                                       
Statement Supporting the Renewal 
of the Information Collection Request
under CERCLA section 103(a) and CWA Section 311  - 
 Episodic Release Notification of Oil and Hazardous Substances


1.	Identification of the Information Collection

      1 (a)	Notification of Episodic Releases of Oil and Hazardous Substances, EPA ICR No. 1049.15, OMB No. 2050-0046

      1 (b) 	Short Characterization

      This information collection request (ICR) addresses the reporting and recordkeeping activities required to comply with the release notification requirements for hazardous substances and oil specified in section 103(a) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended, and section 311 of the Clean Water Act (CWA), as amended. These reporting requirements are codified at 40 CFR parts 110, 117, and 302. This ICR renews the collection activity previously approved under ICR OMB Control No. 2050-0046 which will expire on July 31, 2022. Estimates of the industry and the government burdens to comply with the release notification requirements are presented on an annual basis.
      CERCLA section 103(a) and CWA section 311 require the person in charge of a facility or vessel to notify the National Response Center (NRC) immediately of a hazardous substance release into the environment if the release quantity equals or exceeds the substance's reportable quantity (RQ) level or is an oil discharge into U.S. waters. The regulated community is expected to:
      ::	Gather necessary release data, such as the time, quantity, and source of the release,
      ::	Notify the facility manager of the release,
      ::	Consult with the environmental compliance expert regarding the release,
      ::	Report the release to the NRC; and
      ::	Keep a log of release data such as the time, date, and circumstances of the release. (This information is expected, but not required, under the regulations.)
      There are no recordkeeping requirements specified under CERCLA section 103(a), CWA section 311, or their implementing regulations. The person in charge of the facility or vessel, however, may elect to maintain a log detailing the time, date, and circumstances associated with the reported release to track correspondence with response authorities and to document compliance with release notification requirements under CERCLA and the CWA. EPA assumes respondents will maintain a log of reported releases, so burden and cost estimates associated with recordkeeping are included in the ICR.
2. Need/Authority for Collection; Use/Users of the Data
                              
      2 (a) Need/Authority for the Collection
      
      This collection is required under 40 CFR parts 110, 117, and 302 is authorized under CERCLA sections 103(a) and 104(e), and CWA sections 311 and 308. The regulations implementing CERCLA section 103(a) (40 CFR part 302) require the person in charge of a facility or vessel to immediately notify the NRC of a hazardous substance release if the release quantity equals or exceeds the substance's RQ. The specific information provided in the notification required under CERCLA section 103(a) is authorized under CERCLA section 104(e). Section 104(e) authorizes the collection of release information, entry and inspection of the release site, and sampling activities at the release site for the purposes of "determining the need for response, or choosing or taking any response action under [CERCLA]." The release information collected is the minimum information needed to determine whether a Federal response action is required to control or mitigate any potential adverse effects associated with a release.
      In addition to the CERCLA notification requirements, the regulations implementing CWA section 311 (40 CFR part 110) require immediate notification to the NRC of any release of oil into U.S. navigable waters that causes a sheen, violates applicable water quality standards, or causes a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines. The information required under CWA section 311 is authorized by CWA section 308, which allows for the collection of release information and entry, monitoring, inspection and sampling activities at the release site for the purpose of ensuring that the objectives of the CWA are satisfied. The Federal government must be notified of releases of oil in order to determine whether a response action is necessary to mitigate or prevent damage to public health or welfare or the environment.
      2 (b) Use/Users of the Data	
      The information collected pursuant to CERCLA section 103(a) and CWA section 311 is used by Federal response authorities, such as EPA and U.S. Coast Guard On-Scene Coordinators (OSCs) to evaluate the environmental and human health risks attributable to a reported release and to determine whether a Federal response action is necessary to mitigate or prevent any associated adverse effects. Federal response activities may include monitoring and overseeing cleanup activities conducted by the responsible party, evacuating surrounding populations, and directing the actual cleanup operation. EPA program offices and other Federal agencies also use the information to evaluate the potential need for additional regulations, new permitting requirements for specific substances or sources, or improved emergency response planning.
      State and local government authorities and the regulated community use release information to help inform local emergency response planning. The public use release information to learn of the releases that have occurred in their communities and in the nation and to become informed of any actions undertaken to protect public health and welfare, and the environment. The public has access to release information, statistics, and fact sheets through the Freedom of Information Act and the NRC's website www.nrc.uscg.mil/.  
      
