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 com mercial 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 Prim ary 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, com es 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 Econom y. So for NIST to go ahead with the EPA Audits, the schedulin g 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 econom y of batching similar gas standards, and receiving them all within a specific time frame, will NIST be able to co ntrol 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 b e 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. Weare assuming that only NO, SO 2 and CO 2 will be analyzed, and that only these compounds are with in 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 com ponents. Weare 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 tim e to analyze and report on 57 cylinders. W e 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 ye ars, 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 informatio n 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: 20 2 - 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 PG VP 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 N IST 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 c osts charged by NIST for the above analyses will continue to be reasonable. Id eally, 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 n ext 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