Extracting Useable Data from ERNS Incidents Applicable to HRM Facilities (December 2015)
The Emergency Response Notification System (ERNS) is used to store information on notifications of oil discharges and hazardous substances releases. The types of release reports that are available in ERNS fall into three major categories: substances designated as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended; oil and petroleum products, as defined by the Clean Water Act of 1972 (CWA), as amended by the Oil Pollution Act of 1990; and all other types of materials.  Because CERCLA defines hazardous substances to include CWA hazardous substances and toxic pollutants, the Clean Air Act hazardous air pollutants, the Resource Conservation and Recovery Act hazardous wastes, and the Toxic Substances Control Act imminently hazardous chemical substances, releases of these substances are also subject to CERCLA reporting requirements. ERNS contains, in addition to other data, information about the material and the quantity released, where the release occurred, when the release occurred, and information about property damage, injuries, and deaths occurring due to the release. ERNS primarily contains initial accounts of releases reported to the National Response Center (NRC), made during or immediately after a release occurs when exact details are often unknown.  It also should be noted that the National Response Center is strictly an initial report taking agency and does not participate in the investigation or incident response. The NRC is staffed by Coast Guard personnel.  The NRC receives initial reporting information only and notifies Federal and State On-Scene Coordinators for response. Verification of data and incident response are the sole responsibility of Federal/State On-Scene Coordinators. There may be multiple reports for a single incident, (this occurs when the caller makes a second report to update original data or a private observer reports a release that has already been reported by the facility). Because reports are taken over the phone, transcription errors (e.g., misspellings of discharger or location information), might limit the quality of some data.  

