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
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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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