                          Regulatory Impact Analysis 
                          EPA's 2016 Proposed Rule 
Establishing User Fees for the RCRA Electronic Hazardous 
                      Waste Manifest System (e-Manifest) 
                  U.S. Environmental Protection Agency (EPA) 
              Office of Resource Conservation and Recovery (ORCR) 
                 1200 Pennsylvania Avenue NW (Mailstop 5305P) 
                            Washington DC, 20460 USA 
                                       
                                   April 2016

                               Table of Contents 
Acronyms  ...................................................................................................................................... iii Acknowledgements ........................................................................................................................ iv 
      Executive Summary ...................................................................................................................ES-1 ES.1  Overview   ............................................................................................................ES-1 ES.2  Regulatory Changes .............................................................................................ES-2 ES.3  Affected Universe and Count of Manifests ..........................................................ES-5 ES.4  Summary of Findings ...........................................................................................ES-6 
      ES.5  Other Regulatory and Distributional Issues   .....................................................ES-11 
Chapter 1:  Problem Statement & Justification for Regulatory Changes .................................... 1-1 
      1.1  Historical Background of the Paper Manifest System .............................................. 1-1 
      1.2  Purpose of EPA's Electronic Manifest System Rulemaking .................................... 1-3 
      1.3  The 2012 Hazardous Waste Electronic Manifest Establishment Act ....................... 1-5 
      1.4  The 2014 Final Rule.................................................................................................. 1-6 
      1.5  The Current Proposed Rule ....................................................................................... 1-7 
Chapter 2:  Universe of Affected Entities .................................................................................... 2-1 
      2.1  Industrial Facilities Potentially Affected by e-Manifest ........................................... 2-1 
      2.2  State Governments Potentially Affected by e-Manifest ......................................... 2-24 
      2.3  Summary of Potentially Affected Entities .............................................................. 2-28 
Chapter 3:  Count of Hazardous Waste Manifests ....................................................................... 3-1 
      3.1  Prior Estimates of Manifests ..................................................................................... 3-1 
      3.2  Current Estimate of Manifests .................................................................................. 3-2 
Chapter 4:  Baseline (Paper) Manifest Activities in the Hazardous Waste Management 
Industry ........................................................................................................................................ 4-1 
      4.1  Key Assumptions for Baseline Cost Estimation ....................................................... 4-3 
      4.2  Baseline Costs Accruing to Industry  -  Federal Manifests ........................................ 4-5 
      4.3  Baseline Costs Accruing to Industry  -  State Manifests ............................................ 4-9 
      4.4  Baseline Costs Accruing to EPA ............................................................................ 4-11 
      4.5  Baseline Costs Accruing to States .......................................................................... 4-11 
      4.6  Baseline Costs Accruing to Industry  -  Hazardous Waste Reporting ..................... 4-16 4.7  Baseline Costs Accruing to States  -  Hazardous Waste Reporting ......................... 4-17 
      4.8  Summary of Baseline Costs .................................................................................... 4-18 
Chapter 5:  Costs and Cost Savings of the e-Manifest System .................................................... 5-1 
      5.1  Key Assumptions for e-Manifest System Cost and Cost Savings Estimation .......... 5-3 
      5.2  e-Manifest System Costs to EPA  -  Development and Operations ........................... 5-7 
      5.3  Manifest Processing Costs to EPA ......................................................................... 5-18 
      5.4  Cost and Cost Savings to Industry  -  Manifest Completion and Submittal............. 5-21 
      5.5  Manifest Fees to Industry........................................................................................ 5-30 
      5.6  Cost Savings to States ............................................................................................. 5-36 
      5.7  Hazardous Waste Reporting Costs.......................................................................... 5-37 
      5.8  Summary of Costs and Cost Savings ...................................................................... 5-39 
      5.9  Unquantified Benefits of the e-Manifest System .................................................... 5-42 
      5.10  Caveats: Other Parameters not Considered in this Analysis ................................. 5-42 
Chapter 6:  Sensitivity Analyses of Proposed Rule Costs and Cost Savings............................... 6-1 
      6.1  Number of Manifests ................................................................................................ 6-1 
      6.2  Adoption Rate of the e-Manifest System .................................................................. 6-3 
      6.3  Materials Costs.......................................................................................................... 6-4 
      6.4  CROMERR ............................................................................................................... 6-5 
      6.5  Payback Period.......................................................................................................... 6-7 
Chapter 7:  Supplemental Analyses ............................................................................................. 7-1 
      7.1  Regulatory Planning and Review.............................................................................. 7-1 
      7.2  Regulatory Flexibility ............................................................................................... 7-2 
      7.3  Employment Impact Analysis ................................................................................. 7-10 
      7.4  Unfunded Mandates Analysis ................................................................................. 7-12 
      7.5  Federalism Analysis ................................................................................................ 7-13 
      7.6  Consultation and Coordination with Indian Tribal Governments........................... 7-14 
      7.7  Environmental Justice Analysis .............................................................................. 7-14 
      7.8  Children's Health Protection Analysis.................................................................... 7-14 
      7.9  Energy Impact Analysis .......................................................................................... 7-15 
Appendix A.  Methodology for Estimating Hazardous Waste Tonnage Shipped by SQGs, 
CESQGs, and Generators of State Hazardous Wastes ......................................... A-1 Appendix B.  State Hazardous Waste Programs ..........................................................................B-1 
Appendix C.  2014 EPA Survey of Hazardous Waste Treatment, Storage, and Disposal 
Companies .............................................................................................................C-1 
Appendix D.  Manifest-Related Activities from the Hazardous Waste Manifest System ICR .. D-1 Appendix E.  EPA Paper Manifest Processing Cost Model ........................................................ E-1 Appendix F.  e-Manifest Technical Architecture: Helpdesk Operations ..................................... F-1 
Appendix G.  Industries Potentially Affected by the Proposed Rule, by NAICS Code ............. G-1 
                                          

                                    Acronyms
                                        
ASTSWMO 	Association of State and Territorial Solid Waste Management Officials 
BFRA 	Bona-Fide Reclamation Agreement 
BR 	Biennial Report 
CBA 	Cost-Benefit Analysis 
CBI 	Confidential Business Information 
CDX 	Central Data Exchange 
CESQG 	Conditionally Exempt Small Quantity Generator 
CFR 	Code of Federal Regulations 
COTS 	Commercial Off-the-Shelf 
CPI-U 	Consumer Price Index  -  All Urban Consumers 
CROMERR 	Cross Media Electronic Reporting Rule 
D&B 	Dun & Bradstreet 
DOT 	Department of Transportation 
ENVCAP 	Environmental Compliance Assistance Platform 
EPA 	Environmental Protection Agency 
ETC 	Environmental Technology Council 
GAO 	Government Accountability Office 
HMAC 	Hazardous Materials Advisory Council 
HWMS 	Hazardous Waste Manifest System 
ICR 	Information Collection Request 
IT 	Information Technology 
LQG 	Large Quantity Generator 
NAICS 	North American Industry Classification System 
O&M 	Operations and Maintenance 
OIRA 	Office of Information and Regulatory Affairs 
OMB 	Office of Management & Budget 
ORCR 	Office of Resource Conservation and Recovery 
OSW 	Office of Solid Waste 
QA/QC 	Quality Assurance / Quality Control 
RCRA 	Resource Conservation and Recovery Act 
RFA 	Regulatory Flexibility Act 
RIA 	Regulatory Impact Analysis 
SBA 	Small Business Administration 
SBREFA 	Small Business Regulatory Enforcement Fairness Act of 1996 
SIC 	Standard Industrial Classification 
SISNOSE 	Significant Economic Impact for a Substantial Number of Small Entities 
SQG 	Small Quantity Generator 
TSDF 	Treatment, Storage, or Disposal Facility 
UMRA 	Unfunded Mandates Reform Act 
USC 	United States Code 
WR 	Waste Received 
XML 	Extensible Markup Language 
	
	
	
                                       

	
                                Acknowledgements

                                        
Between 2014 and 2015 under two consecutive work assignments, Industrial Economics Incorporated (IEc) provided analytic support for this RIA: 
             May 2014 to April 2015: WA 2-17 (contact EP-W-12-013)
             May 2015 to April 2016: WA 3-17 (contact EP-W-12-013)

Chris McMinimy, EPA ORCR Economist, was the EPA Contract Officer Technical Representative (COTR) for the work assignments. Other EPA staff assisting with data processing, analysis, and review of prior drafts of this RIA, include (in alphabetical order): Richard Benware, Lee Hofmann, and Mark J. Huff of ORCR.

	
                                        

                               Executive Summary 
 
ES. 1 Overview 
 
Among other regulatory requirements, Subtitle C of the 1976 Resource Conservation and Recovery Act (RCRA) required the U. S. Environmental Protection Agency (EPA) to establish a manifest system to track shipments of hazardous waste from sites where wastes are generated to other sites where hazardous waste is managed (i. e., "cradle-to-grave"). EPA published regulations for a paper manifest system on February 26, 1980 (45 Federal Register 12724). Additionally, in 1984, EPA and the Department of Transportation (DoT) promulgated a Uniform Hazardous Waste Manifest form and procedures (49 FR 10490, March 20, 1984) to create uniform requirements across states and reduce confusion and compliance challenges.[,] The central element of the RCRA manifest is the paper trail chain-of-custody it creates. Each manifest is a paper document that identifies each entity that is responsible for the hazardous waste at each stage of the shipping process, and the final destination of the waste for disposition (i. e. treatment, storage, disposal, or recycling).  
 
In 1976, the House Committee on Interstate and Foreign Commerce estimated that approximately 30 to 35 million tons of hazardous waste were dumped on the ground. In 1984, about 25 million tons of hazardous waste were land-disposed annually, threatening groundwater and soil from contamination. This contamination represented environmental externalities  -  a market failure whereby industrial activities generated hazardous waste, with the consequences impacting the public as a whole. 
 
The purpose of the hazardous waste manifest system is to provide nationwide, cradle-to-grave tracking of all offsite shipments of RCRA-regulated hazardous wastes from their point-ofgeneration (cradle), to their point-of-treatment, storage, disposal, or recycling (grave). The existing manifest system is paper-based, and uses a six-ply carbon copy paper form which must be signed, with one sheet retained for a minimum of three years by every party that has custody of the waste during its shipment. In this way, the system provides a cradle - to-grave record of all RCRA hazardous wastes that are transported offsite from generator facilities to other locations.  
 
While paper manifests have served as a mechanism to guard against illegal dumping, government and industry sources have commented on the substantial cost of implementing this mechanism. EPA's paper manifest system was the largest paperwork burden of the RCRA Subtitle C hazardous waste program. The Office of Management and Budget (OMB) extended approval of the RCRA manifest paperwork burden information collection request (ICR) for only two years in 1994, with the expectation that EPA would, in the interim, adopt manifest revisions that would address its regulatory burden. In 1996, OMB again extended approval of the manifest ICR, but with the expectation that EPA would explicitly address, among other things, innovative approaches as a way to streamline and reduce the annual burden of manifest reporting requirements on the RCRA-regulated community. To reduce paperwork burden on regulated entities, OMB suggested that EPA develop and pilot test the electronic submission and tracking of manifests.  
 
In September 2012, the US Congress passed legislative bill number S. 710 directing EPA to establish an e-Manifest system and authorizing the appropriation of $6 million over 2013 to 2015 for EPA to establish the e-Manifest system. President Obama signed the e-Manifest Act into law on October 5, 2013 (Public law P. L. 112-195). The Act authorizes EPA to collect user fees to recover the costs associated with developing and running e-Manifest. It also defines the goals of the e-Manifest system to be: 
 
       Meeting the needs of the user community, including State governments that collect manifest data, 
       Attracting sufficient user participation and fee revenue to ensure the viability of the system, 
       Decreasing the administrative burden of the RCRA hazardous waste manifest system on the user community, and 
       Providing waste receipt data for the RCRA Hazardous Waste Report (Biennial Report).  
 
The current manifest system reduces the cost of correcting environmental externalities and therefore increases social welfare; it is part of the broader system under RCRA of protecting human health and the environment by ensuring proper disposal of wastes. An electronic manifest system can further improve the efficiency of this system by leveraging new technology to reduce labor and cost burdens of tracking hazardous waste and ensuring safe and proper disposal. Additionally, an electronic system can provide new information about hazardous waste shipments to industrial entities, environmental and safety regulators, and the public. By bringing the availability of manifest information closer to real-time than under the paper system, an electronic manifest system may even generate environmental and human health benefits associated with reduced material use and more rapid response to potential waste-related issues. 
 
ES. 2 Regulatory Changes 
 
EPA plans to publish two rules to fully promulgate the 2012 Electronic Manifest Act. EPA published the first of these two rules (hereafter referred to as the first year rule) in the Federal Register on February 7, 2014. This final rule revised EPA's regulatory requirements for the RCRA hazardous waste manifest system to allow EPA to accept electronic manifests in addition to the existing paper manifests.  
       
In addition, the first year rule: 
       
       Announces EPA's decision to build a single, centralized, e-Manifest system. The decision to build a single system is a departure from the preference expressed by EPA in the 2001 proposed rule to set universal standards that would allow industry to build decentralized electronic manifest systems of their own.  
       
       Defines the universe of entities affected by the e-Manifest program as any facility that completes EPA form 8700-22 and 8700-22A.  
       
       Announces that use of the electronic system will not be mandatory, and that users may choose to submit paper manifests instead.  
 
       Delays the implementation and compliance dates for the provisions of the first year rule until the e-Manifest system is ready for operation and EPA has published a fee schedule for the use of the system in the Federal Register. This information will be published in the final version of the current proposed rulemaking.  
 
       Addresses industry concerns about public access to manifest data and states EPA's decision that manifest data will not be treated as confidential business information (CBI).  
       
       Discusses some technical design aspects of the e-Manifest system, such as how it will capture electronic signatures to be consistent with EPA's 2005 Cross Media Electronic Reporting Rule (CROMERR).  
 
The current rulemaking, for which this RIA is being conducted, will propose a schedule of user fees to cover the costs of building and running the e-Manifest system and e-Manifest program. It will also announce the date when the system will be turned on and EPA will begin to accept electronic manifests. In addition, the user fee rule will address seven issues that arise within the scope of turning on and running the system, and charging and collecting user fees. These issues are essential to successfully implementing the e-Manifest program and running the e-Manifest system. These seven issues are: 
 
          Which users of manifests and manifest data will be charged user fees? To address this issue, EPA first had to identify all potential users of the system. EPA identified three broad groups of users: 1) industrial facilities that must use manifests to comply with regulatory obligations under RCRA, 2) State governments that track manifest data, and 3) members of the general public that do not use manifests to comply with RCRA but are interested in manifest data nonetheless. EPA recognizes that the activities of each of these user groups will burden the system, though likely to varying degrees. EPA is proposing to charge only industrial users to recover the full costs of running the e-Manifest system. This group will likely use the e-Manifest system substantially more than state governments or the public, will likely realize benefits from using e-Manifest to a greater degree than state governments or the public, and can more practically be assigned user accounts than all potentially interested members of the public.  
       