From the National Response Center (NRC) website (http://www.nrc.uscg.mil/Default.aspx), we downloaded, by year, the details for each call made reporting a release  -  from 1982 through 2014.  (Note: the recently updated NRC website now only shows releases reports beginning with 1990.)  Each annual Microsoft Excel data file has the following worksheets:
 Calls (used for this analysis)
 Incident Commons (used for this analysis)
 Incident Details (used for this analysis)
 Material Involved (used for this analysis)
 Material Involved CR (Continuous Release)
 Trains Detail
 Derailed Units
 Vessels Detail
 Mobile Details
However, the data for the calls made from 1982 through 1989 are difficult to use  -  with differing formats, missing and/or inconsistent data fields, etc.  In 1990 a more uniform and consistent format for documenting calls was put into place.   As such, we eliminated the pre-1990 reported releases from further consideration and used only the reported releases, from 1990-2014, as a starting point for subsequent analyses. (Note: For these reported releases, we only used releases for which a facility name was identified.)  Based on the Incident Description data, we also removed reported releases that were identified as drills, i.e., releases that didn't really occur, but served as practice for emergency responders.  Calls that were identified as being an update/correction to a previously reported release were not counted as a separate release; we incorporated any corrected data into the original reported release.
Approach Used to Extract Applicable ERNS Data
We created a Microsoft Access database and uploaded the following ERNS data for 1990 through 2014: 
 For the `Facility Info' table (derived from the Calls and Incident Commons data), we uploaded the records showing the name and address of the facility associated with the reported release. 
 For the `Material Released' table (derived from the Material Involved data), we uploaded records to provide the CHRIS code, material released, and amount released  -  including to water.  (Note: for numerous reported releases, more than one released substance was reported).  
 For each of the `Incident Description' (derived from the Incident Commons data) and Incident Details (derived from the Incident Details data) tables, we uploaded records that included a brief description of the reported release and the type and cause of the release.  The `Incident Details' table includes such information as fire involved, evacuations, fatalities, injuries, damages, road closures, description of remedial response, and federal/state agency notified.  
EPA next needed to determine which of these reported releases involved a CERCLA hazardous substance.  The NRC assigns a 3 letter code, termed a Chemical Hazard Response Information System (CHRIS) code to each reported release incident.  In November 2012, EPA obtained from the Coast Guard a comprehensive list of 2,643 CHRIS codes.  For more than 1,300 of these CHRIS codes, an almost 3,000 page manual developed by the U.S. Coast Guard includes a data sheet that addresses, among other topics, cautionary response information, fire hazards, chemical reactivity, health hazards, and a chemical designation section in which the associated Chemical Abstract Services (CAS) number(s) are indicated.  When made available in the Coast Guard Manual, we used the indicated CAS Number as a bridge to cross-check each of the CHRIS codes with the list of CERCLA Hazardous Substances.  In order to identify those incidents that involved CERCLA hazardous substances, we determined, using the Coast Guard Manual Chemical Hazard Response Information System (CHRIS), COMDTINST M16565.12C (available online at www.chrismanual.com) the Chemical Abstract System (CAS) Number for each of the listed CHRIS codes.  For codes not listed in this manual, EPA manually tried to determine if the released material was a CERCLA hazardous substance by comparing the description of the released material (from the incident report) with the list of CERCLA hazardous substances. Also, some CAS Numbers were not identified in the 1999 version of the Coast Guard Manual; for those CHRIS Codes, we used the CAMEO database to determine the associated CAS Number.  We cross-checked each CAS Number derived from the Coast Guard Manual/Cameo data with the CAS number shown in the List of CERCLA hazardous substances to determine if they matched. We developed an Excel table showing each CHRIS code that we identified as being associated with a CERCLA hazardous substance, the associated CAS No., and corresponding CERCLA hazardous substance name and uploaded these data into the Access database.  
However, EPA needed to use two pathways to evaluate which of the reported releases potentially involved a CERCLA hazardous substance. 
 EPA identified eleven (11) CHRIS codes that were non-specific or served as a "catch-all" code and thus not associated with a specific CAS Number that was needed to make the cross-check with the list of CERCLA hazardous substances (see table below).  However, only five of these codes (MUL, MWS, NCC, RAM, UNK) were used in the ERNS data for 1990-2014.
                  "Non-Specific" Three Letter CHRIS Code 
                         Name of Hazardous Substance 
                                      MUL
Multiple material releases
                                      MWS
Solvents, mixed/waste - possible contaminant
                                      NCC
No CHRIS Code
                                      NEC
Not elsewhere specified
                                      RAD
Radioactive materials
                                      RAM
Radioactive material
                                      RAN
Radionuclides (including radon)
                                      RAS
Radioactive material, surface contaminated objects
                                      RAL
Radioactive material, low specific activity
                                      EHL
Environmentally hazardous substances
                                      UNK
Unknown material
               
EPA extracted the reported releases assigned one of these codes (see table below) and then manually reviewed the description of the `Material Released' and/or the `Incident Details' of each reported release to determine if there was sufficient information to indicate the release potentially involved a CERCLA hazardous substance and thus retain it for further analysis to allow further evaluation and ascertain their applicability to the universe of facilities under consideration.  Because the incidents assigned a NCC code typically do not show a specific CAS No., we primarily used the material released info in each reported incident, to determine which of these incidents might have involved a CERCLA hazardous substance, and extracted incidents based on the following: 
 Cross-referencing with the List of CERCLA Hazardous Substances to identify those incidents for which there was a direct correlation, based on name of the CERCLA hazardous substance.  
 The name of the released material explicitly indicated it was a RCRA hazardous waste (by name, RCRA HW code, etc).
 The name of the released material indicated it likely was a RCRA hazardous waste.
         
