This paper focuses on the development of Cramér-Rao Bound (CRB) expressions for passive source location estimation in various Gaussian noise environments. The scenarios considered involve an unknown deterministic source signal with a short time duration, and additive general Gaussian noise. The mathematical derivation procedure presented is applicable to non-stationary Gaussian noise problems. Specifically, explicit closed-form CRB expressions are presented using the spectrum representation of the signal and noise for stationary Gaussian noise cases.