          What will be the transactional basis for assessing user fee obligations? EPA next considered what interaction between industrial users and the system would constitute the billable event that triggered the system to charge a user fee. EPA recognizes the link between system costs that accrue and the number of manifests that pass through the system. For this reason, EPA considered multiple stages within the lifecycle of a manifest as the potential billable event, focusing on the beginning, when a manifest is initiated in the system, and the end, when a finalized manifest is submitted to the system. Based on this review, EPA is proposing to make the final submission of the manifest to the system the billable event. Because the finalized manifest will be submitted by a treatment, storage, and disposal facility (TSDF), EPA is also proposing that TSDFs will pay the user fee.  
       
          How will users be expected to pay their owed fees? 
      EPA is proposing that users pay fees within 30 days, using an electronic payment method supported by the US Treasury.  
       
          What model or fee formula will EPA rely on for the determination of users' fees? EPA considered several models for assessing user fees. As the submission of the finalized manifest is to be the billable event, each fee formula calculates a per-manifest fee. EPA considered three different options: 
       
       Option 1, the Uniform Cost fee, allocates e-Manifest costs evenly across all manifests, creating a single uniform fee.  
       Option 2, the Marginal Cost fee, differentiates fees by manifest type, reflecting differences in EPA labor costs associated with data entry and management for different types of manifests.  
       Option 3, the Marginal Cost Differentiated fee, differentiates fees by labor costs in the same manner as Option 2, and also differentially assigns operations and maintenance costs by manifest type (e.g., paper manifests versus electronic manifests).  
       
      EPA is proposing to initially assess fees using Option 2. However, if the proportion of electronic manifests remains below 75% of the total volume of manifests five years after the system is turned on, then the fee structure may be changed to reflect Option 3.  
       
         How will the rule address fee trajectory and fee schedule revisions? 
      EPA is proposing to publish a new schedule of fees at two-year intervals, with the first schedule being published in the final version of this rule. At each revision, EPA will run the latest program cost and manifest usage statistics through the fee formula proposed and finalized in this rulemaking to determine fees for the next two-year period. EPA intends to use the same underlying fee formula for the foreseeable future, unless operating conditions or expenditures change drastically and render it obsolete. EPA is also proposing to automatically adjust fees from the first year of each cycle to the second. The purpose of this mid-cycle adjustment would be to account for inflation and any errors (positive or negative) in estimating system usage in the first year of the cycle, which is difficult to predict. Thus, depending on inflation and the accuracy of estimates of system usage for the first year of a cycle, fees in the second period could hypothetically stay about the same, increase, or decrease.  
       
         Which, if any, manifest transactions warrant a fee premium? 
      EPA is proposing to assess two additional fees above and beyond user fees. The first fee will be levied on submissions of non-manifests to the paper processing center. EPA anticipates significant clerical costs associated with opening these materials, determining that they are not manifests, and returning them to the sender via post. EPA is also proposing to assess additional fees on paper manifests that must be resubmitted and undergo additional review and quality assurance (QA/QC) after initial submission.  
       
         What sanctions are being proposed to induce prompt payment of user fees? EPA is proposing a mix of financial, denial of service, and enforcement sanctions on late fee payments to encourage timely payment of user fees. Sanctions will begin with financial penalties, be upgraded to denial of service penalties 120 days after payment is due, and escalate to enforcement sanctions 150 days after payment is due. 
       
Finally, the current proposed rule will revise the manifest regulations at 40 CFR Parts §§ 263.21 by revising existing paragraphs (a) and (b) and adding a new paragraph (c) in that section so that transporters designated on the manifest by generators can make changes on the manifest without prior, explicit approval from the generator, provided their contract with the generator grants them authority to make such changes. EPA is proposing this revision to make the manifest regulations consistent with widespread existing industry practices that enable such changes to the manifest to be made for transportation efficiency. As this revision merely reflects widespread existing industry practices, it is not expected to change industry behavior and thus is not expected to result in net costs or benefits. For this reason this RIA does not estimate the potential economic impacts of this change. 
 
ES.3 Affected Universe and Count of Manifests  
 
This RIA estimates that in total, 210,043 industrial entities and 33 state governments will be affected by the proposed rule and the implementation of the e-Manifest system. Exhibit ES-1 summarizes these counts across entity type. 
 
     
      
                                 Exhibit ES-1 
                   Summary of Universe of Affected Entities 
                                     Item 
                                      A 
                                      B 
                                      C 

                                 Entity Type 
 Number affected 
                               Source and Notes 
                                      1 
LQG and TSDF Shippers 
                                                                        16,345 
2011 RCRA Biennial Report, Exhibit 3.1 
                                      2 
SQG Shippers (who manifest) 
                                                                        35,330 
Estimated based on calculations from EPA's 
2015 Improvements to the Hazardous Waste 
Generator Regulatory Program proposed rule RIA 
                                      3 
CESQG Shippers (who manifest) 
                                                                         2,039 
Estimated based on calculations from EPA's 
2015 Improvements to the Hazardous Waste 
Generator Regulatory Program proposed rule RIA and certain state requirements 
                                      4 
State Waste Shippers (who manifest) 
                                                                       145,522 
Estimated based on calculations from EPA's 
2015 Improvements to the Hazardous Waste 
Generator Regulatory Program proposed rule RIA and states with additional wastes which require manifests for shipment 
                                      5 
SQGs Shipping under BRFAs (who manifest) 
                                                                           447 
Estimated based on calculations from EPA's 
2015 Improvements to the Hazardous Waste 
Generator Regulatory Program proposed rule RIA and states requiring manifests for BFRA shipments 
                                      6 
Industry Subtotal  - 
Shippers who Manifest 
                                                                       199,683 
 
                                      7 
TSDFs (Receivers of Manifests) 
                                                                           413 
2011 RCRA Biennial Report, Exhibit 3.5 
                                      8 
Industry Subtotal  -  Shippers and Receivers who Manifest 
                                                                       200,096 
 
                                      9 
Transporters (Trucks) 
                                                                         9,947 
Estimated based on 1996 and 2001 DoT Truck Use Surveys based on 1992 and 1997 data, scaled to estimate 2012 truck counts 
                                      10 
Industry Total 
                                                                       210,043 
 
                                      11 
State Governments 
                                                                            33 
ENVCAP data 
    
To estimate the total number of manifests used annually, this RIA assumes that LQGs and TSDF shippers operate under a weekly pickup schedule for their hazardous waste. Given this assumption, this RIA estimates a total of 1,029,468 manifests from LQG and TSDF shippers annually. Additionally, this RIA assumes that SQGs and generators of state hazardous wastes operate under a monthly pickup schedule for their hazardous waste, leading to an estimate of 2,200,057 manifests from these entities annually. In total, this RIA estimates 3,229,525 manifests used annually for hazardous waste shipments. 
 
ES.4 Summary of Findings  
 
In establishing an e-Manifest system that will serve as a clearinghouse, on a going-forward basis, for all federal and state manifests, the proposed rule will incur a set of costs for creating the system, and will result in a set of cost savings from reduced burden relative to the baseline system of paper manifest creation, transmittal, and processing. Within the constraints of data availability, EPA identified the incremental costs and cost savings resulting from the proposed rule. EPA also assessed the sensitivity of outcomes to key assumptions. 
 
ES.4.1 Costs of e-Manifest 
 
This RIA considers the following major sources of costs: 
 
       Development and maintenance of the e-Manifest system (EPA costs). A majority of the costs associated with the proposed rule correspond to EPA's development costs for the e-Manifest system. These costs include expenses for both initial system creation and ongoing maintenance, as well as additional costs for activities such as receiving and processing manifests through the e-Manifest system, running a help desk to assist users of the system, and certain Cross-Media Electronic Reporting Rule (CROMERR)-based requirements associated with the system's use. As noted below, EPA will be renumerated for these costs by industry through the user fees. 
       
       Collection and processing of manifests (EPA costs). In addition to the development, operations, and maintenance costs associated with the e-Manifest system, EPA will also collect and process manifests within the e-Manifest system. These costs apply specifically to manifests submitted non-electronically; these manifests must undergo additional processing and data entry tasks before their information can be uploaded to the system and stored in a format akin to those manifests submitted electronically through the e-Manifest system. As noted below, EPA will be renumerated for these costs by industry through the user fees. 
       
       Manifest fees (industry costs). To recoup e-Manifest system development and maintenance costs, the proposed rule will apply fees, on a per-manifest basis, to the hazardous waste industry. Effectively, these fees are equivalent to the sum of EPA's system development and maintenance costs (above) and represent a transfer of those costs to industry. Associated with these fees are additional costs to EPA for payment collection; these costs are imputed into the overall system development and maintenance costs recouped through fees to industry. 
       
Additionally, this RIA considers costs associated with CROMERR requirements for the hazardous waste industry.  
       
ES.4.2 Cost Savings of e-Manifest 
 
This RIA estimates costs savings associated with the following: 
 
       Time and materials savings (industry cost savings). The e-Manifest system will allow manifests to be created and submitted through electronic means, rather than with the current paper form that must be printed, completed, transmitted, submitted, and physically stored in the baseline. This RIA estimates that manifest activities done through the e-Manifest system result in substantial time and materials savings relative to these activities being performed with paper manifests. 
       
       Reduced manifest and program costs (cost savings to states). The proposed eManifest system will obviate the need for states to collect and process manifests. While states may still wish to do so to meet their own regulatory, enforcement, or data needs, manifest collection and processing activities will be conducted for all manifests by EPA through the e-Manifest system (and ancillary systems to handle non-electronic manifests received on a going-forward basis). The burden reduction associated with reduced statelevel manifest collection and processing represents a cost savings to these states. 
       
       Reduced Biennial Report burden (industry and state cost savings). The hazardous waste industry currently undertakes a number of recordkeeping and reporting activities associated with the RCRA Biennial Report. The e-Manifest system will reduce this burden by automatically collecting some information through manifests submitted to the system; this represents a cost savings both to industry and states. 
 
ES4.3. Comparison of Costs and Cost Savings 
 
Exhibit ES-2 presents an overall summary of the baseline, post-rule, and incremental (post-rule less baseline) costs (and cost savings) of the proposed rule. Compared to baseline costs of approximately $224 million, post-rule costs range from $255 million in the first year of system launch to $124 million in the sixth year of system launch. Exhibit ES-3 displays the incremental discounted costs of the rule (using three percent and seven percent discount rates), including the annualized incremental costs of the proposed rule. This RIA estimates approximately $34 million in annualized cost savings over the analyzed six-year period following e-Manifest system launch under a seven percent discount rate and approximately $41 million in annualized cost savings over this period under a three percent discount rate, though the rule results in overall costs in the first two years and cost savings in the following four years. 
 
Note that extending the period of analysis forward in time, other things equal, would increase the cost savings estimate, because the highest cost savings accrue after the system implementation costs have been fully accounted for (in the six-year period and afterward). Additional years would continue to reveal substantial cost savings rather than net costs. Therefore, the estimate of a $34 million annualized cost savings can be thought of as a low-end estimate for the long-term savings associated with a functioning e-Manifest system. For example, extending the period of analysis to ten years from system launch, and assuming that net cost savings in Years 7 through 10 are similar to those experienced in Year 6 leads to an annualized cost savings estimate of approximately $49 million instead.
 
                                 Exhibit ES-2 
Summary of Costs and Cost Savings of the Proposed Rule and e-Manifest System  
                            (2014$, millions of $) 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                                 Cost Category 
Baseline 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
Year 6 
                         Baseline and Post-Rule Costs 
Costs to EPA 
                                      1 
Receipt/review of federal manifests[a] 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                      2 
e-Manifest system  -  annual payment for setup costs ($45.5M total)[b] 
                                                                         $0.00 
                                                                         $9.11 
                                                                         $9.11 
                                                                         $9.11 
                                                                         $9.11 
                                                                         $9.11 
                                                                         $0.00 
                                      3 
e-Manifest system  -  operations costs[c] 
                                                                         $0.00 
                                                                         $23.3 
                                                                         $23.9 
                                                                         $24.6 
                                                                         $25.6 
                                                                         $25.5 
                                                                         $25.5 
                                      4 
e-Manifest system  -  manifest processing costs[c] 
                                                                         $0.00 
                                                                         $28.1 
                                                                         $23.2 
                                                                         $9.76 
                                                                         $1.08 
                                                                         $1.08 
                                                                         $1.08 
                                      5 
                                                                      Subtotal 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
Costs to Industry 
                                      6 
Manifest activities[d] 
                                                                          $189 
                                                                          $183 
                                                                          $161 
                                                                          $129 
                                                                         $85.2 
                                                                         $85.2 
                                                                         $85.2 
                                      7 
CROMERR 
                                                                         $0.00 
$0.0277 
                                                                        $0.123 
                                                                        $0.238 
                                                                        $0.405 
                                                                        $0.318 
                                                                        $0.392 
                                      8 
Manifest fees[e] 
                                                                         $0.00 
                                                                         $60.5 
                                                                         $56.2 
                                                                         $43.5 
                                                                         $35.8 
                                                                         $35.7 
                                                                         $26.6 
                                      9 
Hazardous waste reporting activities 
                                                                         $10.4 
                                                                         $4.75 
                                                                         $4.75 
                                                                         $4.75 
                                                                         $4.75 
                                                                         $4.75 
                                                                         $4.75 
                                      10 
                                                                      Subtotal 
                                                                          $199 
                                                                          $248 
                                                                          $222 
                                                                          $177 
                                                                          $126 
                                                                          $126 
                                                                          $117 
Costs to States 
                                      11 
Manifest receipt and processing[f] 
                                                                         $15.0 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                      12 
Hazardous waste reporting activities 
                                                                         $8.74 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                      13 
                                                                      Subtotal 
                                                                         $23.8 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                      14 
                                                                   Total Costs 
                                                                          $224 
                                                                          $255 
                                                                          $229 
                                                                          $184 
                                                                          $133 
                                                                          $133 
                                                                          $124 
           Incremental Costs (Post-Rule Costs Less Baseline Costs) 
                                      15 
                                                      Incremental Costs to EPA 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                      16 
                                                 Incremental Costs to Industry 
                                                                         $49.5 
                                                                         $23.4 
                                                                       ($21.8) 
                                                                       ($72.8) 
                                                                       ($72.9) 
                                                                       ($81.9) 
                                      17 
                                                   Incremental Costs to States 
                                                                       ($17.7) 
                                                                       ($17.7) 
                                                                       ($17.7) 
                                                                       ($17.7) 
                                                                       ($17.7) 
                                                                       ($17.7) 
                                      18 
                         Total Incremental Costs (Cost Savings) (undiscounted) 
                                                                         $31.7 
                                                                         $5.71 
($39.5) 
($90.5) 
($90.7) 
($99.6) 
                                      19 
                  Total Incremental Costs (Cost Savings) (3% discount rate)[g] 
                                                                         $28.2 
                                                                         $4.93 
($33.1) 
($73.6) 
($71.6) 
($76.4) 
                                      20 
                  Total Incremental Costs (Cost Savings) (7% discount rate)[g] 
                                                                         $24.2 
                                                                         $4.07 
($26.3) 
($56.4) 
($52.8) 
($54.2) 
a This RIA assumes that the proposed rule has no impact on this cost item. For more information on the activities involved, see Exhibit 4-4. b The cost for this item is $45.5M, per Exhibit 5-4, and is incurred by in years prior to e-Manifest system launch. This cost is apportioned into five equivalent payments of $9.11 million to evidence how the fee will be applied to industry to recoup this cost. Note that the entirety of this cost is offset by fees, and it is not included in the total row. 
c The entirety of this cost is offset by fees, and it is not included in the total row. [d] Includes costs for federal and state manifests, capital costs to store manifests, and reclamation agreement-specific recordkeeping activities. This RIA assumes that the proposed rule has no impact on capital costs associated with storing manifests in file cabinets and recordkeeping activities for shipments under reclamation agreements; the difference between baseline and post-rule costs results from the difference in the burden associated with manifest activities for federal and state manifests only. 
 Amount equivalent to the total fee accrued in a given year, as shown in Rows 2 through 4. 
 This RIA assumes that states do not undertake any manifest receipt and processing activities in the post-rule scenario, as the necessary data would be accessible through the e-Manifest system to states at no charge.  
 Figures discounted back to 2014$. That is, the value in Column C is discounted by four years (2018  -  2014), the value in Column D is discounted by five years, and so on. 
                                 Exhibit ES-3 
Summary of Costs and Cost Savings of the Proposed Rule and e-Manifest System, Discounted and Annualized  
                            (2014$, millions of $) 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 
                                      I 

