Renewal
INFORMATION COLLECTION REQUEST
U.S. ENVIRONMENTAL PROTECTION AGENCY
Technology Performance and Product Information to Support Vendor Information Summaries
ICR Number 2154.03, OMB Control Number 2050–0194
March 2008
PART A OF THE SUPPORTING STATEMENT
1. Identification of the Information Collection
1(a) Title of the Information Collection
Technology Performance and Product Information to Support Vendor Information Summaries (Renewal), EPA Number 2154.03 OMB Control Number: 2050-0194
1(b) Short Characterization (Abstract)
The U.S. EPA Office of Research and Development’s National Homeland Security Research Center (NHSRC) is helping to protect human health and the environment from adverse impacts resulting from intentional acts of terror. With an emphasis on decontamination and consequence management, water infrastructure protection, and threat and consequence assessment, NHSRC scientists and engineers are working to develop tools and information that will help detect the intentional introduction of chemical, biological, and radiological contaminants in buildings or water systems, the containment of these contaminants, the decontamination of buildings and/or water systems, and the disposal of material resulting from cleanups.
An important facet of the NHSRC mission is identifying, testing, and evaluating technologies to support water utility operators, emergency responders, and consequence managers. EPA lacks a well documented array of technological tools to adequately address all of the monitoring, detection, decontamination, and treatment tasks associated with remediating contaminated facilities and drinking water supply systems. EPA is aware that significant
research, development, and commercialization efforts are underway by the private sector, but EPA needs to manage the information concerning the myriad of technology choices faced by its customers.
EPA has initiated this effort to develop brief vendor information summaries of available technologies relevant to the detection and decontamination of drinking water systems, building materials, building structures, and indoor air that may become contaminated with chemical, biological, or radiological contaminants. These summaries will be based upon vendor-generated or provided information including any independent, validated test data generated by governmental or other organizations and provided to EPA through this ICR.
EPA will produce 4-10 page summaries on each of the technologies for which vendors voluntarily agreed to submit the requested information. These summaries will be shared with EPA and other emergency response personnel, building and facility managers, and water utility operators. The information provided by technology developers and vendors will also be used by the NHSRC’s Technology Testing and Evaluation Program (TTEP) to identify technologies that may be suitable candidates for testing and evaluation and to track those technologies under development that may eventually be ready for rigorous testing and evaluation.
Developers and vendors with applicable technologies are being searched through all available mechanisms. Once identified, the developer or vendor is sent a letter requesting the submission of specific information pertinent to the performance, operation, maintenance, and cost of the technology (see attachment).
The submission of information is voluntary. Because the summarized information will be publically available, technology vendors/developers will be discouraged from submitting confidential business information, proprietary information, or any sensitive business information.
2. Need For and Use of the Collection
2(a) Need/Authority for the Collection
The Public Health Security and Bioterrorism Preparedness and Response Act (Bioterrorism Act) of 2002 is the legislative mandate for EPA’s work in water security. This law, coupled with executive directives and the Agency’s own strategic plan for homeland security, guides the Agency’s research and technical support activities to protect water infrastructure. The Homeland Security Presidential Directive on Critical Infrastructure Identification, Prioritization, and Protection (HSPD-7) reinforces EPA’s role as the sector-specific lead for water infrastructure. It also assigns the responsibility of coordinating the overall national effort to protect critical infrastructure and key resources of the United States to the Department of Homeland Security. As the sector-specific federal lead for protecting the nation’s drinking water and wastewater infrastructures, EPA plays a critical role in the homeland security arena.
The U.S. EPA Office of Research and Development’s National Homeland Security Research Center (NHSRC) mission includes identifying, testing, evaluating, and reporting on technologies that help decision-makers prepare for, detect, contain, and decontaminate chemical, biological, and radiological attacks directed against buildings, outdoor areas, and water treatment systems. EPA’s Office of Solid Waste and Emergency Response (OSWER) is EPA’s lead office on Federal cleanup actions authorized under the National Contingency Plan. Past attacks and on-going threat scenario analyses of potential terrorist incidents of national significance have illustrated vulnerability in EPA’s emergency response preparedness. Mainly, EPA lacks a well documented array of technological tools to adequately address many of the monitoring, detection, and decontamination tasks associated with remediating contaminated facilities and drinking water supply systems. EPA is aware that significant unstructured research and development is being performed in the private sector, and multiple technological tools that are either directly applicable or can be adapted for the decontamination tasks have been developed
and are being marketed. The information collected through this ICR bundles the needs of the following programs:
ORD, NHSRC: Identify response technology gaps and priority areas for testing and evaluation through the Center’s Technology Testing and Evaluation Program (TTEP).
