To: John Schakenbach/DC/USEPA/US@EPA

From: Scott Evans <sevans@cleanair.com>

Date: 08/23/2010 10:48AM

Subject: Re: Request for Cost Information

Yep.

---

Scott Evans

Clean Air Engineering

500 W. Wood St.

Palatine, Illinois 60067

sevans@cleanair.com

847-654-4569

On Aug 23, 2010, at 9:47 AM, Schakenbach.John@epamail.epa.gov wrote:

Scott,

This is terrific. I assume all of this can be put in the public docket?

John Schakenbach

U.S. Environmental Protection Agency

Clean Air Markets Division

schakenbach.john@epa.gov

Phone: 202-343-9158

Fax: 202-343-2359

-----Scott Evans <sevans@cleanair.com> wrote: -----

To: John Schakenbach/DC/USEPA/US@EPA

From: Scott Evans <sevans@cleanair.com>

Date: 08/23/2010 10:24AM

Subject: Re: Request for Cost Information

Correct. Is this sufficient or do you need additional information?

---

Scott Evans

Clean Air Engineering

500 W. Wood St.

Palatine, Illinois 60067

sevans@cleanair.com

847-654-4569
On Aug 23, 2010, at 8:13 AM, Schakenbach.John@epamail.epa.gov wrote:

Scott,

Thanks much. This is very helpful. I assume that all the cost info you wanted to send me 

was actually in the body of the email and not attached. Correct?

John Schakenbach

U.S. Environmental Protection Agency

Clean Air Markets Division

schakenbach.john@epa.gov

Phone: 202-343-9158

Fax: 202-343-2359

-----Scott Evans <sevans@cleanair.com> wrote: -----

To: John Schakenbach/DC/USEPA/US@EPA

From: Scott Evans <sevans@cleanair.com>

Date: 08/23/2010 04:12AM

Subject: Re: Request for Cost Information

John,

Attached is some cost info I put together in response to the Part 75 

amendment proposal

(1) the cost of staff time to develop and implement the quality manual 

required by the ASTM practice, including document control procedures, hiring 

of additional personnel, performance of annual audits, and documentation of 

corrective action;

The cost of preparing a quality manual depends very much on where an AETB 

starts and the approach used. If we consider the worsts case scenario -- an 

AETB has no quality program, no quality manual and decides to write one 

themselves from scratch. In this instance, the cost could be quite high, say 

6 months of someone full time. At say, $20.00 per hour that would be $20,800. 

However, since the ASTM standard is based on ISO 17025, there is a much 

easier approach. An AETB starting from scratch can purchase one of the many 

ISO 17025 template QA/QC plans available on the market. These range in price 

from about $200 - $1000 depending on the vendor. These templates include all 

of the required procedures including document control procedures. Once this 

template is purchased, an AETB can customize it relatively quickly. I would 

estimate no more than four weeks of someone full time. At the same $20.00 per 

hour rate, this would be $3200. Add in the cost of the most expensive 

template, and you are looking at doing the entire thing for less than $5000. 

Of course this is worst case for an AETB starting from scratch. For AETBs 

that already have an established quality program, the cost would be less. 

Regarding hiring additional personnel, to the best of my knowledge, none of 

the AETB's with interim accreditation have had to hire additional personnel 

in order to comply with the Practice. Clean Air has certainly hired no extra 

personnel to comply with the Practice.
The cost of the annual internal audits depends on the size of the company. 

Small companies with only one office can easily do the internal audit in a 

day with no travel. This would require the time of two people, say one at 

$20/hour and one at $30/hour. This would cost about $400 per year. For larger 

companies, the cost would be greater. We at Clean Air have three offices and 

our annual internal audits cost about $15,000. This includes three people 

with travel expenses.

Regarding corrective action documentation, once an AETB has a system in 

place, the documentation of corrective actions is trivial. In our system, for 

example, an individual logs in, enters a few lines to describe the corrective 

action, and logs out. The whole process takes about 10 minutes.

Overall, once the quality system is in place, the annual operating costs for 

the quality system most likely range from $5,000 per year for a small AETB to 

about $50,000 per year for the very largest firms such as Clean Air. However, 

we should keep in mind that many (if not most) firms already had a quality 

program long before this Part 75 amendment. So the costs of this quality 

system are not attributable to this rule. We would be doing it anyway. Its 

simply a cost of doing business.

(2) application fees and the cost of preparing applications for accreditation 

and/or QI qualification;

The cost of preparing applications is trivial. Since accreditation is not 

required in this rule, the costs of accreditation should not be a factor. 

However, the time to prepare the application for accreditation to STAC is 

less than one person for half a day (assuming the quality system is already 

in place). For QI qualification, the time to complete the application is 

maybe 10 minutes. It should be kept in mind that one does not have to be a 

QSTI to be a qualified individual.

(3) the cost of QI exams, including tuition for preparatory courses, exam 

fees, and travel expenses;

The cost of the QI exams for SES members is $140 for the first exam in one 

exam session and $84 for additional exams. For non-SES members, the cost is 

$155 for the first exam (includes $15 SES membership). Each additional exam 

is $84. There is no need for preparatory courses. Most people who take and 

pass the exams have not attended preparatory courses. Also, travel expenses 

are not necessary. It is possible to get a local proctor to administer the 

exams. Depending on who you find as a proctor, you may have to pay them a 

modest fee ($50-$100) to administer the tests.

(4) any new costs associated with preparation of test plans and reports to 

comply with the specific criteria in the practice; and

I don't believe there are any new costs associated with test plans and 

reports. We certainly have not encountered any.
(5) cost of required records storage and backup. 

Likewise with records and backup. There are no additional costs associated 

with record storage and backup.

John, I hope this information is useful.

Best Regards,

Scott

---

Scott Evans

Clean Air Engineering

500 W. Wood St.

Palatine, Illinois 60067

sevans@cleanair.com

847-654-4569