1
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
1100.12,
OMB
Number
2060­
0191
b)
Short
Characterization
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
for
OMB
approval
under
the
Paperwork
Reduction
Act
and
5
CFR
1320
is
addressed
below.

On
February
15,
2005
(
70
FR
7732),
EPA
requested
comments
on
specific
aspects
of
this
ICR,
with
the
comment
period
closing
on
April
18,
2005.
By
this
deadline,
there
were
no
comments
received
from
affected
entities
or
the
general
public.

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
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
2
Subpart
W­­
Uranium
Mill
Tailings
Piles
­
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rescinded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rescinded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
that
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
3
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
part
61,

Section
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
­
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.
4
3.
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
Piles
­
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,

(
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,
5
(
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,
6
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,

(
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
7
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,
8
(
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
insure
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:
9
(
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,
10
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
11
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
12
authorized
representative.

4.
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
13
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.

5.
NONDUPLICATION,
CONSULTATIONS
AND
OTHER
COLLECTION
CRITERIA
(
a)
Nonduplication
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)
First
Federal
Notice
and
Consultations
On
February
15,
2005
(
70
FR
7732),
EPA
requested
comments
on
specific
aspects
of
this
ICR,
with
a
60
day
comment
period
which
closed
on
April
18,
2005.
Specifically,
there
were
no
comments
received
from
affected
entities
or
the
general
public
by
this
deadline.
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
which
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
and
facility
emission
monitoring
and
compliance
professionals.
As
a
result
of
these
consultations
and
the
provision
in
the
Clean
Air
14
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.

(
c)
Effects
of
Less
Frequent
Collection
All
reporting
is
annually
or
less
frequent
than
annually.

(
d)
General
Guidelines
This
ICR
does
meet
OMB's
collection
guidelines;
has
public
support
(
there
were
no
comments
received
during
the
comment
period
which
ended
April
18,
2005)
and
does
not
duplicate
another
collection.

(
e)
Confidentiality
and
Sensitive
Questions
i.
Confidentiality
This
section
does
not
apply
because
this
ICR
does
not
request
information
of
confidential
nature.

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

6.
BURDEN
AND
COST
OF
THE
COLLECTION
Burden
and
costs
estimates
have
been
calculated
separately
for
each
subpart.
Respondent
labor
rates
are
based
on
the
December
2004
data
in
Table
2
from
the
US
Department
of
Labor,

Bureau
of
Labor
Statistics
(
BLS).
These
rates
are
doubled
in
the
cost
estimate
to
include
overhead.
The
labor
key
is
as
follows:
Management
(
Mgmt)
($
86/
hr)
was
based
on
the
Total
Compensation
for
the
"
Management"
Occupational
Group
in
the
BLS
data.
Technical
(
Tech)
was
based
on
salary
for
a
GS­
13,
step
1
($
62/
hr)
because
a
suitable
occupational
group
was
not
shown
15
in
the
BLS
data.
Clerical
(
Cler)
($
42/
hr)
was
based
on
the
Total
Compensation
for
the
"
Office
and
Administrative
Support"
Occupational
Group
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.)
16
Information
Collection
Hours
and
Costs
for
Underground
Uranium
Mines
Total
Hours
and
Costs
Activity
Table
B
Subpart
B­­
Underground
Uranium
Mines
Manager
$
86/
hour
Technical
$
62/
hour
Clerical
$
42/
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)
20
20
$
1,720
2
40
$
3,440
Perform
emission
monitoring
(
Tech.)
160
160
$
9,920
$
0
$
10,000
2
320
$
19,840
Perform
data
analysis
(
Technical)
40
40
$
2,480
2
80
$
4,960
Prepare
report
(
Mgmt)
10
10
$
860
2
20
$
1,720
Record
Keeping
File
and
maintain
data
(
Clerical)
10
10
$
420
2
20
$
840
TOTAL
30
200
10
240
$
15,400
$
0
$
10,000
2
720
$
30,800
Assumptions:

1.
Capital/
start
up
cost:=
$
0
2.
Annual
cost
(
O
&
M):
2
facilities
x
$
5,000
=
$
10,000
B
­­
Underground
Uranium
Mines
17
In
order
to
comp
a.
read
and
understand
b.
perform
radon­
222
emiss
c.
perform
data
analysis
including
approved
model
d.
prepare
and
submit
report.