OW, OGWDW, Water Security Division - Water and Wastewater Security Product Guide: Technical information on market-ready technologies for drinking water system protection.
OSWER - Readily available technology summaries for use by first responders to determine appropriate technologies available for use and to make informed purchase decisions.
2(b) Practical Utility/Users of the Data
The information collected from technology vendors will serve as an important, objective reference for EPA’s on-scene coordinators, the nation’s water utility operators, and those responsible for decontamination after a terrorist attack. Users of technologies are faced with the daunting task of sorting through an often confusing mass of information provided by a vendor. Much of it is presented in the form of sales brochures and anecdotal information. It is difficult and time consuming for the user to extract the important technical nuggets out of product literature. Users are often faced with making quick decisions about which technology or technologies should or should not be used and do not have the luxury of time for wading through vendor-provided information. This information collection and review will result in technology information summaries that will be easily accessible to potential users. The summaries will be used to share the pertinent pieces of performance information so that the user can quickly match a technology to a given task.
The information collected also serves another purpose in supporting the NHSRC’s Technology Testing and Evaluation Program (TTEP). The purpose of TTEP is to test, evaluate, and report on the performance of commercially available homeland security-related technologies. TTEP will use the information collected as the basis for inviting technology vendors to have their technology evaluated.
EPA is producing 4-10 page summaries on each of the technologies for which vendors agree to submit the requested information (as defined in 4(b)). These summaries will be shared with the Environmental Response Team and the Emergency Response Technology Workgroup, advisors and decision makers, respectively, on national technology purchase decisions. Summaries will also be supplied directly to U.S. EPA’s Federal On-Scene Coordinators and technical personnel supporting the Agency’s cleanup efforts through their online information systems. Additionally, information will be provided to other federal agencies that are involved in supporting the government’s counterterrorism efforts. Specifically, raw information and the final reports will be shared with the Department of State/Department of Defense managed Technical Support Working Group (TSWG) and the Department of Homeland Security’s SAFETY Act Program Office.
Water utilities, whether operated privately or by a municipality, are trying to identify technologies that they can use to protect the public they serve. Although the utility operators are not typically faced with decision making under crisis, they are faced with the same confusing mass of information that technology vendors typically provide. Utility operators will use the information collected under this activity to identify technologies for establishing contaminant warning systems, for treating contaminated water, and for decontaminating distribution systems after an attack. EPA’s Water Security Division has already established the Security Product Guide (http://www.epa.gov/safewater/watersecurity/guide/index.html) for use by water utilities. The technology information summaries will be linked to this site so that they are easily available to the users and so that it will not require going to a separate web site to review the summaries.
3. Nonduplication, Consultations, and Other Collection Criteria
3(a) Nonduplication
EPA has performed an exhaustive review encompassing EPA, Department of Homeland Security (DHS), Department of Defense (DoD), Department of Energy (DOE), and other organizations, to identify specific programs, projects, or reports (referred to as programs) collecting information on technologies similar to what is to be sought through this ICR. The purpose was to avoid duplication of efforts and, to the extent possible, reduce the reporting burden by collecting information that is already available, and contacting vendors solely for the unavailable portions. In addition, EPA contacted selected individuals at these agencies to solicit follow-up information. EPA has produced a tool to track the information in these programs (Homeland Security Technology Roadmap), including the types of technologies reviewed, status, and the type of information they contain. More than 40 specific programs were identified and will be tapped for the information they already contain. However, significant information gaps continue to exist as many of the programs collect only basic information (such as company and product names), or information on products beyond the scope of EPA’s needs under this effort (such as emergency communications equipment).
3(b) Public Notice Required Prior to ICR Submission to OMB
On February 12, 2008 EPA sought comments on this renewal ICR (73 FR 8040). EPA received no comments.
