Solid Waste and
               Emergency Response
EPA 540-R-97-046
OSWER 9360 7-04A
PB97-963313
December 1997
Supertund
Assessing Reports of
Continuous Releases of
Hazardous Substances

A Guide for EPA Regions

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            United States             Office of Emergency and
            Environmental Protection Agency   Remedial Response
                                Washington, DC 20460


            Superfund
4>  EPA  Assessing Reports of Continuous
            Releases of Hazardous
            Substances
            A Guide for EPA Regions
                                                    nf

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The policies and procedures set forth here are intended as guidance to Agency
and other Government employees.  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 EPA
Regions" replaces and updates the October 1990 edition.

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                             TABLE OF CONTENTS


                                                                                Page

BACKGROUND	       	         iii

PARTI:    THE CONTINUOUS RELEASE PROGRAM	            1

       1.0  Introduction  	    	       1

       1.1  Overview of Continuous Release Reporting   ...   .               ....      . .     2

PART 2:    REPORTING REQUIREMENTS FOR CONTINUOUS RELEASES
           OF HAZARDOUS SUBSTANCES    	         3

       2.0  Introduction   	          . .    . .                   ....    3

       2.1  Initial Telephone Notification	4

       2.2  Initial Written Report   	4

       2.3  Follow-up Written Report    	      . .       8

       2.4  Statistically Significant Increase (SSI) Reports	         ...          9

       2.5  Notification of Changes	        9

       2.6  Additional Assistance for EPA Regions  .  .   .  .    	                  10

APPENDICES

       Appendix A: Acronyms

       Appendix B: Suggested Continuous Release Reporting Format

       Appendix C: Suggested CR-ERNS Reporting Format  - Addendum to TRI Form R

       Appendix D: Missing Information Cover Letters and Missing Information Checklist

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                                LIST OF EXHIBITS









EXHIBITS                                                                         Page




Exhibit 2-1:  Reporting Requirements  	  3




Exhibit 2-2:  Referral to the NRC 	  4




Exhibit 2-3:  Requests for Additional Information 	  7

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                                          BACKGROUND
The purpose of this document, "Assessing Reports of
Continuous Releases of Hazardous Substances   A
Guide for EPA Regions" (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 EPA
Regional personnel with information about this reduced
reporting option and the Continuous Release Rule.
The Guide is divided into two parts. Part 1 provides
general information regarding the Continuous Release
Rule.  Part 2 contains detailed information regarding
specific portions of 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 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  Headquarters to discuss vessel-specific
requirements in detail.
                                                   Ill

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                       PART 1: THE CONTINUOUS RELEASE PROGRAM
   1.0 Introduction
    Since  the  enactment  of  the  Comprehensive
Environmental Response, Compensation, and Liability
Act (CERCLA) in 1980, facilities have been required
to report  releases of hazardous substances that equal or
exceed a reportable quantity (RQ). Section 103(f)(2)of
CERCLA  provides   that  releases  of  hazardous
substances that are "continuous" and "stable in quantity
and   rate"   may   qualify  for  reduced   reporting
(notification) requirements.

    Releases that qualify as "Continuous Releases" are
not federally permitted, and they are not necessarily
risk-free. Government response officials are required
to be notified of hazardous substance releases  that
equal or  exceed their RQs on a continuous basis in
order to evaluate the need for a federal response action.
However, because of the  repetitive nature of these
releases,  response officials do not need to be notified
each  time a "continuous" release occurs in order to
determine whether a  response action is warranted. A
primary purpose of the reduced reporting provisions for
continuous releases under CERCLA Section 103(f)(2)
is to eliminate unnecessary redundant reporting.

    The Final Rule on Reporting Continuous Releases
of Hazardous Substances was published on July 24,
1990 (55 Federal  Register (FR) 30166).   The  Rule
became  effective  on September 24,  1990,  and is
codified  at 40 Code  of Federal Regulations (CFR)
302.8 and 355.40.  In the Final Rule, EPA clarifies the
key terms in Section  103(f)(2) (i.e., "continuous" and
"stable"), and the reporting requirements for  such
releases.  As a result  of this Final Rule, EPA Regions
have  received a  substantial number of continuous
release reports from facilities.  It is important that these
reports receive attention as part of the overall release
assessment  process.    Each  continuous  release
notification must be reviewed, and the government or
responsible party should respond to those releases that
do pose a risk to human health and the environment.

    The purpose of this guidance document is to assist
EPA  Regions by reviewing  the continuous  release
reporting process and the options available for
reevaluating and responding to reports of continuous
releases.   The  effective  implementation  of  the
Continuous Release Rule depends largely on whether
EPA Regions fully and efficiently evaluate the risks
associated with the continuous release reports they
receive.

    To minimize  the  burden on limited  Regional
resources, and  to facilitate implementation  of the
Continuous Release Rule, some valuable resource tools
have been developed to assist the Regions.

Information Tracking

    In  the preamble to the Final Rule,  the Agency
stated  that it intended to maintain  the continuous
release  information submitted  in the  Continuous
Release-Emergency Response Notification System
(CR-ERNS) database.   CR-ERNS is a  stand-alone
system  with a database management component that
stores  information supplied to the EPA  Regions by
facilities that have reported continuous  releases  of
hazardous substances.  CR-ERNS was designed as an
information management system that groups together
all of the information submitted by a given facility.

    Through CR-ERNS, telephone notifications from
the National Response Center (NRC) are transmitted to
the EPA Regions, via the  John  A.  Volpe National
Transportation   Systems   Center   (VNTSC)   in
Cambridge, Massachusetts.   These notifications are
automatically loaded and stored in CR-ERNS. When
EPA Regional personnel receive corresponding initial
written reports from facilities,  they enter these reports
into a tracking matrix.  They then transfer any reports
submitted in letter form to the Suggested Continuous
Release Reporting Format (see Appendix  B) and
enter the information into CR-ERNS. If any important
information  is  missing  from  a  continuous  release
report,  the EPA  Region to  which  the  report was
submitted sends a letter to the facility requesting the
missing  information.   (See  Appendix  D  for two
Missing Information  Cover  Letters and a Missing
Information  Checklist  for  requesting additional
information.) Once all of the  information is received
and entered into CR-ERNS, EPA Regional personnel
are able to evaluate all of the continuous releases from
a particular facility using the risk assessment model.