3.	Nonduplication, Consultations, and Other Collection Criteria

       3 (a) Nonduplication

      The information required in the notification call to the NRC is the minimum necessary to evaluate a hazardous substance release or discharge of oil. Direct notification to the NRC helps to ensure a coordinated Federal response effort and avoid unnecessary delays in requesting assistance. One phone call to the NRC fulfills the requirement to report releases of hazardous substances under CERCLA and several other regulatory programs, including the Clean Water Act (CWA), the Resource Conservation and Recovery Act (RCRA), the Hazardous Materials Transportation Act, and the Emergency Planning and Community Right-to-Know Act (EPCRA). When the NRC receives a notification, the NRC watch officer immediately notifies the appropriate Federal OSC, who evaluates the circumstances surrounding the release and determines the need for a Federal response action. 
      EPA analyzed potential areas of overlap in reporting requirements under other statutes and regulations and found only limited overlap such as, for example, with the reporting requirements specified in CERCLA section 103(a) and in certain permitting regulations, which often require reporting if the permitted release or discharge level is exceeded. However, in contrast to notifications of permit violations, Federal officials use release information provided to the NRC to evaluate the release situation in near real time and to determine whether a government response is necessary. Thus, the notification in monthly monitoring reports that a permit release limit is exceeded is not timely for response purposes. Some overlap may also exist with the reporting requirements specified in EPCRA section 304, which requires immediate reporting of releases of CERCLA hazardous substances equal to or above an RQ to state and local response officials (OMB Control Number 2050-0092). However, reporting to the NRC as well as to the appropriate State Emergency Response Commission (SERC) and Local Emergency Planning Committee (LEPC), as required under EPCRA section 304, is necessary because it ensures that the Federal government is alerted to releases that may require a Federal field response and allows for a timely response in the event of an emergency. Although the SERCs and LEPCs are notified of the releases under EPCRA section 304, some SERCs and LEPCs may not have the resources needed for a proper response action. Furthermore, reporting to the NRC, SERC, and LEPC provides for a coordinated and more efficient response effort among Federal, state, and local response officials. The statutory requirements under CERCLA and EPCRA are clear and distinct; the Federal response system, as well as the state and local response systems, must be immediately alerted to potentially dangerous releases of hazardous substances that may pose a threat to public health or welfare or the environment.
      
      3 (b) Public Notice
      
      In compliance with the Paperwork Reduction Act (44 U.S.C. 3501 et seq.), the Agency has notified the public about this ICR renewal through the Federal Register notice on Sept. 23, 2021 (86 FR 52903). EPA received one comment which was supportive of episodic reporting requirements under CERCLA and the renewal of the Information Collection Request.
      
      3 (c) Consultations
      
      EPA contacted six facilities that reported releases to the NRC to collect estimates of the burden for the initial telephone notification to the NRC following a release. Summaries of these calls are in Appendix A. Facilities estimated they spent between 5 and 20 minutes (.08 hour to .33 hour) on the NRC call. These estimates are lower than the estimated burdens used in the previous ICR renewal. Because this is such a small sample and to avoid underestimating the burden in this ICR renewal, EPA is maintaining the previous, higher estimated burdens used in the previous ICR renewal. 
       3 (d) Effects of Less Frequent Collection
      The information required under the regulations implementing CERCLA section 103(a) and CWA section 311 is collected only when reportable releases occur. The information, including the source, quantity, and type of material released and the environmental medium affected, is critical to evaluating the threat posed by the release and the need for a response action. The regulatory requirements evaluated in this ICR represent EPA's efforts to ensure that the NRC is notified immediately of those hazardous substance releases and oil discharges for which a Federal response action may be necessary to protect public health and welfare and the environment.
      3(e)	General Guidelines

      The regulations implementing CERCLA section 103(a) and CWA section 311 adhere fully to OMB's general guidelines concerning the collection of information and the control of paperwork burdens on the public.
      