3(c) Consultations
The consultations shown below were obtained as part of the 2005 ICR process. No substantive changes to the program or respondent universe over the last three years has occurred; therefore, no further consultations were obtained.
Thomas R. Archibald, President/CEO
HazTech Systems, Inc.
800-543-5487 or 209-966-8088
MicroCat/WMD Kit
Mr. Archibald indicated that he found responding to the request straight-forward and clear. He worked closely with EPA contractor staff to ensure that all the topics were addressed.
Dr. Jonathan Shein
Executive VP, Sales & Marketing
NITON LLC
800-875-1578 x 313
978-670-7460 x 313
Dr. Shein was asked to review a draft of the cover letter and the corresponding attachments that were ultimately sent to vendors. He stated “The document appears quite comprehensive. I personally wouldn't think it a problem to answer these questions, especially since the website would provide me as a vendor with potential exposure to users that would otherwise be difficult to achieve. From NITON's perspective, it would be of value to add a brief part on report generation and data integrity (how easy is it to document the results achieved with the analyzers, and is it possible for users of the equipment to modify the data, either accidentally or intentionally).” His suggestions were added to the final package
Kevin M. Morley
Regulatory Analyst
American Water Works Association
202-628-8303
Mr. Morley works closely with the nation’s water utility operators. He was asked to review the vendor letter and the corresponding attachments. He felt that the information collected under this ICR and shared with the water utilities would be very valuable and useful for protecting water systems and supplies.
Ms. Wendy Howe
Director
Support Anti-terrorism by Fostering Effective Technologies (SAFETY) Act Office
Department of Homeland Security
202-772-9887
Ms. Howe has been briefed about this information collection activity on two occasions. The SAFETY Act program collects very detailed information from technology vendors but is unable to share it outside of DHS. Ms. Howe agreed to encourage vendors to supply their SAFETY Act submittal to EPA to, in part, satisfy our information collection needs. She found the letter and the attachments useful and encouraged EPA to move ahead with the effort.
Mr. Lance Brooks
Chemical Countermeasures Portfolio
DHS, OST. PPB
202-254-5768
Mr. Brooks has been briefed about this information collection activity on numerous occasions. He has been instrumental in sharing the names and contacts of vendors whose technologies may
be good candidates for testing under TTEP and for having their existing information available through this information collection activity.
The following paragraphs describe the specific outreach activities that EPA staff performed during the questionnaire development period. These activities were intended to provide EPA with feedback on issues such as questionnaire format, terminology, and technical quality.
In addition to these personal contacts, the information collection staff also provided briefings for members of EPA’s Emergency Response Technical Workgroup (ERTG), EPA’s Office of Pesticide Programs and Toxic Substances (OPPTS), and EPA’s Office of Water during the development of the information collection materials. NHSRC continues to nurture a working relationship with the On-Scene Coordinators to ensure that the information collected and distributed is adequately addresses their needs.
The information collection activities were also briefed to the Distribution System Research Consortium (DSRC). The consortium meets twice a year to address research and technical support issues around distribution systems. Members include representatives from the Department of Homeland Security, the Centers for Disease Control and Prevention, the Department of Defense, the Department of Energy, and the U. S. Geological Survey, among others.
3(d) Effects of Less Frequent Collection
This information collection activity is not conducted according to a periodic or episodic schedule. A master list of technology vendors is being compiled and vendors will be contacted in
batches of 10 to 15 vendors at a time. Vendors will be invited to review their submittal on an annual basis to determine if the existing information needs to be revised and updated. It is
expected that most of the possible vendors will have been contacted and have their reports prepared by the third quarter of FY09.
3(e) General Guidelines
This information collection activity complies with the eight stipulations identified in the guidance.
3(f) Confidentiality
The cover letter specifically states that proprietary or confidential business information will not be accepted because all the information the Agency collects under this information collection activity will be made available to the public.
3(g) Sensitive Questions
No sensitive questions pertaining to private or personal information, such as sexual behavior or religious beliefs, are being asked in the information request letter.
4. The Respondents and the Information Requested
4(a) Respondents/NAICS
Most of the vendors are categorized as analytical laboratory instrument manufacturing (NAICS code 334516) 1. This includes environmental technology vendors, laboratory analytical
1http://www.census.gov/epcd/www/naicstab.htm
instrument manufacturers (e.g., analytical chemistry and sample collection), sensor manufacturers, signal processing vendors, and test kit manufacturers.
