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: 202-343-9158

> Fax: 202-343-2359

> 

> 

> -----"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 Westlin 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 really 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: 202-343-9158

> Fax: 202-343-2359

> 

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

> 

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

> From: "Gail Westlin" <answers@ipass.net>

> Date: 08/09/2010 08:34AM

> 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 proctors that charge $20 per hour, and I've got
them that

> 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.  SES 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 cost 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,

> LLC919-544-6338919-270-1810 mobile  ----- Original Message -----
From:

> Schakenbach.John@epamail.epa.gov To: answers@ipass.net Cc:

> gail_westlin@yahoo.com Sent: Thursday, August 05, 2010 09:10Subject:
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 of 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 of

> 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: 202-343-9158

> Fax: 202-343-2359

> 

> 

> 

> 