                                   Category 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
Year 6 
                                    Total 
                             (Years 1 through 6) 
                                  Annualized 
                Incremental Cost (Cost Savings) (Years 1 - 6) 
                                      1 
Calendar Year 
                                     2018 
                                     2019 
                                     2020 
                                     2021 
                                     2022 
                                     2023 
                                     N/A 
                                     N/A 
                                      2 
Incremental 
Costs (Cost Savings)  -  
Undiscounted 
EPA 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                                                 Offset by fee 
                                     N/A 
                                      3 

Industry 
                                                                        $49.5  
                                                                        $23.4  
                                                                       ($21.8) 
($72.8) 
($72.9) 
($81.9) 
                                                                        ($176) 
                                     N/A 
                                      4 

States 
($17.7) 
($17.7) 
                                                                       ($17.7) 
($17.7) 
($17.7) 
($17.7) 
                                                                        ($106) 
                                     N/A 
                                      5 

Total 
                                                                        $31.7  
                                                                        $5.71  
                                                                       ($39.5) 
($90.5) 
($90.7) 
($99.6) 
                                                                        ($283) 
                                     N/A 
                                      7 
Costs (Cost Savings)  3% Discount Rate[a] 
                                                                         $28.2 
                                                                        $4.93  
                                                                       ($33.1) 
($73.6) 
($71.6) 
($76.4) 
                                                                        ($221) 
                                                                    ($40.9)[b] 
                                      8 
Costs (Cost Savings) 7% Discount Rate[a] 
                                                                        $24.2  
                                                                        $4.07  
                                                                       ($26.3) 
($56.4) 
($52.8) 
($54.2) 
                                                                        ($161) 
                                                                    ($33.8)[c] 
Totals may not sum due to rounding. a Figures discounted back to 2014$. That is, the value in Row 1 is discounted by four years (2018  -  2014), the value in Row 2 is discounted by five years, and so on. [b] Calculated as the annual payment that would need to be made, cognizant of discounting, to reach a total value of $221 million after six years. If the period were extended to ten years (i.e., the total period over which e-Manifest system costs are incurred, including pre-launch setup costs, plus the sixyear period analyzed here), the annualized cost savings would be approximately $26.0 million instead. [c] Calculated as the annual payment that would need to be made, cognizant of discounting, to reach a total value of $161 million after six years. If the period were extended to ten years (i.e., the total period over which e-Manifest system costs are incurred, including pre-launch setup costs, plus the sixyear period analyzed here), the annualized cost savings would be approximately $23.0 million instead.  
 
ES.4.4 Unquantified Benefits 
 
EPA expects that electronic manifests will enhance many stakeholders' abilities to track and extract data on waste shipments by storing and distributing this data in a central, accessible location. EPA has identified six stakeholder groups that may benefit from better access to manifest shipping data: 
 
       Members of industry that use the manifest for tracking waste shipments; 
       Federal and state government RCRA enforcement officials; 
       Emergency responders; 
       Foreign governments; 
       Research institutions; and 
       Communities near RCRA-regulated facilities. 
 
This RIA does not attempt to quantify the value of this benefit. 
 
ES.4.5 Uncertainties in the Estimation of Costs and Cost Savings 
 
This RIA also assesses the impacts of uncertainty and potential deviations in EPA's chosen assumptions. Specifically, this RIA conducts sensitivity analyses regarding the following assumptions and parameters: 
 
       Number of manifests. The analysis evaluates the effect of assuming increased hazardous waste shipping frequencies and consequently more manifests in the system.
       Adoption rate. Because cost savings result from adoption of electronic manifests, adoption patterns drive the magnitude of cost and cost savings.
       Materials costs. The analysis characterizes cost impacts on a more detailed level, specifically assuming that materials costs will be eliminated for manifests generated and submitted electronically.
       CROMERR. The primary analysis assumes that CROMERR applies only to TSDFs and transporters. If CROMERR applied to generators, a large number of additional facilities would incur costs related to this aspect of electronic manifest submission.
       Payback period. Because of the statutory requirement for the manifest fee to recover EPA's costs, the period over which these costs are recovered impacts the level of the fee, and in turn, industry costs.

Overall, this RIA finds that the proposed rule remains a net cost saving rule even under reasonably pessimistic assumptions that increase costs and reduce cost savings. This conclusion does not hold only in extreme cases, such as those where there are relatively few annual manifests completed. 

ES.5 Other Regulatory and Distributional Impacts 

As part of the analysis, EPA assessed the proposed rule's potential impacts related to: 

       Regulatory planning and review: This proposed rule is not expected to result in more than $31.7 million in incremental costs across the economy in any given year and results in net cost savings in most years (an annualized estimate of $34 million in cost savings at a seven percent discount rate). Manifest fees to industry do not exceed $60.5 million in any year, and are, even in early years with lower adoption rates, at least partially offset by industry and state government cost savings. As a result, this RIA concludes that the eManifest system is not an economically significant regulatory action, though it may still be deemed significant due to the novel legal and policy issues it raises.
      
       Regulatory flexibility: Because the e-Manifest system is designed to be an accessible, voluntary system that can reduce costs to any regulated entity, EPA's does not anticipate any adverse impacts on small businesses under the proposed rule. A sensitivity analysis determined that at most, 74 potentially small entities (representing 42 sectors) are affected by the proposed rule, and EPA expects many of these to enjoy cost savings.
      
       Employment impacts: Insufficient data are available to quantify changes in employment associated with the rule. This RIA estimates a reduction in labor hours (approximately 22.8 million over six years) and labor costs faced by all affected entities, including states, hazardous waste generators, transporters, and TSDFs. The RIA does not reflect a complete analysis of labor market effects related to the rule, as the effects are spread across hundreds of thousands of firms in different sectors, and responses to cost reductions are likely to be sector- and firm-specific. Neither the data nor methods were available to conduct such an analysis.

       Unfunded mandates: The e-Manifest proposed rule does not contain a Federal mandate that may result in expenditures of $100 million or more for State, local, and tribal governments, in the aggregate, or the private sector in any one year. As described in Chapter 5, this RIA estimates that the net impact of e-Manifest will be to reduce costs to state governments. The e-Manifest rule will not impose any burden on local or tribal governments as they are not stakeholders in the hazardous waste manifest system. Thus, this rule is not subject to the requirements of sections 202 or 205 of UMRA. This rule is also not subject to the requirements of section 203 of UMRA because it contains no regulatory requirements that might significantly or uniquely affect small governments. The current hazardous waste paper manifest system imposes no burden or requirements on small governments.

       Federalism: As indicated in the UMRA discussion above, this RIA estimates cost savings for state agencies. Thus, the proposed rule would not result in substantial direct compliance costs, as defined in the EPA guidance, for entities owned by state and local governments. EPA does not estimate that the proposed rule would affect the relationship between the federal government and the states or on the distribution of power and responsibilities among the various levels of government.

       Tribal governments: As indicated in the UMRA discussion above, EPA does not estimate any costs of the proposed rule for state and local governments. Based on these results, the proposed rule is not expected to impose a substantial burden on tribal governments.

       Environmental justice: EPA does not estimate that the proposed rule would result in disproportionately high or adverse impacts for minority or low-income populations. Overall, the Agency anticipates that the rule will support the safe shipment and management of hazardous waste, which benefits all communities. As the rule encourages environmentally sound recordkeeping of hazardous wastes, it will likely reduce the risks associated with treatment, disposal, and recovery.

       Children's health protection: EPA does not anticipate that the proposed rule would lead to a disproportionate negative impact on children. As described in the Environmental Justice section above, the rule improves the information available to EPA through notification, tracking, and reporting requirements, and provides for environmentally sound disposal and recovery.

       Energy Impacts: Changes in the management of hazardous waste resulting from the proposed rule are not expected to significantly impact energy production or distribution, as these changes relate only to reporting, though the reduction in material (paper) use anticipated under the rule is likely associated with reduced energy demand to manufacture and transport paper. Changes in hazardous waste manifest practices may lead to changes in the management practices of hazardous waste, although the effect of these changes on energy use and generation is uncertain and likely to be minimal. Aside from the potential change in paper use and waste management practices described above,
      the requirements of the rule would have minimal impact on energy consumption; therefore, the rule is not expected to have a significant adverse effect on energy supply, distribution, or use. In addition, with annualized net costs of no more than $31.7 million per year (including both industry and government net costs), this rule is not considered an economically significant action under Executive Order 12866.
       

                                   Chapter 1 
           Problem Statement and Justification for Regulatory Changes 
                                        
1.1 Historical Background of the Paper Manifest System 
       
Among other regulatory requirements, Subtitle C of the 1976 Resource Conservation and Recovery Act (RCRA) required the U. S. Environmental Protection Agency (EPA) to establish a manifest system to track shipments of hazardous waste from sites where wastes are generated to other sites where hazardous waste is managed (i. e., "cradle-to-grave"). EPA published regulations for a paper manifest system on February 26, 1980 (45 Federal Register 12724). The central element of the RCRA manifest is the paper trail chain-of-custody it creates. Each manifest is a paper document that identifies each entity that is responsible for the hazardous waste at each stage of the shipping process, and the final destination of the waste for disposition (i. e. treatment, storage, disposal, or recycling).  
 
In 1976, the House Committee on Interstate and Foreign Commerce estimated that approximately 30 to 35 million tons of hazardous waste were dumped on the ground. In 1984, about 25 million tons of hazardous waste were land-disposed annually, threatening groundwater and soil from contamination. This contamination represented environmental externalities  -  a market failure whereby industrial activities generated hazardous waste, with the consequences impacting the public as a whole. 
 
The purpose of the hazardous waste manifest system is to provide nationwide, cradle-to-grave tracking of all offsite shipments of RCRA-regulated hazardous wastes from their point-ofgeneration (cradle), to their point-of-treatment, storage, disposal, or recycling (grave). The existing manifest system is paper-based, and uses a six-ply carbon copy paper form which must be signed, with one sheet retained for a minimum of three years by every party that has custody of the waste during its shipment. In this way, the system provides a cradle - to-grave record of all RCRA hazardous wastes that are transported offsite from generator facilities to other locations.  
 
As a component of EPA's hazardous waste regulatory program, manifests help to ensure that hazardous waste is disposed of at permitted treatment, storage, or disposal facilities. For the majority of hazardous waste of in the country, generators, transporters, and disposal facilities are identified and held accountable for proper hazardous waste management, ensuring that the environmental and safety costs of hazardous waste are internalized by private parties and do not fall upon the public. 
 
Soon after the 1980 regulations came into effect, more than 20 states developed and required revised, state-specific hazardous waste manifest forms. These forms meet the minimal Federal requirements but also require additional state information. These differing requirements created significant confusion and compliance challenges, and in 1984, EPA and the Department of Transportation (DoT) in coordinated rulemaking, with significant assistance from the  Association of State and Territorial Solid Waste Management Officials (ASTSWMO) and the 
Hazardous Materials Advisory Council (HMAC), promulgated a Uniform Hazardous Waste Manifest form and procedures (49 FR 10490, March 20, 1984).[,]  
                             What is a manifest? 
                                        
A "manifest," as referred to in this document, is a six-ply paper form that is the center of RCRA's cradle-tograve tracking system for RCRA hazardous waste in the United States. When hazardous waste is moved from one facility to another (i.e., shipped), a manifest that identifies the generator, transporter, and receiving facilities involved, must accompany it. A manifest also requires information on the types and quantities of hazardous waste being transported, and includes a space for handlers to note any discrepancies that may arise in the course of transporting the waste. Each individual shipment of hazardous waste requires its own separate manifest, and every facility or entity that handles (whether generating, receiving, or transferring) that shipment must sign and retain a copy of said manifest. An individual shipment can range in size from a very small quantity (a single container) to a full truck load or even larger; special manifest rules apply to larger vessels such as trains and ships which transport hazardous waste. 
 
EPA first published the regulations requiring the use of the manifest in 1980 in accordance with Section 3002(a)(5) of RCRA, which directs EPA to "establish requirements respecting... use of a manifest system and any other reasonable means necessary to assure that all such hazardous waste generated is designated for treatment, storage, or disposal, and arrives at treatment, storage, and disposal facilities... for which a permit has been issued..." EPA standardized the manifest format nationwide in 2006 with the goal of reducing the administrative burden associated with its use across different states. 
 
