SUPPORTING STATEMENT FOR RadNet ICR# 0877.10

Section I: Part A

1.  Identification of the Information Collection

1.(a)	Title of the Information Collection

RadNet (formerly, Environmental Radiation Ambient Monitoring System
[ERAMS])

1.(b)	Short Characterization

RadNet in this ICR refers to EPA’s national environmental radiation
monitoring network.  The objectives of RadNet (formerly, Environmental
Radiation Ambient Monitoring System [ERAMS] and renamed in 2005 to
RadNet) are to provide a means of estimating ambient levels of
radioactive pollutants in our environment, to follow trends in
environmental radioactivity levels, and to detect and assess the impact
of fallout and other intrusions of radioactive materials.  Data
generated from EPA's RadNet have been and are being used to provide the
information base for making decisions necessary to ensure the protection
of public health.  The system enables EPA to determine if additional
sampling or other actions are required in particular cases of
radioactive releases to the environment, and, where necessary, RadNet
can provide ancillary information on population exposure, radiation
trends, and other aspects of such releases.

The RadNet network is used to collect air particulate, precipitation,
drinking water, and pasteurized milk samples.  Most RadNet air
particulate monitors are capable of measuring radiation from the filter
in real-time, sending the data hourly to EPA.  The data from analysis of
these samples constitute the nation's single major source of
environmental radiation data.  The responsibility for operating RadNet
is assigned by the EPA’s Office of Radiation and Indoor Air to the
Director, National Analytical Radiation Environmental Laboratory
(NAREL), Montgomery, Alabama. The component sampling locations are
distributed throughout the United States and cover each geographical
region, individual states, and most major population centers.  The
respondents, primarily state and some local personnel, voluntarily
collect the samples and complete the information forms.  The forms
request descriptive information related to sample collections (e.g.,
sample type, sample location, length of sampling, and volume
represented).  Requested sampling frequencies are as follows:

Air particulate samples are requested twice weekly. *

Precipitation samples are collected after each measurable rainfall and
composited into monthly samples.

Pasteurized milk samples are collected quarterly.

Drinking water samples are collected quarterly.

*   Many variable, site-specific conditions may preclude predicting a
specific number of filters changed by a respondent weekly.  For example,
operator safety may be compromised by construction or severe weather,
which may preclude routine air sample collection.  Reduced operator
availability may cause reduced filter change frequency if an
operator’s non-volunteer job duties increase, or if frequency of
visits to a monitor site decreases, such as may occur with sites at
remote locations generally visited in conjunction with non-volunteer job
duties.  The RadNet Quality Assurance Project Plan contains a detailed
discussion of these conditions.  It is important to recognize that these
variations do not affect the quality of the results of the analyses.

The samples are sent to NAREL for radiochemical analyses.  To ensure
that the data generated at NAREL are of known quality, a quality
assurance plan (available upon request) is followed during all phases of
sample collection and analysis activities. 

All results are stored in the NAREL computer and made available online
at the EPA website and when necessitated by circumstances can be
available daily. See Attachment 1 for the forms used by respondents and
NAREL personnel to document sampling in all RadNet media:  air,
precipitation, milk, and drinking water.

The utility of RadNet data is evidenced by its extensive use by a number
of federal, state and commercial entities.  DOE's National Laboratories
(including Oak Ridge, Savannah River, Brookhaven, and Argonne) and many
universities across the country utilize the data generated by the
operation of the RadNet network.  RadNet data are also used by the
Nuclear Regulatory Commission (NRC) and NRC licensed nuclear power
plants and their environmental contractors to establish background data.
 These data are used by some power plant operators as a baseline to
ensure compliance with NRC release limits.  The states also use RadNet
data to supplement or compare with environmental radiation information
generated by their own programs.