4(b) Information Requested
(i) Data items, including record keeping requirements
This information collection activity does not require the respondent to keep any records.
The data items being collected are identified in the attachment.
(ii) Respondent Activities
The letter will be sent to a contact within the company that was identified through a preliminary search (web, literature, and word of mouth) by EPA. The respondent will need to:
Review the instructions provided in the cover letter
Identify a point of contact
Collect and assemble the information necessary to address the criteria identified in the attachment to the cover letter
Organize the information into a coherent package
Transmit the information to EPA by mail or by email (O&M cost for postage, computer, and photocopying)
Answer follow up questions for clarification (O&M cost for use of telephone)
Review and comment on draft summary (O&M cost for postage, computer, and photocopying)
Answer follow up questions for clarification (O&M cost for use of telephone)
Once the information is received and reviewed by EPA, the respondent’s point of contact may need to be contacted for clarification or for additional information or both.
After EPA condenses the information into a 4 to 10 page summary, a draft copy will be provided to the respondent for review to ensure that there are no significant errors or omissions.
The attachment to the cover letter includes many data items that the respondent should already possess. It is anticipated that the respondent will have all this information available and accessible for compilation and submittal to EPA. The data items identified should have been generated through the respondent’s customary and usual business practices; however, compiling the data to satisfy the Agency’s request is unique and will require the respondent to devote staff time to the effort.
5. The Information Collected - Agency Activities, Collection, Methodology and Information Management
5(a) Agency Activities
The Agency activities associated with the preparation of technology information summaries will consist of the following:
Prepare letter and send to respondent;
Perform an initial review of the submittal for completeness;
If the package is incomplete, contact the respondent for clarification;
Perform a detailed review of the information and compile a 4 to 10 page summary;
Review the summary;
Provide a draft of the summary to the respondent for comment;
Reconcile respondent comments; and
Produce final summary.
5(b) Collection Methodology and Information Management
In collecting and analyzing the information associated with this ICR, EPA will use personal computers and applicable database and word processing software to manage the information. EPA will ensure the accuracy and completeness of collected information by reviewing each submittal. EPA will also provide a draft copy of the summary to the respondent for review and comment. A complete vendor information submission package will be kept on file by the Office of Research and Development. The information will not be entered into a database and stored electronically. Technology information summaries will be available online through the Water Security Division’s Security Product Guide and separately through the Response Technology Ready Reference web site.
5(c) Small Entity Flexibility
This information collection activity is voluntary, not compulsory. EPA has attempted to streamline the information collection to minimize the amount of time the respondent will need to devote to compiling the items identified in the attachment to the cover letter. The Agency’s intent is to minimize the information collection burden to all businesses regardless of size. If a respondent believes that it is too time consuming, they are under no obligation to provide any
information. The respondent will still be identified on the above mentioned web sites, but the user of the web site will be referred to the vendor for specific information.
5(d) Collection Schedule
This information collection activity is not conducted according to a periodic or episodic schedule. A master list of technology vendors is being compiled and vendors will be contacted in batches of 10 to 15 vendors at a time. The respondent will be mailed a letter requesting that specific information be sent to EPA within 30 days of receipt. Vendors will be invited to review
their submittal on an annual basis to determine if the existing information needs to be revised and updated. It is expected that most of the vendors will have been contacted and have their reports prepared by the third quarter of FY09.
6. Estimating the Burden and Cost of the Collection
This information collection will necessitate the involvement of four general labor categories for each respondent:
Legal staff
Management
Technical staff
Clerical staff
There are no third-party reporting requirements associated with this information collection activity.
6(a) Estimating Respondent Burden
For the purpose of estimating respondent burden, these are the tasks anticipated for each labor category:
Legal staff – perform initial review of the letter; a review of the respondents information submittal package; review the draft summary and technical staff comments
Management – perform initial review of the letter; a review of the respondents information submittal package; review the draft summary and technical staff comments
Technical staff – perform initial review of the letter; collect and organize information into a coherent package; spend time on the phone clarifying response
(after response submittal and after review of summary); if necessary, provide additional supporting documentation (after response submittal and after review of summary) and review draft summary
Clerical staff – provides clerical support such as typing comments for technical staff, sending emails, and packaging and shipping information.