The current manifest is formally designated EPA Form 8700-22. The continuation sheet, wherein additional wastes can be listed, is formally designated EPA Form 8700-22A. The manifest serves a number of functions: 
 
       It is a chain of custody document that industry and regulators use to track shipments of hazardous waste. 
       
       It ensures that generation facilities remain responsible for making certain that their waste is properly transported, treated, stored, and disposed by formalizing arrangements for these activities prior to the waste leaving their facilities. 
 
       It meets the requirements of Department of Transportation shipping papers and bills of lading for hazardous waste shipments. 
 
       It informs emergency response teams about the nature of the hazardous waste present in the case of an accident, spill, or leak. 
 
       It is used by State governments to assess fees and taxes on hazardous waste-related activities, such as generation or shipments, and potentially by the public for informational or research purposes. 
       
A decade later, the manifest system became one target of the federal effort to reduce regulatory burden. In March 1995, President Clinton, Vice President Gore, and the EPA Administrator put forth an agenda to reinvent environmental protection as part of the larger goal of creating a federal government that works more efficiently and costs less. As one effort of this agenda, the Administration and EPA have been committed to the goal of reducing the paperwork burden resulting from environmental regulations by at least 25 percent.  
 
While paper manifests have served as a mechanism to guard against illegal dumping, government and industry sources have commented on the substantial cost of implementing this mechanism.[,] EPA's paper manifest system was the largest paperwork burden of the RCRA Subtitle C hazardous waste program. The Office of Management and Budget (OMB) extended approval of the RCRA manifest paperwork burden information collection request (ICR) for only two years[6] in 1994, with the expectation that EPA would, in the interim, adopt manifest revisions that would address its regulatory burden. In 1996, OMB again extended approval of the manifest ICR, but with the expectation that EPA would explicitly address, among other things, innovative approaches as a way to streamline and reduce the annual burden of manifest reporting requirements on the RCRA-regulated community. To reduce paperwork burden on regulated entities, OMB suggested that EPA develop and pilot test the electronic submission and tracking of manifests.  
 
Reducing the cost of correcting environmental externalities will increase social welfare. An electronic manifest system can further improve the efficiency of this system by leveraging new technology to reduce labor and cost burdens of tracking hazardous waste and ensuring safe and proper disposal. Additionally, an electronic system can provide new information about hazardous waste shipments to industrial entities environmental and safety regulators, and the public. By bringing the availability of manifest information closer to real-time than under the paper system, an electronic manifest system may even generate environmental and human health benefits associated with reduced material use and more rapid response to potential waste-related issues. 
 
1.2 Purpose of EPA's Electronic Manifest System Rulemaking 
       
As of FY2014, EPA estimates the total annual nationwide paperwork burden of the federal paper manifest system is 2.5 million hours for shipment of EPA-regulated hazardous wastes. In addition, 19 state governments currently require transporters of state (not federally)regulated hazardous wastes to use EPA's RCRA paper manifest; 23 state governments provided EPA with information about their manifest collection and processing activities. Added together, the current annual national paperwork burden hours for EPA-regulated plus state-regulated hazardous waste shipments is estimated in this RIA to involve 6.3 million labor hours per year to process approximately 3.2 million RCRA paper manifests at an estimated annual cost to industry and state governments of approximately $220 million per year. With relatively rare exceptions, EPA itself does not print, distribute, collect, or process RCRA paper manifests, though it incurs relatively small costs annually to receive and review exception reports and similar activities, detailed in Chapter 4 as "Agency burden" costs borne by EPA.  
 
On May 22, 2001, EPA's Office of Solid Waste (now named the Office of Resource 
Conservation and Recovery, or ORCR) published in the Federal Register its intent to implement an e-Manifest system, recognizing that information technologies present tremendous potential for reducing the significant paperwork burden of the current paper-based manifest system. Since 
2001, EPA has explored multiple information technology (IT) design configurations for an eManifest system to replace the current paper process, involving a number of activities and Federal Register notices, some of which are summarized below. 
 
       EPA solicited stakeholder input on conceptual framework, roadmap, funding, governance, technical and business process approaches and options for an e-Manifest system during a two-day public meeting held in Washington, D.C. on May 19 and 20, 2004. 
    
       On April 18, 2006, EPA published a public notice to announce and request comment on 
      EPA's intention to develop a centralized web-based IT system that would be hosted on EPA's IT architecture. EPA received strong support for a national web-based system funded through user-fees. In addition, commenters generally supported EPA's position that use of e-Manifests should be at the election of the users rather than mandatory.  
    
       On February 26, 2008, EPA published a notice to announce the availability of additional information on the e-Manifest project and solicit additional comments on two issues raised in response to the April 2006 notice: concern that an optional e-Manifest system would create dual paper and electronic systems, and differing perspectives related to confidential business information (CBI) claims for e-Manifests. The notice also 
      confirmed EPA's commitment to finalizing a federal regulation that would authorize the use of electronic manifests as the legal equivalent of paper manifests.  
    
       On November 19 and 20, 2008, EPA's ORCR held a meeting of state government and RCRA-regulated industry representatives in Arlington, VA to discuss EPA's 2006 announced preferred approach to develop a centralized web-based IT system that would be hosted on EPA's existing IT architecture. Meeting participants were asked for input into the design, development, and operation of the centralized e-Manifest system.  
 
1.3 The 2012 Hazardous Waste Electronic Manifest Establishment Act 
 
In September 2012, the US Congress passed legislative bill number S. 710 directing EPA to establish an e-Manifest system and authorizing the appropriation of $6 million over 2013 to 2015 for EPA to establish the e-Manifest system. President Obama signed the e-Manifest Act into law on October 5, 2013 (Public law P. L. 112-195). Among other things, the Act specifies dates by which EPA must meet certain system milestones. These milestones are:  
 
       Publishing a regulation promulgating the Act;  
    
       Establishing a system advisory board to make recommendations on the operation of the system; and 
     
       Bringing the e-Manifest system online such that it can accept electronic manifests from any user.  
 
In addition to establishing system and program milestones for e-Manifest, the Act also: 
 
       Authorizes EPA to collect user fees to recover the costs associated with developing and running e-Manifest.  
       
       Establishes a special revolving System Fund to receive user fees.  
       
       Defines the goals of the e-Manifest system to be: 
       
           Meeting the needs of the user community, including State governments that collect manifest data, 
           Attracting sufficient user participation and fee revenue to ensure the viability of the system, 
           Decreasing the administrative burden of the RCRA hazardous waste manifest system on the user community, and 
           Providing waste receipt data for the RCRA Hazardous Waste Report (Biennial Report).  
                   
       Establishes regular oversight of fee revenue and system expenses by both Congress and the EPA Inspector General's office.  
       
1.4 The 2014 Final Rule 
       
EPA plans to publish two rules to fully promulgate the 2012 Electronic Manifest Act. EPA published the first of these two rules (hereafter referred to as the first year rule) in the Federal Register on February 7, 2014. This final rule revised EPA's regulatory requirements for the RCRA hazardous waste manifest system to allow EPA to accept electronic manifests in addition to the existing paper manifests.  
       
In addition, the first year rule: 
       
       Announces EPA's decision to build a single, centralized, e-Manifest system. The decision to build a single system is a departure from the preference expressed by EPA in the 2001 proposed rule to set universal standards that would allow industry to build decentralized electronic manifest systems of their own. EPA moved towards the centralized approach after receiving negative feedback from stakeholders in 2001 and 2004 on the decentralized approach.  
       
       Defines the universe of entities affected by the e-Manifest program as any facility that completes EPA form 8700-22 and 8700-22A.  
       
       Announces that use of the electronic system will not be mandatory, and that users may choose to submit paper manifests instead.  
 
       Delays the implementation and compliance dates for the provisions of the first year rule until the e-Manifest system is ready for operation and EPA has published a fee schedule for the use of the system in the Federal Register. This information will be published in the final version of the current proposed rulemaking.  
 
       Addresses industry concerns about public access to manifest data and states EPA's decision that manifest data will not be treated as confidential business information (CBI).  
       
       Discusses some technical design aspects of the e-Manifest system, such as how it will capture electronic signatures to be consistent with EPA's 2005 Cross Media Electronic Reporting Rule (CROMERR).  
 
1.5 The Current Proposed Rule 
       
The current rulemaking, for which this RIA is being conducted, will propose a schedule of user fees to cover the costs of building and running the e-Manifest system and e-Manifest program. It will also announce the date when the system will be turned on and EPA will begin to accept electronic manifests. In addition, the user fee rule will address seven issues that arise within the scope of turning on and running the system, and charging and collecting user fees. These issues are essential to successfully implementing the e-Manifest program and running the e-Manifest system. These seven issues are: 
 
   Which users of manifests and manifest data will be charged user fees? 
To address this issue, EPA first had to identify all potential users of the system. EPA identified three broad groups of users: 1) industrial facilities that must use manifests to comply with regulatory obligations under RCRA, 2) State governments that track manifest data, and 3) members of the general public that do not use manifests to comply with RCRA but are interested in manifest data nonetheless. EPA recognizes that the activities of each of these user groups will burden the system, though likely to varying degrees. EPA is proposing to charge only industrial users to recover the full costs of running the e-Manifest system. Manifest-related costs, including activities associated with completing the manifest, as well as purchase of the manifest itself and any associated user fees are all parts of the broader cost of managing hazardous waste. By levying costs associated with the e-Manifest system, which will facilitate hazardous waste management, on industry, these costs are kept internal to the industry, akin to the pre-rule scenario. This is more efficient than a structure where other groups, (i.e., governments and/or the public) would ultimately bear the cost for the e-Manifest system. Additionally, industry will likely use the e-Manifest system substantially more than state governments or the public, will likely realize benefits from using e-Manifest to a greater degree than state governments or the public, and can more practically be assigned user accounts than all potentially interested members of the public.  
 
   What will be the transactional basis for assessing user fee obligations? 
EPA next considered what interaction between industrial users and the system would constitute the billable event that triggered the system to charge a user fee. EPA recognizes the link between system costs that accrue and the number of manifests that pass through the system. For this reason, EPA considered multiple stages within the lifecycle of a manifest as the potential billable event, focusing on the beginning, when a manifest is initiated in the system, and the end, when a finalized manifest is submitted to the system. Based on this review, EPA is proposing to make the final submission of the manifest to the system the billable event. Because the finalized manifest will be submitted by a treatment, storage, and disposal facility (TSDF), EPA is also proposing that TSDFs will pay the user fee, thereby internalizing the costs of the hazardous waste manifest.  
 
   How will users be expected to pay their owed fees? 
EPA is proposing that users pay fees within 30 days, using an electronic payment method supported by the US Treasury.  
 
   What model or fee formula will EPA rely on for the determination of users' fees? EPA considered several models for assessing user fees. As the submission of the finalized manifest is to be the billable event, each fee formula calculates a per-manifest fee. EPA considered three different options for calculating the fee. Option 1, the Uniform Cost fee, allocates e-Manifest costs evenly across all manifests, creating a single uniform fee. Option 2, the Marginal Cost fee, differentiates fees by manifest type, reflecting differences in EPA labor costs associated with data entry and management for different types of manifests. Option 3, the Marginal Cost Differentiated fee, differentiates fees by labor costs in the same manner as Option 2, and also differentially assigns operations and maintenance costs by manifest type (e.g., paper manifests versus electronic manifests), reflecting differences in these costs by type of manifest.  
 
EPA's proposed, fourth option is to initially assess fees using the calculus of Option 2. However, if the proportion of electronic manifests remains below 75% of the total volume of manifests six years after the system is turned on, then the fee structure will be changed to reflect Option 3.  
 
   How will the rule address fee trajectory and fee schedule revisions? 
EPA is proposing to publish a new schedule of fees at two-year intervals, with the first schedule being published in the final version of this rule. At each revision, EPA will run the latest program cost and manifest usage statistics through the fee formula proposed and finalized in this rulemaking to determine fees for the next two-year period. EPA intends to use the same underlying fee formula for the foreseeable future, unless operating conditions or expenditures change drastically and render it obsolete. EPA is also proposing to automatically adjust fees from the first year of each cycle to the second. The purpose of this mid-cycle adjustment would be to account for inflation and any errors (positive or negative) in estimating system usage in the first year of the cycle, which is difficult to predict. Thus, depending on inflation and the accuracy of estimates of system usage for the first year of a cycle, fees in the second period could hypothetically stay about the same, increase, or decrease.  
 
   Which, if any, manifest transactions warrant a fee premium? 
EPA is proposing to assess two additional fees above and beyond user fees. The first fee will be levied on submissions of non-manifests (i.e., other required or requested regulatory or enforcement information for the facility or firm in question not associated with the manifest, such as responses to requests for information, permit applications, etc.) to the paper processing center. EPA anticipates significant clerical costs associated with opening these materials, determining that they are not manifests, and returning them to the sender via post. EPA is also proposing to assess additional fees on paper manifests that must be resubmitted and undergo additional review and quality assurance (QA/QC) after initial submission. Manifest resubmission and additional review may be triggered by findings requiring corrections with the initial manifest submission, a failure of the initial submission to meet certain data validation requirements, and similar issues. 
 
   What sanctions are being proposed to induce prompt payment of user fees? 
EPA is proposing a mix of financial, denial of service, and enforcement sanctions on late fee payments to encourage timely payment of user fees. Sanctions will begin with financial penalties, be upgraded to denial of service penalties 120 days after payment is due, and escalate to enforcement sanctions 150 days after payment is due. 
 
Finally the current proposed rule will revise the manifest regulations at 40 CFR Parts §§ 263.21 by revising existing paragraphs (a) and (b) and adding a new paragraph (c) in that section so that transporters designated on the manifest by generators can make changes on the manifest without prior, explicit approval from the generator, provided their contract with the generator grants them authority to make such changes. EPA is proposing this revision to make the manifest regulations consistent with widespread existing industry practices that enable such changes to the manifest to be made for transportation efficiency. As this revision merely reflects widespread existing industry practices, it is not expected to change industry behavior and thus is not expected to result in net costs or benefits. For this reason this RIA does not estimate the potential economic impacts of this change. 

                               Chapter 2 Universe of Affected Entities 
 
This chapter provides an overview of the universe of industrial facilities and government entities that may be affected by the fees for the Hazardous Waste Manifest System proposed rule. The rule may affect any industrial facility that uses, signs, or completes a RCRA hazardous waste manifest in the course of conducting business. Thus, the universe of facilities potentially affected by this rule is both large and diverse. To provide a comprehensible picture of this universe, the first section of this chapter describes and categorizes potentially affected facilities according to their roles within the RCRA hazardous waste system and their locations. 
 