Data from this program have been used to measure fallout following
atmospheric nuclear weapon tests until 1980, when atmospheric testing of
nuclear weapons ceased.  During and following the accident at Three Mile
Island, RadNet stations in the adjacent states demonstrated to the
public that there were no radioactive materials in their areas as a
result of the accident.  Increased monitoring following the nuclear
incident at Chernobyl in 1986 provided daily reports of atmospheric
concentrations of radionuclides across the United States.  Most
recently, RadNet was the largest source of radiological data following
the Fukushima reactor accidents in 2011.

The collection of samples will involve 302 respondents with an annual
respondent burden cost of approximately 299,913 dollars, including costs
of benefits and overhead. The respondents are not asked or required to
keep records and all supplies and equipment relating to RadNet
activities are provided by NAREL at no cost to the respondents.

RadNet data back to 1981 may be found at the EPA web site
http://www.epa.gov/radnet/radnet-data/online-data.html.  RadNet data on
the web are interactive--the database can be queried and searched. 
Quarterly reports are no longer produced in hard copy, due to the
availability of RadNet data online.  NAREL does not survey respondents,
other than on specific issues regarding their work as sample collectors.
  That is done through routine conversations with them via telephone as
part of the process of maintaining the flow of samples and supplies
between NAREL and respondents.

Currently, expansion of the real-time air network of RadNet, which began
in 2006, is being completed.  Since 2006, the number of air samplers has
increased from 52 to the current 146 and will increase to a total of 156
during the period of this ICR (from February 2013 through February
2016).  The total of 156 samplers will be comprised of 140
near-real-time samplers plus a legacy of approximately 16 conventional
samplers.  The size of the other media networks (milk, drinking water,
and precipitation) are expected to remain essentially unchanged, except
for the normal fluctuation of volunteer participants.  The increased
burden for the Agency provided in this supporting statement is primarily
the result of the increased sample load inherent in an expanded air
monitoring system.

2.  Need for and Use of the Collection

2.(a)	Need / Authority for the Collection

The legal basis of RadNet originated and resides in Executive Order
10831 and Public Law 86-373.  Executive order 10831 was announced to the
public on July 31, 1959, and issued August 4, 1959.  This order came in
response to recommendations contained in a memorandum to the President
from Elmer B. Staats on July 31, 1959.  As reiterated before the Joint
Committee on Atomic Energy by Maurice H. Stans, these recommendations
also became a part of the legislative history of the 1959 amendments to
the Atomic Energy Act. Radioactive fallout and environmental radiation
monitoring became a responsibility of the Department of Health,
Education and Welfare (HEW) under these legal mandates.  In 1970,
Reorganization Plan No. 3 transferred HEW's fallout and radioactive
monitoring responsibilities to the Environmental Protection Agency
(EPA).  On July 1, 1973, through its Office of Radiation Programs (ORP),
EPA developed and implemented a new continuous monitoring system.  This
system, originally termed ERAMS and now called RadNet, was designed to
complete and complement the monitoring system previously instituted by
HEW's Public Health Service under Executive Order 10831.

The objectives of RadNet are to provide a means of estimating ambient
levels of radioactive pollutants in our environment, to follow trends in
environmental radioactivity levels, and to assess the impact of fallout
and other intrusions of radioactive materials.  Data generated from
EPA's RadNet have been and are being used to provide the information
base for making decisions necessary to ensure the protection of public
health.  The system enables EPA to determine if additional sampling or
other actions are required in particular cases of radioactive releases
to the environment, and, where necessary, RadNet can provide ancillary
information on population exposure, radiation trends, and other aspects
of such releases.

2.(b)	Use / Users of the Data

Data generated by RadNet are used to provide a means of estimating
ambient levels of radioactive pollutants in our environment, to follow
trends in environmental radioactivity levels, and to detect and assess
the impact of fallout and other intrusions of radioactive materials. 
Data generated from EPA's RadNet have been and are being used to provide
the information base for making decisions necessary to ensure the
protection of public health.  The system enables EPA to determine if
additional sampling or other actions are required in particular cases of
radioactive releases to the environment and, where necessary, RadNet can
provide ancillary information on population exposure, radiation trends,
and other aspects of such releases.