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Risk Assessment Model

    An important component of CR-ERNS is the
Priority  Assessment Model (PAM).   RAM  is  a
chronic risk assessment model that contains Region-
specific soil and  climate data,  as well as fate  and
transport modes.  PAM  can be  used by Regions to
quickly identify which continuous releases may pose a
significant  risk to  human  health,  welfare,  or the
environment.    PAM   evaluates  the  information
submitted in the written continuous release reports and
estimates risk for three exposure pathways: air, surface
water, and ground water.

    PAM reduces the burden associated with reviewing
continuous  release  notifications submitted  to  each
Regional Office.  Using the  PAM results, Regional
response personnel are able to make a  rapid, systematic
initial  evaluation of the  potential threats to human
health  and  the environment  posed  by  the  reported
hazardous substance releases. The initial review will
facilitate establishing priorities for closer evaluation of
releases  posing   the  greatest risk.    PAM model
documentation is available to the Regions in another
publication  in  this  series  "Continuous  Release
Emergency Response Notification System and Priority
Assessment Model  - Model  Documentation."   The
documentation presents the fate and transport modeling
assumptions incorporated into PAM and explains how
to interpret the PAM reports.

Additional Materials

    The  following materials also are  available for the
regulated community:

    •    A  Fact  Sheet  describing  the  notification
        requirements for  continuous  releases  of
        hazardous substances; and

    •    A  Guidance Document for the  regulated
        community on complying with the continuous
        release   reporting   requirements.   This
        document,   A  Guide  for Facilities  on
        Compliance, provides specific  guidance on
        filing  a  continuous release  report   and
        includes a copy of the Suggested Continuous
        Release  Reporting  Format   for submitting
        written continuous release information for the
        initial  and follow-up reports.  The Guide also
        includes  a  checklist of  the  information
        required  in  the  written reports and tables
        illustrating where facilities must submit each
        type of continuous release report.
    The preamble  and  Final  Rule  for  reporting
continuous  releases have  been distributed to  each
Regional Office. For convenience, some of the core
information from the guidance document for facilities
has been  included  in  this Guide.   Copies of. the
complete guidance package are available by calling the
CR-ERNS Operational Support HelpLine at 703-934-
3765  or the RCRA/SuperfunoVEPCRA  Hotline at
1-800-424-9346 (in Washington, DC, 703-412-9810),
1-800-553-7672 (TDD-hearing impaired).

    It is likely that the regulated community  will
continue to  ask EPA  Regional personnel questions
about the continuous release reporting requirements.
To minimize the burden on Regions, callers also may
be referred  to  the  CR-ERNS Operational Support
HelpLine at 703-934-3765.

    Regions can  also  receive assistance with CR-
ERNS technical questions through the CR-ERNS User
Support HelpLine at 703-934-3455.
   1.1  Overview of Continuous Release
        Reporting
    Under CERCLA Section 103(f)(2), a release of a
hazardous substance,  at  or above  an RQ,  that is
"continuous"  and "stable in quantity and rate" may
qualify  for reduced reporting.  The Rule  defines
"continuous1'   as a release   that   occurs  without
interruption or abatement or that is routine, anticipated,
intermittent, and incidental to normal operations or
treatment processes. According to the Final  Rule, a
release is "stable in quantity and rate" if it is predictable
and regular in the amount and rate of emission.

    Some examples of releases that may qualify as
continuous include:  releases from batch production of
a substance every week or series of weeks; start-up of
a machine on a regular schedule; and the release of a
hazardous  substance  in  some predictable manner
during  a production or treatment  process.  Some
examples of  releases that  are not continuous may
include:  unanticipated, episodic releases such as spills
or  pipe ruptures;  equipment  failures;  emergency
shutdowns; or accidents. These episodic releases must
be reported per-occurrence to the NRC if they occur at
or above their RQ.  The following  Section  of this
Guide, Part 2, discusses the reporting requirements for
continuous releases of hazardous substances.

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                 PART 2: REPORTING REQUIREMENTS FOR CONTINUOUS
                          RELEASES OF HAZARDOUS SUBSTANCES
   2.0 Introduction
     Although CERCLA Section  103(0(2) provides
for reduced reporting of continuous releases, it does not
eliminate the requirement to report such releases.  The
reporting  requirements  for  continuous releases of
CERCLA hazardous substances are outlined in Exhibit
2-1 below, and  then explained more  fully  in the
following text.
     Please note  that for releases  of  CERCLA
hazardous substances. Federal authorities (i.e., the NRC
and  the  appropriate  EPA Region) and  the  State
Emergency Response Commission  (SERC),  and  the
Local Emergency Planning Committee (LEPC) must be
notified. However, non-CERCLA extremely hazardous
substances (EHSs) do not require federal notification
and so need only be reported to the appropriate SERC
and LEPC.  The requirements for non-CERCLA EHSs
are outlined fully in the "Reporting Requirements for
Continuous Releases  of Hazardous Substances   A
Guide  for  Facilities  on Compliance."  Since EPA
officials  will  receive only  reports  of  CERCLA
hazardous  substances, the  requirements  for non-
CERCLA EHSs will not be addressed in  this Guide for
EPA Regions.  For the  purposes of this Guide, it should
be assumed that all releases are releases of CERCLA
hazardous substances.

     In addition,  please note that 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.

     To qualify as a continuous release,  a facility must
report a release under CERCLA Section 103(a) for a
"period sufficient" to establish the release as continuous
and stable in quantity and rate. This requires an initial
telephone call to the NRC. However, as long as the
        EXHIBIT 2-1:
REPORTING REQUIREMENTS

 Standard Reporting Requirements

      Initial telephone call to the NRC,
      SERC, and LEPC.

      Initial written report to the EPA
      Region, SERC, and LEPC within
      30 days of the telephone call.

      One-time, first anniversary
      written  follow-up report to the
      EPA Region one year later.