      3 (f) Confidentiality 
      
      The regulations implementing CERCLA section 103(a) and CWA section 311 do not require the submission of any proprietary business information. The information collection requested under these regulations is in compliance with the Privacy Act of 1974 and OMB Circular A-108.
      3(g)	Sensitive Questions
      
      The regulations implementing CERCLA section 103(a) and CWA section 311 do not require the submission of any sensitive information. 
4.	Respondents' NAICS Codes; Information Requested
      
      4 (a) Respondents' NAICS Codes
      
      EPA expects a number of different industrial categories to report hazardous substance releases and oil discharges pursuant to the requirements specified in CERCLA section 103(a) and CWA section. These sections apply to facilities in both the manufacturing and non-manufacturing sectors.  
      	
      Facilities in the following major NAICS groups at the two-digit level that may be subject to either or both implementing regulations under CERCLA section 103(a) and CWA section 311 are: 11 (Agriculture, Forestry, Fishing and Hunting), 22 (Utilities), 31-33 (Manufacturing), 43 (Wholesale Trade), 44-45 (Retail Trade), and 48-49 (Transportation and Warehousing). Facilities under other NAICS codes may be covered by these regulations but are not listed above.

      4 (b) Information Requested
     
       	(i)  Data Items

      See Appendix B for a list of the information items required to be provided in the notification call to the NRC for an episodic release. 
      As mentioned previously, there are no recordkeeping requirements specified under CERCLA section 103(a), CWA section 311, or their implementing regulations. The person in charge of the facility or vessel, however, may elect to maintain a log detailing the time, date, and circumstances associated with the reported release. EPA assumes that respondents will maintain a reported release log, so burden and cost estimates associated with recordkeeping are included in this ICR.
      
        (ii) Respondent Activities

      To comply with the notification requirements specified in the regulations implementing CERCLA section 103(a) and CWA section 311, the regulated community is expected to perform the following activities:
      
      ::	Gather necessary release data, such as the time, quantity, and source of the release,
      ::	Report the release by telephone to the NRC, and,
      ::	Keep a log of release data such as the time, date, and circumstances of the release. (This information is expected but not required under the regulations.)
 5.  THE INFORMATION COLLECTED  -  AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT
      5(a)	Agency Activities
      
      Every hazardous substance release and oil discharge reported by the regulated community to the NRC must be evaluated by a Federal On-Scene Coordinator (OSC), who is notified of a release by a telephone call from the NRC within 15 minutes of the release. The NRC informs the OSC about whether the release is to air, soil, water, etc., the source of the release, and the type of substance released. The OSC is responsible for evaluating the circumstances surrounding the release to determine whether government monitoring and/or a Federal response action may be necessary.
      
      Release notification information is stored in EPA's WebEOC, a web-based crisis management system which supports response management for significant incidents and daily operations in the Regional Response Centers and EPA's Headquarters Emergency Operations Center (EOC). The primary activity of the Federal government under the regulations implementing CERCLA section 103(a) and CWA section 311 is processing and recording the reported release information and responding to releases that may pose a significant hazard to public health or welfare or the environment.
      
      5(b)	Collection Methodology and Management
      
      A person in charge of a facility or vessel that experiences a reportable release under CERCLA section 103(a) and CWA section 311 must notify the NRC by phone. The NRC then notifies the appropriate EPA Region or United States Coast Guard Office, the affected state, and any other Federal agency that may be able to support a potential response action.
      Release notification information is stored in EPA's WebEOC, a web-based crisis management system which supports response management for significant incidents and daily operations in the Regional Response Centers and EPA's Headquarters Emergency Operations Center. 
      
