SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

A.	JUSTIFICATION

1.	IDENTIFICATION OF INFORMATION COLLECTION

a)	Title: NESHAP for Radionuclides (40 CFR part 61, subparts B, K, R and
W) (Renewal)

EPA Number  1100.13, OMB Number  2060-0191

b)	Short Characterization

On January 31, 2009, OMB approval to collect information associated with
National Emission Standards for Hazardous Air Pollutants (NESHAPs)
relative to radionuclides will expire.  This renewal request is for
continued collection of information from various source categories.  The
information to be collected is non-statistical in nature and, therefore,
only Part A of the supporting statement requesting OMB approval under
the Paperwork Reduction Act and 5 CFR 1320 is addressed below.

On September 18, 2008 (73 FR 54156), EPA requested comments on specific
aspects of this ICR, with the comment period closing on November 17,
2008.  By this deadline, there were no comments.

On December 15, 1989, pursuant to Section 112 of the Clean Air Act as
amended in 1977 (42 USC 1857), the Environmental Protection Agency (EPA)
promulgated NESHAPs to control radionuclide emissions from several
source categories.  The regulations were published in 54 FR 51653, and
are codified at 40 CFR Part 61 subparts B, K, R, and W, and impose the
following radionuclide dose and emission standards:

Subpart B--Underground Uranium Mines		- 10 mrem/yr

Subpart K--Elemental Phosphorous Plants 		- 2 curies/yr

Subpart R--Phosphogypsum Stacks			- 20 pCi/m2-s

Subpart W--Uranium Mill Tailings			- 20 pCi/m2-s

Originally there were seven subparts - B, H, I, K, R, T and W--that were
published in the December 15, 1989 Federal Register (54 FR 51653). 
Since the 1989 notice, subparts I and T are no longer regulated by EPA. 
Due to petitions for reconsideration, EPA rescinded subpart T as it
applies to owners and operators or uranium mill tailings disposal sites
licensed by NRC or an affected Agreement State on July 15, 1994, 59 FR
36280.  Subpart I as it applies to NRC-licensed facilities was rescinded
on December 30, 1996 (61 FR 68971) because, in the 1990 Clean Air Act
amendments, Congress directed EPA to stop regulating radionuclide
emissions from NRC licensed facilities if EPA determines that the NRC
regulatory program protects the public health with an ample margin of
safety.  After careful review, EPA determined that public health would
be protected with an ample margin of safety by NRC’s program.  Subpart
H does not require an ICR because it covers Federal facilities, which
are not subject to the Paperwork Reduction Act.  The existing subpart I
of the radionuclide NESHAP now only applies to non-DOE federal
facilities not licensed by NRC.   The non-DOE federal facilities not
licensed by NRC, namely DoD facilities, are expected to have emissions
below 1% of the standards and are therefore not subject to the reporting
requirements.

Information collected is used by EPA to ensure that public health
continues to be protected from the hazards of airborne radionuclides by
compliance with these standards.  If the information were not collected,
it is unlikely that a violation of these standards would be identified
and, thus, there would be no corrective action initiated to bring the
facilities back into compliance.  Compliance is demonstrated through
emission testing and/or dose calculation.  All facilities are required
to calculate, monitor, and maintain their records for 5 years.  The
rationale for the 5 year record keeping requirement is from the Code of
Federal Regulations (CFR), 40 CFR 61.95.  In some cases, they also
report their results to EPA.

2. NEED FOR AND USE OF THE COLLECTION

(a) Need/Authority for the Collection

In the context of the Clean Air Act (42 USC 1857), Section 114
authorizes the Administrator of EPA to require any person who owns or
operates any emission source or who is subject to any requirements of
the Act to:

- Establish and maintain records;

- Make reports, install, use, and maintain monitoring equipment or
method;

- Sample emissions in accordance with EPA-prescribed locations,
intervals and methods; and

- Provide information as may be requested.

(b) Practical Utility/Users

EPA’s regional offices use the information collected to ensure that
public health continues to be protected from the hazards of
radionuclides by compliance with health based standards.

EPA's compliance monitoring activities vary widely.  EPA could issue a
letter requesting information about compliance or could conduct a full
scale investigation, including on-site inspections.											