The estimated hours associated with these tasks is included in Table 6-1. No comments were received from the public during the comment period. Therefore, the hours were estimated after discussions with the individuals previously mentioned (Section 3(c)) as well as discussions with the EPA and contractor technical staff working on this information collection.
6(a) Estimating Respondent Costs
(i) Estimating Labor Costs
The labor rates and categories available in the Labor Department’s Employer costs for Employee Compensation are not directly applicable to this information collection. The labor cost estimates used for this information collection are based on previous discussions with the individuals previously mentioned and the EPA and contractor technical staff working on this
information collection. The hourly rates used in Table 6-1 are comparable to approximately half those of the average GSA Schedule Professional Engineering Services contractor labor categories.
(ii) Estimating Capital and Operations and Maintenance Costs
Respondents will not incur capital costs in responding to this information collection. The O&M costs to respondents are very small and include photocopying, postage, telephone system usage (principally long distance telephone call charges and a portion of the costs of maintaining
a phone system), and the use of existing computers for typing letters, and collecting and managing the information provided to the Agency in response to this information collection. The O&M costs are identified in Table 6-1. They were derived in the same manner as the labor categories and costs.
(iii) Capital/Start-up vs. Operating and Maintenance (O&M) Costs
See Section 6(a)(ii).
(iv) Annualizing Capital Costs
Not applicable to this information collection action.
Table 6-1
Estimated Annual Respondent Burden and Cost |
||||||||||||
Information Collection Activity Tasks |
Hours and Costs per Respondent |
Total Hours and Costs |
||||||||||
Legal $125/hr |
Mgr $105/hr |
Tech. $70/hr |
Clerical $35/hr |
Respond hr/yr |
Labor $/year |
Capital/Startup Cost |
O&M Cost |
Number of Respond. |
Total hrs/yr |
Total Labor $/yr |
Total O&M $/yr |
|
Review the instructions provided in cover letter |
0.5 |
0.5 |
0.5 |
|
1.5 |
$150.00 |
$0.00 |
$0.00 |
70 |
105 |
$10,500 |
0 |
Collect information |
|
|
3 |
|
3 |
$210.00 |
$0.00 |
$0.00 |
210 |
$14,700 |
0 |
|
Assemble and organize information |
|
|
2 |
1 |
3 |
$175.00 |
$0.00 |
$0.00 |
210 |
$12,250 |
0 |
|
Review package for completeness |
0.5 |
0.5 |
0.5 |
|
1.5 |
$150.00 |
$0.00 |
$0.00 |
105 |
$10,500 |
0 |
|
Transmit information to Agency |
|
|
|
0.5 |
0.5 |
$17.50 |
$0.00 |
$2.00b |
35 |
$1,225 |
140 |
|
Answer follow up questions for clarification |
|
|
1 |
|
1 |
$70.00 |
$0.00 |
$1.00c |
70 |
$4,900 |
70 |
|
Review and comment on draft summary |
1 |
1 |
1 |
|
3 |
$300.00 |
$0.00 |
$1.00a |
210 |
$21,000 |
70 |
|
Transmit comments to Agency |
|
|
|
0.5 |
0.5 |
$17.50 |
$0.00 |
$1.00a |
35 |
$1,225 |
70 |
|
Answer follow up questions for clarification |
|
|
1 |
|
1 |
$70.00 |
$0.00 |
$1.00b |
70 |
$4,900 |
70 |
|
Subtotal |
2 |
2 |
9 |
2 |
15 |
$1160.00 |
$0.00 |
$6.00 |
Annualized Totals |
1050 |
$81,200 |
$420 |
b Postage, computer, photocopying c Telephone system use
6(c) Estimating Agency Burden and Cost
This information collection will necessitate the involvement of the following general labor categories:
EPA
Management
Technical staff
Contractor
Management
Technical staff
Clerical
Table 6-2 contains a detailed estimate of the Agency and contractor labor hours and costs associated with this information collection activity. The estimates are based on the information requests that were sent to technology vendors (respondents) during the 180-day emergency ICR period. There are no start-up or capital costs. Operations and maintenance costs for the contractor staff are included in the fully-loaded hourly costs identified in the table.