      5(c)	Small Entity Flexibility
      
      The notification requirements apply equally to all facilities or vessels, regardless of size, that have reportable releases of CERCLA hazardous substances or oil. The regulations do not impose any general information collection or recordkeeping requirements on small businesses. The notification requirements specified under these regulations represent the minimum amount of information necessary for Federal response officials to determine whether a government response action is needed to prevent or mitigate any damage to public health or welfare or the environment. These reporting requirements cannot be reduced for small businesses without jeopardizing the Federal government's ability to evaluate the threat posed by a release and determine whether a Federal response is necessary.
      
      5(d)	Collection Schedule
      
      Information is not collected at any specified frequency; rather, it is collected when reportable releases occur. Under CERCLA section 103(a), a release of a hazardous substance is reportable when it equals or exceeds its RQ. Pursuant to CWA section 311, a discharge of oil into navigable waters is reportable whenever the discharge causes a sheen, violates applicable water quality standards, or causes a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.
      
6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

      6(a)	Estimating Respondent Burden
      
      Under CERCLA section 103(a) and CWA section 311, the person in charge of a facility or vessel that experiences a reportable release is expected to perform the following activities: (1) gather necessary release data, such as the time, date, quantity, and source of the release; (2) report the release by telephone to the NRC; and (3) keep a log of release data such as time, date, and circumstance of the release. Respondents are not required to keep a log of release data under the episodic release notification regulation; however, EPA assumes respondents will do so.
      
      Exhibit 1 presents a summary of the unit burden hours associated with reporting a typical release to the NRC. The burden associated with the "Initial telephone call to the NRC" includes time spent gathering data on the release. EPA has estimated that the respondent's total burden for reporting a typical release is 1.02 hours. These estimates are unchanged from the previous ICR renewal.
                                   Exhibit 1
         Unit Burden Hours for Reporting a Typical Release to the NRC
                              Collection Activity
                                 Burden Hours
                              Total Burden Hours

                                  Managerial
                                   Technical
                                   Clerical

Initial telephone call to the NRC
                                     0.32
                                     0.32
                                     0.00
                                     0.64
Recordkeeping
                                     0.02
                                     0.18
                                     0.18
                                     0.38
                                     Total
                                     0.34
                                     0.50
                                     0.18
                                     1.02
 
      6(b)	Estimating Respondent Costs
      
      	(i) Labor Costs

      EPA estimates costs to respondents by multiplying the respondent burden estimates for each labor category by the corresponding labor rate for that category. EPA updated labor rates from the previous ICR using the employer costs for employee compensation tables from the Bureau of Labor Statistics (BLS), Dec. 2020. EPA then multiplied unit costs for each respondent or activity by the number of respondents or activities performed on an annual basis to yield a total cost for each information collection activity in section 6(d). These costs are shown in Exhibit 2.

	Updated hourly respondent labor costs for manufacturing facility respondents are $73.50 for managerial staff, $58.08 for technical staff, and $27.28 for clerical staff, including wages and benefits.  Updated hourly respondent labor costs for non-manufacturing facility respondents are $62.46 for managerial staff, $33.84 for technical staff, and $26.37 for clerical staff.

	EPA then calculated average labor rates for each labor category, assuming that manufacturing and non-manufacturing facilities each account for 50 percent of all facilities. Therefore, the average wage rate for managerial labor is calculated as $67.98, technical labor is calculated as $45.96 and clerical labor is calculated as $26.83. This is a change from the previous ICR renewal, which used only manufacturing wage rates and did not include nonmanufacturing industry wage rates, which are lower than manufacturing wage rates. EPA believes that an average of each labor category wage rate from the manufacturing and nonmanufacturing industries is a more accurate reflection of the wages earned by employees in the NAICS sectors potentially subject to the information collection requirements of this ICR than wage rates from manufacturing industries alone.

