II: SOURCE INFORMATION
(continued)
Part C. Identity anil Quantity of Each Hazardous Substance or Mixture Released From Each Source
Please provide a SEPARATE sheet for EACH source. Photocopy this page if necessary.
Name of Source: Nprth Stack - Transfer Storage Shed
List each hazardous substance released from the source identified above and provide the following information. (For an exnuiple, sec Table I of
Reporting Requirements for Continuous Releases of Hazardous Substances - A Guide for Facilities and Vessels on Compliance.)
Name of Hazardous Substance
CASRN#
Normal Range
(iiiQbjpar kg per day)*
Upper Bound Lower Bound
Number
of Releases
(per year)
Total Quantity
Released in-Rrcviotis Year
(!t%>kg)!
Months of
the Release
Acetaldehyde
75070
14.4 0
365
4,500
All
Benzene
71432
39 0
365
9,200
All
Acrolein
107028
2.5 0
365
570
All
List each mixture released from the source identified above and provide the following information. (For an example, see Table 2 of Reporting
Requirements for Continuous Releases of Hazardous Substances - A Guide for Facilities and Vessels on Compliance.)
Name of Mixture
Name of
Hazardous
Substance
Components
CASRN#
Normal Range of
Components
(in lbs, or kg per day)*
Weight Upper Lower
Percentage Bound Bound
Normal Range of
Mixture
(in lbs. or kg per day)*
Upper Lower
Bound Bound
Total Quantity of
Number Mixture Released Months
of Releases in Previous Year of the
(per year) (in lbs, or kg) Release
~ Please be sure to include units where appropriate. Also, if the release is a radionuclide. writs of curies (I 'I) arc appropriate.
-------
SECTION II: SOURCE
INFORMATION
CR-ERNS Number
900004
Part A; Basis for Asserting the Release is Continuous and Stable in Quantity and Rati*.
For EACH source of a release of a hazardous substance or mixture from your facility or
vessel, provide the following information on a SEPARATE sheet. Photocopy this page if
necessary.
Name of Source: South Stack - Transfer Storage Shed
1. indicate whether the release from this source is either.
continuous without interruption x OR routine, anticipated, intermittent .
2. Identify the activities) that results in the release from this source (e.g_ batch process, filling of a storage tank).
If malfunction, describe the matfonctkn and explain why the release from the malfunction should be considered
continuous and stable in quantity and me.*
The intermediate storage between transfer stations.
3. Identify below how you established the pattern of release and calculated release estimates.
Past release Knowledge of the facility/vessel's X Engineering estimate
operations and release histoty
AP-42 x Best professional judgment Other (explain)
* Note that unanticipated events, such as spills, pipe ruptures, equipment failures, emergency shutdowns, or accidents,
do not qualify for reduced reporting under CERCLA section 103(f)(2). Unanticipated events are not incidental to
normal operations and. by definition, are not continuous or anticipated, and em not sufficiently predictable or regular
to be considered stable in quantity and rate.
-------
SECTION II: SOURCE
INFORMATION
(continued)
CR-ERNS Number
900004
j Name of Source: South Stack ~ Transfer Storage Shed |
Part B: Specific Information on the Source
For the source identified above, provide the following information. Please provide a SEPARATE
sheetfor EACH source. Photocopy this page if necessary.
AFFECTED MEDIUM. Identify the environmental medium (i.e., air, surface water, soil, or ground water) that is
affected by the release from this source. If your source releases hazardous substances to more than one medium (e.g.. a
wastepile releasing to air and ground water), treat die release to EACH medium as a separate source and complete
Section II, Parts A, B, and C, of this format for EACH medium affected.
O AIR X_ (stack X or area ) If the medium affected is air, please also specify whether the
source is a stack or a ground-based area source.
• If identified source is a stack, indicate stack height: 15 feetar meters; OR
• If identified source is an area source (e.g., waste pile, landfill, valves, tank vents, pump seals, fugitive
emissions), indicate surface area: square feet or square meters.