 Circumstantial Reporting
 Requirements

      Immediate reporting to the NRC,
      SERC, and LEPC of statistically
      significant increases (SSIs).

      Notification of a change in
      previously submitted release
      information.  Either:
         For any changes in source or
         composition, treatment as  if
         it were a "new" release under
         the "old" CR-ERNS number
         (i.e., new initial telephone
         call, initial written, and first
         anniversary follow-up
         report); or
         For other changes, written
         notification to the EPA
         Region within 30 days of the
         change.

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 person in charge of the facility has a sufficient basis to
 determine that the release is continuous and stable,
 there is no need for multiple calls.  The determination
 of whether  a release  is continuous  and  stable  in
 quantity and rate may also be based on past release
 data, engineering judgment, historical knowledge of the
 operating processes,  or some other sound technical
 basis.
    2.1  Initial Telephone Notification
      The main purpose of the initial telephone call is
 to alert government authorities that the release will be
 reported  under  the  provisions  of  the  Continuous
 Release Rule.  The initial telephone notification must
 be made to three government authorities:  the NRC,
 SERC, and LEPC. Any initial telephone calls made to
 the Regions should be referred to the NRC (see Exhibit
 2-2).
                  EXHIBIT 2-2:
            REFERRAL TO THE NRC

     Q.   What if the  person  in  charge  at  the
          facility places the initial telephone call
          to the Region rather than to the NRC?

     A.   The Region should direct the person to
          call the NRC.  The NRC must assign, the
          facility a CR-ERNS number that will be
          used  to track the continuous release
          reports.
      In the initial telephone call, the person in charge
of the facility must identify the release as a report of a
continuous release  at  or above the  RQ, and  must
provide:   the name and location of the facility; the
name and address of its corporate affiliation; the name
of the person in charge of the facility; and the name of
each hazardous substance released.  When the initial
telephone  call is received, the  NRC  will  assign the
facility a CR-ERNS number that will be used to track
all continuous release information  reported by the
facility.

     The  National Oil  and  Hazardous  Substances
Pollution  Contingency Plan  (NCP)  provides that  a
telephone notification of a release to the NRC must be
relayed immediately to the appropriate OSC. However,
 in the case of continuous release notifications,  EPA
 and the NRC have agreed that given the nature of the
 initial telephone calls and the information they contain,
 the number of potential calls the NRC may receive, and
 the usual character of continuous releases as part of
 normal operations at a facility, the NRC will transmit
 these  notifications   electronically  through  batch
 transmissions  to  the  EPA Regions via the  John A.
 Volpe National Transportation Center (VNTSC).
                                                            2.2   Initial Written Report
Responsibilities of the Regulated Community

     Within  30   days   of  the   initial  telephone
notification, the person in charge of the facility is
required to submit an  initial written report to the
appropriate EPA Region, SERC,  and LEPC.  The
Continuous Release Rule requires the person in charge
to provide:

     •     General  information  on   the  facility,
          including   the   location   and  size   of
          surrounding  sensitive   populations  and
          ecosystems;

     •     Information on  each  individual   release
          source, including the names and quantities
          of hazardous substances released from each
          source, the  normal range and frequency of
          the  release from  the  source,  and  the
          environmental medium  affected  by  the
          release;

     •     Information on each hazardous substance
          released,  including information  about
          mixtures containing hazardous substances,
          an estimate of the total annual amount of the
          hazardous  substance  released from  all
          sources during the previous year, and a brief
          statement describing the basis for stating
          that the  release is continuous and stable in
          quantity and rate.

     Data and other information substantiating that the
release  is continuous and stable in quantity and rate
need not be included in the report; such information
should be kept on file at the facility.

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      The Suggested Continuous Release Reporting
Format for initial  written and  follow-up  reports,
Appendix B, outlines all of the pieces of information
that are required by the Continuous Release Rule and
CR-ERNS.   Regional personnel should encourage
facilities to use this format. Use of the format greatly
facilitates both reporting and  report processing and
ensures that all of the key elements required by  the
Rule are included in each report.

Regional Report Processing Under CR-ERNS

      Following  receipt  of  a letter or  suggested
reporting format containing the required information
for the initial written report,  the data should be entered
into CR-ERNS under the facility CR-ERNS  number
assigned by  the  NRC during the  initial  telephone
notification. Entering the release data into CR-ERNS
will provide other Agency program offices  and  the
public  with  access  to  the   information.    If  the
information is submitted in letter form, the information
may  first have  to  be extracted  and put onto  the
Suggested Continuous Release Reporting Format to
facilitate report processing. The  Region may wish to
use contractor support to extract information onto the
Suggested Reporting Format and to enter data into
CR-ERNS.

      When reviewing the  initial report, the Region
should evaluate whether the information submitted is
complete.  In particular, the  release data should be
sufficient to enable Regional personnel to evaluate the
risks to human health and the environment.

      If the information submitted is incomplete, there
are two  Missing  Information Cover Letters and  a
Missing Information Checklist included in Appendix
D  of  this  Guide  that  you  may   find useful   in
corresponding with  individual facilities  to  request
additional information concerning  their continuous
release reports. Sample Letters #1 and #2 can be used
to request missing information from facilities.  Sample
Letter #1 should be used when the most recent report
received is less than a year old or is a follow-up report.
Sample Letter #2 should be used when the most recent
report received is an initial written report or change
notification that is more than one year old. Regardless
of which sample letter is used, the Missing Information
Checklist should be attached.

     The CR-ERNS Suggested Reporting Format may
also be used to identify precisely the information that
is missing from the facility's written submission.  It is
possible to input partial information into the suggested
format.   The blank areas in the  format can  then be
circled  or  highlighted and attached to  the  Sample
Letters to assist in requesting the missing information
from the facility.

Reporting  by the Toxic Release Inventory Form

    Owners  or operators of facilities subject to  the
requirements  of   Superfund  Amendments   and
Reauthorization Act (SARA) Title III Section 313 may
submit a copy of the Toxic Release  Inventory (TRI)
form required under EPCRA Section 313'(along with
certain additional information) in lieu of an initial
written or follow-up report.