When EPA first learns of a compliance problem, EPA attempts to remedy
the problem by holding informal discussions with the owner/operator of
the source.  If it is not possible to remedy the problem informally,
formal action is taken.  EPA's Clean Air Act Compliance Enforcement
Guidance Manual identifies the Agency's informal and formal enforcement
operating procedures.

3.  NON DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA

(a)  Non duplication

In accordance with 40 CFR Part 61, the specific information requested by
this notice is not currently collected by any other office within EPA or
any other governmental agency. 

(b) Public Notice Required Prior to ICR Submission to OMB

On September 18, 2008 (73 FR 54156), EPA requested comments on specific
aspects of this ICR, with a 60 day comment period which closed on
November 17, 2008.  Specifically, there were no comments received from
affected entities or the general public by this deadline.  

(c) Consultations

In developing the regulations, EPA gathered extensive background
information on the affected facilities.  In addition to background
information collected from the regulated sources, public comments were
received during the rulemaking process and they are contained in the
public docket.  Since the rules were promulgated, there have been
opportunities for dialogue between EPA and affected facilities which
have resulted in changes to the rules, memorandums of understanding, and
rescissions.  In preparing this request, EPA also contacted contractors,
EPA staff, and facility emission monitoring and compliance
professionals.  As a result of these consultations and the provision in
the Clean Air Act Amendments, EPA was able to eliminate duplication of
effort between EPA and NRC in instances where EPA determined that the
NRC program could provide protection of the public health with an ample
margin of safety.

(d)  Effects of Less Frequent Collection

All reporting is annually or less frequent than annually.

(e)  General Guidelines

      This ICR meets OMB’s collection guidelines, had no public
comments during the comment period which ended November 17, 2008, and
does not duplicate another collection.

(f)	Confidentiality							

This section does not apply because this ICR does not request
information of confidential nature. 

	(g) Sensitive Questions

This section is not applicable because this ICR does not request
sensitive information.

4.  THE RESPONDENTS AND THE INFORMATION REQUESTED

(a) Respondents NAICS Codes

The NAICS Codes associated with the activity of the respondents are:

Elemental Phosphorous		-   325188

Phosphogypsum Stacks		-   212392

Underground Uranium Mines		-   212291

Uranium Mill Tailings		-   212291

(b) Information Requested

Descriptions of the reporting requirements are listed separately for
each subpart.

Reporting

Subpart B - Underground Uranium Mines

The mine owner or operator shall annually calculate and report the
results of the compliance calculations and the input parameters used in
making the calculation.  The compliance calculations include using 40
CFR part 61, Appendix B, Method 115 to calculate the source terms used
in the program COMPLY-R which calculates the dose.  The report shall
cover the emissions of a calendar year and shall be sent to EPA by March
31 of the following year.  Each report shall also include the following
information:

(1) The name and location of the mine (including latitude and
longitude),  

(2) The name of the person responsible for the operation of the facility
and the name of the person preparing the report (if different), 

(3) The results of the emissions testing conducted and the dose
calculated using the procedures in Section 61.23,

(4) A list of the stacks or vents or other points where radioactive
materials are released to the atmosphere, including their location,
diameter, flow rate, effluent temperature and release height,

(5) A description of the effluent controls that are used on each stack,
vent, or other release point and the effluent controls used inside the
mine, and an estimate of the efficiency of each control method or
device,

(6) Distances from the points of release to the nearest residence,
school, business or office and the nearest farms producing vegetables,
milk and meat,  

(7) The values used for all other user-supplied input parameters for the
computer model and the source of these data,

(8) Each report shall be signed and dated by a corporate officer in
charge of the facility and contain the following declaration immediately
above the signature line:  "I certify under penalty of law that I have
personally examined and am familiar with the information submitted
herein and based on my inquiry of those individuals immediately
responsible for obtaining the information, I believe that the submitted
information is true, accurate and complete.  I am aware that there are
significant penalties for submitting false information including the
possibility of fine and imprisonment.  See 18 U.S.C. 1001."