© SURFACE WATER (stream ,lake ,or other )
• If the release affects any surface water body, give die name of tbe water body.
• If the release affects a stream, give the stream order or average flow rate, in cubic feet per second,
stream order or average flow rate: cubic feet/secood; OR
• If the release affects a lake, give the surface area of die lake in acres and the average depth in meters,
surface area of lake: acres and average depth of lake: meters.
© SOIL OR GROUND WATER
If die release is on or under ground, indicate the distance to the closest water well.
Optional Information
The following information is not required in the final rule; however, such information will assist EPA in
evaluating the risks associated with the continuous release. If this information is not provided, EPA will
make conservative assumptions about tbe appropriate values. Please note that the units specified below
are suggested units. You may use other units; however, be certain that the units are clearly identified.
For a stack release to air. provide the following
information, if available:
Inside diameter meters
Gas Exit Velocity 6»9 jfeetlsccond or
meters/seeead-^^
Gas Temoerature 193 deweetFahrenheiO,
Keivin, or' Celsius
• For a release to surface water, provide the
following information, if available:
Avetase Vdocitv feet/secood
of Surface Water
-------
SECriON II: SOURCE INFORMATION
(continued)
CR-EKNS Number
900004
Part C. Identity ail J Quantity of Each Hazardous Substance or Mixture Released From Each Source
Please provide a SEPARATE sheet for EACH source. Photocopy this page if necessary.
Name of Source; §outh Stack - Transfer Storage Shed
List each linznnlous substance released front (lie source identified above nud provide tiic following information. (Far an example, see Table I of
Reporting Requirements for Continuous Releases of Hazardous Substances - A Guide for Facilities and Vessels on Compliance.)
Name of 1 lazardous Substance
CASRNH
Normal Range
\in IbS j&r kg per day)*
UppcMJomid Lower Bound
Number
of Releases
(per vcar)
Total Quantity
RcleascdjtuPrevious Year
(in^lbs^or kg)*
Months of
the Release
Acetaldehyde
75070
14.4
0
365
4,500
All
Benzene
71432
39
0
365
9,200
All
Acrolein
107028
2.5
0
365
570
All
List each mixture released from the source identified above and provide the following information. (For nit example, see Table 2 of Reporting
Requirements for Continuous Releases of Hazardous Substances - A Guide for Facilities and Vessels on Compliance.)
Name of Mixture
Name of
Hazardous
Substance
CASRNfl
Normal Range of
Components
(in lbs. or kg per day)*
Weight Upper Lower
Percentage Bound Bound
Normal Rnitgc of
Mixture
(in lbs. or kg per day)*
Upper Lower
Bound Bound
Total Quantity of
Number Mixture Released Months
of Releases in Previous Year of the
fner year) fin lbs, or kg) Release
* I'lease be sure to include units where appropriate. Also, if the release is a radionuclide. units of curies (( I) are appropriate.
-------
SECTION II: SOURCE
INFORMATION
CR-ERNS Number
900004
Part A: Basis for Asserting the Release is Continuous and Stable in Quantity and Rate
For EACH source of a release of a hazardous substance or mixture from your facility or
vessel, provide the following information on a SEPARATE sheet. Photocopy this page if
necessary.
Name of Source: Fugitive Emissions - Stockpiles
1. Indicate whether the release from this source is either:
continuous without interruption X OR routine, anticipated, intermittent
2. Identify the activity(ies) that resuhs in the release from this source (e.g_ batch process, filling of a storage tank).
If malfunction, describe the malfunction and explain why the release from the malfunction should be considered
continuous and stable in quantity and rate *
Stockpile storage emissions prior to railcar transportation.
3. Identify bdow how you established the pattern of release and calculated release estimates.
Past release data
Knowledfise of die facility/vessel's
X Fngitwring estimate
operations and release history
AP-42
^ Best professional judgment
Other (explain)
Analytic test data
* Mote that unanticipated events, suck as spills, pipe ruptures, equipment failures, emergency shutdowns, or accidents,
do not qualify for reduced reporting under CERCLA section 1030(2). Unanticipated events are not incidental to
normal operations and. by definition, am not continuous or anticipated, and are not sufficiently predictable or regular
to be considered stable in quantity and rate.