      These rates reflect employer cost for employee compensation include both employer costs for legally required benefits (e.g., social security, worker's compensation, and unemployment insurance), other important fringe benefit categories (e.g., insurance, paid leave, retirement and savings), overhead, and general and administrative costs.
      	(ii) Capital and O&M Costs
      
      EPA does not anticipate that respondents will incur either capital or O&M costs under this ICR. Costs associated with the burden hours presented in section 6(a) of this ICR (1049.14) are shown in Exhibit 2.
      
      
                                   Exhibit 2
             Unit Cost for Reporting a Typical Release to the NRC
                                       
                                       
  Capital/                 Start-up Costs
                                  O&M Cost
                                    Total 
                                   Unit Cost
                              Collection Activity
                                  Managerial
                                  Technical 
                                   Clerical 



Initial NRC Notification 
                                    $21.75
                                    $14.71
                                       0
                                    $0.00 
                                    $0.00 
                                                                         $36.46
Recordkeeping
                                     $1.36
                                     $8.27
                                     $4.83
                                    $0.00 
                                    $0.00 
                                                                         $14.46
                                     Total
                                    $23.11
                                    $22.98
                                     $4.83
                                    $0.00 
                                    $0.00 
                                                                         $50.92

EPA estimates that it costs the respondent $50.92 to report a typical release to the NRC and record the release data in the respondent's log.
      
      6(c)	Estimating Agency Burden and Cost 
      
      Federal government staff perform the following activities under the episodic release notification regulation: (1) process respondent telephone notifications of a release; (2) monitor cleanup activities; and (3) conduct field response actions. Only the first activity involves the processing of submitted paperwork and is covered by this ICR.
      
       Exhibit 3 shows the numbers of NRC telephone notifications received during 2018-2020 by type of release (hazardous substances and oil), and the total annual average. Exhibit 4 shows the estimated unit burden hours and costs and total annual burden hours and costs for the NRC's "process telephone notifications" activity. 
      
      Processing Telephone Notification
      The total burden of processing a telephone notification of a release consists of the time the NRC uses to (1) communicate with the respondent, (2) record and enter the information provided in the telephone call into the NRC data base, and (3) contact the predesignated EPA or Coast Guard OSC or other parties by telephone. After consulting with the NRC, EPA is updating the burden estimate to process a telephone notification. The NRC has informed EPA that it estimates that the three activities described above required an average of 17 minutes total per notification, so EPA is lowering the estimate used in previous ICR renewal from one hour to 17 minutes (.28 hour).
      For the period covered by this ICR renewal, EPA estimates that the average hourly labor cost for the NRC staff is $50.69. This is calculated as the average of the 2021, GS-9, step 1 hourly wage ($28.81) for civilian employees in the Washington DC area and the E-6 military hourly wage for over 6 years of service ($34.55), multiplied by 1.60 to account for fringe and overhead ($31.68 x 1.6 = $50.69). Therefore, the unit cost associated with processing an initial telephone call is $14.19 (.28 hour x $50.69 per hour). See Exhibits 3 and 4.
      
                                   Exhibit 3
                NRC Telephone Notifications Received 2018-2020
                             Collection Activity 
                                     Year
                                     Total
                                Annual Average
                                       
                     NRC Telephone Notifications Received
                                     2018
                                     2019
                                     2020
                                       
                                       
                                       
CERCLA HS 
                                     7,580
                                     7,818
                                     6,862
                                    22,260
                                     7,420
                                       
CWA oil discharges
                                    13,035
                                    12,404
                                    10,650
                                    36,089
                                    12,030
                                       
                                     Total
                                    20,615
                                    20,222
                                    17,512
                                    58,349
                                    19,450