 In order to complete the Subpart B reporting requirements respondents
will:

a.  read and understand the regulatory provision,

b.  perform radon-222 emission measurements as required in Appendix B,
Method 115,

c.  perform data analysis including Method 115 source term calculations
and COMPLY-R dose calculation,

d.  prepare and submit report.

For recordkeeping requirements, all facilities are required to
calculate, monitor, and maintain their records for five years and upon
request be made available for inspection by the Administrator, or
his/her authorized representative.  (See Table B)

Subpart K - Elemental Phosphorus Plants

Each owner or operator of an elemental phosphorus plant shall test
emissions from the plant annually according to the procedures in Section
61.123 and using the test methods in Section 61.125.

Each owner or operator of an elemental phosphorus plant shall furnish
the Administrator with a written report on the results of the emission
test within 60 days of conducting the test.  The report must provide the
following information:  

(1) The name and location of the facility (including latitude and
longitude), 

(2) The name of the person responsible for the operation of the facility
and the name of the person preparing the report (if different),

(3) A description of the effluent controls that are used on each stack,
vent or other release point and an estimate of the efficiency of each
device,

(4) The results of the testing, including the results of each sampling
run completed,

(5) The values used in calculating the emissions and the source of
these data,

(6)  Each report shall be signed and dated by a corporate officer in
charge of the facility and contain the following declaration immediately
above the signature line:  "I certify under penalty of law that I have
personally examined and am familiar with the information submitted
herein and based on my inquiry of those individuals immediately
responsible for obtaining the information, I believe that the submitted
information is true, accurate and complete.  I am aware that there are
significant penalties for submitting false information including the
possibility of fine and imprisonment.  See, 18 U.S.C. 1001."

In order to complete these reporting requirements respondents will:

a.  read and understand the regulatory provision,

b.  perform the emission monitoring and test procedures in Section
61.125,

c.  perform data analysis including calculation of annual emission rate,

d.  prepare and submit the report to EPA. 

For recordkeeping requirements, all facilities are required to
calculate, monitor, and maintain their records for five years and upon
request be made available for inspection by the Administrator, or
his/her authorized representative.  (See Table K)

Subpart R -Phosphogypsum Stacks

Sixty days following the date at which a stack becomes an inactive
stack the owners or operators of the inactive phosphogypsum stack shall
test the stack in accordance with the procedures described in 40 CFR
part 61, Appendix B, Method 115.  This is a one-time report.  However,
if an owner or operator removes phosphogypsum from an inactive stack,
the owner shall test the stack once a year for every year in which
phosphogypsum is removed from the stack.

EPA shall be notified at least 30 days prior to an emission test so that
EPA may, at its option, observe the test.  Ninety days after the testing
is required, the owner or operator shall provide EPA with a report
detailing the actions taken and the results of the radon-222 flux
testing.  Each report shall also include the following information:

(1) The name and location of the facility, 

(2) A list of the stacks at the facility including the size and
dimensions of the stack, 

(3) The name of the person responsible for the operation of the facility
and the name of the person preparing the report (if different), 

(4) A description of the control measures taken to decrease the radon
flux from the source and any actions taken to ensure the long term
effectiveness of the control measures, and 

(5) The results of the testing conducted, including the results of each
measurement,

(6) Each report shall be signed and dated by a corporate officer in
charge of the facility and contain the following declaration immediately
above the signature line:  "I certify under penalty of law that I have
personally examined and am familiar with the information submitted
herein and based on my inquiry of those individuals immediately
responsible for obtaining the information, I believe that the submitted
information is true, accurate and complete. I am aware that there are
significant penalties for submitting false information including the
possibility of fine and imprisonment. See 18 U.S.C. 1001."

Also, the owner or operator of the stack from which the phosphogypsum
is removed shall determine annually the average radium-226 concentration
at the location in the stack from which the phosphogypsum will be
removed as provided by Section 61.207.  Each distributor, retailer, or
reseller who distributes phosphogypsum for use in agriculture shall
prepare certification documents which conform to the requirements of
Section 61.208.