-------
SECTION II: SOURCE
INFORMATION
(continued)
CR-ERNS Number
900004
Name of Source; Fugitive Emissions - Stockpiles
Part B: Specific Information on the Source
For the source identified, above, provide the following information. Please provide a SEPARATE
sheet for EACH source. Photocopy this page if necessary.
AFFECTED MEDIUM. Identify the environmental medium {i.e., air, surface water, soil, or ground water) that is
affected by the release from this source. If your source releases hazardous substances to more than one medium (e.g., a
wastepile releasing to air and ground water), treat the release to EACH medium as a separate source and complete
Section II, Parts A, 8, and C. of this format for EACH medium affected.
O AIR r (stack or area x ) If the medium affected is air, please also specify whether the
source is a stack or a ground-based area source.
• If identified source is a stack, indicate stack height: feet or meters; OR
• If identified source is an area source (e.g., waste pile, landfill, valves, tank vents, pump seals, fugitive
emissions), indicate surface area: 10 squnrr fhr nr rqttars meters. Square kilometers
© SURFACE WATER (stream ,Iake ,or other.
.)
If the release affects any surface water body, give the name of the water body.
If the release affects a stream, give the stream order or average flow rate, in cubic feet per second,
stream order or average flow rate: cubic feet/second: OR
If the release affects a lake, give the surface area of the lake in acres and the average depth in meters,
surface area of lake: acresand average depth of lake: meters.
© SOIL OR GROUND WATER
If the release is on or under ground, indicate the distance to the closest water well.
Optional Information
The following information is not required in the final rule; however, such information will assist EPA in
evaluating the risks associated with the continuous release. If this information is not provided, EPA will
make conservative assumptions about the appropriate values. Please note that the units specified bdow
are suggested units. You may use other units; however, be certain thai the units are dearly identified.
For a stack release to air. provide the following
infonnatioa, if available:
Inside diameter feet or meters
Gas Exit Velocity feet/second or
meters/second
Gas TcmDcranire degrees Fahrenheit.
Kelvin, or Celsius
• For a release to surface water, provide the
following information, if available:
Averaae \Wocitv feet/second
of Surface Water
.y
-------
CR-ERNS Number
900004
SECTION II: SOURCE INFORMATION
(continued)
Pari C, Identity and Quantity of Each Hazardous Substance or Mixture Released From Each Source
Please provide a SEPARATE sheet for EACH source. Photocopy this page if necessary,
Name of Source; fugitive Emissions - stockpile
List each mixture released from the source identified above and provide the following information. (For mi example, see Table 2 of Reporting
Requirements for Continuous Releases of Hazardous Substances - A Guide for Facilities and Vessels on Compliance.)
Normal Range of
Name of Components
Hazardous (in-Jbs. or kg par day)'
Substance Weight Upper Lower
Name of Mixture Components CASRN# Percentage JJottiuJ Boyiic)
Stockpile
Cesium-134 3967709 1.5% 3.7 cl 0
Thorlum~232 7440291 17%
Radium-226 13982633 7.5%
Weight
Percentage JJmiiuJ Boyiic)
1.8 cl
Normal Range of
Mixture
(mlbsr or kg-per-dny)'
Upper Lower
Qoijiid Bound
25ci Oci
Total Quantity of
Number Mixture Released
of Releases in Previous Year
(per year) tiybsretidU
365
1,500 ei
Months
of (lie
Release
All
List cncli hazardous substance released from the source identified above and provide the following information. (For an example, sec 'I able I of
Reporting Requirements for Continuous Releases of Hazardous Substances
Normal Range
(in lbs. or kg per day)*
Name of Hazardous Substance CASRN M Upper Bound Lower Bound
A Guide for Facilities and Vessels on Compliance.)
Number
of Releases Released in Previous Year
(per year)
Months of
the Release
* I'lease he sure to include units wlwiv appropriate. Also, if the release is a radionuclide, units of curies {('I) are appropriate.
