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

From: "Guenther, Franklin R." <franklin.guenther@nist.gov>

Date: 08/16/2010 04:15PM

Cc: "Gameson, Lyn" <lyn.gameson@nist.gov>

Subject: RE: NIST Cost Forecast for PGVP Cylinder Analyses

John,

NIST began the audit of commercial EPA Protocol Gas standards through funding out of several different 

offices within EPA. The cost that we estimated to setup and deliver the data quality requested was 

approximately $2,000 per cylinder for a tri-blend mixture. NIST saw additional value in this program 

during these years as it allow NIST to assess how effective the traceability chain was performing from 

Primary standard, through SRMs and NTRMs, down to EPA Protocol Gases. Therefore NIST was willing 

to subsidize the effort to some extent. That is no longer the case as we feel we have demonstrated that 

the traceability chain is effective, as long as proper procedures (EPA protocol gas document as an 

example) are strictly followed by the specialty gas company delivering the product.

As NIST is a government agency, and due to the fact that we are not funded to do this particular activity, 

we must recover any costs expended in accomplishing the audit of EPA Protocol Gas Standards going 

forward. That being said, NIST is now in a much better position to audit these gas standards as we have 

developed many of the procedures and methods to accomplish the task. However, with every new audit, 

comes different concentrations and challenges which must be dealt with, costing extra time and effort.

NIST is also being tasked with several new programs that will require ever increasing research time for 

the Gas Metrology Group. These programs include Climate Change and the Hydrogen Economy. So for 

NIST to go ahead with the EPA Audits, the scheduling of the activity during the year must be strictly set 

out and followed by all the companies involved in the audit. It is only with the economy of batching similar 

gas standards, and receiving them all within a specific time frame, will NIST be able to control costs. 

NIST, along with EPA, must set a strict time schedule, those cylinders with the appropriate funding 

documents, that arrive within that time frame will be part of the audit. Those that do not will be excluded.

That is the only way NIST will be able to control costs.

For the estimation of per cylinder costs for the audit of tri-blend gas mixtures, NIST is using the 

experiences of the 2010 audit. We are assuming that only NO, SO2 and CO2 will be analyzed, and that 

only these compounds are within the gas mixture along with balance gas nitrogen. Additional compounds 

within the gas mixture, even if they are not to be analyzed, complicate the analysis of the primary

components. We are also assuming that the concentrations will all fall within a relatively narrow band that 

can be defined by EPA in the low, mid and high ranges. This is how the 2010 audit was designed, and 

our costs for this audit fell within the $2000 per cylinder estimate. The 2010 audit consumed 715 hours of 

time to analyze and report on 57 cylinders. We believe we can design a better sampling system and 

reduce that time to 550 hours for the same 57 cylinders. This amount of resources equals $1,500 per 

cylinder, and is our estimate for this activity in 2011. NIST will commit to this cost estimate for three 

years, until 2013, when we will re-evaluate the cost and effectiveness of the program.
Franklin R. Guenther

Group Leader, Gas Metrology Group

National Institute of Standards and Technology

Gaithersburg, MD 20899-8393

From: Schakenbach.John@epamail.epa.gov [mailto:Schakenbach.John@epamail.epa.gov] 

Sent: Monday, August 16, 2010 2:28 PM

To: Guenther, Franklin R.

Subject: Fw: NIST Cost Forecast for PGVP Cylinder Analyses

Frank,

At the risk of being a pest, any information you can provide on NIST PGVP costs (see below) 

would be very helpful.

Thanks

John Schakenbach

U.S. Environmental Protection Agency

Clean Air Markets Division

schakenbach.john@epa.gov

Phone: 202-343-9158

Fax: 202-343-2359

-----Forwarded by John Schakenbach/DC/USEPA/US on 08/16/2010 02:16PM -----
To: "Guenther, Franklin R." <franklin.guenther@nist.gov>

From: John Schakenbach/DC/USEPA/US

Date: 08/05/2010 10:17AM

Subject: NIST Cost Forecast for PGVP Cylinder Analyses

Frank,

I am writing a response to comments document for EPA's recent proposed rule related to 

the Protocol Gas Verification Program. We have received several comments related to 

cost. There is a concern that the amount charged by NIST to perform EPA Protocol gas 

cylinder analyses may spiral upward over time. As you know, every year each EPA Protocol 

gas production site (there are about 30 such sites) will contract with NIST to analyze up to 

4 cylinders, for a total of 120 cylinders to be analyzed with an analysis report produced by 

NIST each year.

I realize that NIST is a government agency that, by statute, can receive funds from the 

private sector for services performed. Is there some assurance that you can provide me 

that the costs charged by NIST for the above analyses will continue to be reasonable.

Ideally, it would be very helpful if you could provide an estimate of the total annual cost 

(assume all tri-blend cylinders) and expected cost increase, if any, per year for the next five 

years. This type of cost forecast will allow specialty gas companies to have more certainty 

in their budget process.

Best Regards,

John Schakenbach

U.S. Environmental Protection Agency

Clean Air Markets Division

schakenbach.john@epa.gov

Phone: 202-343-9158

Fax: 202-343-2359