Using TRI Form R for Continuous Release Reporting

A facility wants to use the reduced reporting option under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) section 103(f)(2) for releases of hazardous substances that occur in a manner that is continuous and are stable in quantity and rate. Can the Toxics Release Inventory (TRI) Form R be used to satisfy continuous release reporting?

A facility can fulfill the continuous release reporting requirements under CERCLA section 103(f)(2) by filing a Form R with an addendum. The addendum provides EPA with details about the continuous release that are not available from the Form R itself, but that are required to properly evaluate the risks associated with the release. The format for the addendum can be found in Appendix C of Reporting Requirements of Continuous Releases of Hazardous Substances, A Guide for Facilities on Compliance (EPA540-R-97-047).