-------
SECTION III: HAZARDOUS
SUBSTANCE
INFORMATION
CR-ERNS Number
900004
Calculation of the SSI Trigger
For EACH hazardous substance or hazardous substance component of a mixture indicated in
Section II, Part C, list the names of the releasing sources and their upper bounds. Please use a
SEPARATE sheet for EACH hazardous substance. Photocopy this page if necessary.
Name of Hazardous Substance:
To calculate the SSI trigger (i.e.. the upper bound of the normal range of a release) for the hazardous substance
identified above, aggregate the upper bounds of the normal range of the identified hazardous substance across all
sources identified in Section U, Part C. If the hazardous substance is also a component of a mixture, be certain to
include the upper bound of the component as calculated in Section H, Part C, in your calculation of the SSI trigger.
TOTAL - SSI trigger for this hazardous substance release* : 3«7 ci
* This methodfor calculating the SSI trigger for the hazardous substance assumes that all releases of the
same hazardous substance or mixture occur simultaneously. To the extent that a hazardous substance is
releasedfrom your facilityfrom different sources and at different frequencies, you may adjust the SSI
trigger as appropriate, so that it more accurately reflects the frequency and quantity of the release. The
SSI trigger in the final analysis must reflect the upper bound of the normal range of the release, taking
into consideration all sources of the release at the facility or vessel The normal range of the release
includes all releases previously reported or occurring over a 24-hour period during the previous year.
Name of Source(s')
Upper Bound of the Normal Range of
the Release (specify lbs., kg. o/c5T
Fugitive Emissions - Stockpiles 3.7
-------
SECTION III: HAZARDOUS
SUBSTANCE
INFORMATION
CR-ERNS Number
900004
Calculation of the SSI Trigger
For EACH hazardous substance or hazardous substance component of a mixture indicated in
Section II, Part C, list the names of the releasing sources and their upper bounds. Please use a
SEPARATE sheet for EACH hazardous substance. Photocopy this page if necessary.
Name of Hazardous Substance: Thorium-232
To calculate the SSI trigger (i.e., the upper bound of the normal range of a release) for the hazardous substance
identified above, aggregate the upper bounds of die normal range of the identified hazardous substance across all
sources identified in Section II, Part C. If the hazardous substance is also a component of a mixture, be certain to
include the upper bound of the component as calculated in Section Q, Part C, in your calculation of the SSI trigger.
Name of SourceiV) Upper Bound of the Nonnal Ranee of
the Release (specify lbs., kg. ogj^iy
Fugitive Emission - Stockpiles 4.2
TOTAL - SSI trigger for this hazardous substance release* : Cl
* This methodfor calculating the SSI triggerfor the hazardous substance assumes that all releases of dm
same hazardous substance or mixture occur simultaneously. To the extent that a hazardous substance is
releasedfrom your facilityfrom different sources and at different frequencies, you may adjust the SSI
trigger as appropriate, so that it more accurately reflects the frequency and quantity of dm release. The
SSI trigger in the final analysis must reflect the upper bound of the normal range of the release, taking
into consideration all sources of the release at the facility or vessel The normal range of the release
includes all releases previously reported or occurring aver a 24-hour period during the previous year.
-------
SECTION III: HAZARDOUS
SUBSTANCE
INFORMATION
CR-ERNS Number
900004
Calculation of the SSI Trigger
For EACH hazardous substance or hazardous substance component of a mixture indicated in
Section II, Part C, list the names of the releasing sources and their upper bounds. Please use a
SEPARATE sheet for EACH hazardous substance. Photocopy this page if necessary.
Name of Hazardous Substance: Radium- 226
To calculate the SSI mgger (i.e., the upper bound of the normal range of a release) for die hazardous substance
identified above, aggregate the upper bounds of die normal range of the identified hazardous substance across all
sources identified in Section n, Part C. If the hazardous substance is also a component of a mixture, be certain to
include the upper bound of the component as calculated in Section Q, Part C, in your calculation of the SSI trigger.
