From:	"Stephen Mandel" <StephenM@spectragases.com>

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

Cc:	Joe Elkins/RTP/USEPA/US@EPA

Date:	04/10/2008 02:57 PM

Subject:	PGVP



John,

It was interesting to see the comments.

First off, Spectra Gases Inc is very supportive of the EPA’s efforts
to assure the quality of gases being sold as EPA Protocol. Spectra
would, of course, prefer that the program be funded totally by EPA but
we understand the constraints and are prepared to pay our fair share.

The comments about ISO 17025 are noted, but if EPA was to require ISO
17025 certification of an EPA Protocol Gas manufacturer it would force
the small companies out of the market. In checking with our quality
people the cost to hire an outside consultant (if you are a small
company you wouldn’t have the internal staff) to prepare the
documentation necessary would probably be in the $40,000 to $50,000
range. This is, of course, a one time fee but these documents do require
updating on a continual basis. Next the company has to hire the
certification agency (A2LA). This may cost $15-20,000. This is for the
initial period and then again every three years. There would then be
periodic audits that will cost in the neighborhood of $5,000/year.

As to the proposed cost ($6,000 to $7,000/ year), any company that is
producing Protocols has to have an investment that is in excess of
$500,000 in equipment for blending and analysis, in standards, and in
cylinders and valves. So an increase of 1.5% is nothing (other than a
smokescreen). However, if as has been suggested there are some companies
manufacturing Protocols that do not utilize SRMS or NTRMs then indeed
the minimal cost of the PGVP program may indeed be a big cost to them.

John, the importance of US EPA Protocol Gases being of known quality is
most important. The utility industry bases many of their decisions on
what these gases are telling them. Federal and State Agencies use EPA
Protocol Gases to evaluate the quality of the air that we all breathe.
Do we want this data to be suspect because we don’t know with any
certainty the quality of the standards that are being used? 

 Stephen B. Mandel, QEP

Spectra Gases Inc

908-252-9300  ext 6218

 