The owner or operator of a stack from which phosphogypsum will be
removed and distributed in commerce pursuant to Section 61.204, Section
61.205, or Section 61.206 shall prepare a certification document for
each quantity of phosphogypsum which is distributed in commerce which
includes:

(1) The name an address of the owner or operator,

(2) The name and address of the purchaser or recipient of the
phosphogypsum,

(3) The quantity (in pounds) of phosphogypsum sold or transferred,

(4) The date of sale or transfer,

(5) The average radium-226 concentration, in pCi/g, of the phosphogypsum
to Section 61.207, and 

(6) The signature of the person who prepared the certification.

Each distributor, retailer, or reseller who purchases or receives
phosphogypsum for subsequent resale or transfer shall prepare a
certification document for each quantity of phosphogypsum which is
resold or transferred which includes:

(1) The name and address of the owner or operator,

(2) The name and address of the purchaser or recipient of the
phosphogypsum,

(3) The quantity (in pounds) of phosphogypsum sold or transferred,

(4) The date of resale or transfer,

(5) A description of the intended end use for the phosphogypsum,

(6) A copy of each certification document which accompanied the
phosphogypsum at the time it was purchased or received by the
distributor, retailer, or reseller, and

(7) The signature of the person who prepared the certification. 
Submission of certification documents to EPA is not a requirement.

In order to complete these reporting requirements respondents will:

a.  read and understand the regulatory provision,

b.  perform the radon flux testing in Section 61.203,

c.  perform radium-226 sampling and measurement procedures in Section
61.207 (if required),

d.  perform data analysis including Method 115 radon flux or radium-226
concentration calculations,

e.  prepare and submit the report and prepare a certification document
if required.

For record keeping requirements, all facilities are required to
calculate, monitor, and maintain their records for five years and upon
request be made available for inspection by the Administrator, or
his/her authorized representative.  (See Table R)

Subpart W - Uranium Mill Tailings

The owners or operators of operating existing mill impoundments shall
report the results of the compliance calculations required in Section
61.253 and the input parameters used in making the calculation for each
calendar year shall be sent to EPA by March 31 of the following year. 
Each report shall also include the following information: 

(1) The name and location of the mill, 

(2) The name of the person responsible for the operation of the
facility and the name of the person preparing the report (if different),

(3) The results of the testing conducted, including the results of each
measurement,  

(4) Each report shall be signed and dated by a corporate officer in
charge of the facility and contain the following declaration immediately
above the signature line:  "I certify under penalty of law that I have
personally examined and am familiar with the information submitted
herein and based on my inquiry of those individuals immediately
responsible for obtaining the information, I believe that the submitted
information is true, accurate and complete. I am aware that there are
significant penalties for submitting false information including the
possibility of fine and imprisonment. See 18 U.S.C. 1001."

In order to complete these reporting requirements respondents will:

a.  read and understand the regulatory provision,

b.  perform testing required in 40 CFR part 61, Appendix B, Method 115,

c.  perform data analysis including Method 115 radon flux calculations,

d.  prepare and submit the report to EPA. 

For record keeping requirements, all facilities are required to
calculate, monitor, and maintain their records for five years and upon
request be made available for inspection by the Administrator, or
his/her authorized representative.  (See Table W)

Record Keeping

The record keeping requirements of each subpart are similar and have
been summarized in the paragraph below.

The owner or operator of the facility must maintain records documenting
the source of input parameters including the results of all measurements
upon which they are based, the calculations and/or analytical methods
used to derive values for input parameters, and the procedure used to
determine compliance.  This documentation should be sufficient to allow
an independent auditor to verify the accuracy of the determination made
concerning the facility's compliance with the standard.  These records
must be kept at the mill or facility for at least five years and, upon
request, be made available for inspection by the Administrator, or
his/her authorized representative.

5.	THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT

(a) Agency Activities

Information being collected is pursuant to Federal regulation. Agency
activities consist of reviewing owner or operator test reports and
maintaining files.

(b) Collection Methodology and Management

The Office of Radiation and Indoor Air and the EPA regional offices have
planned and allocated resources for the efficient and effective
management and use of this information. 