    If facilities submit a TRI form in lieu of the initial
written or follow-up report, Regions  can  extract the
following information from it:

General information

    •    The complete name of the  facility (Part  1
         Section 4.1);

    •    The location of the  facility,  including
         latitude and longitude (Part  1 - Sections 4.1
         and 4.6);

    •    The Dun  and Bradstreet number (Part  I
         Section 4.7); and,

    •    The name and telephone   number of the
         person in charge (Part 1 - Sections 3 and 4).

Hazardous substance information

    •    The name and identity  of the  hazardous
         substance (Part 2 - Sections 1.2 and 1.3);

    •    The Chemical Abstracts Service Registry
         Number (CASRN) (Part 2 - Section 1.1);

    •    An estimate of the total  annual  amount of
         the hazardous substance or mixture released
         from all sources during the previous year
         (Part 2 - Section 5).

Source-specific information

    •    The source(s)  of the  release  (Part 2
         Sections 5.1 - 5.5).

    •    The environmental medium affected by  the
         release (Part 2 - Section 5).

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      In addition to the information on the TRI Form,
 some supplemental information is necessary to make a
 continuous  release  report complete under the Rule.
 EPA Regions should verify that  all of the  required
 supplemental information is supplied by the facility
 with the completed TRI Form.  EPA has developed a
 suggested  reporting  form  for TRI  reports titled
 Suggested   CR-ERNS   Reporting   Format  •-
 Addendum to TRI  Form R and appears as Appendix
 C of this document.  It  is recommended that TRI
 reporters use this supplemental form.

      If facilities choose not to use this form, they must
 still provide the complete information. The Continuous
 Release Rule  requires the  following supplemental
 information in addition to that which appears on a TRI
 Form:

      •     The population density within a one-mile
            radius of the facility;

      •     The identity  and   location of  sensitive
            populations and ecosystems within a one-
            mile radius of the facility;

      •     The upper and lower bounds of the normal
            range of each hazardous substance release
            (in pounds or kilograms) over the  previous
            year;

      •     The frequency of  the  release  and the
            fraction of the release from each release
            source and the specific period over which
            it occurs (i.e., the number of releases per
           year and  the  months during which the
           release occurs);

      •     A brief statement describing the  basis for
           stating that the release is continuous and
           stable in quantity and rate; and

      •     A signed statement that  the  hazardous
           substance described  is continuous and
           stable in quantity  and rate and that  all
           reported information is both accurate and
           current.

      In  addition   to  the above information,  the
following additional information on the source of the
hazardous substance release and the environmental
medium  affected by the release also appears on the
Suggested Reporting Format and is needed to run the
PAM. This information must be submitted by the
facility if EPA elects to use PAM to assess the risks
associated with the continuous release:

    •     If the  source of the release is a stack, the
          stack height in feet or meters;

    •     If the source is a waste pile, landfill, valve,
          tank vent, or other area source, the surface
          area or area of the release source in square
          feet or meters;

    •     If the  release affects a  stream, the  stream
          order or average flow rate in cubic feet per
          second;

    •     If the release affects a lake, the surface area
          of the lake in acres and the average depth of
          the lake in feet or meters; and

    •     If the release is  on or  under ground,  the
          location of any public water supply wells
          within a two-mile radius of the site.

    Regional personnel also may  want to ensure that
the most recent TRI report has been submitted  so that
the evaluation of the continuous release  is not based
upon outdated and inaccurate information.

Priority Assessment Model (PAM) Processing

    Using the data entered into CR-ERNS from each
initial written or follow-up report, Regional personnel
can  use  PAM  to  generate  the  risk-screening
information for each written continuous release report.
PAM  is  a  screening  level  model  that simulates
contaminant fate and transport in three environmental
pathways: air, surface water, and ground water. This
multimedia approach accounts for the wide variety of
release  mechanisms that  may be encountered  in
continuous release reports.  PAM screening will help
Regions   set  priorities for  addressing  the  most
significant releases first.

    PAM produces four reports: a Summary Facility
Evaluation Report; an  Input Parameters  Report;  a
Detailed Evaluation Report; and  an Execution Log.
These four PAM reports and the  CR-ERNS Facility
Printout will assist Regional personnel in identifying
continuous releases that may need further investigation
or response first.   See the CR-ERNS/PAM  Model
Documentation Report for additional information on
fate and transport simulation in the three pathways and
for an explanation of how the results from PAM will be
reported and can be interpreted.

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Regional Review of Continuous Release Data and
PAMs

      There is no  specified deadline for Regional
review of initial  written or follow-up reports.  The
Regions   have  discretion   to  decide  when  each
continuous release written report should be reviewed
and  the associated risks assessed.  The Region may
decide,  for example, to review written reports from
facilities in a specific geographical area concurrently.
In this way, the Region may do a comparative analysis
of releases from different facilities and perhaps even
determine the cumulative risks to persons living within
a specific area.

      When reviewing  the initial report, the  EPA
Region   should  evaluate whether  the information
submitted is clear and appears sufficient to establish the
release as continuous and  stable.  In particular, the
release data should be sufficient to enable Regional
personnel to evaluate the risks to human health and the
environment.  Regional personnel can use PAM reports
to assist in continuous release report review, however.
Regions  should  remain  mindful that PAM  is  a
screening level tool.

       It is  permissible  for the Region  to  seek
clarification of  information in a written  report,  to
inspect  a facility, or to  take any other action if any
submitted information  causes concern.   The  EPA
Region  is  not obligated to  respond to a  facility's
continuous release written report. However, under the
Continuous Release Rule, a facility may assume that it
can continue to report on the reduced reporting basis
authorized in CERCLA 103(0(2) unless a Region or
some other cognizant government agency contacts the
facility about the continuous release reports.

Response Options

      The response options  available to EPA Regional
response personnel for continuous releases include all
actions that may be taken in response to  episodic
releases.  They  include, but are not limited to, the
following:

•     Regional response  personnel may decide that no
      action is appropriate.

•     Regional   response   personnel  may   seek
      clarification of information in a written report or
      request additional information if there are doubts
      or questions about the report or about the basis
      reported for establishing a release as continuous
      (see Exhibit 2-3).
              EXHIBIT 2-3:
    REQUESTS FOR ADDITIONAL
            INFORMATION

Q.   What  if the information provided  is
     insufficient to properly evaluate the
     release or is confusing or unclear?