 For the other reported releases, for which we had a specific CHRIS code and associated CAS Number, we determined the direct association between each CHRIS code and the list of CERCLA hazardous substances. (Note: For the CHRIS codes in the Coast Guard Manual where a CAS Number was not designated but simply indicated as `Not available' and those CHRIS Codes that are not included in the Coast Guard Manual, EPA used the CAMEO database to determine which, if any, CAS No. was available for making the cross reference with the list of CERCLA hazardous substances.)  Overall, we ultimately identified 753 CHRIS codes that are potentially associated with a CERCLA hazardous substance (based on CAS No.) and applied these codes to the remaining reported releases associated with a CERCLA hazardous substance.  The next step was to identify which of these reported releases might have occurred at a facility within the hardrock mining (HRM) universe.  We did not limit the selection to only facilities believed to be currently operating but also considered any that were operating in some capacity during the 1990-2014 timeframe.) Since the ERNS release incident reports do not include a SIC/NAICS code, we had to rely primarily on facility names to extract the potentially applicable and relevant incidents.  To do so, we applied multiple queries to the dataset release incidents to extract the incidents that might have occurred at HRM facilities.  These queries used terms (e.g., mine, smelter, gold, copper, phosphate) and names of specific facilities (e.g., alcoa, barrick, kennecott), applied to the Facility Name field, to extract an initial cut of reported releases potentially associated with hardrock mining and processing facilities.  Although numerous facilities might have the same name, we tried to determine the nature of the business conducted at each location  -  to identify only those that were of specific interest for the HRM universe.  
   
 Variations in the reported name of the facility, along with name changes due to mergers, company reorganizations, mis-spellings, etc. result in a given facility sometimes having multiple names over the 1990-2014 period.  As such, taking into account the facility name, facility address, and incident description, we assigned a facility name to provide consistency and thus facilitate and enhance our analyses of the reported release incidents.  We manually reviewed each of these release incidents to determine which of them likely were associated with potential HRM facilities. 

 Using the facility name, address, and incident description, we assigned one of the following commodity groups (Aluminum, Bulk Products, Ferrous Metals, Industrial rocks/Mineral feedstocks, Non-Ferrous Metals, Phosphates, Rare Earth Minerals, and Radioactive Metals) to each reported release, as shown in the following table.   However, 59 commodity classes of non-fuel hardrock mining sectors were identified by EPA (as noted in the Hoffman-Mahmud memo) to be excluded from among those "hardrock mining facilities" for which financial responsibility requirements under CERCLA 108(b) will be first developed.  
   
