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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. 1 ------- 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 ------- 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). 3 ------- 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. 4 ------- 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 5 ------- 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 ------- 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 ------- 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. 9 ------- 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 ------- 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. 11 ------- 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 12 ------- 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. ------- 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 14 ------- 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. 15 ------- 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 16 ------- 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. 17 ------- 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. 18 ------- 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." 19 ------- 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. 20 ------- 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 21 ------- 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 ------- 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. 23 ------- 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. 24 ------- 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. 25 ------- 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. 26 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- ------- ------- * m United States Environmental Protection Agency (5204G) Washington, DC 20460 Official Business Penalty for Private Use $300 ------- |