6200-09 Continuous Release Reporting for Farms

Form Approved OMB No. 2050-0086; Expires 12/31/2011

Continuous Release Reporting for Farms

ID Number
(CR-ERNs or Other)

SECTION II: ANIMAL WASTE SOURCE INFORMATION

Part A: Basis for Asserting the Release is Continuous and Stable in Quantity and Rate
For EACH animal waste source of a release of a hazardous substance to the air from your farm, provide the following
information. Use a SEPARATE sheet for each animal waste source.

Name of Animal Waste Source:

Check One - Whether the release from this
animal waste source is either:

Continous without interruption.
Routine, anticipated, intermittent.

Identify the activity(ies) that results in the release from this animal waste source (e.g., manure pile, lagoon, etc.) to the air.

Identify below how you established the pattern of release and calculated release estimates. Check all that apply.
Past Release Data

Knowledge of the farm operations and release history.

AP-42 Procedures

Engineering Estimate

Best Professional Judgment

Other (explain)

EPA Form 6200-09, Continuous Release Reporting for Farms

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INSTRUCTIONS
SECTION II: ANIMAL WASTE SOURCE
INFORMATION (Part A)
ID Number (CR-ERNS or Other):
The CR-ERNS number is not required for this submission; however, if you choose to use the CR-ERNS number as an ID number call
the National Response Center (NRC) 1-800-424-8802 and state that you are making an Initial Telephone Notification.
The Other number can be obtained from the State Emergency Response Commission (SERC) and/or Local Emergency Planning
Committee (LEPC).
The ID Number is for identification purposes only and may or may not be required by your SERC and/or LEPC.
General overview - When completing your written reports, you must take into consideration all animal waste sources of the release to the air from your farm. For
example, if the aggregate amount of a particular hazardous substance released within 24 hours from your farm equals or exceeds an RQ, then each animal waste source
of the particular release to the air must be identified, even if some release amounts from individual animal waste sources do not equal or exceed the RQ. The purpose of
requiring information on the animal waste source(s) of the release to the air is to provide EPA with sufficient information to evaluate the risk associated with the
continuous release. Providing this information accurately in the written report will minimize future requests for additional information or clarification.
In this section of the written report, you should identify and describe separately each continuous release animal waste source. If the continuous release of the same
hazardous substance comes from two or more animal waste sources (e.g., two barns), then information should be reported separately for each of the animal waste
sources. For example, if a barn is one of several animal waste sources of a hazardous substance release to the air at your farm, you must provide information on that
barn including: the identity of the hazardous substance(s) being released from the barn; the quantity released to the air; and the frequency of the release from the barn.
If you have a release of a particular hazardous substance from three barns, you should report each barn separately and provide the required information specified for
each barn.
Although the continuous release reporting regulation allows multiple concurrent releases of the same CERCLA hazardous substance to be considered as if they were
one continuous release, aggregate reporting of such releases to the air from different animal waste sources complicates risk analyses. Area sources are most readily
aggregated for purposes of continuous release reporting and risk evaluation when the frequency of the release to the air from each animal waste source is the same.
Similarly, aggregated barn releases are most readily evaluated if the frequency of the release from each barn is the same. If you elect to aggregate releases across the
farm, be certain to identify information about each animal waste source of the release to the air.
Identification of animal waste sources - In Section II, you must identify (i.e., name) and describe each continuous release animal waste source. There are several ways
to name animal waste sources. It is important to: (1) provide a name that clearly identifies the animal waste source; and (2) avoid giving two or more animal waste
sources the same name. It is also important to remember when naming your animal waste sources that you may be contacted with questions regarding releases from
one of your named animal waste sources. It would be prudent, therefore, to name the animal waste sources at your farm in a manner that will be easy for you and other
employees to identify them. For example, if your plant has four lagoons, two manure piles, and five barns, you may name the animal waste sources as follows: Lagoon
#1; Lagoon #2; Lagoon #3; Lagoon #4; Manure pile #1; Manure pile #2; and Barm #1. Barm #2. Barm #3, Barn #4, and Barn #5.
Required information - Section II, Animal Waste Source Information, contains three Parts (A, B, and C). You must provide the information required in each of these
Parts for each continuous release animal waste source. Be sure to place the name of the animal waste source on all pages associated with that specific source.
Part A - Basis for Asserting the Release is Continuous and Stable in Quantity and Rate:
You must first identify the animal waste source of the release (include the name of the animal waste source in all subsequent parts), then briefly describe the basis for
stating that the release is continuous and stable in quantity and rate. Your description of the basis for stating that the hazardous substance release is continuous and
stable in quantity and rate should include whether the release is continuous without interruption, or is a routine, anticipated, intermittent release. It should also
include information on when the release is expected ot occur (i.e., evidence of predictability of the release). The general assumption is that releases of hazardous
substances to the air from animal waste at farms is essentially on-going and therefore continuous.
Your description should also identify the activity that results in the release. If the release occurs because of a malfunction or other unusual event, this should be
explained fully.
Finally, your description should include information on how you established the pattern of the release and calculated release estimates (e.g., engineering estimates,
your best professional judgment, past release data).
For each animal waste source identified, provide the following information:
(1) Indicate whether the release is continuous without interruption or abatement or routine, anticipated, and intermittent.
(2) Identify the activity or activities that cause the release to the air from the animal waste source.
(3) Identify how you established the pattern of the release and calculated release estimates.