The utility of the RadNet data is evidenced by its extensive use by a
number of federal, state and commercial entities.  DOE's national
Laboratories (including Oak Ridge, Savannah River, Brookhaven, and
Argonne) and many universities across the country utilize the data
generated by the operation of the RadNet network.  RadNet data are also
used by the Nuclear Regulatory Commission and NRC licensed nuclear power
plants and their environmental contractors to establish background data.
 These data are used by some power plant operators as a baseline to
ensure compliance with NRC release limits.  The states also use RadNet
data to supplement or compare with environmental radiation information
generated by their own programs.

Data from this program have been used to measure fallout following
atmospheric nuclear weapon tests until 1980, when atmospheric testing of
nuclear weapons ceased.  During and following the accident at Three Mile
Island, RadNet stations in the adjacent states demonstrated to the
public that there were no radioactive materials in their areas as a
result of the accident.  Increased monitoring following the nuclear
incident at Chernobyl in 1986 provided daily reports of atmospheric
concentrations of radionuclides across the United States.  Most
recently, RadNet was the largest source of radiological data following
the Fukushima reactor accidents in 2011.

3.	Non-duplication, Consultations, and Other Collection Criteria

3. (a)	Non-duplication	

RadNet has been in operation for 40 years.  During that time, data
derived from the system have been disseminated nationally and
internationally.  The professional/information network developed over
the life of RadNet has identified other environmental radiation data
systems in the United States, but none have RadNet's national scope or
exact collection and analytical structure.  This was recently
highlighted during the months following the nuclear reactor accidents in
Fukushima, Japan.

Immediately following the accident at Chernobyl in 1986 in the former
Soviet Union, the President's order charged EPA with lead responsibility
for monitoring possible environmental effects in the United States.  It
was the unique nationwide monitoring capability of RadNet that helped
EPA respond to that Presidential Order.  Similarly, during the nine-year
EPA follow-up monitoring of the accident at Three Mile Island RadNet was
called upon because of its unique national scope and analytical
structure and capability.

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

The first Federal Register(FR) notice has been completed.  The notice
was published February 15, 2013 in FR Vol. 78, No. 32.  EPA received no
comments.

3. (c)	Consultations

The National Analytical Radiation Environmental Laboratory (NAREL) is
involved in telephone and written communication with the respondents who
supply the samples.  In addition, NAREL is an active participant in the
Council of Radiation Control Program Directors (CRCPD), which is an
association of individuals from radiation programs from all fifty
states.  These individuals and their associates make up a significant
number of RadNet data users.  NAREL's participation in this association
allows for frequent consultations on a variety of issues involving
RadNet with many RadNet data users.  Comments from federal and state
agencies and other organizations concerning RadNet are welcomed and are
noted at NAREL.  

3. (d)	Effects of Less Frequent Collection

Alternate, less frequent collection intervals have been considered but
not adopted because these would not provide the continuous current
"picture" of the radiation levels across the United States now available
with the current system.  Less frequent collection would eliminate the
ability to determine and respond to elevated radiation levels soon after
they occur and would dramatically decrease the ability to map trends in
radiation data following a release.

3. (e)	General Guidelines

The respondents are requested to supply precipitation samples and air
filters and accompanying forms more often than on a quarterly basis. 
This is done so that elevated levels of radiation will be detected as
soon as possible so as to allow for the quickest response possible to
potential health threats.  

The respondents submit sample collection information on a one page form
that accompanies the sample to the NAREL.  Since most samples are
collected in the field, electronic means of recording or sending the
information are not feasible.  In addition, to avoid assigning incorrect
sampling information to a sample, the sample and sampling information
need to be linked when they are sent to the lab.  The most effective
means to do this is to attach a form with the information to the sample.

