Record of Communication

Subject : L ogistics for Cy linder Anal ys is On December 7, 2009, Lyn Gameson of the National Institute of Standards and Technology (NI ST) responded to an inquiry from John Schakenbach of the Environmental Protection Agency (EPA) reg arding Protocol Gas Verification Program (PGVP) logistics that would allow accurate, low cost, and fast cy linder anal ys is. EPA Assumptions : a.) We believe there are approximately 14 specialty

gas companies that market EPA Protocol gases; some of these c ompanies have multiple production sites. We estimate there are about 30 EPA Protocol gas production sites in the U.S. b.) Each of these production sites would enter into an agreement with NI ST each y ear to anal yz e cy linders and produce and send to EPA r eports and to determine whether the certification label accompan yi ng each cy linder meets the requirements of the Traceability Protocol for up to 4 cy linders from each production site, for a total of 120 cy linders. c.) Therefore, in less than one y ear, ea ch year, NIST would need to anal yz e and produce and send to EPA reports for up to 120 cy linders, and determine whether the certification label accompan yi ng each cy linder meets the requirements of the Traceability Protocol. d.) EPA (through our contractor ) would send NIST 6 batches of 20 cylinders each. Each batch would have cy linders of similar composition and concentration. EPA Questions :

- Is 20 cy linders per batch optimum for y ou?

- How long should we wait between batch shipments?

- Assuming th e appropriate interval between batches, how long would it take NIST to complete all of the tasks in b.) above for all 120 cy linders?

- Can cy linder batches arrive at NIST and can analy sis start at any time during the ye ar? NI ST Assumptions : a) All audi t cy linders will be purchased by the contractor and stored b y them. b) We will be sent a list of the cy linders purchased, including copies of the vendor Certificates of Anal ys is. c) We will inform the contractor what cylinders to ship and when

- most proba bly in batches of 20 cylinders of the same range. d) The audit gas mixtures will be in three ranges, currently :2 High: CO2 at 20%; NO at 900 ppm; SO2 at 1000 ppm Mid: CO2 at 12%; NO at 400 ppm; SO2 at 500 ppm Low: CO2 at 5%; NO at 50 ppm; SO2 at 50 pp m e) We understand that the gas mixture compositions may change in the future. If the following hold true for future changes, then there will be little or no impact on our schedule:

e1) No more than three gas mixture ranges e2) The concentration for each component falls under the following ranges: CO: 2
- 20% NO: 50
- 1000 ppm SO2: 50
- 1000 ppm If future changes fall outside these assumptions, then we need to be informed as soon as possible so that we can discuss the impa ct on our schedu le (and costs). f) No impurity

(including NOx) analy sis is required. NI ST Answers : If the above assumptions hold, then the answers are: Question: Is 20 cylinders per batch optimum for y ou? Answer : Yes. Question: How long should we wait between bat ch shipments? Answer : As per our instructions / schedule. Ty pically , two weeks. Question: Assuming the appropriate interval between batches, how long would it take NI ST to complete all of the tasks in b.) above for all 120 cy linders? Answer : Six months (including report write up)

- maximum. Question: Can cy linder batches arrive at NI ST and can analy sis start at any time during the ye ar? Answer : As per our instructions / schedule. We are planning to be in position to take delivery of the first batc h in earl y February.