Pursuant to CERCLA regulations, facilities must submit a continuous release report when they release a CERCLA hazardous substance that equals or exceeds a reportable quantity (RQ) on a continuous basis. Once a continuous release report has been sent to EPA, how does the facility report changes in information other than source or composition?
If a facility determines that the information previously submitted in any initial written or follow-up report for continuous releases of CERCLA hazardous substances is no longer accurate, the facility must notify the EPA regional office by letter within 30 days. All notifications of changes must include the original Continuous Release – Emergency Response Notification System (CR-ERNS) number assigned to the facility by the National Response Center (NRC) in the initial telephone notification, as well as a signed statement with the notification verifying that all reported information on the release submitted to date is accurate and current. Examples of changes in other information include changes in the facility ownership, changes in the identity of the person in charge of the facility, or changes in the sensitive populations and ecosystems.
Although not required, it is advised that the appropriate SERC and LEPC be notified of any changes in other information regarding release of either CERCLA hazardous substances or non-CERCLA EHSs (i.e. EPCRA EHSs listed in 40 CFR part 355, Appendix A and B).
Additional information about continuous release reporting can be found in the Reporting Requirements for Continuous Releases of Hazardous Substances: A Guide for Facilities on Compliance (EPA540-R-97-047), available at the following URL:
EPA regional contact information for continuous release reporting is available at the following URL:
https://19january2021snapshot.epa.gov/epcra/cr-erns-regional-contacts