The e-Manifest rule may also potentially affect a number of state governments. Under RCRA, state governments have the discretion to impose additional requirements on hazardous waste shipments as long as these requirements are at least as stringent as federal RCRA requirements. A number of state governments have adopted additional standards that may be affected by the eManifest system. In particular, requirements that industrial facilities submit copies of the hazardous waste manifest to the state may be streamlined by the e-Manifest system. The second section of this chapter describes the Federal requirements governing state manifest collection programs, and the additional requirements that states often impose on RCRA hazardous waste shipments.  
 
2.1 Industrial Facilities Potentially Affected by e-Manifest 
 
The universe of facilities that may be affected by the e-Manifest rule includes all facilities that may use, sign, or complete a RCRA hazardous waste manifest in the course of conducting business. As this is a large and heterogeneous group of facilities, this chapter sorts them into three groups according to the role that each has in the RCRA hazardous waste system. The three different roles are:  
 
       Treatment, storage, and disposal facilities (TSDFs) that receive, treat and dispose of hazardous waste; 
       
       Generators that produce hazardous waste and send it offsite to TSDFs for treatment and disposal; and 
 
       Transporters that deliver shipments of waste from generator sites to TSDF sites. 
 
The rest of this section describes each of these three groups in further detail. It provides information on counts of facilities in aggregate and by state, the quantities of hazardous waste handled by each facility type, and prevalent NAICS codes for each group where applicable. 
 
2.1.1 Treatment, Storage, and Disposal Facilities (Receiving Hazardous Waste) 
 
Treatment, storage, and disposal facilities are facilities that are permitted under RCRA to receive shipments of RCRA hazardous waste to be treated, stored, or disposed of, as per 40 CFR Part 264 and 40 CFR Part 265. TSDFs will likely be the heaviest and most important users of the eManifest system, because they are required to directly interface with all received manifests. 
 
Facilities permitted as TSDFs may be affected by the proposed rule in multiple ways. The primary role of TSDFs is to serve as the final destination for shipments of waste, which these facilities then treat, store, or dispose. When serving in this capacity, TSDFs act as receivers of hazardous waste. However, TSDFs may also interact with hazardous waste manifests in other ways: specifically, some TSDFs may generate hazardous waste and ship it off-site. When serving in this alternate capacity, TSDFs are considered to be generators of hazardous waste, and the TSDFs that engage in these activities are considered in Section 2.1.2 below. Meanwhile, the remainder of this section considers TSDFs serving in the primary capacity as receivers of hazardous waste generated by other entities.  
 
Under RCRA, TSDFs receiving hazardous waste are required to sign and date manifests, note significant discrepancies in the manifest, return a signed manifest to the transporter, send copies of import-affiliated manifests to EPA within 30 days of delivery, and retain a manifest copy for at least three years. Additionally, TSDFs may provide full RCRA compliance services to their generator customers, especially in those cases where a TSDF services relatively small generators. Where this occurs, rather than merely treating waste, TSDFs will also provide services such as preparing copies of the manifest, and transporting waste using trucks owned by the TSDF. Correspondingly, for a certain number of manifests, the TSDF is involved directly in every aspect of manifest activities associated with shipping the waste. For these as well as all other manifests, under the proposed rule, TSDFs are responsible for transmitting the completed, finalized copies of manifests to the e-Manifest system. Additionally, fees for e-Manifest system use will be levied when the manifest is submitted; correspondingly TSDFs will be the only facilities responsible for paying fees directly to EPA for use of the system. 
 
2.1.1.1 National and State Counts of TSDFs 
 
Data describing the universe of TSDFs comes from the RCRA Hazardous Waste Report (Biennial Report), a summary of hazardous waste generation, shipment, and treatment released every two years. These data, hereafter referred to throughout this RIA as "Biennial Report" data, are compiled from waste reports submitted by TSDF facilities as a part of existing reporting obligations under RCRA. The RCRA Biennial Report therefore provides a fairly complete picture of the TSDF universe that will be impacted by electronic manifests.  
 
According to the 2011 RCRA Biennial Report (the most recent available), 413 TSDF facilities that were operating in 2011 received hazardous waste from offsite for the purposes of treating, storing, or disposing of it.[,] The remainder of this section refers to these facilities as "receiver TSDFs" as a clarifying measure to distinguish these facilities from facilities permitted as TSDFs that generate and ship hazardous waste off-site, which are discussed on Section 2.1.2. 
 
The Biennial Report data document the number of receiver TSDFs operating in each state and territory of the United States. Exhibits 2-1 and 2-2 display this information in table and map form. These Exhibits show that while receiver TSDFs are spread across the country, they are generally clustered in areas with denser population and more industrial activity. Over half of the receiver TSDFs reported in the 2011 RCRA Biennial Report are located in just 10 states. Texas, the state with the most reported receiver TSDFs, has 44, while New Hampshire, Montana, and Wyoming have none. 
 	 
                                 Exhibit 2-1 
Counts of Receiver TSDF Facilities by State According to the 2011 RCRA Biennial Report 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 
Item 
                                      A 
                                      B 
                                      C 
                                      D 

                                    State 
Receiver 
                                    TSDF* 
                                  Facilities 
                                National Rank 
                                      % 
                                   National 
                                    Total 
                                   (B/413) 

                                    State 
Receiver 
                                    TSDF* 
                                  Facilities 
                                National Rank 
                                      % 
National 
                                    Total 
                                   (B/413) 
                                      1 
Alabama 
                                                                             8 
                                                                            15 
                                                                          1.9% 
                                      29 
Navajo Nation 
                                                                             0 
                                                                            50 
                                                                          0.0% 
                                      2 
Alaska 
                                                                             1 
                                                                            45 
                                                                          0.2% 
                                      30 
Nebraska 
                                                                             3 
                                                                            34 
                                                                          0.7% 
                                      3 
Arizona 
                                                                             6 
                                                                            22 
                                                                          1.5% 
                                      31 
Nevada 
                                                                             5 
                                                                            28 
                                                                          1.2% 
                                      4 
Arkansas 
                                                                             4 
                                                                            32 
                                                                          1.0% 
                                      32 
New 
Hampshire 
                                                                             0 
                                                                            50 
                                                                          0.0% 
                                      5 
California 
                                                                            41 
                                                                             2 
                                                                          9.9% 
                                      33 
New Jersey 
                                                                             9 
                                                                            14 
                                                                          2.2% 
                                      6 
Colorado 
                                                                             6 
                                                                            22 
                                                                          1.5% 
                                      34 
New Mexico 
                                                                             5 
                                                                            28 
                                                                          1.2% 
                                      7 
Connecticut 
                                                                             3 
                                                                            34 
                                                                          0.7% 
                                      35 
New York 
                                                                            16 
                                                                             6 
                                                                          3.9% 
                                      8 
Delaware 
 	 	1 
                                                                            45 
                                                                          0.2% 
                                      36 
North 
Carolina 
                                                                            14 
                                                                             8 
                                                                          3.4% 
                                      9 
District of Columbia 
                                                                             0 
                                                                            50 
                                                                          0.0% 
                                      37 
North Dakota 
                                                                             3 
                                                                            34 
                                                                          0.7% 
                                      10 
Florida 
                                                                            15 
                                                                             7 
                                                                          3.6% 
                                      38 
Ohio 
                                                                            22 
                                                                             4 
                                                                          5.3% 
                                      11 
Georgia 
                                                                             7 
                                                                            19 
                                                                          1.7% 
                                      39 
Oklahoma 
                                                                             6 
                                                                            22 
                                                                          1.5% 
                                      12 
Guam 
                                                                             1 
                                                                            45 
                                                                          0.2% 
                                      40 
Oregon 
                                                                             3 
                                                                            34 
                                                                          0.7% 
                                      13 
Hawaii 
                                                                             1 
                                                                            45 
                                                                          0.2% 
                                      41 
Pennsylvania 
                                                                            24 
                                                                             3 
                                                                          5.8% 
                                      14 
Idaho 
                                                                             3 
                                                                            34 
                                                                          0.7% 
                                      42 
Puerto Rico 
                                                                             3 
                                                                            34 
                                                                          0.7% 
                                      15 
Illinois 
                                                                            13 
                                                                            10 
                                                                          3.1% 
                                      43 
Rhode Island 
                                                                             2 
                                                                            41 
                                                                          0.5% 
                                      16 
Indiana 
                                                                            13 
                                                                            10 
                                                                          3.1% 
                                      44 
South 
Carolina 
                                                                             6 
                                                                            22 
                                                                          1.5% 
                                      17 
Iowa 
                                                                             4 
                                                                            32 
                                                                          1.0% 
                                      45 
South Dakota 
                                                                             1 
                                                                            45 
                                                                          0.2% 
                                      18 
Kansas 
                                                                             6 
                                                                            22 
                                                                          1.5% 
                                      46 
Tennessee 
                                                                             8 
                                                                            15 
                                                                          1.9% 
                                      19 
Kentucky 
                                                                             8 
                                                                            15 
                                                                          1.9% 
                                      47 
Texas 
                                                                            44 
                                                                             1 
                                                                         10.7% 
                                      20 
Louisiana 
                                                                             8 
                                                                            15 
                                                                          1.9% 
                                      48 
Trust 
Territories 
                                                                             0 
                                                                            50 
                                                                          0.0% 
                                      21 
Maine 
                                                                             2 
                                                                            41 
                                                                          0.5% 
                                      49 
Utah 
                                                                            10 
                                                                            12 
                                                                          2.4% 
                                      22 
Maryland 
                                                                             3 
                                                                            34 
                                                                          0.7% 
                                      50 
Vermont 
                                                                             2 
                                                                            41 
                                                                          0.5% 
                                      23 
Massachusetts 
                                                                             7 
                                                                            19 
                                                                          1.7% 
                                      51 
Virgin Islands 
                                                                             0 
                                                                            50 
                                                                          0.0% 
                                      24 
Michigan 
                                                                            14 
                                                                             8 
                                                                          3.4% 
                                      52 
Virginia 
                                                                             5 
                                                                            28 
                                                                          1.2% 
                                      25 
Minnesota 
                                                                             6 
                                                                            22 
                                                                          1.5% 
                                      53 
Washington 
                                                                             7 
                                                                            19 
                                                                          1.7% 
                                      26 
Mississippi 
                                                                             2 
                                                                            41 
                                                                          0.5% 
                                      54 
West Virginia 
                                                                             5 
                                                                            28 
                                                                          1.2% 
                                      27 
Missouri 
                                                                            17 
                                                                             5 
                                                                          4.1% 
                                      55 
Wisconsin 
                                                                            10 
                                                                            12 
                                                                          2.4% 
                                      28 
Montana 
                                                                             0 
                                                                            50 
                                                                          0.0% 
                                      56 
Wyoming 
                                                                             0 
                                                                            50 
                                                                          0.0% 
                                                                         Total 
                                                                           413 
                                                                               
                                                                          100% 
* "Receiver TSDF" refers to those facilities receiving waste from off-site to treat, store, or dispose of it. 
Source: 2011 RCRA Biennial Report Exhibit 3.5. Available at: http://www.epa.gov/osw/inforesources/data/br11/national11.pdf 
 
 	 
                                 Exhibit 2-2 
                 Counts of Receiver TSDF Facilities by State 
                  According to the 2011 RCRA Biennial Report 
                                        
 
 
 
2.1.1.2 Quantities of Waste Received from Offsite by Receiver TSDFs 
 
According to the 2011 RCRA Biennial Report, receiver TSDFs received 6,180,031 tons of hazardous waste nationally. Texas was the state that received the largest quantity of hazardous waste (653,609 tons); Alaska (among states with receiver TSDFs receiving waste from offsite), accounted for the smallest quantity: 11 tons. Consistent with the number of receiver TSDFs, quantities of waste received are correlated with areas that have historically had significant industrial activity. The ten states that received the largest quantities of hazardous waste accounted for, 4,226,802 tons, or 68 percent of the total hazardous waste received: Texas, Ohio, Louisiana, Indiana, Michigan, Pennsylvania, Illinois, Kansas, Alabama, and New Jersey. Exhibit 2-3 displays this information below. 
 
 
                                 Exhibit 2-3 
Quantity of Hazardous Waste Received by State According to the 2011 RCRA Biennial Report 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 

                                    State 
                                Tons Received 
                                National Rank 
                                     % of 
National 
                                    Total 
                                    (B/6, 
180,031) 

