6100-10 Continuous Release Reporting Form

Form Approved OMB No. 2050-0086
Expiration Date: XX-XX-XXXX

Continuous Release Reporting Form
SECTION III: SUBSTANCE
INFORMATION

CR-ERNS Number:

Calculation of the SSI Trigger
For EACH 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.
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 lbs., 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 the normal range of the release, taking into
consideration all sources of the release at the facility or vessel. The normal range of the release includes all
releases previously reported or occurring over a 24-hour period during the previous year.
EPA Form 6100-10, Continuous Release Reporting Form

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INSTRUCTIONS
SECTION III: SUBSTANCE INFORMATION
CR-ERNS Number:
If you are reporting a release of a CERCLA hazardous substance(s), you will be assigned a CR-ERNS number when you make
this initial telephone call to the NRC (1-800-424-8802). This CR-ERNS number will become the identifier for your facility. Your
CR-ERNS number will never change; it is the number that identifies you in the CR-ERNS database.
After you provide the required information for all sources of continuous releases from your facility, you must aggregate
information of a hazardous substance release from all sources to determine the SSI trigger (upper bound of the normal range)
for each hazardous substance released at your facility.
The SSI trigger of a particular hazardous substance is calculated by aggregating the upper bounds of the hazardous
substance released across all sources at a facility.
If you are aggregating CERCLA hazardous substance releases from separate, contiguous, or adjacent facilities and
reporting them in a single report, aggregate the upper bound of the normal range of the hazardous substance released from all
sources at the site to determine the SSI trigger. If you aggregate your releases across facilities, the SSI trigger must also be sitespecific, not facility-specific. Aggregating releases across facilities at the same site may reduce your reporting burden; however,
EPA will evaluate the risks associated with the releases as if the releases were from one facility.
To calculate the SSI trigger for each hazardous substance you should:
1.

List each specific source name and enter the upper bound of the normal range of the release from that source. If the
identified hazardous substance is a component of a mixture, enter the upper bound of the normal range for that
component of the mixture (as determined in Section II, Part C).

2.

Aggregate the upper bound quantities from each source of the release. Report these totals as the SSI trigger for the
hazardous substance. The example that is provided below illustrates the calculation of the SSI trigger for a release of
ammonia.

The above method for calculating the SSI trigger of a hazardous substance assumes that all releases of the same
hazardous substance occur simultaneously (i.e., over the same 24-hour period). To the extent that the frequency of the release
differs, you may adjust the SSI trigger so that it more accurately reflects the frequency and quantity of the hazardous substance
released from all sources over a 24-hour period. The SSI trigger in the final analysis must reflect the upper bound of the normal
range of the release, taking into consideration all sources of the release at the facility. The normal range of the release includes
all continuous releases previously reported or occurring over a 24-hour period during the previous year.

Calculation of the SSI Trigger for a
Hazardous Substance
Hazardous
Upper
Substance
Source
Bound
Ammonia

Tank Vents
in Building #1

120 lbs.

Valves in
Building #5

115 lbs.

Upper Bound for Ammonia

235 lbs.

For the purposes of this example, it is assumed
that the only sources of the ammonia release at
the facility are the Tank Vents in Building #1
and the Valves in Building #5.

Paperwork Reduction Act Notice
The public reporting and recordkeeping burden for this collection
of information is estimated to average 10 hours per response.Send
comments on the Agency's need for this information, the accuracy
of the provided burden estimates, and any suggested methods for
minimizing respondent burden, including through the use of
automated collection techniques to the Director, Collection
Strategies Division, U.S. Environmental Protection Agency
(2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460.
Include the OMB control number in any correspondence. Do not
send the completed form to this address.