Name of Source^ Upper Bound of the Normal Ranee of
the Release (specify lbs., kg. oi(CPft\
Fugitive Emissions - Stockpiles 1.8
TOTAL - SSI trigger for this hazardous substance release* :
1.8 Ci
* This methodfor calculating the SSI trigger for the hazardous substance assumes that all releases of the
same hazardous substance or mixture occur simultaneously. To the extent that a hazardous substance is
releasedfrom yourfacility from different sources and at different frequencies, you may adjust the SSI
trigger as appropriate, so that it more accurately reflects the frequency and quantity of the release. The
SSI trigger in the final analysis must reflect the upper bound of the normal range of dm release, taking
into consideration all sources of the release at the facility or vessel The normal range of the release
includes all releases previously reported or occurring over a 24-hour period during the previous year.
-------
SECTION III:
HAZARDOUS
SUBSTANCE
INFORMATION
CR-ERNS Number
900004
Calculation of the SSI Trigger
For EACH hazardous substance or hazardous substance component of a mixture indicated in
Section II, Part C, list the names of the releasing sources and their upper bounds. Please use a
SEPARATE sheet for EACH hazardous substance. Photocopy this page if necessary.
Name of Hazardous Substance:
Benzene
To calculate the SSI trigger (i.e.. the upper bound of the normal range of a release) for the hazardous substance
identified above, aggregate the upper bounds of the normal range of the identified hazardous substance across all
sources identified in Section II. Part C. If the hazardous substance is also a component of a mixture, be certain to
include the upper bound of die component as calculated in Section II, Part C, in your calculation of the SSI trigger
Name of Sourcefs)
Fugitive Emissions - Truck
Loading / Unloading
North Stack - Transfer Storage Shed
South Stack - Transfer Storage Shed
Upper Bound of the Normal Ranee of
the Release fspecif^Tbs^ kg. or Ci)
46.3
39
39
TOTAL - SSI trigger for this hazardous substance release*
124.3 lbs.
* This methodfor.-caiculating the SSI trigger for the hazardous substance assumes that all releases of the
same hazardous substance or mixture occur simultaneously. To the extent that a hazardous substance is
releasedfrom your facility from different sources and at different frequencies, you may adjust the SSI
trigger as appropriate, so that it more accurately reflects the frequency and quantity of the release. The
SSI trigger in the final analysis must reflect the upper bound of the normal range of the release, taking
into consideration all sources of the release at the facility or vessel. The normal range of the release
includes all releases previously reported or occurring over a 24-hour period during the previous year.
-------
SECTION III:
HAZARDOUS
SUBSTANCE
INFORMATION
CR-ERNS Number
900004
Calculation of the SSI Trigger
For EACH hazardous substance or hazardous substance component of a mixture indicated in
Section II, Part C, list the names of the releasing sources and their upper bounds. Please use a
SEPARATE sheet for EACH hazardous substance. Photocopy this page if necessary.
Name of Hazardous Substance; Acetaidehyde
To calculate the SSI trigger (i.e.. the upper bound of the normal range of a release) for the hazardous substance
identified above, aggregate the upper bounds of the normal range of the identified hazardous substance across all
sources identified in Section II, Part C. If the hazardous substance is also a component of a mixture, be certain to
include the upper bound of the component as calculated in Section II, Part C. in your calculation of the SSI trigger.
Name of SourceCs)
Fugitive Emissions - Truck
Loading / Unloading
North Stack
South Stack
Transfer Storage Shed
Transfer Storage Shed
Upper Bound of the Normal Ranee of
the Release (specify iSOkg. or CD
1,007.4
14.4
14.4
TOTAL - SSI trigger for this hazardous substance release* : 1,036.2 lbs.