                                    State 
                                Tons Received 
                                National Rank 
                                     % of 
National 
                                    Total  
                                    (B/6, 
180,031) 
                                      1 
Alabama 
                                   246,204 
                                      9 
                                     4.0% 
                                      29 
Navajo Nation 
                                      0 
                                      50 
                                     0.0% 
                                      2 
Alaska 
                                      11 
                                      49 
                                     0.0% 
                                      30 
Nebraska 
                                    37,429 
                                      27 
                                     0.6% 
                                      3 
Arizona 
                                    17,882 
                                      30 
                                     0.3% 
                                      31 
Nevada 
                                    78,743 
                                      21 
                                     1.3% 
                                      4 
Arkansas 
                                   240,584 
                                      11 
                                     3.9% 
                                      32 
New Hampshire 
                                      0 
                                      50 
                                     0.0% 
                                      5 
California 
                                   183,117 
                                      12 
                                     3.0% 
                                      33 
New Jersey 
                                   242,396 
                                      10 
                                     3.9% 
                                      6 
Colorado 
                                    43,840 
                                      26 
                                     0.7% 
                                      34 
New Mexico 
                                    4,738 
                                      37 
                                     0.1% 
                                      7 
Connecticut 
                                    8,826 
                                      35 
                                     0.1% 
                                      35 
New York 
                                    83,406 
                                      20 
                                     1.3% 
                                      8 
Delaware 
                                     115 
                                      46 
                                     0.0% 
                                      36 
North Carolina 
                                    12,276 
                                      31 
                                     0.2% 
                                      9 
District of Columbia 
                                      0 
                                      50 
                                     0.0% 
                                      37 
North Dakota 
                                     295 
                                      43 
                                     0.0% 
                                      10 
Florida 
                                    10,760 
                                      32 
                                     0.2% 
                                      38 
Ohio 
                                   621,070 
                                      2 
                                    10.0% 
                                      11 
Georgia 
                                    3,861 
                                      38 
                                     0.1% 
                                      39 
Oklahoma 
                                    94,277 
                                      19 
                                     1.5% 
                                      12 
Guam 
                                      37 
                                      48 
                                     0.0% 
                                      40 
Oregon 
                                    55,174 
                                      23 
                                     0.9% 
                                      13 
Hawaii 
                                     190 
                                      44 
                                     0.0% 
                                      41 
Pennsylvania 
                                   428,355 
                                      6 
                                     6.9% 
                                      14 
Idaho 
                                   112,238 
                                      17 
                                     1.8% 
                                      42 
Puerto Rico 
                                    1,184 
                                      40 
                                     0.0% 
                                      15 
Illinois 
                                   379,907 
                                      7 
                                     6.1% 
                                      43 
Rhode Island 
                                    10,001 
                                      33 
                                     0.2% 
                                      16 
Indiana 
                                   463,055 
                                      4 
                                     7.5% 
                                      44 
South Carolina 
                                   154,608 
                                      14 
                                     2.5% 
                                      17 
Iowa 
                                     570 
                                      41 
                                     0.0% 
                                      45 
South Dakota 
                                     102 
                                      47 
                                     0.0% 
                                      18 
Kansas 
                                   262,248 
                                      8 
                                     4.2% 
                                      46 
Tennessee 
                                    28,854 
                                      28 
                                     0.5% 
                                      19 
Kentucky 
                                   106,383 
                                      18 
                                     1.7% 
                                      47 
Texas 
                                   653,609 
                                      1 
                                    10.6% 
                                      20 
Louisiana 
                                   486,260 
                                      3 
                                     7.9% 
                                      48 
Trust Territories 
                                      0 
                                      50 
                                     0.0% 
                                      21 
Maine 
                                     141 
                                      45 
                                     0.0% 
                                      49 
Utah 
                                   145,602 
                                      16 
                                     2.4% 
                                      22 
Maryland 
                                    56,462 
                                      22 
                                     0.9% 
                                      50 
Vermont 
                                    1,511 
                                      39 
                                     0.0% 
                                      23 
Massachusetts 
                                    8,917 
                                      34 
                                     0.1% 
                                      51 
Virgin Islands 
                                      0 
                                      50 
                                     0.0% 
                                      24 
Michigan 
                                   443,698 
                                      5 
                                     7.2% 
                                      52 
Virginia 
                                     535 
                                      42 
                                     0.0% 
                                      25 
Minnesota 
                                   169,083 
                                      13 
                                     2.7% 
                                      53 
Washington 
                                    51,895 
                                      25 
                                     0.8% 
                                      26 
Mississippi 
                                    17,926 
                                      29 
                                     0.3% 
                                      54 
West Virginia 
                                    6,426 
                                      36 
                                     0.1% 
                                      27 
Missouri 
                                   152,381 
                                      15 
                                     2.5% 
                                      55 
Wisconsin 
                                    52,849 
                                      24 
                                     0.9% 
                                      28 
Montana 
                                      0 
                                      50 
                                     0.0% 
                                      56 
Wyoming 
                                      0 
                                      50 
                                     0.0% 
                                                                         Total 
6,180,031 
                                        
                                     100% 
Source: 2011 RCRA Biennial Report Exhibit 3.5. Available at: http://www.epa.gov/osw/inforesources/data/br11/national11.pdf 
 
2.1.2 Generators 
 
Generators are the largest and most diverse category of industrial entities subject to RCRA manifest requirements and therefore affected by the rule. Generators include any facility that produces listed or characteristic hazardous waste as defined in 40 CFR Part 261 or any other waste defined as hazardous by a state authorized to implement RCRA. Generators fall into five categories of relevance related to the rulemaking. Three of them, Federal Large Quantity Generators (LQGs), Federal Small Quantity Generators (SQGs), Federal Conditionally Exempt Small Quantity Generators (CESQGs), are defined in the federal RCRA program. Two other categories reflect specific state programs: generators of state (non-federal) hazardous wastes and generators of hazardous wastes that are exempt from federal RCRA manifest requirements but subject to state manifest requirements. Generators that treat waste onsite and do not ship it offsite are not required to use manifests are not in the universe affected by the proposed rule.  
 
The way in which generators develop manifests and therefore interact with the e-Manifest system will likely vary across the universe. Larger, more sophisticated generators may initiate manifests (i.e., create the manifest and enter relevant material, quantity, and shipment information), while smaller generators may allow the receiving TSDF to initiate manifests on their behalf. EPA anticipates that all generators (even those who still generate paper manifests) will use the e-Manifest system to meet requirements for ensuring their waste has been 
successfully been shipped and their manifests have been successfully finalized and submitted.  
 
Throughout this chapter and the remainder of this RIA, the term "shipper" is used to describe the subset of hazardous waste generators in each category who ship their hazardous waste off-site and are therefore subject to the proposed rule. This RIA avoids describing these entities solely as "generators" because different types of generators are specifically defined by RCRA, and include facilities not affected by the proposed rule. 
 
2.1.2.1 Large Quantity Generators 
 
Large quantity generators (LQGs) are facilities that produce greater than or equal to 1,000 kilograms of hazardous waste in a month or greater than 1 kg of acute hazardous waste in a month. LQGs are required to report their activities to EPA; as a result, according to the 2011 RCRA Biennial Report, approximately 87 percent of the facilities reporting waste shipments offsite are LQGs (14,262 facilities).  
 
National and State Counts of LQG Facilities and non-LQG TSDF Shipper Facilities 
 
The RCRA Biennial Report reflects data compiled from waste reports submitted by LQG facilities as a part of their reporting obligations under RCRA, and provides a comprehensive overview of the LQG universe that may be subject to the proposed rule. The Biennial Report identifies LQGs as facilities that generate hazardous wastes above certain quantities as a byproduct of primary operations. The Biennial Report also identifies "non-LQGs," a category of facilities that has been interpreted in prior RCRA hazardous waste manifest ICRs and economic analyses as TSDF facilities that are similar to LQGs because they ship waste offsite to other TSDFs in sufficient quantities to meet LQG classification thresholds. Both LQG and non-LQG shipping TSDFs are considered potentially affected facilities and counted in this RIA.[15] According to the 2011 RCRA Biennial Report 16,447 facilities operating in 2011 generated sufficient quantities of hazardous (or acutely hazardous) waste to meet the LQG threshold.[16] Of these, the 2011 Biennial Report data indicate that 16,345 LQGs and non-LQG TSDF shippers shipped hazardous waste offsite for treatment in 2011; these facilities are subject to manifest requirements and affected by the proposed rule.[17] 
 
The geographic distribution of LQGs and non-LQG TSDF shippers is similar to that of receiver 
TSDFs. Exhibit 2-4 displays Biennial Report data on LQG locations; about half of the LQGs (approximately 52 percent) reported in the 2011 RCRA Biennial Report are located in 10 states.[18] The number of LQGs and non-LQG TSDF shippers varies considerably across states. New York, the state with the most reported LQGs and non-LQG TSDF shippers, has 1,473, while North Dakota, the state with the fewest reported number of LQGs and non-LQG TSDF shippers, has 18. 
 
                                 Exhibit 2-4 
Count of LQGs and Non-LQG TSDF shippers by State from the 2011 RCRA Biennial Report 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 

                                    State 
                                 LQG Shipper 
                                  Facilities 
                                    Non-LQG 
TSDF Shipper 
                                  Facilities 
                                 Total (B + C) 
                                National Rank 
                             % of National Total 
                                  (D/16,345) 
                                      1 
Alabama 
                                                                           223 
                                                                            16 
                                                                           239 
                                                                            24 
                                                                          1.5% 
                                      2 
Alaska 
                                                                            27 
                                                                            15 
                                                                            42 
                                                                            46 
                                                                          0.3% 
                                      3 
Arizona 
                                                                           211 
                                                                            14 
                                                                           225 
                                                                            25 
                                                                          1.4% 
                                      4 
Arkansas 
                                                                           122 
                                                                            20 
                                                                           142 
                                                                            32 
                                                                          0.9% 
                                      5 
California 
                                                                         1,226 
                                                                            26 
                                                                          1252 
                                                                             2 
                                                                          7.7% 
                                      6 
Colorado 
                                                                           107 
                                                                            51 
                                                                           158 
                                                                            30 
                                                                          1.0% 
                                      7 
Connecticut 
                                                                           279 
                                                                            16 
                                                                           295 
                                                                            21 
                                                                          1.8% 
                                      8 
Delaware 
                                                                            49 
                                                                            10 
                                                                            59 
                                                                            42 
                                                                          0.4% 
                                      9 
District of Columbia 
                                                                            23 
                                                                             1 
                                                                            24 
                                                                            50 
                                                                          0.1% 
                                      10 
Florida 
                                                                           278 
                                                                           171 
                                                                           449 
                                                                            12 
                                                                          2.7% 
                                      11 
Georgia 
                                                                           331 
                                                                            52 
                                                                           383 
                                                                            15 
                                                                          2.3% 
                                      12 
Guam 
                                                                             8 
                                                                             0 
                                                                             8 
                                                                            53 
                                                                          0.0% 
                                      13 
Hawaii 
                                                                            30 
                                                                            19 
                                                                            49 
                                                                            43 
                                                                          0.3% 
                                      14 
Idaho 
                                                                            18 
                                                                            21 
                                                                            39 
                                                                            49 
                                                                          0.2% 
                                      15 
Illinois 
                                                                           640 
                                                                           230 
                                                                           870 
                                                                             5 
                                                                          5.3% 
                                      16 
Indiana 
                                                                           501 
                                                                            14 
                                                                           515 
                                                                            10 
                                                                          3.2% 
                                      17 
Iowa 
                                                                           128 
                                                                            32 
                                                                           160 
                                                                            29 
                                                                          1.0% 
                                      18 
Kansas 
                                                                           170 
                                                                            44 
                                                                           214 
                                                                            26 
                                                                          1.3% 
                                                                                                                                                                                           
LQG" hazardous waste generator TSDFs overlap. It is possible that some of these facilities generate hazardous waste and ship it to other receiver TSDFs, while also functioning as receiver TSDFs for hazardous waste shipments from other generators. . 
   Individual facilities are tracked by EPA using unique RCRA IDs assigned to each facility. Based on permitting status across various RCRA requirements, it is possible for a TSDF that receives waste from off-site (i.e., a receiver TSDF) to also function as a non-LQG shipper. The 2011 Biennial Report indicates that LQGs are the vast majority of hazardous waste shippers, but does not delineate the volume of hazardous waste shipped by LQGs relative to nonLQG TSDF shippers. 
   2011 RCRA Biennial Report Exhibit 1.1. Available at: 
http://www.epa.gov/osw/inforesources/data/br11/national11.pdf [17] 2011 RCRA Biennial Report Exhibit 3.1. Available at: 
http://www.epa.gov/osw/inforesources/data/br11/national11.pdf 
[18] These states are New York, California, Texas, Ohio, Illinois, Pennsylvania, New Jersey, North Carolina, Wisconsin, and Indiana. 
                                 Exhibit 2-4 
Count of LQGs and Non-LQG TSDF shippers by State from the 2011 RCRA Biennial Report 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 

                                    State 
                                 LQG Shipper 
                                  Facilities 
                                    Non-LQG 
TSDF Shipper 
                                  Facilities 
                                 Total (B + C) 
                                National Rank 
                             % of National Total 
                                  (D/16,345) 
                                      19 
Kentucky 
                                                                           264 
                                                                             0 
                                                                           264 
                                                                            23 
                                                                          1.6% 
                                      20 
Louisiana 
                                                                           330 
                                                                            37 
                                                                           367 
                                                                            17 
                                                                          2.2% 
                                      21 
Maine 
                                                                            52 
                                                                            14 
                                                                            66 
                                                                            41 
                                                                          0.4% 
                                      22 
Maryland 
                                                                           130 
                                                                             2 
                                                                           132 
                                                                            34 
                                                                          0.8% 
                                      23 
Massachusetts 
                                                                           406 
                                                                            43 
                                                                           449 
                                                                            12 
                                                                          2.7% 
                                      24 
Michigan 
                                                                           346 
                                                                           126 
                                                                           472 
                                                                            11 
                                                                          2.9% 
                                      25 
Minnesota 
                                                                           320 
                                                                             2 
                                                                           322 
                                                                            19 
                                                                          2.0% 
                                      26 
Mississippi 
                                                                           125 
                                                                             0 
                                                                           125 
                                                                            35 
                                                                          0.8% 
                                      27 
Missouri 
                                                                           280 
                                                                            55 
                                                                           335 
                                                                            18 
                                                                          2.0% 
                                      28 
Montana 
                                                                            40 
                                                                             0 
                                                                            40 
                                                                            48 
                                                                          0.2% 
                                      29 
Navajo Nation 
                                                                             1 
                                                                             0 
                                                                             1 
                                                                            56 
                                                                          0.0% 
                                      30 
Nebraska 
                                                                            63 
                                                                            20 
                                                                            83 
                                                                            39 
                                                                          0.5% 
                                      31 
Nevada 
                                                                            66 
                                                                            33 
                                                                            99 
                                                                            37 
                                                                          0.6% 
                                      32 
New Hampshire 
                                                                           100 
                                                                            52 
                                                                           152 
                                                                            31 
                                                                          0.9% 
                                      33 
New Jersey 
                                                                           562 
                                                                            99 
                                                                           661 
                                                                             7 
                                                                          4.0% 
                                      34 
New Mexico 
                                                                            39 
                                                                             5 
                                                                            44 
                                                                            45 
                                                                          0.3% 
                                      35 
New York 
                                                                         1,473 
                                                                             0 
                                                                          1473 
                                                                             1 
                                                                          9.0% 
                                      36 
North Carolina 
                                                                           440 
                                                                           102 
                                                                           542 
                                                                             8 
                                                                          3.3% 
                                      37 
North Dakota 
                                                                            18 
                                                                             0 
                                                                            18 
                                                                            52 
                                                                          0.1% 
                                      39 
Ohio 
                                                                           712 
                                                                           197 
                                                                           909 
                                                                             4 
                                                                          5.6% 
                                      40 
Oklahoma 
                                                                           168 
                                                                            22 
                                                                           190 
                                                                            27 
                                                                          1.2% 
                                      41 
Oregon 
                                                                           179 
                                                                             0 
                                                                           179 
                                                                            28 
                                                                          1.1% 
                                      42 
Pennsylvania 
                                                                           672 
                                                                           177 
                                                                           849 
                                                                             6 
                                                                          5.2% 
                                      43 
Puerto Rico 
                                                                            76 
                                                                             3 
                                                                            79 
                                                                            40 
                                                                          0.5% 
                                      44 
Rhode Island 
                                                                            64 
                                                                            27 
                                                                            91 
                                                                            38 
                                                                          0.6% 
                                      45 
South Carolina 
                                                                           256 
                                                                            27 
                                                                           283 
                                                                            22 
                                                                          1.7% 
                                      46 
South Dakota 
                                                                            32 
                                                                             9 
                                                                            41 
                                                                            47 
                                                                          0.3% 
                                      47 
Tennessee 
                                                                           321 
                                                                             0 
                                                                           321 
                                                                            20 
                                                                          2.0% 
                                      48 
Texas 
                                                                           990 
                                                                             0 
                                                                           990 
                                                                             3 
                                                                          6.1% 
                                      49 
Trust Territories 
                                                                             1 
                                                                             2 
                                                                             3 
                                                                            54 
                                                                          0.0% 
                                      50 
Utah 
                                                                           112 
                                                                             1 
                                                                           113 
                                                                            36 
                                                                          0.7% 
                                      51 
Vermont 
                                                                            39 
                                                                             9 
                                                                            48 
                                                                            44 
                                                                          0.3% 
                                      52 
Virgin Islands 
                                                                             2 
                                                                             0 
                                                                             2 
                                                                            55 
                                                                          0.0% 
                                      53 
Virginia 
                                                                           212 
                                                                           168 
                                                                           380 
                                                                            16 
                                                                          2.3% 
                                      54 
Washington 
                                                                           417 
                                                                             1 
                                                                           418 
                                                                            14 
                                                                          2.6% 
                                      55 
West Virginia 
                                                                            99 
                                                                            43 
                                                                           142 
                                                                            32 
                                                                          0.9% 
                                      56 
Wisconsin 
                                                                           381 
                                                                           139 
                                                                           520 
                                                                             9 
                                                                          3.2% 
                                      57 
Wyoming 
                                                                            15 
                                                                             4 
                                                                            19 
                                                                            51 
                                                                          0.1% 
                                                                         Total 
                                                                        14,174 
                                                                         2,171 
                                                                        16,345 
                                                                               
