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

  HYPERLINK "mailto:sevans@cleanair.com"  sevans@cleanair.com 

847-654-4569

On Aug 23, 2010, at 9:47 AM,   HYPERLINK
"mailto:Schakenbach.John@epamail.epa.gov" 
Schakenbach.John@epamail.epa.gov  wrote:

Scott,

 

This is terrific.  I assume all of this can be put in the public
docket?

John Schakenbach

U.S. Environmental Protection Agency

Clean Air Markets Division

  HYPERLINK "mailto:schakenbach.john@epa.gov" \t "blank" 
schakenbach.john@epa.gov 

Phone: 202-343-9158

Fax: 202-343-2359

-----Scott Evans <  HYPERLINK "mailto:sevans@cleanair.com" 
sevans@cleanair.com > wrote: -----

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

From: Scott Evans <  HYPERLINK "mailto:sevans@cleanair.com" 
sevans@cleanair.com >

Date: 08/23/2010 10:24AM

Subject: Re: Request for Cost Information

Correct. Is this sufficient or do you need additional information?

---

Scott Evans

Clean Air Engineering

500 W. Wood St.

Palatine, Illinois  60067

  HYPERLINK "mailto:sevans@cleanair.com" \t "blank"  sevans@cleanair.com


847-654-4569

On Aug 23, 2010, at 8:13 AM,   HYPERLINK
"mailto:Schakenbach.John@epamail.epa.gov" \t "blank" 
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

  HYPERLINK "mailto:schakenbach.john@epa.gov" \t "blank" 
schakenbach.john@epa.gov 

Phone: 202-343-9158

Fax: 202-343-2359

-----Scott Evans <  HYPERLINK "mailto:sevans@cleanair.com" \t "blank" 
sevans@cleanair.com > wrote: -----

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

From: Scott Evans <  HYPERLINK "mailto:sevans@cleanair.com" \t "blank" 
sevans@cleanair.com >

Date: 08/23/2010 04:12AM

Subject: Re: Request for Cost Information

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 additional 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 quality 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 all 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 $20/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.

Regarding 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 process 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. However, 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 business.

 

(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 should 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 exam 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 Engineering

500 W. Wood St.

Palatine, Illinois  60067

  HYPERLINK "mailto:sevans@cleanair.com" \t "blank"  sevans@cleanair.com


847-654-4569

