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

From: laptop@ipass.net Date: 08/10/2010 06:00AM Cc: answers@ipass.net Subject: Re: Request for Cost Information
John/Gail, These numbers look about right to me. The rates are billing rates. Most people will only count internal rates i.e. no profitand minimal overhead. So that would reduce the costs to the company by about 40%. Puerto rico is cooler than Raleigh high of 82 today. So keep cool. Mike
Quoting Schakenbach.John@epamail.epa.gov:
> Roger that. Thanks > > John Schakenbach > U.S. Environmental Protection Agency > Clean Air Markets Division > schakenbach.john@epa.gov > Phone: 202

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- 9158 > Fax: 202

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----- "Gail Westlin" <answers@ipass.net> wrote:

----- > > To: John Schakenbach/DC/USEPA/US@EPA > From: "Gail Westlin" <answers@ipass.net> > Date: 08/09/2010 11:25AM > cc: "Michael Hartman" <laptop@ipass.net>, Peter Westlin/RTP/USEPA/US@EPA > Subject: Re: Request for Cost Information > > John: Mike is going to be out of the office until the middle of September. > I'll take a stab at part of this. Mike can probably do a better job than I > can, but we'll see what I can provide. I'll put my responses in > red. Gail

----- Original Message

----- From: Schakenbach.John@epamail.epa.gov > To: Gail Westl in Sent: Monday, August 09, 2010 09:11Subject: Re: Request for > Cost Information > Mike and Gail, Thank for taking the time to do this. The time estimates you > provided for various activities to implement ASTM D 7036 are helpful. > However, it would re ally help if you could provide approximate actual costs > for your company to do the activities identified in each paragraph of > your response below. Thanks again for your efforts on this. > John Schakenbach > U.S. Environmental Protection Agency > Clean Air Markets Division > schakenbach.john@epa.gov > Phone: 202

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- 9158 > Fax: 202

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----- "Gail Westlin" <answers@ipass.net> wrote:

-----

> > To: John Schakenbach/DC/USEPA/US@EPA > From: "Gail Westlin" <answers@ipass.net> > Date: 08/09/2010 08:3 4AM > cc: Peter Westlin/RTP/USEPA/US@EPA > Subject: Re: Request for Cost Information > > John: You have asked me for a cost estimate to implement the ASTM D

- 7036

- 04 > Quality Standard. I will give it my best try and answer your points as you > have stated them. (1) The cost to develop and to implement the quality > manual. This, like most things in the standard, depends on the size of the > business and the degree to which the company would like the comply. The > standard gives an outline of a quality manual in the appendix. Several small > businesses in SES collaborated to prepare a QA Manual for use by the > participating businesses. Each section of the QA manual took from 4

- 8 hours > to write and review. Walt Smith (who reviews the manuals for STACs) states > that a person needs to answers ~300 questions to develop a good QA manual. In > both cases, 1

- 2 weeks of work would be needed by a knowledgeable person

- > almost everything in a quality manual is already require by the methods as > are the audits. The main element of ASTM D

- 7036

- 04 that is not necessarily > in the method is the documentation of the requirements. Most of what a > quality manual requires should be done now and there should be no additional > hiring needed. If it takes 8 hours to write the manual, I'll use Mike's rate > of $103 per hour ($824) and my rate of $61 per hour ($488) to come up with > a $1,312 total. As for the part where Walt Smith states that a person needs > to answer ~ 300 questions and Mike speculates that 1

- 2 weeks of work would be > needed, if you say 2 weeks (80 hours) at $103 per hour, then that would be > $8,240.00 just for Mike's time. (2) and (3) Application Fees. I am not > sure for accreditation as I plan to self

- accredit ($0 fee), but the tests for > QSTI are $155 per test for a non

- SES member, $140 per test for a SES member. > If a person takes more than one test during the same examination session, the > additional group tests are $84 each. Additional charges that may be incurred > would be if a proctor and location is used other than a smoke school site > (i.e., a Sylvan learning school, local community college, etc.) and those > fees would vary depending on location. Note: Only the team > leader/senior

- responsible person need be a QSTI. The test is good for 5 > years. I do not know what fees STAC charge for accreditation. Sorry. As > for the fees for taking the QSTI/QSTO exams, the cost for one test for a > non

- SES member is $155, for a member is $140. If more than one test is taken > during the same examination session, the additional tests are $84.00 each. > As for the proctor fees, I was unable to get an average from ETA (Eastern > Technical Associates). This is the response I received from the coordinator > there: "I've got proctor s that charge $20 per hour, and I've got themthat