A.   The Region may  request  additional
     information  or  clarification  of  the
     submitted information.

Q.   What if the person in charge of a facility
     does not submit the written report when
     due or does not submit the report at all?

A.   If the  facility fails to  submit the initial
     written report  within 30 days of the
     initial telephone notification to the NRC
     (or the follow-up report within a year of
     the submitted initial report), the  EPA
     Region may require  the information
     pursuant to the authority of CERCLA
     Section 104(e).   The  Region also has
     access to all of the other enforcement
     tools under CERCLA.
 If the facility has not already done so, Regional
 response personnel may request that the facility
 establish a release  as continuous and stable by
 reporting it for some period on a per-occurrence
 basis under CERCLA Section 103(a).

 Regional response personnel  may  review  the
 release information and decide that the quantity
 released is potentially hazardous and, despite its
 continuity  and stability, the release  should be
 reported on  a per-occurrence basis to  ensure
 opportunity for evaluation of each release event.

 Regional response personnel may determine that
 there is no need for a response, but that the upper
 bound of the normal range is too high given, for
 example, the characteristics of the substance being
 released, the frequency of the release,  or  the
 sensitivity of the location of the release. Response
 personnel could  decide that a specified level
 below the reported upper bound of the  normal
 range may minimize the risk to human health and
 the environment, and may require the reporting of

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      any  releases above  a somewhat lower  upper
      bound on a per-occurrence basis.

 •    Regional  response personnel may  decide  to
      perform a site inspection or field response at the
      facility.

 •    Regional response personnel may alert a permit
      program office or other office that a release from
      the facility merits further evaluation.

 •    Regional response personnel may decide that a
      government  response action  at  the  facility is
      necessary.

 •    Regional  response personnel  may  utilize  the
      enforcement  tools provided under CERCLA for
      obtaining a response action by the facility.

 Releases into the Coastal Zone

      The  Continuous Release Rule requires  that the
 person in charge of the facility submit an initial written
 report  and  a  one-time  follow-up  report  to  the
 appropriate EPA Region. To date there have been few
 continuous release reports from vessels.  Therefore, the
 "Reporting Requirements for Continuous Releases of
 Hazardous Substances  -  Guide for  Facilities  on
 Compliance" refers persons in charge of vessels, who
 wish to report continuous releases, to EPA  for details
 on reporting requirements for vessels.   Regions may
 feel free to refer these  questions to the  CR-ERNS
 Operational Support HelpLine.

      In addition, it is possible that an EPA Region will
 receive some continuous release written reports from
 facilities or vessels discharging hazardous substances
 into the  coastal zone.  Primary responsibility  for
 evaluating releases into the coastal zone belongs to the
 U.S. Coast Guard (USCG).  Copies of written reports
describing  releases into  the coastal zone,  therefore,
should be forwarded to the appropriate USCG  District
Office. This is particularly important because the NRC
will notify the USCG directly about any SSI  reports or
other episodic release reports from facilities and vessels
within the USCG's jurisdiction.
   2.3   Follow-up Written Report
Responsibilities of the Regulated Community

     Within 30 days of the first anniversary date of the
initial written report, the person in charge of the facility
is required to reassess all reported continuous releases
and submit a one-time, written first anniversary follow-
up report to  the  EPA Regional Office.  Unlike the
initial telephone notifications to  the NRC or the initial
written reports which are submitted to the EPA and to
state and local authorities (the SERC and LEPC), the
one-time, written follow-up report is submitted only to
the EPA Regional Office.  It is possible, therefore, that
SERCs or LEPCs may call the EPA Regions to request
copies of follow-up written  notifications.

     The information  required in the written follow-up
report is identical to the  information required  in the
initial written  report, but the  follow-up report should be
based on release data gathered over the year. Because
the initial written report is required within 30 days of
the initial telephone call, the information contained in
the initial written report may not be conclusive. During
the period between the initial report and the follow-up
report, the facility will be aware of what must be
reported in the follow-up report and can be expected to
gather more  accurate information about the release.
Although  actual  monitoring by  the facility is not
necessarily required to  satisfy the conditions for
reduced reporting  under the Continuous Release Rule,
the follow-up report will probably be more accurate.

     After the first anniversary  follow-up report has
been submitted to the  EPA Regional Office, the person
in charge of the facility is responsible for reassessing
the release annually, but is not required  to notify EPA
unless there  is  a change in the release information
previously reported.  The person in charge, however,
must  maintain   documentation  of   each   annual
evaluation,  even  if  there  are  no  changes  in the
information previously submitted.

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Regional Report Processing

      After the follow-up  report  is  received, the
information should be entered into CR-ERNS and the
risks assessed using PAM.  Unless there are changes in
the release, the Region is not expected to receive any
reports from the facility once the written follow-up
report has been submitted.  If the Region for any reason
suspects that annual evaluations are not occurring, or
that previously  submitted  information is not  being
updated   properly,   the   Region   may   request
documentation from the person in charge indicating
that annual evaluations have been performed at the
facility.

      It may be useful to check or verify continuous
release   supporting    documentation,   including
documentation on the annual assessments, during ad
hoc facility inspections or during program reviews or
permit  development  negotiations.   Facilities  must
provide this documentation upon request. CR-ERNS
also can be a useful enforcement tool.  Because each
report submitted by a facility will be numbered, CR-
ERNS can be used to identify facilities that have not
submitted required reports.  For example, CR-ERNS
can be used to identify facilities that have not submitted
their initial written report within 30 days after making
their initial telephone notification.
   2.4   Statistically Significant Increase
         (SSI) Reports
      After the standard reporting requirements of the
initial telephone notification, initial written report, and
follow-up report have been  met,  a facility is only
required to  notify government authorities if certain
circumstances occur  (i.e., there is  an SSI or  any
changes in the information previously submitted). If
these  circumstances  occur,  there  are  additional
circumstantial reporting requirements. These reporting
requirements are covered in Sections 2.4 and 2.5  of this
Guide.