                                                                          100% 
Source: 2011 RCRA Biennial Report Exhibit 3.1. Available at: http://www.epa.gov/osw/inforesources/data/br11/national11.pdf 
 
National and State Counts of Hazardous Waste shipped offsite for treatment by LQGs and nonLQG TSDF Shippers 
 
The 2011 RCRA Biennial Report also provides data on the quantities of hazardous waste generated and shipped by LQGs. According to the 2011 RCRA Biennial Report, LQGs and nonLQG TSDFs generated 34,334,072 tons of hazardous waste nationally; the bulk of this waste is treated onsite by facilities that also have permitted treatment, storage, and disposal operations. According to the Biennial Report, in 2011 5,951,421 tons of hazardous waste, about 17 percent of the tons generated, was shipped offsite for treatment, storage, or disposal, and therefore subject to accompanying manifest requirements. LQGs and non-LQG TSDF shippers in Texas shipped the largest quantity of hazardous waste offsite (607,321 tons), while LQGs and nonLQG TSDF shippers in North Dakota shipped the fewest, 1,179 tons (Exhibit 2-5). 
 
                                 Exhibit 2-5 
Tons of Hazardous Waste Shipped by LQGs and Non-LQG TSDF Shippers According to the 2011 RCRA Biennial 
                                    Report 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 

                                    State 
                                 Tons Shipped 
                                National Rank 
                      % of National Total (B/5,951,421) 
                                      1 
Alabama 
                                                                       192,988 
                                                                            10 
                                                                          3.2% 
                                      2 
Alaska 
                                                                         2,010 
                                                                            48 
                                                                          0.0% 
                                      3 
Arizona 
                                                                        26,453 
                                                                            37 
                                                                          0.4% 
                                      4 
Arkansas 
                                                                       206,634 
                                                                             8 
                                                                          3.5% 
                                      5 
California 
                                                                       428,745 
                                                                             4 
                                                                          7.2% 
                                      6 
Colorado 
                                                                        34,621 
                                                                            34 
                                                                          0.6% 
                                      7 
Connecticut 
                                                                        24,080 
                                                                            38 
                                                                          0.4% 
                                      8 
Delaware 
                                                                        42,992 
                                                                            29 
                                                                          0.7% 
                                      9 
District of Columbia 
                                                                         1,139 
                                                                            53 
                                                                          0.0% 
                                      10 
Florida 
                                                                        33,513 
                                                                            35 
                                                                          0.6% 
                                      11 
Georgia 
                                                                        42,299 
                                                                            30 
                                                                          0.7% 
                                      12 
Guam 
                                                                            88 
                                                                            54 
                                                                          0.0% 
                                      13 
Hawaii 
                                                                         1,300 
                                                                            51 
                                                                          0.0% 
                                      14 
Idaho 
                                                                         6,353 
                                                                            42 
                                                                          0.1% 
                                      15 
Illinois 
                                                                       205,010 
                                                                             9 
                                                                          3.4% 
                                      16 
Indiana 
                                                                       389,389 
                                                                             5 
                                                                          6.5% 
                                      17 
Iowa 
                                                                        50,702 
                                                                            27 
                                                                          0.9% 
                                      18 
Kansas 
                                                                       135,492 
                                                                            16 
                                                                          2.3% 
                                      19 
Kentucky 
                                                                       181,968 
                                                                            11 
                                                                          3.1% 
                                      20 
Louisiana 
                                                                       516,470 
                                                                             3 
                                                                          8.7% 
                                      21 
Maine 
                                                                         2,324 
                                                                            47 
                                                                          0.0% 
                                      22 
Maryland 
                                                                        54,574 
                                                                            25 
                                                                          0.9% 
                                 Exhibit 2-5 
Tons of Hazardous Waste Shipped by LQGs and Non-LQG TSDF Shippers According to the 2011 RCRA Biennial 
                                    Report 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 

                                    State 
                                 Tons Shipped 
                                National Rank 
                      % of National Total (B/5,951,421) 
                                      23 
Massachusetts 
                                                                        42,013 
                                                                            31 
                                                                          0.7% 
                                      24 
Michigan 
                                                                       177,852 
                                                                            12 
                                                                          3.0% 
                                      25 
Minnesota 
                                                                        69,223 
                                                                            24 
                                                                          1.2% 
                                      26 
Mississippi 
                                                                        72,996 
                                                                            22 
                                                                          1.2% 
                                      27 
Missouri 
                                                                        80,894 
                                                                            18 
                                                                          1.4% 
                                      28 
Montana 
                                                                         5,956 
                                                                            43 
                                                                          0.1% 
                                      29 
Navajo Nation 
                                                                            28 
                                                                            55 
                                                                          0.0% 
                                      30 
Nebraska 
                                                                        43,653 
                                                                            28 
                                                                          0.7% 
                                      31 
Nevada 
                                                                        11,932 
                                                                            40 
                                                                          0.2% 
                                      32 
New Hampshire 
                                                                         3,949 
                                                                            45 
                                                                          0.1% 
                                      33 
New Jersey 
                                                                       328,224 
                                                                             6 
                                                                          5.5% 
                                      34 
New Mexico 
                                                                        10,387 
                                                                            41 
                                                                          0.2% 
                                      35 
New York 
                                                                       165,811 
                                                                            15 
                                                                          2.8% 
                                      36 
North Carolina 
                                                                        91,039 
                                                                            17 
                                                                          1.5% 
                                      37 
North Dakota 
                                                                         1,179 
                                                                            52 
                                                                          0.0% 
                                      38 
Ohio 
                                                                       565,599 
                                                                             2 
                                                                          9.5% 
                                      39 
Oklahoma 
                                                                        29,941 
                                                                            36 
                                                                          0.5% 
                                      40 
Oregon 
                                                                        77,564 
                                                                            20 
                                                                          1.3% 
                                      41 
Pennsylvania 
                                                                       262,668 
                                                                             7 
                                                                          4.4% 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

                                       
                                       
                                       
                                       
                                      42 
Puerto Rico 
                                                                        35,153 
                                                                            33 
                                                                          0.6% 
                                      43 
Rhode Island 
                                                                        16,239 
                                                                            39 
                                                                          0.3% 
                                      44 
South Carolina 
                                                                       171,165 
                                                                            14 
                                                                          2.9% 
                                      45 
South Dakota 
                                                                         1,394 
                                                                            49 
                                                                          0.0% 
                                      46 
Tennessee 
                                                                        52,837 
                                                                            26 
                                                                          0.9% 
                                      47 
Texas 
                                                                       607,321 
                                                                             1 
                                                                         10.2% 
                                      48 
Trust Territories 
                                                                            14 
                                                                            56 
                                                                          0.0% 
                                      49 
Utah 
                                                                        79,429 
                                                                            19 
                                                                          1.3% 
                                      50 
Vermont 
                                                                         2,592 
                                                                            46 
                                                                          0.0% 
                                      51 
Virgin Islands 
                                                                         1,325 
                                                                            50 
                                                                          0.0% 
                                      52 
Virginia 
                                                                        71,565 
                                                                            23 
                                                                          1.2% 
                                      53 
Washington 
                                                                        75,742 
                                                                            21 
                                                                          1.3% 
                                      54 
West Virginia 
                                                                        39,478 
                                                                            32 
                                                                          0.7% 
                                      55 
Wisconsin 
                                                                       173,034 
                                                                            13 
                                                                          2.9% 
                                      56 
Wyoming 
                                                                         4,079 
                                                                            44 
                                                                          0.1% 
                                        
                                                                         Total 
                                                                     5,951,421 
 
                                     100% 
Source: 2011 RCRA Biennial Report Exhibit 3.1. Available at: http://www.epa.gov/osw/inforesources/data/br11/national11.pdf 
 
2.1.2.2 Small Quantity Generators 
 
Small Quantity Generators (SQGs) are facilities that produce between 100 kilograms and 1,000 kilograms of hazardous waste, in a month. SQGs are far more numerous than LQGs, but produce and ship less hazardous waste, though relatively few SQGs treat waste on site. SQGs are subject to fewer reporting requirements under RCRA than LQGs; as a result data to describe the population of SQGs are more limited. 
 
National and State Counts of SQG Facilities 
 
The universe of SQGs operating in the U.S. is more difficult to accurately characterize than the universe of LQGs, because SQGs are not required by RCRA to submit data to the Biennial Report. SQGs are required to obtain a RCRA ID number and notify state regulators and EPA of their status the first time they generate a sufficient quantity of hazardous waste to meet the SQG threshold. However, SQGs are not required to recertify or follow up in subsequent years, making it difficult to verify that their status has not changed over time. Because the Biennial Report includes only facilities that actively generate data in a given year and are required to report, the total number of operating SQGs is not readily available. 
 
To estimate the size of the SQG universe, this RIA uses the estimation approaches and results in EPA's 2015 Improvements to the Hazardous Waste Generator Regulatory Program proposed rule RIA. In that RIA, EPA pioneered two methodologies to estimate active SQGs; both estimates use the data files that underpin the RCRA Biennial Report.  
 
For the low-end estimate, EPA used the Waste Received (WR) form in the underlying Biennial Report data files to identify the facilities that shipped hazardous waste off-site; the analysis then cross-checked this list against the Site ID form in RCRAInfo to identify active SQGs in 2011. This universe was then supplemented with new SQGs notifying after a certain cutoff date (at which point they may not have been captured on the WR forms) and available state-level information on SQG universes. This low-end estimate of approximately 45,800 SQGs may omit some SQGs that manage hazardous waste on site, or SQGs that TSDFs failed to report on data forms specific to the Biennial Report. 
 
The approach to the high-end estimate of SQGs is similar to that of the low-end estimate, but uses WR forms from each of the three Biennial Report cycles of 2007, 2009, or 2011 to identify SQGs shipping waste off-site in any of those three periods. This approach was similarly supplemented with available state-level data and other information as described for the low-end approach. Because some facilities may have been SQGs for one reporting cycle, but not for others, this approach may lead to an overestimate of the current universe of SQGs, or the universe of SQGs at any specific point in time in recent history. This alternative approach leads to a high-end estimate of approximately 59,700 SQGs nationwide. 
 
This RIA averages the estimates from these two approaches, which leads to an estimate of 52,732 SQGs nationwide. For a small number of states, EPA was able to obtain specific estimates for the count of SQGs within the state; in these cases, no averaging was applied and EPA used the actual count of SQGs instead.  
 
Like LQGs and TSDFs, SQGs are located throughout the U.S., but tend to be concentrated in industrial areas. The 10 states with the most SQGs account for almost 60 percent of the national total. The number of SQGs varies considerably across states. California, the state with the most estimated SQGs, has 5,915, while Montana, the state with the fewest estimated SQGs, has 66 (Exhibit 2-6).  
 
Similar to LQGs, not all of the SQGs identified by EPA as detailed above engage in shipping hazardous waste; EPA separately estimated within the 2015 Improvements to the Hazardous Waste Generator Regulatory Program proposed rule RIA that only 77 percent of SQG-generated hazardous waste is sent offsite for treatment, storage, or disposal. This RIA assumes that the proportion of waste shipped off-site equates to the proportion of SQGs shipping hazardous waste off-site. That is, as shown in Exhibit 2-6, only 77 percent of the estimated number of SQGs in each state is assumed to ship hazardous waste off-site, and thus be subject to the proposed rule.  
 