	
                                   Exhibit 4
Burden Hours and Costs for Processing a Telephone Notification  -  Federal Government
                              Collection Activity
                  Average Number of Reportable Releases/Year
                               Unit Burden Hours
                          Unit Capital/Start Up Cost
                               Unit O&M Cost
                               Hourly Labor Cost
                           Total Annual Burden Hours
                               Total Annual Cost
                       Processing Telephone Notification
                                    19,450
                                      .28
                                    $0.00 
                                    $0.00 
                                    $50.69 
                                     5,446
                                   $276,058

                                       
                                       
                                       
                                       
                                       
                                       
                                       
      
      Response Activities
      Response actions resulting from release notifications made to the NRC under this ICR are not covered under this ICR.
	6(d)	Estimating the Respondent Universe and Total Annual Respondent Burden and Costs

      EPA obtained NRC data from 2018, 2019 and 2020 to estimate the number of releases that will be reported to the NRC during the ICR renewal period of 2022 through 2024. The exhibits in this section show projected annual release notifications, burden hours, and costs.
      The total cost and total burden estimates presented in this ICR are the aggregate annual costs and burden hours associated with reporting all hazardous substance releases and oil discharges pursuant to CERCLA section 103(a) and CWA section 311.
      Exhibit 5 presents the annual total annual burden hour and cost estimates for respondents.
                                       
                                   Exhibit 5
Estimated Annual Burden Hours and Costs Incurred by Industry (Respondents) 2022-2024
                              Collection Activity
                  Average Number of Reportable Releases/Year
                               Unit Burden Hours
                         Unit Cost/Reportable Release
                              Total Burden Hours
                               Total Annual Cost
                            Telephone Notification
                                    19,450
                                     0.64
                                    $36.46
                                    12,448
                                   $453,854
Recordkeeping
                                    19,450
                                     0.38
                                    $13.46
                                     7,391
                                   $99,483 
                                     Total
                                       
                                     1.02
                                    $56.72
                                    19,839
                                   $553,337

      6(e)	Bottom Line Burden Hours and Cost

      Exhibit 6 summarizes the bottom-line burdens and costs incurred by both respondents and government. The bottom-line burden to respondents is approximately 19,839 hours per year, at a cost of $553,337. The bottom line burden to the government is approximately 5,446 hours per year, at a cost of $276,058. 
      
      
                                   Exhibit 6
            Estimated Annual Burden Hours and Costs for Information
  Collection Under CERCLA Section 103(a) and CWA Section 311 for 2022 - 2024
                                    Sector
                                 Burden Hours
                                     Cost
Industry (Respondent)
                                    19,839
                                   $553,337 
Government
                                     5,446
                                   $276,058

      6(f)	Reasons for Change in Burden
      
      Compared to the previous ICR, the estimated respondent unit burden has remained the same and the estimated annual respondent burden has increased in this ICR renewal. Regarding annual burden, the projected number of annual release notifications in this renewal (19,450) is slightly higher than the projected number of release notifications in the previous ICR (18,447).  This increase in NRC notifications results in a higher total estimated respondent burden of 19,839 hours for this ICR renewal compared to 18,816 hours in the previous ICR.
      
      Despite a slight increase in the estimated number of NRC notifications for this ICR renewal period compared to the previous ICR (19,450 vs. 18,477), the government burden is expected to decrease substantially for this ICR renewal. This decrease is attributable to a reduced burden estimate for NRC staff to perform their activities under the ICR, from 1 hour to 17 minutes (.28 hour) per notification received, based on burden estimates provided by the NRC.
      