3. (f-g)	Confidentiality and Sensitive Questions	

The section on confidentiality and sensitive questions does not apply to
RadNet.  The respondents do not supply confidential or sensitive
information.

4.  The Respondents and the Information Requested

4.(a)	Respondents / NAICS Codes

All fifty states, primarily the State Public Health Departments (NAICS
Code 92312), send samples along with one page sample collection forms to
NAREL.  The respondents were chosen for two basic reasons: most of them
routinely collect samples of this type as part of their normal
activities, and in order to obtain meaningful information concerning
ambient radiation levels for the entire United States samples must be
collected from as many parts of the country as feasible.

 

4.(b)(i)	Information Requested

Respondents provide actual samples of air, precipitation, drinking
water, and milk.  Respondents do provide descriptive information about
their samples on one page forms (see Attachments 1-6).  The respondents
are not requested or required to maintain records.  Since the forms, as
shown in the attachments, have had only very minor changes over time
expiration dates are not included on them.  

4.(b)(ii)	Respondent Activities	

RadNet respondents perform the following tasks in order to provide
samples to NAREL:

Read instructions concerning the sampling process

Collect samples in appropriate containers

Mail/ship samples to NAREL in Montgomery, Alabama

Complete description forms regarding samples

Most respondents are employees of state health agencies and routinely
perform sampling of their own that is analogous to RadNet sampling.  

5.	The Information Collected

5.(a)	Agency Activities

Since RadNet began operating in the early 1970's, the following
functions have been part of EPA's inventory of Agency activities:

Maintain a master database

Answer respondent questions

Coordinate respondent sample submissions

Maintain records of sample submissions

Publish and disseminate data from sample analyses

Analyze samples submitted by respondents

Prepare and send sampling material

Provide maintenance and or replacements for sampling instruments

5.(b)	Collection Methodology and Management

The RadNet network involves the collection of a variety of samples
including air filters, milk, drinking water, and rain water
(precipitation) samples.  Standard Operating Procedures (available upon
request), contain the detailed procedures used to ensure uniform
collection of the samples and the standard forms filled out by the
respondents when they collect the samples.  The forms were designed to
minimize the burden on the respondents.  In most cases only the date of
sampling, location of sampling, and the name of the individual taking
the sample are required.  Since most samples are taken in the field, an
electronic means of recording and sending this information is not
feasible.  To ensure that the sample collection information accompanies
the correct sample, the sample and the information need to be sent
together.  This is best accomplished by attaching the one page form to
each sample when it is sent to the NAREL.

When the samples and accompanying forms arrive at NAREL, the samples are
assigned an identification number.  This number and information from the
accompanying forms are entered into the NAREL computer.  The samples are
then analyzed for a variety of radionuclides.    Data from the analyses
performed at NAREL are also entered into the computer.  The data are
stored in a database and are available to the public online at the EPA
website http://iaspub.epa.gov/enviro/erams_query_v2.simple_query.  When
necessitated by unique circumstances, data from the RadNet network can
be made available daily.  The data are verified by at least two
individuals at NAREL.  To ensure that the data are accurate and
reliable, all activities associated with the RadNet network must conform
to the RadNet Quality Assurance Project Plan and the Quality Assurance
Manual, which detail the data quality objectives, project organization
and responsibility, internal quality control checks, and other areas
relating to quality assurance.  

5.(c)	Small Entity Flexibility

This section is not applicable because the respondents are state
agencies.

5.(d)	Collection Schedule

Listed below are the requested sample collection frequencies that
require completion of sample collection forms.

Sample					Requested Collection frequency

Milk					Quarterly	

Drinking water				Quarterly

Precipitation				As precipitation occurs

	Air filters				Two times per week *

*   Many variable, site-specific conditions may preclude predicting a
specific number of filters changed by a respondent weekly.  For example,
operator safety may be compromised by construction or severe weather,
which may preclude routine air sample collection.  Reduced operator
availability may cause reduced filter change frequency if an
operator’s non-volunteer job duties increase, or if frequency of
visits to a monitor site decreases, such as may occur with sites at
remote locations generally visited in conjunction with non-volunteer job
duties.  The RadNet Quality Assurance Project Plan contains a detailed
discussion of these conditions.  It is important to recognize that these
variations do not affect the quality of the results of the analyses.

