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

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

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

Phone: 202-343-9158

Fax: 202-343-2359