* This methodfor calculating the SSI trigger for the hazardous substance assumes that all releases of the
same hazardous sutstance or mixture occur simultaneously. To the extent that a hazardous substance is
releasedfrom your facility from different sources and at differentfrequencies, you may adjust the SSI
trigger as appropriate, so that it more accurately reflects the frequency and quantity of the release. The
SSI trigger in the final analysis must reflect the upper bound of the normal range of the release, taking
into consideration all sources of the release at the facility or vesseL The normal range of the release
includes all releases previously reported or occurring over a 24-hour period during the previous year.
-------
SECTION III: HAZARDOUS
SUBSTANCE
INFORMATION
CR-ERNS Number
900004
Calculation of the SSI Trigger
For EACH hazardous substance or hazardous substance component of a mixture indicated in
Section //, Part C, list the names of the releasing sources and their upper bounds. Please use a
SEPARATE sheet for EACH hazardous substance. Photocopy this page if necessary.
Name of Hazardous Substance: Acrolein
To calculate the SSI trigger (i.e., the upper bound of the normal range of a release) for the hazardous substance
identified above, aggregate the upper bounds of the normal range of the identified hazardous substance across all
sources identified in Section II, Part C. If the hazardous substance is also a component of a mixture, be certain to
include the upper bound of the component as calculated in Section II, Part C, in your calculation of the SSI trigger.
Name of SourceCs")
North Stack - Transfer Storage Shed
South Stack - Transfer Storage Shed
Upper Bound of the Normal Range of
the Release Cspecifv/fbsi kg. or Ci)
2.5
2.5
TOTAL - SSI trigger for this hazardous substance release*
5.0 lbs.
* This methodfor calculating the SSI trigger for the hazardous substance assumes that all releases of the
same hazardous substance or mixture occur simultaneously. To the extent that a hazardous substance is
releasedfrom your facility from different sources and at differentfrequencies, you may adjust the SSI
trigger as appropriate, so that it more accurately reflects the frequency and quantity of the release. The
SSI trigger in the final analysis must reflect the upper bound of the normal range of the release, taking
into consideration all sources of the release at the facility or vesseL The normal range of the release
includes ail releases previously reported or occurring over a 24-hour period during the previous year.
-------
APPENDIX E
COMPLETED SUGGESTED CR-ERNS REPORTING FORMAT --
ADDENDUM TO TRI FORM R
-------
CR-ERNS Report — Addendum to Form R
CR-ERNS #:
900004
Source Information: For EACH source of a release from your facility, provide the following
information on a SEPARATE sheet.
Name of Source; Fugitive Emissions - Truck Loading / Unloading
Indicate whether the release from this source is either:
continuous without interruption
OR routine, anticipated, intermittent
X
Pattern of the Release: Identify below how you established the pattern of release and
calculated release estimates.
Past release data
AP-42
X
Knowledge of the facility's
operations and release history
Best professional judgement
Engineering Estimates
Other (explain)
Environmental Medium affected by the release from this source:
X Air Surface Water Soil or Ground Water
Air
Surface
Water
If release is to air, please indicate stack heightOR surface area of the release.
Stack Height
OR
18 ft3
Surface Area
If release is to Surface Water, please indicate name, type and specific information
of the water body:
Name of water body ¦
If stream:
If lake:
_ Stream Order OR
Surface area (ac) AND
Average flow rate (ft3/sec)
Average Depth (m)
Soil or
Ground Water
Indicate distance of closest water well:
Hazardous Substance Information:
Name of Hazardous
Substance:
CASRN#
Upper Lower
Bound Bound
(in lbs. or kg per day)
Number of
Days Release
Occurs (per year)
Months of
the Release
Acetaldehyde
Benzene
75070
71432
1,007.4
46.3
2.33
0
240
350
Jan,Feb, Apr,
May, June, Aug,
All
Page 2 9/97
-------
CR-ERNS Report — Addendum to Form R
CR-ERNS #: 900004
Source Information: For EACH source of a release from your facility, provide the following
information on a SEPARATE sheet.
Name of Source: North Stack - Transfer Storage Shed
Indicate whether the release from this source is either:
continuous without interruption X OR routine, anticipated, intermittent
Pattern of the Release: Identify below how you established the pattern of release and
calculated release estimates.