In the rare case of an emergency, such as Three Mile Island, Chernobyl,
or Fukushima, EPA may request an increased sample collection frequency.	

6.	Estimating the Burden and Cost of Collection

6.(a)	Estimating Respondent Burden

Total individual respondent burden for RadNet is estimated to be 8,243
hours annually.  This 5 percent reduction in burden from 8,710 hours
annually is primarily driven by the use of improved technology which
reduces manual calculations for the real-time air monitors.  Improved
technology of the RadNet real-time air monitors also allows some
operations to be performed by EPA personnel at NAREL rather than
requiring respondent time.  EPA continues to look for other ways to
reduce operator burden, particularly in the real-time air monitoring
program.  

Burden hour estimates are based primarily on sample collection times
tested by NAREL personnel and informal telephone conversations with
respondents over the years.  Additional information used in estimating
burden hours was obtained through discussions of NAREL personnel with
personnel from state radiation departments at Council of Radiation
Control Program Directors (CRCPD) meetings.  Discussions with
respondents and RadNet management revealed that the technical labor
category is the most appropriate one for all RadNet burden activities.

Although the respondent burden assumes 302 sampling locations, there can
be times when the actual number of stations reporting is less than that,
due to unexpected nonparticipation by some stations.  However,
participation is not anticipated to decrease by more than 15 percent.

	

6.(b)	Estimating Respondent Cost

Total respondent cost for RadNet is estimated to be about $300,000
annually.  This 37 percent reduction in cost from about $480,000
annually is again primarily driven by the use of improved technology. 
The improved technology of the real-time RadNet air monitors allows
operation by volunteers with a much wider range of technological skills
which reduces the hourly rate assumed in the calculation.  Additionally,
as stated in 6.(a), improved technology aides in reducing respondent
burden and thus cost.  

Informal conversations and discussions with respondents and RadNet
management have revealed that the technical labor category is the
correct one for all RadNet respondent burden activities.  Since the
hourly wages of the respondents depend on years of employment and the
pay scales of their respective states, an actual average hourly wage
would require obtaining confidential information from the respondents. 
Based on our informal discussions with respondents and RadNet managers,
the hourly rate at the GS-9(1) level, 36.384 dollars/hour ($22.74 per
hour times a 1.6 overhead multiplication factor, based upon OPM salary
tables for “rest of U.S.” effective January 2012 as displayed at
http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2012/g
eneral-schedule/rus_h.pdf), is a good approximation of the
respondents’ hourly wage for this technical labor category.  This is
reduced from the previous reports which used GS-12(1) as a basis.  This
reduction is due to newer information concerning respondent’s time
burden and reduced burden of the real-time air program due to improved
technology.  

The respondents are not asked or required to keep records, and all
supplies and materials relating to RadNet activities are provided by the
NAREL at no cost to the respondents.

There are no capital costs for sample collectors (respondents). All
equipment and materials are supplied by NAREL. 

6.(c)	Estimating Agency Burden and Cost

Total agency burden and cost for RadNet are estimated to be about 28,700
hours and $2,376,000 annually.  The 31 percent increase in burden from
21,930 is primarily due to additional sample throughput in the
laboratory and additional data review and maintenance operations needed
to support the expanded network of real-time air monitors.  These
additional hours result in a 25% increase in agency personnel cost from
about $1,447,000 to $1,803,000 annually.  Additionally, EPA estimates
the cost for supplies for the RadNet program to be $78,000 annually,
which is a 5% increase due to the additional RadNet air samplers. 
Finally, EPA estimates the capital costs to decrease significantly from
about $1,383,000 to about $495,000.  The decrease in capital cost is
primarily due to EPA having completed air monitor purchases, which was
the largest capital acquisition.