Records must be maintained documenting the source of input parameters
including the results of all measurements upon which they are based, the
calculations and/or analytical methods used to derive values for input
parameters, and the procedure used to determine effective dose
equivalent.  This documentation should be sufficient to allow an
independent auditor to verify the accuracy of the determination made
concerning the facility's compliance with the standard.  These records
must be kept at the site of the facility for at least five years and,
upon request, be made available for inspection by the Administrator, or
the Administrator’s authorized representative.

The Agency has determined that the annual report review and periodic on
site inspection is the most effective method to insure compliance.  EPA
regional office staff review facility annual reports to determine if
compliance with the regulatory standards are being maintained. 
Verification of data is accomplished by recalculation of dose using
computer models and conducting site inspections or witnessing an
emission test. 

(c) Small Entity Flexibility

None of the regulations covered by this ICR are applicable to small
entities. 

(d) Collection Schedule

For some subparts, annual reports are required to provide yearly
certification of compliance with a health based standard; therefore,
less frequent reporting was not considered an option to reduce burden
because of the yearly stipulation in the rule.  However, for other
subparts (such as subpart R), it was determined during rulemaking that
less frequent reports were adequate to protect public health.

	

6.  ESTIMATING THE BURDEN AND COST OF THE COLLECTION

Burden and costs estimates have been calculated separately for each
subpart.  Respondent 

labor rates are based on ‘mean’ values from the 2007 data of the US
Department of Labor, Bureau of Labor Statistics (BLS) for the mining
industrial sector.  These national industry-specific occupational
employment and wage estimates are calculated with data collected from
employers of all sizes, in metropolitan and non-metropolitan areas in
every State and the District of Columbia, in NAICS 212000 - Mining
(except Oil and Gas).  These rates are increased by 120% in the cost
estimate to include inflation and overhead.  The labor key is as
follows: Management (Mgmt) ($102/hr) was based on the Total Compensation
for the (Management( Occupational Group in the mining sector in the BLS
data.  Technical (Tech) was based on the mean salary for “all
production operations” ($41/hr) in the mining sector which includes
mining machine operators, water and liquid waste treatment plant and
system operators, and chemical plant and system operators.  Clerical
(Cler) ($34/hr) was based on the Total Compensation for the (Office and
Administrative Support Occupations( in the mining sector in the BLS
data.

  The tables representing each subpart are listed below with their
reporting requirement information.  (Note: Subpart R has 2 tables; Table
1 represents the 20 stacks required to complete a one-time report and
Table 2 represents the 12 stacks that have to conduct radon flux testing
every year when phosphogypsum is removed from the stacks.)

Information Collection                              Hours and Costs for
Underground Uranium Mines                                            
Total Hours and Costs    

Activity		

Table B

Subpart B-- Underground Uranium Mines	

	

Manager

$102/hour

	

Technical

$41/hour	

Clerical

$34/hour	

Respond.

hours/

year	

Labor cost/year/Respond.	

Capital/

startup cost	

O & M

Cost	

Number of Respon.	

Total hours/

year	

Tot Labor cost/

year



Reporting	

	

	

	

	

	

	

	

	

	

	





Read and understand the regulatory provision (Mgmt)	

	

    10	

	

	

    10    	

$1,020	

	

	

        15	

150	

$15,300



Perform emission monitoring (Tech.)	

	

       	

   160    	

	

   160 	

$6,560	

$0   	

$75,000 	15	

2400	

$173,400





Perform data analysis (Technical)	

	

	

      40   	

	

     40   	

$1,640	

	

	15	

600	

 $24,600



Prepare report (Mgmt)	

	

    10	

	

	

     10     	

$1,020	

	

	15	

150	

$15,300



Record Keeping	

	

	

	

	

	

	

	





	





File and maintain data (Clerical)	

	

	

	

     10	

     10     	

$   340	

	

	15	

150	

 

$5,100



TOTAL	

	

     20	

    200	

     10	

    230	

$10,580	

$0	

$75,000	15	

3450	

$233,700

Assumptions:

1.  Capital/start up cost: = $0

2.  Annual cost (O & M): 15 facilities x $5,000 = $75,000

B -- Underground Uranium Mines

In order to complete Subpart B reporting requirements respondents will:

read and understand the regulatory provision,

perform radon-222 emission measurements as required in 40 CFR part 61,
Appendix B, Method 115,

perform data analysis including Method 115 source term calculations and
dose calculation using an approved model

prepare and submit report.