      If a change at a facility  results in an increase in
the quantity of a release above  the reported normal
range, and other reported characteristics of the release
remain  unchanged,  the release  must  be reported
immediately to the NRC, SERC, and LEPC as an SSI
report.  An SSI should be treated like an episodic
release.
    In accordance with § 300.125 of the NCR the
NRC  will  notify the  appropriate federal  OSC by
telephone immediately following the  telephone call
from the facility reporting the SSI. The SSI should be
evaluated  in a  manner  similar  to  other  episodic
releases. The difference is, however, that baseline data
are available about  the hazardous substance release
from previously submitted written reports. Like other
episodic releases, the OSC should evaluate the SSI to
determine whether it poses a risk to .luman health and
the environment, and whether a response action should
be taken.

    If the release at the facility  exceeds the normal
range several times, the person in charge of the facility
may want  to amend  the  normal  range  to  more
accurately reflect current releases.  To modify  the
normal range, the person in charge of the facility must
report at least one release as an SSI, and at the same
time may inform the NRC, SERC. and LEPC that  the
normal range is being modified.  Within 30 days of this
telephone notification,  the person in charge of the
facility must submit a written report to the EPA Region
specifying the new range for the  release, the reason for
the change, and the basis for asserting that the release
is continuous and stable at the increased quantity.  The
person in charge of the facility must also submit a first
anniversary follow-up report for a modification of the
normal range, as they would for any other change in
source or composition of the release.
                                                            2.5  Notification of Changes
    Another circumstantial reporting requirement is a
report of a change in release information previously
submitted.   There are two  types  of changes to a
continuous  release report. The first type is a change in
the source or composition of the release.  The second
type  includes all  other kinds of changes.  Actions
appropriate for each type of change are outlined below.

Changes in Source or Composition

    If there is a change in the sources or composition
of a  continuous release, the release is considered a
"new" release. The new release may pose a hazard that
warrants timely evaluation and, therefore, to report this
new  release under CERCLA Section 103(0(2),  the
facility must establish that it is continuous and stable in
quantity and rate.  To do this, the facility  should call
the NRC, SERC, and LEPC and submit a new initial

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written  report and follow-up report  for the facility
taking into consideration the change.

      Upon receipt of a changed release report,  the
Region  should  evaluate the new information  by
accessing  CR-ERNS and comparing the information
included  in  the  changed  release report with  the
information  previously reported by the  facility.
Regions should be alert to the need to identify the new
or changed information in the report  and follow-up
with  the  facility  as needed to clarify  any  unclear
elements.   Once this evaluation is  completed,  the
Region  should access  PAM  to  generate new risk
estimates  based on the revised information.

Changes  Other Than a  Change   in  Source or
Composition

      Notification of any  changes in the reported
information,  other than a change in the source or
composition  of the release,  must be submitted in
writing  to the EPA  Region by the person in charge
within 30 days of determining  that  the previously
submitted information  is  no longer  valid.   These
changes do not require resubmission of  the report, only
a signed letter  outlining the changes. Examples of
changes  other than a change  in   the source  or
composition  are:  a change in the frequency of the
release; a change in the facility  ownership; or a change
in the name and telephone  number of the person in
charge.  These changes do not require reassessment of
the risks posed by the release from PAM.
    In  addition,  EPA Headquarters  provides  the
Regions with assistance on questions about continuous
releases  or  CR-ERNS  through  the  CR-ERNS
Operational Support HelpLine at 703-934-3765. For
answers to technical questions concerning the operation
of CR-ERNS, Regions can call the CR-ERNS  Users
Supports HelpLine at 703-934-3484.
   2.6  Additional Assistance for EPA
        Regions
     Details on  the  continuous release  reporting
requirements  are  outlined   in  the   "Reporting
Requirements for Continuous Releases of Hazardous
Substances - A Guide for Facilities on Compliance,"
which provides specific instructions on completing a
continuous release report.  Appendix D of the Guide
for Facilities on Compliance provides an example of a
properly  completed Suggested  Continuous Release
Reporting Format.  Appendix  E of the Guide for
Facilities on Compliance provides an example of a
properly  completed Suggested CR-ERNS Reporting
Format - Addendum to TRI Form R. These formats,
as well as the rest of the Guide, should prove helpful to
both EPA Regional personnel and reporting facilities.
                                                   10

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APPENDIX A
ACRONYMS

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                                          ACRONYMS
CASRN        Chemical Abstracts Service Registry Number




CERCLA       Comprehensive Environmental Response, Compensation, and Liability Act of 1980




CFR           Code of Federal Regulations




CR-ERNS      Continuous Release Emergency Response Notification System




EHS           Extremely Hazardous Substance




EPA           Environmental Protection Agency




EPCRA        Emergency Planning and Community Right-to-Know Act




FR            Federal Register




LEPC          Local Emergency Planning Committee




NCP           National Contingency Plan




NRC           National Response Center




OSC           On-Scene Coordinator




RQ            Reportable Quantity




SARA          Superfund Amendments and Reauthorization Act of 1986




SERC          State Emergency Response Commission




SSI        -   Statistically Significant Increase




TERC          Tribal Emergency Response Commission




TRI        -   Toxic Release Inventory




VNTSC    -   John A. Volpe National Transportation Center

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                  APPENDIX B
SUGGESTED CONTINUOUS RELEASE REPORTING FORMAT

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SECTION I: GENERAL rp
INFORMATION
Date of Initial Release:
Type Of Report: Indicate belov
1 J Initial Written Notification


Date of
/ the type of report you are submitl
First Anniversary Wrirter
Follow-up ["I ofaCh
Report — initial 1
fcNS Number:
Initial Call to NRC:
ting.
i Notification 	 Written Notification
ange to [ | of a Change to
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.