 Each release reported to the National Response Center is classified, using one of the Incident Types described in the table below.  For the purposes of the CERCLA 108(b) HRM rulemaking, we believe the release incidents classified as fixed and storage tank are the most applicable.  
         Types of Incidents for Classifying Reports of Released Hazardous Substances
                                   AIRCRAFT 
                                   PLATFORM 
An AIRCRAFT Incident includes all aircraft, commercial and private, whether flying or grounded. For example, a hydraulic leak from an aircraft that occurs while undergoing repairs would require a report.
A PLATFORM Incident is specifically for offshore or near shore oil and natural gas extracting facilities. The area and block number are important fields that need to be entered in this report, unless the platform is in state waters. Please enter the OCSG, OCSP, or state lease numbers in the report.
                              CONTINUOUS RELEASE 
                                   RAILROAD 
A CONTINUOUS RELEASE is a release above the Federal limits, also called reportable quantity (RQ), due to normal operations of a facility. This incident type has five categories: Initial, Baseline, Change in Source and/or Composition, Annual, and Statistically Significant Increase (SSI).  For detailed info on the EPA's Continuous Release Program check out their web site.
A RAILROAD Incident includes all transportation modes used on rail. The NRC takes reports on all Railroad Incidents including derailments of freight and commercial trains, HAZMAT and non-hazmat rail incidents, light rail, subway, metro rail, and grade crossing accidents.
                                    FIXED 
                                    MOBILE 
A FIXED Incident is the widest ranging incident type and includes the release of material from non-mobile machinery, refineries, manufacturing plants, and numerous other fixed facilities. 
A MOBILE Incident refers to all transportation modes used on land. It includes commercial and private vehicles, motorcycles etc. Some of the most common incidents associated with this category are tractor-trailer accidents. 
                                 STORAGE TANK 
                                UNKNOWN SHEEN 
A STORAGE TANK Incident pertains to containers that store hazardous materials located virtually anywhere including facilities, private property, and various transportation modes. Common storage tank incidents include leaking or overfilled home heating oil tanks, ruptured underground storage tanks from construction activity and petroleum storage facilities. 
An UNKNOWN SHEEN Incident type pertains to any material on the water that has been discovered and whose source is unknown. Please describe the size and color of the material and an estimate of the amount released. (I.E. less than a gallon, less than 100 gallons, over 3000 gallons, etc.). Information on weather and direction of movement are also important.
                                   PIPELINE 
                                    VESSEL 
A PIPELINE Incident refers to pipelines that transport materials off site. This does not include pipelines within a facility. Such pipelines are often regulated by the Department of Transportation. Common pipeline types include flow, distribution and gathering lines transporting crude oil or natural gas from one facility to another.
A VESSEL Report includes all transportation modes used on the water.   Common reports include private vessels that accidentally release bilge water, oil barges with leaks, cranes that are on barges, etc.
Source: http://www.nrc.uscg.mil/htmlreport.html
However, based on the incident description, we believe some release incidents may have been incorrectly classified.  For example, a Pipeline Incident is intended to refer to pipelines that transport materials off site and does not include pipelines within a facility.  For releases that were originally classified as `Pipeline' but that did not seemingly involve actual transport of the hazardous substance offsite, we assigned a substitute classification, usually `Process or Transfer Piping/Pump/Valve', based on the information provided in the incident description.  To facilitate and enhance our analyses of the reported release incidents, we assigned a more detailed Incident Type, as a substitute for each of the originally reported Incident Types, using one of the following:  
Blasting/Drilling Operation
Canal/Ditch/Channel
Capacitor/Transformer
Coke Oven/Battery and Associated Equipment
Continuous/Planned Release
Dumping
Facility Building
Loading/Unloading: Barge/Vessel
Loading/Unloading: Tanker/Trailer Truck
Mine
Motor Vehicle: Car/Truck
Non-Transport: Drum/Container/Cylinder/Tote/Portable Tank
Onsite Excavating/Hauling/Loading Machine
Other Miscellaneous Equipment
Other Miscellaneous Release/Discharge
Pond/Impoundment/Pile/Landfill
Process or Transfer Piping/Pump/Valve
Process Unit, Storage/Treatment Tank-Sump
Residential Impact
Secondary Containment Area/Leachate Collection
Stack/Vent/Flare/Air Pollution Control
Train/Railcar
Transport: Drum/Container/Cylinder/Tote/Portable Tank
Transport: Tanker/Trailer Truck

In addition to each reported release incident being designated with an Incident Type, an Incident Cause also is provided in the ERNS data.  Again, as with the Incident Type, we assigned our own Incident Cause, based on the information provided in the incident description, to facilitate and enhance our analyses of these data.  As such, we assigned one of the following Incident Causes to each release incident, as a substitute for each of the originally reported Incident Causes:  
Accident/Operator Error
Damage Due to Storm/Weather (Wind/Rain/Ice)
Demolition Activity
Equipment Failure: Flange/Gasket
Equipment Failure: Misc/Unspecified
Equipment Failure: Miscellaneous/Unspecified
Equipment Failure: Piping/Hose Break or Leak
Equipment Failure: Pressure Relief Valve
Equipment Failure: Process/Storage/Treatment Unit Structural Integrity
Equipment Failure: Pump
Equipment Failure: Radiator/Cooling Line
Equipment Failure: Secondary Containment
Equipment Failure: Valve
Excess Pressure/Temperature
Fire/Explosion
Illegal Dumping
Maintenance/Repair/Sampling/Testing
Normal Operating and Material Handling
Operator Error
Overfill
Plant/Process Upset
Power Outage/Electrical Malfunction
Startup/Shutdown Issue
Unknown
   