­
The
estimated
capital/
start­
up
cost
includes
the
m
testing
for
one
mine.

­
Capital/
start­
up
burden
includes
understanding
regulatory
pro
(
there
was
no
capital
cost
in
this
cycle).

­
Estimated
annual
costs
related
to
testing
include
calibration,
and
repairs
c
­
Estimated
annual
burden
hours
collecting
emission
data
from
monitoring
equip
data
analysis
and
calculations,
report
preparation
and
data
management.

­
Based
on
reports
received
during
the
previous
reporting
period,
two
mines
are
operating.
18
Information
Collection
Hours
and
Costs
for
Elemental
Phosphorus
Total
Hours
and
Costs
Activity
Table
K
Subpart
K­­

Elemental
Phosphorus
Plants
Manager
$
86/
hour
Technical
$
62/
hour
Clerical
$
42/
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)
0
0
Perform
emission
monitoring
(
Tech.)
240
240
$
14,880
$
0
$
10,200
2
480
$
29,760
Perform
data
analysis
(
Technical)
8
8
$
496
2
16
992
Prepare
report
(
Mgmt)
8
8
$
688
2
16
1,376
Record
Keeping
File
and
maintain
data
(
Clerical)
10
10
$
420
2
20
840
TOTAL
8
248
10
266
$
16,484
$
0
$
10,200
2
532
$
32,968
Assumptions:

1.
Capital/
start
up
cost:
2
facilities
x
$
0
=
$
0
2.
Annual
cost
(
O
&
M):
2
facilities
x
$
5,100
=
$
10,200
19
K­­
Elemental
P
In
order
to
complete
th
a.
read
and
understand
the
re
b.
perform
the
emission
monitoring
c.
perform
data
analysis
including
calcul
d.
prepare
and
submit
the
report
to
EPA.

­
It
is
estimated
that
2
facilities
will
complete
these
­
The
estimated
cost
for
a
contractor
to
complete
testing
i
20
Information
Collection
Hours
and
Costs
for
Phosphogypsum
Stack
Total
Hours
and
Costs
Activity
Table
R1
Subpart
R­­
Phosphogypsum
Stacks
Manager
$
86/
hour
Technical
$
62/
hour
Clerical
$
42/
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)
40
40
$
3,440
20
800
$
68,800
Perform
emission
monitoring
(
Tech.)
64
64
$
3,968
$
0
$
152,000
20
1280
79,360
Perform
data
analysis
(
Technical)
8
8
$
512
20
160
10,240
Prepare
report
(
Mgmt)
8
8
$
688
20
160
13,760
Record
Keeping
File
and
maintain
data
(
Clerical)
10
10
$
420
20
200
8,400
TOTAL
48
72
10
130
$
9,088
$
0
$
152,000
20
2600
$
180,560
Assumptions:
Tables
R1
&
R2
1.
Capital/
start
up
cost:
20
facilities
x
$
0
=
$
0;
(
Table
2)
10
facilities
x
$
0
=
$
0
21
2.
Annual
cost
(
O
&
M):
20
facilities
x
$
7600
=
$
152,000
(
Table
2)
12
facilities
x
$
835
=
$
10,020
Total
O
&
M
for
Tables
R1
&
R2
=
162,020
Information
Collection
Hours
and
Costs
Per
Respondent
Total
Hours
and
Costs
Activity
Table
R2
Subpart
R­­
Phosphogypsum
Stacks
Manager
$
86/
hour
Technical
$
62/
hour
Clerical
$
42/
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)

Perform
radon
flux
testing
(
Tech.)
64
64
$
3,968
$
0
$
10,020
12
768
$
47,616
Perform
radium­
226
sampling
and
measurement
proce­

dures
(
Tech.)
8
8
$
496
12
96
5,952
Prepare
data
analysis
(
Tech.)
8
8
$
496
12
96
5,952
Prepare
report
and
certification
papers
(
Mgmt)
10
10
$
860
12
120
10,320
Record
Keeping
22
File
and
maintain
data
(
Clerical)
10
10
10
$
420
12
100
5,040
TOTAL
10
80
10
100
$
6,240
$
0
$
10,020
12
1,180
$
74,880
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
$
56/
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
20
stacks
will
be
required
to
complete
this
one­
time
report.