Date


Name and Position
Signature


Part A. Facility or Vessel Information

Name of Fac
Person
in Charge
of Facility
or Vessel
f7_ _Ğ1ĞA__
v acuity
Address or
Vessel
Port of
Registration
Dun and Bra
Facility/Vesa
Location
PartB. Pop
Population
Density
Sensitive
Populations
and
Ecosystems
Within One
Mile Radius

ility or Vessel





Name of Person in Charge
Position
Telephone No. ( ) Alternate Telephone No. ( )
Street
City



County
State Zip Code

dstreet Number for Facility |

?1 Latitude De
Longitude De

g Min Sec
g Min Sec


Vessel LORAN Coordinates



mlation Information
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 preserve

Distance and direction from facility
s, etc.)




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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(0 (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.

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 SECTION II: SOURCE
                  INFORMATION
                  (continued).
                                      CR-ERNS Number:
  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.
  OAIR
(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 Velocity  	feet/second or
                               meters/second
         Gas Temperature 	degrees Fahrenheit,
                              Kelvin, or Celsius
                                            For a release to surface water, provide the
                                            following information, if available:
                                            Average Velocity 	 feet/second
                                            of Surface Water

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SECTION II: SOURCE INFORMATION
                (continued)
                                                          CR-ERNS 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 Ibs. or kg per day)*      Release Occurs    Released in Previous Year  Months of the
  Name of Hazardous Substance   CASRN #      Upper Bound    Lower Bound      (per year)           (in Ibs. 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 Ibs. or kg per day)*
 Weight     Upper   Lower
Percentage   Bound   Bound
  Normal Range of
      Mixture
(in Ibs. or kg per day)*
  Upper   Lower
  Bound Bound
Number of  Tolal Quantity of
Days Release Mixture Released
 Occurs     in Previous Year
(per year)    (in Ibs. or kg)
Months
 of the
 Release
               Please be sure to include units where appropriate. Also, if the release is a radionuclide. units of curies (Cl) are appropriate.

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     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 Range of
                                                    the Release (specify Ibs.. kg. or Ci)
   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 die 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.

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                        APPENDIX C
SUGGESTED CR-ERNS REPORTING FORMAT -- ADDENDUM TO TRI FORM R

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                      CR-ERNS Report - Addendum to Form R
   This Form serves as an addendum to EPCRA Section 313 Toxic Release Inventory (TR1)
   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
                         Follow-up
                         Report
Initial
Written
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 1 <)'97

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 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 release data


            AP-42
             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:
     	   Air                	  Surface Water
                                              Soil or Ground Water
    Air
  Surface
  Water
  Soil or
  Ground Water
If release is to air, please indicate stack height OR surface area of the release.
Stack Heieht OR Surface Area




If release is to Surface Water, please indicate name, type and
of the water body:
\Jimp of watpr hoHv
If stream' Stream f^rder OR
If lake* Surfacp area (ac) AND

lto. Indicate distance of closest water well:

specific information
Average flow n
Average Depth



ite (fWsec)
(m)

   Hazardous Substance Information:
    Name of Hazardous
    Substance:
CASRN#
Upper      Lower
Bound      Bound
(in Ibs. or kg per day)
Number of
Days Release
Occurs (per year)
Months of
the Release
                                                                                          Page 2 9/97

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            APPENDIX D
MISSING INFORMATION COVER LETTERS
AND MISSING INFORMATION CHECKLIST

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                         MISSING INFORMATION COVER LETTER #1

                          Most recent report received is less than a year old.


[Name of Person in Charge]
[Title]
[Facility Name, Division]
[Street Address]
[City, State Zip Code]

Dear [Name of Person in Charge]:

The purpose of this letter is to verify the accuracy and adequacy of your report of a continuous release of a
hazardous substance that equals or exceeds a reportable quantity (RQ), under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA).

CERCLA provides that releases of hazardous substances that are continuous and stable in quantity and rate
may be reported less frequently than on a per-occurrence basis if certain criteria are met.  Continuous
Release Rules were published on July 24, 1990 (55 FR 30166) effective September 24, 1990, and are
codified at 40 C.F.R. section 302.8.

According to our records, your facility filed with the Environmental Protection Agency (EPA) [a(n) initial
written or change] notification of a continuous release of a hazardous substance on [Date of most recent
correspondence]. To properly evaluate your facility's continuous release, EPA needs complete and
accurate information.  In your latest correspondence, several pieces of information were missing. These
have been identified on the enclosed "Missing Information Checklist."

To assist you in submitting the required information, EPA has developed a sample reporting format for
initial, change notification, and follow-up reports. Adequate review of your continuous release report
cannot be complete unless all the information on the format is supplied for each source.

EPA has transferred your facility's continuous release information onto a copy of this reporting format
(enclosed). Please review it for accuracy. In addition, please complete the highlighted missing
information.  Send this format and the information requested, within 30 days of your receipt of this letter
to: Mr. C.R. Ems, Regional Continuous Release Coordinator, 401 M Street, Washington, DC 20202.

Please note that EPA has no record of receiving your first anniversary follow-up report for this reported
release. According to the Continuous Release Rule, you must submit a follow-up report within 30 days of
the first anniversary date of your initial written or change notification report. The follow-up report is based
on actual release data gathered since the initial  written report or change notification.  Follow-up reports that
are due can be submitted onto the enclosed blank format and should be sent to the above address.

Please feel free to copy the blank reporting format for your use in submitting future continuous release
reports. Thank you for your prompt attention to this matter.  If you have any questions, please call Mr.
C.R. Ems Regional Continuous Release Coordinator, at (999) 999-9999.

                                                        Sincerely,
                                                        C.R. Ems
                                                        Regional CR-ERNS Coordinator
                                                        Enclosures

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                         MISSING INFORMATION COVER LETTER #2

                         Most recent report received is more than a year old.
[Name of Person in Charge]
[Title]
[Facility Name, Division]
[Street Address]
[City, State Zip Code]

Dear [Name of Person in Charge]:

The purpose of this letter is to verify the accuracy and adequacy of your report of a continuous release of a
hazardous substance that equals or exceeds a reportable quantity (RQ), under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA).

CERCLA provides that releases of hazardous substances that are continuous and stable in quantity and rate
may be reported less frequently than on a per-occurrence basis if certain criteria are met.  Continuous
Release Rules were published on July 24, 1990 (55 FR 30166) effective September 24, 1990, and are
codified at 40 C.F.R. section 302.8.