      6(g)	Burden Statement
      The annual public reporting and recordkeeping burden for this collection of information is estimated to average approximately 1.02 hours per response, which includes 0.64 hours associated with the initial notification and 0.38 hours record keeping per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.
      To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No. EPA-HQ-SFUND-2013-0549, which is available for online viewing at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select "search," then key in the Docket ID Number identified above. Out of an abundance of caution for members of the public and our staff, the EPA Docket Center and Reading Room is closed to the public, with limited exceptions, to reduce the risk of transmitting COVID-19. Our Docket Center staff will continue to provide remote customer service via email, phone, and webform. For further information about the EPA's public docket, Docket Center services and the current status, please visit us online at https://www.epa.gov/dockets. The telephone number for the Docket Center is (202) 566-1744.  
 	Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID No. EPA-HQ-SFUND-2013-0549
 in any correspondence.
                                  APPENDIX A
               Summary of Consultation Calls with NRC Reporters
      EPA made calls to six facilities in August 2021 reporting incidents to the National Response Center (NRC). The interviewees were selected randomly from incident reports retrieved from publicly released information (http://www.nrc.uscg.mil/) published by the NRC associated with material releases subject to required Comprehensive Environmental Response and Liability Act (CERCLA) reporting in 2020. Once a facility staff person familiar with incident reporting was identified, a short interview was conducted to estimate the time required for notification activities. Overall, the facility staff reported that they spent between 5 and 20 minutes notifying the NRC of the incident.
Call Summaries:

Incident #1  -  October 2020
CONSOLIDATED EDISON COMPANY OF NEW YORK      
3101 20th Avenue                             
ASTORIA, NY 11105
PRIMARY Phone: (212) 580-8383 
Type of Organization: PUBLIC UTILITY
Substance spilled:  Sulfuric Acid into storm drain

The respondent said that it took 5 minutes to contact the NRC.  

Incident # 2  -  October 2020
BASF CORP.                               
GEISMAR, LA
PRIMARY Phone: (225) 936-6874
Substance Spilled:  Chlorine  -  equipment failure; Medium  -  Air

The respondent said that it took less than 5 minutes to provide release information to the NRC. 

Incident #3  -  January 2020
Taft Manufacturing
Taft, CA
Phone: (661) 623-5801
Substance spilled:  Acrolein - equipment failure; medium -air

The respondent stated that it took less than 10 minutes to provide release information to the NRC.

Incident #4  -  January 2020
Modern Plating
Freeport, IL

Phone: (815) 235-1111
Substance spilled:  Hydrochloric acid

The respondent stated that it took 20 minutes to provide release information to the NRC.  

Incident #5  -  January 2020
Blythe Energy Inc.
Blythe, CA
Phone: (209) 924-1824
Substance spilled:  Anhydrous Ammonia

The respondent stated that it took 10 minutes to provide release information to the NRC.

Incident #6  -  October 2020
Dunn Company of Imperial Valley
Imperial, CA
Phone: (928) 446-9481
Substance spilled:  Sulfuric Acid

The respondent stated that it took 15 minutes to provide release information to the NRC. 


      
      
      
      
      
      
      












                                  APPENDIX B
                    Information Items Required in NRC Call
      The information provided in the telephone call to the NRC serves to notify government authorities of the release and provides them with a description of the circumstances surrounding the release. The following information is requested from all callers:
      ::	The name and location of the individual reporting the release, the name and type of organization (e.g., general public, industrial facility, or Federal, state, or local government) with which the individual reporting the release is affiliated, and the telephone number of the person reporting the release.
      ::	The name and location of the facility or vessel reporting the release, the type of organization, and the telephone number of the facility or vessel.
      ::	The location of the release.
      ::	The date and time of the release.
      ::	The name and type of material involved in the release, and the quantity of the substance released.
      ::	The source of the release, the vehicle identification or carrier number, if applicable, and a brief description of the source.
      ::	The environmental medium affected by the release (e.g., air, land, surface water, or ground water).
      ::	The cause of the incident (e.g., transportation accident, operational error, natural phenomenon), and a brief description of the release scenario denoting any unusual circumstances associated with the release.
      ::	Information on damages that occurred as a result of the release, including the number of injuries, number of deaths, and any property damage.
      ::	A description of the response actions taken at the release site, if any.
      ::	The name(s) and type of organization(s) that the caller has already notified; and
      ::	Any additional comments or information regarding the release.

