Compliance Status Report
Source Description 391-3-19-.06(3)(b)1.

(http://rules/sos.state.ga.us/docs/391/3/19/06.pdf)

Description

This portion of the CSR describes any potential source areas at the site. The following should be considered when assessing potential source areas:

• Areas of known or suspected leaking tanks or piping
• Areas of known or suspected spills
• Underground piping
• Floor drains/sumps
• Chemical storage areas
• Chemical processing areas
• Waste collection areas
• Waste disposal areas
• LNAPL/DNAPL (http://www.epa.gov/superfund/health/conmedia/gwdocs/non_aqu.htm)

A description of the source areas should include the following items:

• Historical activities at the site including past site uses
• Locations where chemicals were stored and transported across the site
• Process operations both outside and inside site buildings
• Waste generated at the site and how waste was disposed
• Loading/unloading locations
• List of chemicals formerly used at the site

The description of the sources should include a source name, number or any other description; the name of regulated substances released from the source; the chronology of each source of a release (if known); and a description of the source function, size, and design.

List of Figures to Include

• A site map showing the locations of all suspected source areas. The map should have a scale of 1” = 200’ or less.
• If any engineering drawings are available of the source, a copy of these should be provided.

Common Mistakes

• Not including a list and description of sources in the CSR
• Not including descriptions of historical activities, especially process areas, at the site that may have impacted the site
• Not providing a general historical review using historical resources:
• City directories
• Fire insurance maps
• Aerial photographs
• Not including one or several certain obvious areas, as listed above, as a potential source

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