According to our records, your facility filed with the Environmental Protection Agency (EPA) [a(n) initial
written, follow-up, or change] notification of a continuous release of a hazardous substance on [Date of
most recent correspondence]. To properly evaluate  your facility's continuous release, EPA needs
complete and accurate information. In your latest correspondence, several pieces of information were
missing.  These have been identified on the enclosed "Missing Information Checklist."

To assist you in submitting the required information, EPA has developed a sample reporting format for
initial, change notification, and follow-up reports.  Adequate review of your continuous release report
cannot be completed unless all the information on the format is supplied for each source.

EPA has transferred your facility's continuous release information onto a copy of this reporting format
(enclosed). Please review it for accuracy. In addition, please complete the highlighted missing
information.  Send this format and the information requested,  within 30 days of your receipt of this letter
to: Mr. C.R. Erns, Regional Continuous Release  Coordinator, 401 M Street, Washington, DC 20202.

We have included a new blank reporting format for your use in submitting future continuous release
reports. Thank you for your prompt attention to this matter. If you have questions, please call Mr. C.R.
Erns Regional Continuous Release Coordinator, at (999) 999-9999.

                                                        Sincerely,
                                                        C.R. Erns
                                                        Regional CR-ERNS Coordinator
                                                        Enclosures

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                                 MISSING INFORMATION CHECKLIST

                 As submitted, your continuous release report ( #	) was missing the information indicated
        below.  Please provide the information indicated by the check marks.

D      A signed statement. A signed statement is required to verify your continuous release,   \lthoughthis
        information is not vital to evaluating the risks of your release, it is required by CR-ERNS Rule. Though
        variations in wording are acceptable, a standard signed statement reads as follows: "The hazardous
        substance release(s) described is/are continuous and stable in quantity and rate under the definitions in 40
        C.F.R. section 302.8(b) and all reported information is accurate and current to the best of our knowledge."
        Please provide such a statement.

D      The facility address. The facility address submitted in the report was incomplete. Information regarding
        the location of the facility is essential to processing the report.  If the actual location of the facility is
        different from the mailing address of the company, please submit both addresses.  Please remember to
        include rhe county in which the facility is located.

D      The county. The county where the facility is located is important information used in processing a facility's
        continuous release report. Please submit this information as it was not included in your report.

D      The Dun and Bradstreet Number. The Dun and Bradstreet number provides additional information about
        a facility. Please submit this information.  If your facility does not have a Dun and Bradstreet Number,
        please write "not applicable."

D      Facility location. Facility location is delineated by the latitude and longitude. Please give the full
        coordinates to indicate your facility's location.

D      The sensitive populations and ecosystems within a one-mile radius.  Each sensitive population or
        ecosystem within a one-mile radius of your facility should be identified.  Schools, hospitals, and nursing
        homes are examples of sensitive populations.  Ecosystems are areas containing wildlife (i.e., reserves or
        wetlands) that are threatened by potential releases. Please describe the location of each such sensitive area
        in relation to the facility (e.g., "Little Flower Elementary School is located 400 yards southwest of the
        facility")- Exact addresses afe not required.

D      Specific source information.  To make accurate risk assessments, it is essential that EPA have detailed
        information for each releasing source.  Detailed information for each specific source should include:  the
        hazardous substances released; the volume of the substances released; the affected media (e.g., air or
        surface water); and the method of dispersion (e.g., stack or area source).  Please also include the individual
        heights of all stacks or, in the case of fugitive or  area sources, the surface area. It is not sufficient to report
        that your facility is releasing from southwestern stacks; instead, you must define each of these stacks'
        specifications individually.  Please provide this more detailed information for each of your releasing
        sources.

D      The source activity. For the purposes of risk assessment, it is important that your facility indicate the
        activity causing the release of a hazardous substance from each source.  Please provide a brief description
        of the activity that causes a continuous release for each specific source.

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D      The pattern of the release. The CR-ERNS Rules require a description of how the "pattern of the release"
        was established for each releasing source. Such patterns may have been established through use of previous
        data, engineering estimates, knowledge of the facility's operations and release history, best professional
        judgment, or another means. Please indicate how your facility established its pattern of release for each
        source.

D      The affected media. The media affected by each source is an important piece of information for risk
        assessment. EPA needs to know the type of media affected (i.e., air, surface water). In addition, EPA needs
        the specifications for each source affecting the medium.  For example, in the case of an air release, EPA
        asks that you provide an estimated stack height or surface area (even if the source is defined as fugitive) so
        that a risk assessment can be properly made.

D      Volume definition. Sources are/are not defined, and therefore volumes are  not allocated to each source.
        Please indicate the volume of each hazardous substance released from each  individual source by providing
        either actual volumes or percentage values.

D      The upper and lower  bound of the release. The upper and  lower bounds represent the range of the
        amount of a hazardous  substance emitted over a 24 hour period from each source.  These figures are
        required to determine both the facility's statistically significant increase (SSI) trigger and the allowable
        emission rate per substance per  day. Please provide an upper and  lower bound for each hazardous
        substance from each individual  source.

D      The number of releases per year.  The number of releases per year for each source is not specifically
        defined in your report.  Please determine the number of days per year each source releases the hazardous
        substance, not the number of days that the facility operates. Stating "continuous" is not sufficient as one
        source may be continuously operating 365 days a year, while another source may also be continuous, but
        only operating 350 days a year.

D      Total annual quantity released.  For each source, please indicate the total annual quantity of each
        hazardous substance released.

D      Months of the release. For each source, please indicate the exact months during which each hazardous
        substance is released, (i.e., For Source A, N'Ox is released in Feb. and May, and H;S is released Jan.
        through Dec.)

D      SSI Trigger. Please calculate the Statistically Significant Increase Trigger by aggregating the upper bound
        amounts over all sources for each hazardous substance.

D      Optional information. In addition, it would be helpful if you could provide the optional information
        requested. This information is not required, but will make the preliminary risk evaluation much more
        accurate. Additional information may be provided for the following: for release to air through stacks -
        inside diameter, gas exit velocity, and gas temperature; for release to surface water - average velocity of the
        surface water.

Q      Other. Please provide the following additional missing information.

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