Table 6-2
Estimated Annual Agency Burden and Cost |
||||||||||||
Information Collection Activity Tasks
|
Agency Hours and Costs |
Contractor Hours and Costs |
Total Hours and Costs |
|||||||||
Mgr $70/hr |
Tech. $60/hr |
Agency hr/yr |
Agency $/yr |
Mgr $175/hr |
Tech. $120/hr |
Clerical $45/hr |
Contractor hr/yr |
Contractor $/yr |
Number of Respond. |
Total hrs/yr |
Total $/yr |
|
Prepare letter and send to respondent |
0.25 |
0.50 |
0.75 |
$47.50 |
0.25 |
0.50 |
0.25 |
1.00 |
$115.00 |
70 |
122.5 |
$11,375.00 |
Perform initial review of submittal for completeness |
|
|
0.00 |
$0.00 |
|
3.00 |
|
3.00 |
$360.00 |
210 |
$25,200.00 |
|
Contact respondent for clarification |
|
|
0.00 |
$0.00 |
|
1.00 |
|
1.00 |
$120.00 |
70 |
$8,400.00 |
|
Review and evaluate information |
|
|
0.00 |
$0.00 |
|
5.00 |
|
5.00 |
$600.00 |
350 |
$42,000.00 |
|
Prepare draft 4 to 10 page summary |
|
|
0.00 |
$0.00 |
|
15.00 |
3.00 |
18.00 |
$1,935.00 |
1260 |
$135,450.00 |
|
Internal review of draft summary |
|
2.00 |
2.00 |
$120.00 |
2.00 |
|
|
2.00 |
$350.00 |
280 |
$32,900.00 |
|
Send draft to respondent for review and comment |
|
|
0.00 |
$0.00 |
|
|
0.25 |
0.25 |
$11.25 |
17.5 |
$787.50 |
|
Review respondent comments |
|
1.00 |
1.00 |
$60.00 |
1.00 |
1.00 |
|
2.00 |
$295.00 |
210 |
$24,850.00 |
|
Contact respondent for clarification |
|
|
0.00 |
$0.00 |
|
1.00 |
|
1.00 |
$120.00 |
70 |
$8,400.00 |
|
Reconcile comments and produce final summary |
|
1.00 |
1.00 |
$60.00 |
|
3.00 |
1.00 |
4.00 |
$405.00 |
350 |
$32,550.00 |
|
Review and release final summary |
1.00 |
2.00 |
3.00 |
$190.00 |
1.00 |
2.00 |
|
3.00 |
$415.00 |
420 |
$42,350.00 |
|
Bi-weekly teleconferences to discuss status |
|
0.10 |
0.10 |
$6.00 |
0.10 |
1.00 |
|
1.10 |
$137.50 |
84 |
$10,045.00 |
|
Subtotal |
1.25 |
6.60 |
7.85 |
$483.50 |
4.35 |
32.50 |
4.50 |
41.35 |
$4,863.75 |
Annualized Totals |
3444 |
$340,462.50 |
6(d) Estimating the Respondent Universe and Total Burden and Costs
Tables 6-1 and 6-2 include these totals.
6(e) Bottom Line Burden hours and Cost Tables
Tables 6-1 and 6-2 include these totals.
6(f) Reasons for Change in Burden
No substantive changes to the program over the last three years have occurred; therefore, there is no change in burden.
6(g) Burden Statement
The annual public reporting and recordkeeping burden for this collection of information is estimated to average 15 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 No. EPA-HQ-ORD-2008-0067, which is available for public viewing at the Office of Research and Development (ORD) 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 Research and Development Docket is (202) 566-1752. An electronic version of the public docket is available through http://www.regulations.gov. Use www.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 Office for EPA. Please include the EPA Docket ID No. (EPA-HQ-ORD-2008-0067) and OMB control number (2050-0194) in any correspondence.
ATTACHMENT 1
Information Request Cover Letter with Attachment
Dear :
The purpose of this letter is to invite your company to participate in a technology information collection activity being coordinated by the U.S. Environmental Protection Agency’s (EPA) National Homeland Security Research Center (NHSRC). This information collection activity is part of a project called the Response Technology Ready Reference (RTRR). The purpose of RTRR is to gather existing technology performance information, summarize it, and have it available to technology users.
