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 doc ket? 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 su fficient or do you need additional information?



## --- Scott Evans Clean Air Engineering 500 W. Wood St. Palatine, Illinois 60067 sevans@cleanair.com 847
-654
-4569On 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 Inform ation 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 ad ditional 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 qua lity 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 al l 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 $2 0/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. Regard ing 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 pr ocess 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. H owever, 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 bu siness.

(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 shou ld 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 ex am 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 Engin eering 500 W. Wood St. Palatine, Illinois 60067 sevans@cleanair.com 847
- 654
- 4569