Our agency burden estimates are based on our years of experience in
operating the RadNet network.  Since the activities for the operation of
RadNet involves worker at various GS levels, we used composite burden
hours and calculated hourly costs at the GS-13 level (step 1) times 1.6
(the overhead multiplication factor) to be 62.74 dollars/hour.  The
total number of annual hours devoted to RadNet by Agency personnel is
estimated to be 28,706 hours.  

	6.(d)	Bottom Line Burden Hours and Cost/Burden Tables

See burden tables on pages 11-13.

6.(e)	Reasons For Change in Burden

Total respondent burden for RadNet was reduced by 5% primarily due to
the use of improved technology of the RadNet real-time air monitors. 
Total agency burden increased by 31 percent, primarily due to additional
sample throughput in the laboratory and additional data review and
maintenance operations needed to support the expanded network of
real-time air monitors.

6.(f)	Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average just under 0.5 hours per
response.  Burden means the total time and effort 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 No.
EPA-HQ-OAR-2003-0041-0008, which is available for online viewing at 
HYPERLINK "http://www.regulations.gov/" www.regulations.gov , or in
person viewing at the Office of Air and Radiation Docket in the EPA
Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW,
Washington, DC.  The EPA/DC Public Reading Room is open from 8 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 Air and Radiation Docket is 202-566-1742.   Use
EPA’s electronic docket and comment system at  HYPERLINK
"http://www.regulations.gov/" www.regulations.gov , to submit or view
public comments, access the index listing of the contents of the docket,
and to access those documents in the docket that are available
electronically.  Once in the system, select “docket search,” then
key in the docket ID number identified above.  Please note that EPA’s
policy is that public comments, whether submitted electronically or in
paper, will be made available for public viewing at  HYPERLINK
"http://www.regulations.gov/" www.regulations.gov  as EPA receives them
and without change, unless the comment contains copyrighted material,
CBI, or other information whose public disclosure is restricted by
statute.  For further information about the electronic docket, go to 
HYPERLINK "http://www.regulations.gov/" www.regulations.gov .

Section II: Part B

In the case of the RadNet network, respondents send in actual samples
such as air filters, milk, drinking water, and rain.  With each sample
the respondents send in a one page form which basically requires the
date and location of sampling, the size of the sample, and the name of
the individual taking the sample.  This is basic information that
identifies the sample and requires no real data gathering on the part of
the respondent.  The respondent simply supplies information on the
sampling process that he/she just performed.

The design of RadNet makes it the most comprehensive radiation
monitoring network in the nation.  The 302 sampling sites span the
United States and cover most major population centers in all
geographical regions.  They are typically located at or near state
health facilities and samples are collected voluntarily by state
personnel.  Although the choice of sampling station locations is not
based on a truly randomized design, the nationwide dispersion of sites
does represent a close approximation to randomly selected locations with
consideration given to population centers and potential radiation source
distribution.  This arrangement maximizes the coordination with state
and local agencies collecting the samples as it does not place stations
in extremely remote and relatively inaccessible locations.

The RadNet network satisfies the three major objectives of an
environmental monitoring program as set forth by the Health Physics
Society's Committee on Upgrading the Quality of the Environmental Data
(EPA 520/1-80-012).  These objectives are:

a.	to assess dose,

b.	to determine any trends of environmental radiation dose rates and
concentrations 	

	of radioactive materials, and 

c.	to reassure members of the public and governmental organizations
regarding

 	radiation hazards and environmental radiation exposures.

The Society specifically references EPA's RadNet as an example of a
functioning environmental monitoring program that incorporates these
major desirable features. 