The Agency is actively participating in the ongoing national efforts to ensure the safety and security of select portions of the nation’s critical infrastructure – specifically focusing on water treatment infrastructure and the decontamination of buildings, structures, and outdoor areas. A critical facet of the Center’s overall homeland security mission is identifying, testing, and evaluating technologies.
The RTRR contains brief summaries of technologies that are offered for use to emergency responders, consequence managers, and water utility operators in responding to a chemical, biological, or radiological attack or for use in response to an unintentional release of contaminants. This information also serves as a ready reference of technologies that may be appropriate for testing and evaluation under the Agency’s Technology Testing and Evaluation Program (TTEP). The brief summaries capture key information about commercially available technologies that are relevant to the detection and decontamination of water treatment infrastructure, building materials, building structures, outdoor areas, and indoor air that may become contaminated with chemical, biological, and radiological warfare agents. These summaries are based upon vendor-provided data and information including, when available, validated test data generated by governmental or other organizations.
This invitation requests your company to supply detailed technical information to help us more fully understand the capabilities of the TECHNOLOGY NAME and to summarize the information for the technology users mentioned previously. Attachment 1 identifies the types of information and data we would like to include in each summary. We would appreciate your providing this information to us and identifying a technical point of contact that EPA can communicate with concerning questions or clarifications about the submittal. This is a voluntary program and the government will not be responsible for costs your company may incur in responding to this request.
For this submission, please do not submit any proprietary information, confidential business information, or other information that you do not wish to be made public. The technology information summary report to be prepared under this effort, along with selected supporting documentation, will be available on a web site for dissemination to the public through such means as a web site or direct mailings.
We plan to complete an information summary for your technology within four weeks of receipt of your complete response to the items identified in Attachment 1. Please provide information on your technology by DATE. A member of the review team will be assigned to your technology to work with you in compiling your information, and will contact you in the interim should information gaps be identified. We will provide you with the opportunity to review the summary report before it is finalized.
Please email the name, address, telephone and fax number, and email address of your technical point of contact and any questions you might have. Please e-mail materials to Batelle (point of contact to be determined) or send them to the following address:
Battelle
505 King Avenue
Columbus, Ohio 43201-2693
If you have questions about this request, please contact Shannon Serre, EPA, NHSRC at 919-541-3817 or [email protected].
Sincerely,
/s/
Jonathan Herrmann
Director
National Homeland Security Research Center
Paperwork Reduction Act Burden Statement: The public reporting and recordkeeping burden for this collection of information is estimated to average 15 hours per response. Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies Division, U.S. Environmental Protection Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number 2050-0194 in any correspondence. Do not send the information requested above to this address.
ATTACHMENT 2
Detection Technologies for Biological and Chemical Threats
Criteria for Technology Assessment
Background Information: The following criteria are intended for use in assessment of products/technologies used for detection of biological agents and toxins in indoor air. These criteria also will have applicability to products/technologies used for detection of chemical warfare agents and industrial chemicals.
Category 1 - Product and Vendor Information
1. Product Name and Classification
2. Company Information
3. Company Representative
4. Individual Submitting Application
5. Commercial Availability – Discusses whether the product is currently commercially available.
Category 2 - Product Description
1. Product Description – Detailed description of the product; including operation, functions, intended use, size, dimensions, and weight.
2. Method of Detection – Description of the principles of operation.
3. Intended User(s) – Types of individuals who will use the product (for example, first responders, HazMat, military personnel, plant engineers, skilled laborers, etc.).
4. Utility Requirements – Description of the electric, water, telephone, internet, and other utility requirements for the product.
5. Durability – Ability to withstand wear and tear, based on engineering design and materials of construction (also considering conditions or factors that could reduce the operating lifetime.)
6. Application(s) – Specify the area in which the product is designed to operate (for example, ducts, rooms, plenum, air returns, piping, or in process).
7. Accessories – Description of accessories required for proper use of the “base model” as well as optional accessories.
8. Decontamination – Description of the method for decontaminating the product following use.
9. Portability – Ability to transport the product. Takes into account whether the product requires installation to operate and special licensing or other requirements for transport or shipping. Includes information about whether unit can be carried by hand or needs a vehicle for operation.