X
Knowledge of the facility's Engineering Estimates
operations and release history
Past release data
AP-42
X
Best professional judgement
Other (explain)
Environmental Medium affected by the release from this source:
X
Air
Surface Water
Soil or Ground Water
Air
Surface
Water
If release is to air, please indicate stack heightOR surface area of the release.
15 feet
Stack Height
OR
Surface Area
If release is to Surface Water, please indicate name, type and specific information
of the water body:
Name of water body
If stream: Stream Order OR Average flow rate (ft3/sec)
If lake: Surface area (ae) AND Average Depth (m)
Soil or
Ground Water
Indicate distance of closest water well:
Hazardous Substance Information:
Name of Hazardous
Substance:
CASRN#
Upper Lower
Bound Bound
(in lbs. or kg per day)
Number of
Days Release
Occurs (per year)
Months of
the Release
Acetaldehyde
Benzene
Acrolein
75070
71432
107028
14.4
39.0
2.5
0
0
0
365
365
365
All
All
All
Page 2 9/97
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CR-ERNS Report - Addendum to Form R
CR-ERNS #: 900004
Source Information: For EACH source of a release from your facility, provide the following
information on a SEPARATE sheet.
Name of Source: South Stack - Transfer Storage Shed
Indicate whether the release from this source is either:
continuous without interruption X OR routine, anticipated, intermittent
Pattern of the Release: Identify below how you established the pattern of release and
calculated release estimates.
X
Knowledge of the facility's Engineering Estimates
operations and release history
Past release data
AP-42
X
Best professional judgement
Other (explain)
Environmental Medium affected by the release from this source:
X
Air
Surface
Water
Air
Surface Water
Soil or Ground Water
If release is to air, please indicate stack heightOR surface area of the release.
15 feet
Stack Height
OR
Surface Area
If release is to Surface Water, please indicate name, type and specific information
of the water body:
Name of water body
If stream:
If lake:
Stream Order OR
Surface area (ac) AND
Average flow rate (ft3/see)
Average Depth (m)
Soil or
Ground Water
Indicate distance of closest water well:
Hazardous Substance Information:
Name of Hazardous
Substance:
CASRN#
Upper Lower
Bound Bound
(in lbs. or kg per day)
Number of
Days Release
Occurs (per year)
Months of
the Release
Acetaldehyde
Benzene
Acrolein
75070
71432
107028
14.4
39.0
2.5
0
0
0
365
365
365
AH
All
All
Page 2 9/97
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CR-ERNS Report- Addendum to Form R
CR-ERNS#: 900004
Source Information: For EACH source of a release from your facility, provide the following
information on a SEPARATE sheet.
Name of Source: Fugitive Emissions - Stockpiles
Indicate whether the release from this source is either:
continuous without interruption X OR routine, anticipated, intermittent
Pattern of the Release: Identify below how you established the pattern of release and
calculated release estimates.
Past release data
AP-42
Knowledge of the facility's X Engineering Estimates
operations and release history
X
Best professional judgement
Other (explain)
Environmental Medium affected by the release from this source:
X
Air
Surface
Water
Air
Surface Water
Soil or Ground Water
If release is to air, please indicate stack heightOR surface area of the release.
Stack Height OR 10 ^
Surface Area
If release is to Surface Water, please indicate name, type and specific information
of the water body:
Name of water body
If stream:
If lake:
_ Stream Order OR
Surface area (ac) AND
Average flow rate (ftVsec)
Average Depth (m)
Soil or
Ground Water
Indicate distance of closest water well:
Hazardous Substance Information:
Name of Hazardous
Substance:
CASRN#
Upper Lower
Bound Bound
(in lbs. or kg per day)
Number of
Days Release
Occurs (per year)
Months of
the Release
Cesium-134
Thorium-232
Radium-226
3967709
7440291
13982633
3.7 ci
4.2 ci
1.8 ci
0
0
0
365
365
365
All
All
All
Page 2 9/97
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* m
United States
Environmental Protection Agency
(5204G)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
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