-  The estimated capital/start-up cost includes the monitoring equipment
needed to perform Method 115 testing for one mine.  

-  Capital/start-up burden includes understanding regulatory provisions
and installation of equipment (there was no capital cost in this cycle).


-  Estimated annual costs related to testing include calibration, and
repairs costs.

-  Estimated annual burden hours collecting emission data from
monitoring equipment and performing data analysis and calculations,
report preparation and data management.

-  Based on reports received during the previous reporting period,
fifteen mines are capable of operating.  

Information Collection                                 Hours and Costs
for Elemental Phosphorus                                                
Total Hours and Costs        

Activity

Table  K

Subpart K-- Elemental Phosphorus Plants	

	

Manager

$102/hour

	

Technical

$41/hour	

Clerical

$34/hour	

Respon.

hours/

year	

Labor cost/year	

Capital/

startup cost	

O & M

Cost	

Number of Respon.	

Total hours/

year	

Tot Labor cost/

year



Reporting	

	

	

	

	

	

	

	

	

	

	





Read and understand the regulatory provision (Mgmt)	

	

   10

   	

	

       	

10

         	

$1,020

       	

     	

      	

1

	

10	

$1,020



Perform emission monitoring (Tech.)	

	

       	

   240   	

	

  240  	

$9,840	

   $0	

$5,100	

1	

240	

$14,940



Perform data analysis (Technical)	

	

	

       8    	

	

      8   	

$     328	

	

	

1	

8	

$328



Prepare report (Mgmt)	

	

    10	

	

	

      10	

$     1,020	

	

	

1	

10	

$1,020



Record Keeping	

	

	

	

	

	

	

	

	

	

	





File and maintain data (Clerical)	

	

	

	

    10	

     10    	

$     340	

	

	

1	

10	

$340



TOTAL	

	

    20	

   248	

    10	

   278	

$12,548	

   $0	

$5,100	

1	

278	

$17,648

Assumptions:

1. Capital/start up cost: 0 facilities x $0 = $0

2. Annual cost (O & M): 0 facilities x $5,100 = $0

 

K--Elemental Phosphorus Plants

In order to complete these reporting requirements respondents will:

a.	read and understand the regulatory provision,

b.	perform the emission monitoring and test procedures in Section
61.125,

c.	perform data analysis including calculation of annual emission rate,

d.	prepare and submit the report to EPA.

- It is estimated that 1 facility will complete these reporting
requirements. 

- The estimated cost for a contractor to complete testing is $5,100.

	Information Collection Activity	   Hours and Costs for Phosphogypsum
Stack    				Total Hours and Costs       

Table R1

Subpart R-- Phosphogypsum Stacks     	

	

Manager

$102/hour

	

Technical

$41/hour	

Clerical

$34/hour	

Respond.

Hours/

year	

Labor cost/year/Respond.	

Capital/

startup cost	

O & M

Cost	

Number of Respon.	

Total hours/

year	

Tot Labor cost/

year



Reporting	

	

	

	

	

	

	

	

	

	

	





Read and understand the regulatory provision (Mgmt)	

	

 10 	

	

	

10	

$1,020	

	

	

      39	

 390	

$39,780



Perform emission monitoring (Tech.)	

	

        	

  64   	

	

64 	

$2,624	

$0	

$702,000	

      39	

2496	

 $804,336



Perform data analysis (Technical)	

	

	

    8   	

	

  8   	

$   328	

	

	

      39	

 312	

 $12,792



Prepare report (Mgmt)	

	

  10	

	

	

  10  	

$   1,020	

	

	

      39	

 390	

 $39,780



Record Keeping	

	

	

	

	

	

	

	

	

	

	





File and maintain data (Clerical)	

	

	

	

  10	

10    	

$   340	

	

	

      39	

 390	

 $13,260



TOTAL	

	

  20	

 72	

   10 	

102	

$5,332	

$0	

$702,000	

      39	

3978	

$909,948

Assumptions: Tables R1 & R2

1. Capital/start up cost: 39 facilities x $0 = $0; (Table 2) 39
facilities x $0 = $0

2. Annual cost (O & M): 39 facilities x $18,600 = $702,000   (Table 2) 
10 facilities x $835 = $8,350

Total O & M for Tables R1 & R2 = $710,350

Information Collection Activity        Hours and Costs Per Respondent  
                              	 		Total Hours and Costs  

Table R2

Subpart R--  Phosphogypsum Stacks	

	

Manager

$102/hour

	

Technical

$41/hour	

Clerical

$34/hour	

Respond.

