Overview
Title
Information Collection Request; Comment Request; National Emission Standards for Hazardous Air Pollutants (NESHAP) for Radon Emissions From Operating Mill Tailings (Renewal)
Agencies
ELI5 AI
The EPA wants to keep checking how radon (a smelly gas) is handled at places called uranium mill tailings to keep everyone safe. They are asking people to share their thoughts on how this check-up should happen, and they say it might be a bit easier for people to help than before.
Summary AI
The Environmental Protection Agency (EPA) has submitted a request to renew the collection of information related to federal standards for controlling radon emissions from uranium mill tailings. This renewal is necessary for maintaining public health safety by ensuring compliance with these standards. The EPA is asking for additional public comments on this information collection request, which involves the collection of records and inspection of facilities. The agency estimates a decrease in the number of respondents and associated burden compared to previous estimates.
Abstract
The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), NESHAP for Radon Emissions from Operating Mill Tailings (EPA ICR Number 2464.03, OMB Control Number 2060-0706) to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act. This is a proposed extension of the ICR, which is currently approved through December 31, 2020. Public comments were previously requested via the Federal Register on August 20, 2020 during a 60-day comment period. This notice allows for an additional 30 days for public comments. A fuller description of the ICR is given below, including its estimated burden and cost to the public. 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.
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AnalysisAI
The document from the Environmental Protection Agency (EPA) seeks public comments on renewing an information collection request concerning radon emissions from uranium mill tailings. The goal of this request is to ensure ongoing compliance with federal standards that protect public health from the harmful effects of airborne radon. These standards apply to facilities that recover uranium and manage mill tailings, requiring them to maintain and report specific records about operations. With the current request renewal, the EPA estimates a decrease in the number of respondents and related work burden compared to previous estimates.
Summary of the Document
The Environmental Protection Agency (EPA) is attempting to renew an information collection effort designed to regulate and monitor radon emissions from operational uranium mill tailings. This is part of a broader effort to safeguard public health against airborne radionuclides. The renewal involves extending the collection process previously approved, recognizing certain changes in respondent burdens and compliance requirements. The document opens a period for the public to provide additional comments or queries on this proposed renewal.
Key Issues and Concerns
While the document includes important updates and changes, several issues need more clarity:
Reduction in Respondent Burden: The document notes a decrease in the estimated hours required for respondents, but lacks a detailed explanation of the reduction in the number of responses. This absence might lead to confusion about the specific reasons behind fewer respondents.
Technical Language: Terms like "SWIPR system" are mentioned without explanation. This language may be opaque to those outside the niche industry, creating a barrier to understanding for the general public.
Frequency of Response: The document indicates reporting should occur at least monthly or as activities dictate, but provides no clear guideline on which activities require more frequent reporting. This ambiguity could lead facilities to inconsistently interpret their obligations.
Projections and Future Impact: It states no new facilities are expected to comply with these standards in the next few years, but it lacks an explanation for this projection. This absence leaves questions about the future scope and impact of regulations.
Cost Clarifications: While the document states there are zero operational costs associated, it would be beneficial to explain why these costs are nonexistent in this case, as it may not align with typical expectations.
Impact on the Public and Stakeholders
The renewal of the information collection is vital for ensuring that uranium mill operations remain compliant with health and safety regulations. By doing so, it protects the general public from elevated risks of radon exposure, which is essential for public health in areas surrounding uranium milling operations.
Additionally, stakeholders within the uranium industry, including mine operators and associated businesses, are directly impacted. They must remain informed and ready to comply with record keeping and reporting standards. While the reduction in the burden is a positive change, the confusion regarding reporting frequencies and operational requirements might need addressing to prevent compliance issues.
Overall, while this document has practical implications for compliance, it also highlights the need for comprehensive communication to ensure clarity and reduce obstacles for stakeholders who must adhere to federal standards. For the public, it reflects a continued effort by regulatory bodies to maintain standards that prioritize health and safety.
Financial Assessment
The document from the Environmental Protection Agency (EPA) provides financial details concerning the renewal of the Information Collection Request (ICR) under the National Emission Standards for Hazardous Air Pollutants (NESHAP) related to radon emissions from operating mill tailings. The financial aspect of this ICR is crucial for understanding the economic impact on the respondents, which primarily consist of uranium recovery facilities.
Total Estimated Cost
The document specifies a total estimated cost of $115,812 per year. Notably, this figure includes $0 annualized capital or operation & maintenance costs, which might prompt readers to question why these usually significant costs do not contribute to the total financial burden. This absence of capital and maintenance expenses may imply that the relevant operations are either covered by existing infrastructure or simply do not require additional spending for the activities mentioned. However, such assumptions could benefit from clarification to enhance understanding.
Respondent Burden and Changes
There is a noted decrease of 5,347 hours in the total estimated respondent burden compared to the previously approved ICR. This decrease suggests a reduction in the time respondents are expected to spend complying with the ICR requirements, translating into potential cost savings in terms of labor or other resources. Although the document attributes this reduction to a decrease in the number of respondents, it might further clarify how fewer respondents directly affect the aggregate burden and subsequently the overall costs.
Furthermore, while the document mentions a transition of the SWIPR system from a start-up phase to an operations-and-maintenance mode, any cost implications related to this transition are not detailed. For instance, while the operational efficiencies from such transitions might contribute to cost savings, including this context would provide a fuller financial picture.
Uncertainty and Future Costs
There is an assertion that no additional facilities are anticipated to fall under these requirements in the coming years. This projection underlines a stable financial outlook without expected increases in compliance costs due to an expansion in the number of regulated entities. While this may reinforce the reliability of the cost estimates provided, additional insight into the data or analysis supporting this projection could alleviate uncertainties about future financial obligations.
Overall, the financial references raise meaningful points about respondent costs and operational transitions, yet more detailed explanations could further enhance transparency and assist stakeholders in comprehensively assessing their financial commitments under this information collection request.
Issues
• The document mentions an estimated decrease of 5,347 hours in respondent burden, but does not provide a detailed explanation or analysis of why the number of respondents has decreased.
• The document uses technical language such as 'SWIPR system from a start-up to an operations-and-maintenance mode' without providing context or explanation for what a SWIPR system is, which could be confusing to those unfamiliar with industry-specific terminology.
• The information regarding the frequency of response is somewhat ambiguous, stating 'Reporting at least monthly; more frequent or one-time collection of records, depending on activity.' More specific guidance on what activities require more frequent submissions might be beneficial.
• The document mentions that no additional facilities will become subject to the requirements in the next few years without specifying the basis for this projection, leaving room for uncertainty about the potential for future regulatory impact.
• The document might benefit from an executive summary or a simplified explanation of the changes in the estimates for better comprehension by non-experts.
• It's unclear what the total cost for operation & maintenance is, even though the document states $0, which might need further clarification about what these costs typically encompass or why they are absent.