­
It
is
estimated
that
12
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.
23
24
Information
Collection
Hours
and
Costs
Per
Respondent
Total
Hours
and
Costs
Activity
Table
W
Subpart
W­­

Uranium
Mill
Tailings
Piles
Manager
$
86/
hour
Technical
$
62/
hour
Clerical
$
42/
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)

Perform
radon
flux
testing
(
Tech.)
32
32
$
1,984
$
0
$
7,800
3
96
$
5,952
Perform
data
analysis
(
Technical)
8
8
$
496
3
24
1,488
Prepare
report
(
Mgmt)
10
10
$
860
3
30
2,580
Record
Keeping
File
and
maintain
data
(
Clerical)
10
10
$
420
3
30
1,260
TOTAL
10
40
10
60
$
3,760
$
0
$
7,800
3
180
$
11,280
Assumptions:

1.
Capital/
start
up
cost:
3
facilities
x
$
0
=
$
0
2.
Annual
cost
(
O
&
M):
3
facilities
x
$
2600
=
$
7,800
25
W­­
Uranium
M
In
order
to
complete
th
a.
read
and
understand
the
re
b.
perform
radon
flux
testing
requi
c.
perform
data
analysis
including
Metho
d.
prepare
and
submit
the
report
to
EPA.

­
It
is
estimated
that
the
testing
materials
for
100
me
obtained
from
a
contract
source
at
a
cost
of
$
25/
measure
­
It
is
estimated
that
it
will
take
one
day
for
two
people
to
place
8wo
people
to
collect
the
canisters
and
ship
them
to
a
testing
lab.

­
It
is
estimated
that
3
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
2
B
$
0.00
$
10,000
720
$
30,800
2
K
$
0.00
$
10,200
532
$
32,968
32
R
(
R1&

R2)
$
0.00
$
162,020
2600
$
255,440
3
W
$
0.00
$
7,800
180
$
11,280
TOTALS
$
0.00
$
190,020
4,032
$
330,488
Average
annual
burden
per
response:
4032
hours/
39
respondents
=
103
hours.
For
capital
with
a
26
20
year
life,
and
Total
Annualized
Ca
Total
Annualized
Capital
a
ESTIMATED
AGENCY
BURD
The
burden
to
the
EPA
is
only
for
revie
ensure
that
emissions
and
dose
are
within
the
the
regulated
community
as
they
have
to
monitor
em
necessary
reports
for
compliance
purposes.
The
estimated
in
the
table
below.
Agency
salaries
were
found
in
2005
Gener
data
for
review
of
reports
for
compliance
was
based
on
the
salary
sca
with
a
multiplier
of
1.6
to
include
overhead;
this
resulted
in
$
56/
hr.
For
the
salary
scale
for
a
GS­
9,
step
5
(
Cler)
was
used
with
a
multiplier
of
1.6
to
account
this
resulted
in
$
32/
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@$
56/
hr
$
336
File
reports
(
Cler)

4@
$
32/
hr
$
128
SUB­
TOTAL
0
0
10
$
464
TOTAL
for
39
respondents
390
$
18,096
EXPLANATION
OF
BURDEN
ESTIMATE
CHANGE
27
Some
burden
est
due
to
facility
closure.

Burden
Statement:
The
an
collection
of
information
is
estima
time,
effort,
or
financial
resources
expen
or
provide
information
to
or
for
a
Federal
age
instructions;
develop,
acquire,
install,
and
utilize
tec
collecting,
validating,
and
verifying
information,
processi
disclosing
and
providing
information;
adjust
the
existing
ways
t
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
information;
search
data
sources;
complete
and
review
the
collection
of
info
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
an
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
vali
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
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
OAR­
2005­
0017,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,

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
28
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
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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
EPA
Docket
ID
OAR­
2005­
0017
and
OMB
Control
Number
2060­
0191
in
any
correspondence.