Hours/

year	

Labor cost/year/Respond.	

Capital/

startup cost	

O & M

Cost	

Number of Respond.	

Total hours/

year	

Tot Labor cost/

year



Reporting	

	

	

	

	

	

	

	

	

	

	





Read and understand the regulatory provision (Mgmt)	

	

   N/A	

	

	

	

	

	

	

	

	





Perform radon flux testing (Tech.)	

	

       	

  64	

	

64    	

$2,624	

$0	

$8,350	

10	

 640	

$34,590



Perform radium-226 sampling and measurement proce-    dures (Tech.)	

	

       	

    8   	

	

  8 	

$ 328	

	

	10	

80	

$3,280



Prepare data analysis (Tech.)	

	

	

    8   	

	

  8 	

$ 328	

	

	10	

   80	

   $3,280



Prepare report and certification papers (Mgmt)	

	

  10	

	

	

10	

$1,020	

	

	10	

 100 	

   $10,200



Record Keeping	

	

	

	

	

	

	

	





	





File and maintain data (Clerical)	

	

  10	

  	

10	

10   	

$ 340	

	

	10	

 100	

   $3,400



TOTAL	

	

 10	

80	

10	

100	

$4,640	

$0	

$8,350	10	

 1,000	

$54,750

R - Phosphogypsum 

In order to complete these reporting requirements respondents will:

a.	read and understand the regulatory provision,

b.	perform the radon flux testing in Section 61.203,

c.	perform radium-226 sampling and measurement procedures in Section
61.207 (if required),

d.	perform data analysis including Method 115 radon flux or radium-226
concentration calculations,

e.	prepare and submit the report and certification document if required.

- It is estimated that the testing materials for 300 measurements and
the analysis is obtained from a contract source at a cost of
$60/measurement.  

- It is estimated that it will take four days for two people to place,
collect and ship 300 samples to a testing lab.  

- It is estimated that 39 stacks (all) will be required to complete this
one-time report. 

- It is estimated that 10 phosphogypsum stacks will have to conduct
radon flux testing every year because phosphogypsum is removed from the
stack.  For these stacks, the radium-226 concentration must also be
determined and included in certification papers. 

Information Collection                                 Hours and Costs
Per Respondent                                               Total Hours
and Costs                 

Activity

Table W

Subpart W-- Uranium Mill Tailings Piles	

	

Manager

$102/hour

	

Technical

$41/hour	

Clerical

$34/hour	

Respond.

Hours/

year	

Labor cost/year/Respond.	

Capital/

startup cost	

O & M

Cost	

Number of Respond.	

Total hours/

year	

Tot Labor cost/

year



Reporting	

	

	

	

	

	

	

	

	

	

	





Read and understand the regulatory provision (Mgmt)	

	

   10	

	

	

    10	

$1,020	

	

	

7	

70	

$7,140



Perform radon flux testing (Tech.)	

	

     	

   32   	

	

   32 	

$1,312	

$0	

$18,200	

     7	

224	

  $27,384



Perform data analysis (Technical)	

	

	

    8   	

	

    8   	

$ 328	

	

	

     7	

56	

    $2,296



Prepare report (Mgmt)	

	

   10	

	

	

  10    	

$1,020	

	

	

     7	

70	

    $7,140



Record Keeping	

	

	

	

	

	

	

	

	

	

	





File and maintain data (Clerical)	

	

	

	

10	

  10  	

$ 340	

	

	

     7	

70	

    $2,380



TOTAL	

	

   20	

   40	

10	

  70	

$4,020	

$0	

$18,200	

     7	

490	

$46,340

Assumptions:

1. Capital/start up cost: 0 facilities x $0 = $0

2.  Annual cost (O & M): 7 facilities x $2600 = $18,200

W--Uranium Mill Tailings

In order to complete these reporting requirements respondents will:

a.	read and understand the regulatory provision,

b.	perform radon flux testing required in 40 CFR part 61, Appendix B,
Method 115,

c.	perform data analysis including Method 115 radon flux calculations,

d.	prepare and submit the report to EPA.