> charge $75 per hour, per person (which is highway robbery!...but they are the > only ones local). Some of them charge by the test...again as low as $20 per > test up to $50 per test. I've tried to kind of make a standard for when they > don't have a set price already of $50/hour for 1

- 5 people, $75/hour for 6

- 10 > people, and then $100/hour for more than that..." I hope this will give you > an idea of the additional fees when someone opts for a proctor rather than > taking the exam during a smoke school session. Sometimes companies will > combine their resources and send their employees to utilize one proctor at > one time. There are no fees to pursue the qualification approval process > through SES. SE S membership approved and developed the SES QSTI program as
a > voluntary program for our members to demonstrate knowledge and experience > with test procedures. Once the exam(s) are passed, the individual has the > option to submit an application that is reviewed by the SES QSTI/QSTO Review > Committee and if approved, will receive a Qualified Source Testing Individual > (Or Qualified Source Testing Observer) Certificate showing they have met the > requirements of the SES QSTI/QSTO program. Some people will have to travel > to take the test and they can best estimate the costs. Depending on how many > tests are being taken, it will take one to two days to take the test(s). The > length of each test if 1

- 1/2 hours. Therefore, the travel costs of ~ $200

- > $800, depending on mode of travel, should be sufficient. In my opinion, > reading the methods are the best prep courses. This should be normal for a > stack tester. While there are people who offer courses to help prepare for > the exam(s), this co st is optional. The intent of ASTM D

- 7036

- 04 was that the > individual's experience and knowledge of the methods should come from actual > test experience, not classes. People usually try to arrange testing close to > their offices, so travel by car is the most common mode of travel. The > $200

- $800 range Mike stated is probably a reasonable range. This range > includes if they are traveling to take the exam at a smoke school or if they > are traveling to a proctored exam (I believe). I don't think this $200

- $800 > includes the travel hours and the hours involved in taking the exam, just the > costs of travel itself (mileage, per diem, etc.) (4) Test plans are > required. However, they can be as short as the test protocols required by > most States are the test protocol in the ERT (electronic reporting tool). > These can be filled out in one

- two hours. This is another case of most > companies already using test plans so that the client and the tester, as well > as the State/Federal agencies are in agreement as to the plan and its > execution. If you expect 2 hours to do a test plan, again taking Mike's> hourly rate and my hourly rate, that would be a total cost of ~$328.00.

> However, if you are using the ERT, the time may be a little longer depending > on the parameters required, but should be no more than about 3 hours to set > up the initial test plan portion. (5) We already store the proposals, test > plans, reporting and billing both in hard copy and electronically. The > additional costs for the QA, training records and other items in ASTM > D

- 7036

- 04 are minimal (~10

- 20% increase) in storage costs. In dollar > amounts, I am guessing that might be $10

- 20 per month. I hope this helps. > These are only my estimates and for the most part, these are part of good > working practices for stack samplers. The QA manual is obviously the most > expensive and time

- consuming; however, once implemented, the cost savings and > test efficiency are a by

-product of a good quality system. Let me know if you > need more information. Michael HartmanAir

- Tech Environmental, > LLC919

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- 6338919

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- 1810 mobile

----- Original Message

----- From: > Schakenbach.John@epamail.epa.gov To: answers@ipass.net Cc: > gail_westlin@yahoo.com Sent: Thursday, August 05, 2010 09:1 0Subject: Request > for Cost Information > Mike, I'm writing the response to comments document for the AETB and PGVP > proposed rule. There are a number of comments related to cost. It would > help me a lot if you could provide a cost estimate for each o f the following, > which is a direct quote from a commenter: "(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; (2) > application fees and the cost of preparing applications for accreditation > and/or QI qualification; (3) the cost of QI exams, including tuition for > preparatory courses, exam fees, and travel expenses; (4) any new costs > associated with preparation of test plans and reports to comply with the > specific criteria in the practice; and (5) cost of required records storage > and backup. While the costs may turn out to be reasonable and EPA may be o f > the view that AETBs already should be operating in a manner consistent with > the ASTM practice, that view is not a justification for excluding those costs > from the ICR." > Thanks > John Schakenbach > U.S. Environmental Protection Agency > Clean Air Markets Division > schakenbach.john@epa.gov > Phone: 202

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- 9158 > Fax: 202

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