TABLE 1

Annual Respondent Burden Cost Estimates

Activity	Hours per Occurrence

(A)	Occurrences per Year

(B)	Hours per Respondent per Year

(C = A x B)	Respondents per Year

(D)	Burden-hours per years

(E = C x D)	Cost per year

(F = E x $36.38/hr)*

Read Instructions







    Air 	1	2	2	156	312	11,351.81

    Precipitation 	0.5	2	1	33	33	1,200.67

    Drinking water	0.5	2	1	74	74	2,692.42

    Milk	1	2	2	39	78	2,837.95

Collect Samples







    Air	0.32	104	32.9	156	5137.6	186,926.44

    Precipitation	0.23	26.2	6.1	33	201.6	7,335.01

    Drinking  Water	0.15	4	0.6	74	44.4	1,615.45

    Milk	3.90	4	15.6	39	608.4	22,136.03









Complete and Mail Forms







    Air	0.1	104	10.4	156	1622.4	59,029.40

    Precipitation	0.1	26.2	2.6	33	86.4	3,143.58

    Drinking Water	0.1	4	0.4	74	29.6	1,076.97

    Milk	0.1	4	0.4	39	15.6	567.59









TOTAL ANNUAL  HOURS	8243









	TOTAL ANNUAL  LABOR COST

299,913.31









RESPONDENTS’ TOTAL ANNUAL COST**

299,913.31

*  The rate used in this table is that of a GS-9/1 for 2012.  The
$36.384 per hour amounts to the GS-9/1 rate of $22.74/hr multiplied by
an overhead rate of 1.6.

**  Record keeping costs, capital costs, and maintenance costs are zero
(0) for respondents.

					TABLE 2

Annual Agency Burden/Cost Estimates

(Activities)

Line Item	Burden Activity	Annual Hours	Agency Costs*

1	Maintaining master database	50	3,137.00

2	Monitoring real-time data (contractor)	3,288	206,000.00

3	Monitoring real-time data (NAREL)	500	31,370.00

4	Maintain real-time monitors (contractor)	6,480	421,200.00

5	Maintain system operations (NAREL)	1,500	94,120.00

76	IT support (contractor)	1,920	108,000.00

7	Answering respondent questions	210	13,175.40

8	Coordinating respondent submissions	1,462	91,725.88

9	Maintaining records of samples	1,462	91,725.88

10	Publishing and disseminating data	300	18,822.00

11	Analyzing samples	9,734	610,711.16

12	Providing sampling supplies	1,800	112,932.00

	TOTAL	28,706	1,802,909.32

* For federal employees, the activity costs assume an average of GS-13/1
($62.74/hr) rate.  Lines 2, 4, and 6 are contractor costs.  GS hourly
rates

 are based upon 2012 data from the Office of Personnel Management
(http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2012/
general-schedule/rus_h.pdf).

					TABLE 3

Agency Burden/Cost Estimates (Capital Costs)*

Line Item 	Unit Cost ($)	No. Units	Total ($)

Physical site preparation for air samplers	3,000	4	12,000

Supplies to field stations 	500	156	78,000

Maintain real-time monitors parts (annual total)	180,000	1	180,000

Maintain real-time monitors (contractor site visits, annual total)
180,000	1	180,000

IT costs 



	Data disaster recovery site	22,000	1	22,000

Oracle license	15,000	1	15,000

Internet access	18,000	1	18,000

FTP software	500	1	500

Records retention	1,800	1	1,800

Backup software	6,000	1	6,000

Equipment refresh	10,000	1	10,000

CDX website host	50,000	1	50,000

Grand Total	573,300

*All capital costs in this table, except for the $78,000 to supply field
stations, pertain to costs supporting the expansion and upgrade

 of the RadNet air network.

					TABLE 4

Summary of Respondent and Agency Total Costs

Line Item	Total ($)

Annual Respondent Burden	299,913.31

Annual Agency Burden for Activities	1,802,909.32

Annual Agency Burden for Capital Costs	573,300

Combined (activity and capital cost) Burden

       to the Agency	2,376,209.32



ATTACHMENT 1

Forms Used by RadNet Respondents

(click on PDF icon below)

 

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