- It is estimated that the testing materials for 100 measurements and
the analysis is obtained from a contract source at a cost of 
$25/measurement.  

- It is estimated that it will take one day for two people to place 100
canisters and one for two people to collect the canisters and ship them
to a testing lab.  

- It is estimated that 7 facilities will file a report annually.

- The estimated cost for a contractor to complete the testing is $2600

SUMMARY OF BURDEN ESTIMATE FOR RESPONDENTS   

No of Respondents	

Subpart	

Capital/Start-up

 Cost	

(O & M)

Cost	

Annual Burden Hours

	

Annual 

Costs





15	

 B	

$0.00	

$75,000	

3450	

$233,700



1	

 K	

$0.00	

$5,100	

278	

$17,648



39	

 R 	

$0.00	

$710,350	

4,978	

$964,698





7	

 W	

$0.00	

$18,200	

490	

$46,340



	

TOTALS	

$0.00	

$808,650	

9,196	

$1,262,386



Average annual burden per response: 9,196 hours/62 respondents = 148
hours.  For capital with a 20 year life, and assuming 5% discount rate,
the annualized cost is 8.02% of the capital cost.

Total Annualized capital/start up cost: $0 x 8.02% = $0  

Total Annualized Capital and O&M Costs: $0+ $808,650 = $808,650.

ESTIMATED AGENCY BURDEN AND COST

The burden to the EPA is only for reviewing the reports submitted by the
regulated community to ensure that emissions and dose are within the
limits set by the regulations. The main burden is on the regulated
community as they have to monitor emissions, compile the data, and
submit the necessary reports for compliance purposes. The estimated
agency burden and costs are as shown in the table below.    Agency
salaries were found in 2008 General Schedule Salary Table.  The data for
review of reports for compliance was based on the salary scale for
GS-13, step 5 (Tech), with a multiplier of 1.6 to include overhead; this
resulted in $60/hr.  For the Clerical category, the salary scale for a
GS-9, step 5 (Cler) was used with a multiplier of 1.6 to account for
overhead; this resulted in $35/hr. 

SUMMARY OF BURDEN ESTIMATE FOR THE AGENCY

AGENCY	

Capital/Start-Up Burden Hours	

Capital/Start-up Cost	

Annual Burden Hrs per Report	

Annual Costs per Report



Review  reports for compliance verification (Tech)	

	

	

6@$60/hr	

$360



File reports (Cler)	

	

	

4@ $35/hr	

$140



SUB-TOTAL	

0	

0	

10	

$500



TOTAL for 62 respondents	

620	

$31,000



EXPLANATION OF BURDEN ESTIMATE CHANGE

Burden estimates increased because the number of facilities affected has
increased due to renewed interest in uranium mining and phosphgypsum
usage. 

Burden Statement:  The annual public reporting and record keeping burden
for this collection of information is estimated to average 148 hours 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
EPA-HQ-OAR-2003-0085, which is available for public viewing at the
Office of Indoor Air and Radiation Docket in the EPA Docket Center
(EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington,
DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to
4:30 p.m., Monday through Friday, excluding legal holidays.  The
telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Office of Indoor Air and Radiation Docket is
(202) 566-1742.  An electronic version of the public docket is available
through Regulations.gov at http://www.regulations.gov.  

Use regulations.gov 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.  Once
in the system, select “search,” then key in the docket ID number
identified above.  Also, you can send comments to the Office of
Information and Regulatory Affairs, Office of Management and Budget, 725
17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. 
Please include the Docket ID EPA-HQ-OAR-OAR-2003-0085 and OMB Control
Number 2060-0191 in any correspondence. 

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