Category 3 - Performance Characteristics
1. Detected Compounds and/or Agents – List of chemical and/or biological agents the unit is capable of detecting.
2. Units of Measurement – Identify if the unit produces a qualitative or quantitative result (or either, depending on configuration). For quantitative results, identify the unit of measurement as ppb, mg/m3, CFU, Fg/L, or other unit. For qualitative results, describe the indicator (e.g., color change, plus/minus sign, noise) and the threshold value. Identify if there is an audible or visible alarm.
3. Throughput or Measurement Rate – Identify the amount of time required to set up, conduct analysis, and produce results (also noting factors that affect the throughput or measurement rate).
4. Standard Operating Procedure, Method, or User’s Manual – Is a procedure for the operation of the unit documented and available?
Method Start-up – What steps, if any, are required to validate the method for a specific application? What steps should be used to verify the proficiency of an operator?
Quality Control Procedures – Identify recommended QC checks and frequency for normal operation
Instrument Calibration – Describe the process that is required to calibrate the instrument in the field (if necessary).
5. Performance Parameters – For the performance parameters below, provide performance data using the method along with a brief description of how the performance data were generated.
Accuracy
Precision
Bias
False positive/false negative rate
Upper and Lower Detection Limits
Linear Dynamic Range
Method/Instrument Sensitivity
Method Optimization and Ruggedness Testing
6. Detector Saturation – Concentrations of agents or compounds that may produce saturation or instrument flooding, and lead to false negative readings.
7. Operational Considerations – Information regarding operational considerations that may affect product performance, including ranges of temperature, humidity, dust, wind movement, and/or rain. Also includes information about operation in explosive atmospheres, near high voltage wires, or other conditions.
8. Potential Interferences – Potential cross sensitivities, spectral interferences, or other potential interference that could affect product performance; also noting ways to modify the method to remove or compensate for common interferences.
Category 4 – Cost Information
1. Product Cost – The cost of the basic model and all required accessories.
2. Accessories Cost – Cost of required accessories and optional accessories.
3. Consumable Material Cost – Cost of consumable materials (for example, solutions, sampling media) required for proper operation. Identify those consumables that are proprietary and include information about their availability.
4. Special Testing Cost – Cost of scheduled special testing (for example, wipe testing).
5. Calibration Cost – Cost of regularly scheduled manufacturer calibration.
6. Training Cost – Cost of vendor-required or recommended training for users/operators of the product.
7. Warranty Information –Information about the warranty for the product and accessories.
8. Technical Service –Types of customer and technical service provided to customers in the event that the instrument requires a repair.
Category 5 - Other Information
1. Personnel Requirements – Number and experience level of personnel required to operate the unit.
2. Training Requirements – Requirements or recommendations for training personnel to be able to operate the product.
3. Data Management - Method of storing and managing data. Includes whether the product is programmable, manual, or automatic; how many sets of data can be stored; whether or not there are any software requirements; and ability to log data remotely.
4. Storage and Handling – Description of how the unit should be stored.
5. Waste Generation – Description of waste streams generated from the method their disposition.
6. Routine Maintenance Requirements – Routine requirements for maintenance.
7. Independent Validation/Verification – Indication of availability of independent evaluations or reviews (for example, industry review, peer-review, scientific journals, military reviews, or independent laboratory evaluations). Includes information about testing with live agent (if applicable).
8. Recommended Corroborative or Supporting Data – The vendor should suggest other analytical techniques that can be used to confirm or corroborate the results of the method, and any supporting data (e.g., meteorological) that are required for interpretation of the results.
Category 6 - Health and Safety Information
1. Personnel Hazard – Potential health hazard (acute or chronic), if any, to personnel operating the device (e.g. electrical hazards, explosion, radiation, exposure or chemicals). May also include information about the proper personal protection equipment required during use to ensure worker health and safety.
2. Environmental Hazard – Degree of environmental hazard or impact associated with direct contact to the product or its by-products.
3. Public Health Hazard – Potential health hazard (acute or chronic) to the public (building visitors, occupants, and/or community) resulting from the operation of the device.
March 2005
File Type | application/msword |
Author | sserre |
Last Modified By | Spencer W. Clark |
File Modified | 2008-04-28 |
File Created | 2008-04-17 |