                                 Exhibit 2-6 
                          Estimate of SQGs by State 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 

                                    State 
                                 Low Count[a] 
                                High Count[a] 
                              Average (B+C)/2[a] 
                                     Rank 
                              % Total (D/52,732) 
                       Estimated Count of SQGs Shipping 
Off-Site (D * 0.77) 
                                      1 
Alabama 
                                                                         1,226 
                                                                         1,226 
                                                                         1,226 
                                                                            16 
                                                                          2.3% 
                                                                           944 
                                      2 
Alaska 
                                                                            96 
                                                                           143 
                                                                           120 
                                                                            46 
                                                                          0.2% 
                                                                            92 
                                      3 
Arizona 
                                                                           511 
                                                                           770 
                                                                           641 
                                                                            23 
                                                                          1.2% 
                                                                           494 
                                      4 
Arkansas 
                                                                           256 
                                                                           318 
                                                                           287 
                                                                            34 
                                                                          0.5% 
                                                                           221 
                                      5 
California 
                                                                         5,915 
                                                                         5,915 
                                                                         5,915 
                                                                             1 
                                                                         11.2% 
                                                                          4555 
                                      6 
Colorado 
                                                                           434 
                                                                           482 
                                                                           458 
                                                                            29 
                                                                          0.9% 
                                                                           353 
                                      7 
Connecticut 
                                                                           756 
                                                                         1,092 
                                                                           924 
                                                                            19 
                                                                          1.8% 
                                                                           711 
                                      8 
Delaware 
                                                                           155 
                                                                           218 
                                                                           187 
                                                                            44 
                                                                          0.4% 
                                                                           144 
                                      9 
District of Columbia 
                                                                            36 
                                                                            74 
                                                                            55 
                                                                            52 
                                                                          0.1% 
                                                                            42 
                                      10 
Florida 
                                                                         3,800 
                                                                         3,800 
                                                                         3,800 
                                                                             3 
                                                                          7.2% 
                                                                          2926 
                                      11 
Georgia 
                                                                           900 
                                                                         1,288 
                                                                         1,094 
                                                                            17 
                                                                          2.1% 
                                                                           842 
                                      12 
Guam 
                                                                             3 
                                                                             8 
                                                                             6 
                                                                            54 
                                                                          0.0% 
                                                                             5 
                                      13 
Hawaii 
                                                                           122 
                                                                           165 
                                                                           144 
                                                                            45 
                                                                          0.3% 
                                                                           111 
                                      14 
Idaho 
                                                                            79 
                                                                            89 
                                                                            84 
                                                                            49 
                                                                          0.2% 
                                                                            65 
                                      15 
Illinois 
                                                                         2,958 
                                                                         4,897 
                                                                         3,928 
                                                                             2 
                                                                          7.4% 
                                                                          3025 
                                      16 
Indiana 
                                                                           790 
                                                                         1,156 
                                                                           973 
                                                                            18 
                                                                          1.8% 
                                                                           749 
                                      17 
Iowa 
                                                                           471 
                                                                           675 
                                                                           573 
                                                                            27 
                                                                          1.1% 
                                                                           441 
                                      18 
Kansas 
                                                                           480 
                                                                           680 
                                                                           580 
                                                                            25 
                                                                          1.1% 
                                                                           447 
                                      19 
Kentucky 
                                                                           355 
                                                                           469 
                                                                           412 
                                                                            31 
                                                                          0.8% 
                                                                           317 
                                      20 
Louisiana 
                                                                           705 
                                                                         1,068 
                                                                           887 
                                                                            20 
                                                                          1.7% 
                                                                           683 
                                      21 
Maine 
                                                                           304 
                                                                           304 
                                                                           304 
                                                                            33 
                                                                          0.6% 
                                                                           234 
                                      22 
Maryland 
                                                                           974 
                                                                         1,780 
                                                                         1,377 
                                                                            13 
                                                                          2.6% 
                                                                          1060 
                                      23 
Massachusetts 
                                                                         2,683 
                                                                         2,683 
                                                                         2,683 
                                                                             5 
                                                                          5.1% 
                                                                          2066 
                                      24 
Michigan 
                                                                         1,486 
                                                                         2,194 
                                                                         1,840 
                                                                             8 
                                                                          3.5% 
                                                                          1417 
                                      25 
Minnesota 
                                                                         1,366 
                                                                         1,366 
                                                                         1,366 
                                                                            14 
                                                                          2.6% 
                                                                          1052 
                                      26 
Mississippi 
                                                                           210 
                                                                           286 
                                                                           248 
                                                                            37 
                                                                          0.5% 
                                                                           191 
                                      27 
Missouri 
                                                                         1,279 
                                                                         1,727 
                                                                         1,503 
                                                                            11 
                                                                          2.9% 
                                                                          1157 
                                      28 
Montana 
                                                                            55 
                                                                            77 
                                                                            66 
                                                                            51 
                                                                          0.1% 
                                                                            51 
                                      29 
Navajo Nation 
                                                                             6 
                                                                             6 
                                                                             6 
                                                                            53 
                                                                          0.0% 
                                                                             5 
                                      30 
Nebraska 
                                                                           226 
                                                                           273 
                                                                           250 
                                                                            36 
                                                                          0.5% 
                                                                           193 
                                      31 
Nevada 
                                                                           196 
                                                                           280 
                                                                           238 
                                                                            38 
                                                                          0.5% 
                                                                           183 
                                      32 
New Hampshire 
                                                                           201 
                                                                           201 
                                                                           201 
                                                                            41 
                                                                          0.4% 
                                                                           155 
                                 Exhibit 2-6 
                          Estimate of SQGs by State 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 

                                    State 
                                 Low Count[a] 
                                High Count[a] 
                              Average (B+C)/2[a] 
                                     Rank 
                              % Total (D/52,732) 
                       Estimated Count of SQGs Shipping 
Off-Site (D * 0.77) 
                                      33 
New Jersey 
                                                                           850 
                                                                           850 
                                                                           850 
                                                                            21 
                                                                          1.6% 
                                                                           655 
                                      34 
New Mexico 
                                                                           156 
                                                                           236 
                                                                           196 
                                                                            42 
                                                                          0.4% 
                                                                           151 
                                      35 
New York 
                                                                         1,983 
                                                                         3,255 
                                                                         2,619 
                                                                             7 
                                                                          5.0% 
                                                                          2017 
                                      36 
North Carolina 
                                                                         1,169 
                                                                         1,786 
                                                                         1,478 
                                                                            12 
                                                                          2.8% 
                                                                          1138 
                                      37 
North Dakota 
                                                                            62 
                                                                            78 
                                                                            70 
                                                                            50 
                                                                          0.1% 
                                                                            54 
                                      38 
Ohio 
                                                                         2,041 
                                                                         3,240 
                                                                         2,641 
                                                                             6 
                                                                          5.0% 
                                                                          2034 
                                      39 
Oklahoma 
                                                                           379 
                                                                           502 
                                                                           441 
                                                                            30 
                                                                          0.8% 
                                                                           340 
                                      40 
Oregon 
                                                                           235 
                                                                           285 
                                                                           260 
                                                                            35 
                                                                          0.5% 
                                                                           200 
                                      41 
Pennsylvania 
                                                                         2,721 
                                                                         4,293 
                                                                         3,507 
                                                                             4 
                                                                          6.7% 
                                                                          2700 
                                      42 
Puerto Rico 
                                                                            96 
                                                                           115 
                                                                           106 
                                                                            47 
                                                                          0.2% 
                                                                            82 
                                      43 
Rhode Island 
                                                                           700 
                                                                           700 
                                                                           700 
                                                                            22 
                                                                          1.3% 
                                                                           539 
                                      44 
South Carolina 
                                                                           485 
                                                                           722 
                                                                           604 
                                                                            24 
                                                                          1.1% 
                                                                           465 
                                      45 
South Dakota 
                                                                           182 
                                                                           256 
                                                                           219 
                                                                            39 
                                                                          0.4% 
                                                                           169 
                                      46 
Tennessee 
                                                                           442 
                                                                           710 
                                                                           576 
                                                                            26 
                                                                          1.1% 
                                                                           444 
                                      47 
Texas 
                                                                         1,471 
                                                                         2,164 
                                                                         1,818 
                                                                             9 
                                                                          3.4% 
                                                                          1400 
                                      48 
Trust Territories 
                                                                             3 
                                                                             5 
                                                                             4 
                                                                            56 
                                                                          0.0% 
                                                                             3 
                                      49 
Utah 
                                                                           174 
                                                                           205 
                                                                           190 
                                                                            43 
                                                                          0.4% 
                                                                           146 
                                      50 
Vermont 
                                                                           185 
                                                                           250 
                                                                           218 
                                                                            40 
                                                                          0.4% 
                                                                           168 
                                      51 
Virgin Islands 
                                                                             6 
                                                                             5 
                                                                             6 
                                                                            54 
                                                                          0.0% 
                                                                             5 
                                      52 
Virginia 
                                                                         1,274 
                                                                         2,029 
                                                                         1,652 
                                                                            10 
                                                                          3.1% 
                                                                          1272 
                                      53 
Washington 
                                                                           532 
                                                                           604 
                                                                           568 
                                                                            28 
                                                                          1.1% 
                                                                           437 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

                                       
                                       
                                       
                                       
                                       
                                       
                                       

                                      54 
West Virginia 
                                                                           280 
                                                                           376 
                                                                           328 
                                                                            32 
                                                                          0.6% 
                                                                           253 
                                      55 
Wisconsin 
                                                                         1,227 
                                                                         1,227 
                                                                         1,227 
                                                                            15 
                                                                          2.3% 
                                                                           945 
                                      56 
Wyoming 
                                                                            75 
                                                                            99 
                                                                            87 
                                                                            48 
                                                                          0.2% 
                                                                            67 
                                                                               
                                                                         Total 
                                                                        45,762 
                                                                        59,702 
                                                                        52,732 
                                                                               
                                                                        100.0% 
                                                                        40,604 
Source: 2015 Improvements to the Hazardous Waste Generator Regulatory Program proposed rule RIA. Available at: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2012-0121-0002.  a In cases where the Improvements to the Hazardous Waste Generator Regulatory Program proposed rule RIA contained specific estimates for the count of SQGs in a given state, no averaging is applied, and columns B, C, and D report the actual count of SQGs within the state. 
 
SQGs Operating under Reclamation Agreements 
 
Even among SQGs that ship waste off-site, not all hazardous waste shipped requires a manifest. Specifically, hazardous waste that is transported and covered under a bona-fide reclamation agreement (BFRA) is not required to have accompanying manifests, unless the SQG is in a state that explicitly requires manifests for hazardous waste sent for reclamation and recovery. 
 
EPA estimates that 10 percent of all SQG-generated hazardous waste is managed off-site via reclamation and recovery. Note that this fraction is a subset of the 77 percent of SQG-generated hazardous waste shipped off-site. Correspondingly, if it is assumed that SQGs who use BFRAs manage all of their hazardous waste in this way, then the universe of SQG shippers who manifest is smaller than the universe of SQG hazardous waste shippers, because some SQG shippers manage their hazardous waste via off-site reclamation and recovery, which in most states does not require a RCRA manifest.  
 
This RIA therefore assumes that 10 percent of the SQG-generated federal hazardous waste, and 
10 percent of the SQGs in each state are governed by BFRAs, and calculates the total universe of SQGs who ship hazardous waste and may be affected by the proposed rule by subtracting 10 percent of total hazardous waste shipped by SQGs, and 10 percent of the SQGs themselves, from the total estimate of SQG shippers in each state. For example, as shown in Exhibit 2-6, this RIA estimates 1,226 SQGs in Alabama, of which 944 (77 percent) are estimated to ship hazardous waste off-site. Given the assumption that 10 percent of SQG-generated hazardous waste (and thus, correspondingly, 10 percent of SQGs, consistent with assumptions above) is shipped offsite for reclamation and recovery purposes, 123 SQGs in Alabama (10 percent of 1,226) are assumed to ship hazardous waste that does not require a manifest. The resulting estimate of SQG shippers who manifest in Alabama is 821. Exhibit 2-7 below repeats this calculation for each state; in total, this RIA estimates 35,330 SQG shippers who manifest as compared to 40,604 SQG shippers. 
 
                                 Exhibit 2-7 
Count of SQGs who Manifest for Shipments of Hazardous Waste Off-Site, by State 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      D 
                                      E 

                                    State 
Estimated 
                                Count of SQGs 
                                  Estimated 
                                   Count of 
                                     SQGs 
                         Shipping OffSite (B * 0.77) 
Estimated Count of 
                                SQGs Shipping 
                                 Off-Site for 
                               Reclamation and 
                              Recovery (B * 0.1) 
                              Estimated Count of 
                                   SQGs who 
                                   Manifest 
                                  (C  -  D) 
                              % Total (D/35,330) 
                                      1 
Alabama 
                                                                         1,226 
                                                                           944 
                                                                           123 
                                                                           821 
                                                                          2.3% 
                                      2 
Alaska 
                                                                           120 
                                                                            92 
                                                                            12 
                                                                            80 
                                                                          0.2% 
                                      3 
Arizona 
                                                                           641 
                                                                           494 
                                                                            64 
                                                                           429 
                                                                          1.2% 
                                      4 
Arkansas 
                                                                           287 
                                                                           221 
                                                                            29 
                                                                           192 
                                                                          0.5% 
                                      5 
California 
                                                                         5,915 
                                                                          4555 
                                                                           592 
                                                                         3,963 
                                                                         11.2% 
                                      6 
Colorado 
                                                                           458 
                                                                           353 
                                                                            46 
                                                                           307 
                                                                          0.9% 
                                      7 
Connecticut 
                                                                           924 
                                                                           711 
                                                                            92 
                                                                           619 
                                                                          1.8% 
                                      8 
Delaware 
                                                                           187 
                                                                           144 
                                                                            19 
                                                                           125 
                                                                          0.4% 
                                      9 
District of Columbia 
                                                                            55 
                                                                            42 
                                                                             6 
                                                                            37 
                                                                          0.1% 
                                      10 
Florida 
                                                                         3,800 
                                                                          2926 
                                                                           380 
                                                                         2,546 
                                                                          7.2% 
                                      11 
Georgia 
                                                                         1,094 
                                                                           842 
                                                                           109 
                                                                           733 
                                                                          2.1% 
                                      12 
Guam 
                                                                             6 
                                                                             5 
                                                                             1 
                                                                             4 
                                                                          0.0% 
                                      13 
Hawaii 
                                                                           144 
                                                                           111 
                                                                            14 
                                                                            96 
                                                                          0.3% 
                                      14 
Idaho 
                                                                            84 
                                                                            65 
                                                                             8 
                                                                            56 
                                                                          0.2% 
                                      15 
Illinois 
                                                                         3,928 
                                                                          3025 
                                                                           393 
                                                                         2,631 
                                                                          7.4% 
                                      16 
Indiana 
                                                                           973 
                                                                           749 
                                                                            97 
                                                                           652 
                                                                          1.8% 
                                      17 
Iowa 
                                                                           573 
                                                                           441 
                                                                            57 
                                                                           384 
                                                                          1.1% 
                                      18 
Kansas 
                                                                           580 
                                                                           447 
                                                                            58 
                                                                           389 
                                                                          1.1% 
                                      19 
Kentucky 
                                                                           412 
                                                                           317 
                                                                            41 
                                                                           276 
                                                                          0.8% 
                                      20 
Louisiana 
                                                                           887 
                                                                           683 
                                                                            89 
                                                                           594 
                                                                          1.7% 
                                      21 
Maine 
                                                                           304 
                                                                           234 
                                                                            30 
                                                                           204 
                                                                          0.6% 
                                      22 
Maryland 
                                                                         1,377 
                                                                          1060 
                                                                           138 
                                                                           923 
                                                                          2.6% 
                                      23 
Massachusetts 
                                                                         2,683 
                                                                          2066 
                                                                           268 
                                                                         1,798 
                                                                          5.1% 
                                      24 
Michigan 
                                                                         1,840 
                                                                          1417 
                                                                           184 
                                                                         1,233 
                                                                          3.5% 
                                      25 
Minnesota 
                                                                         1,366 
                                                                          1052 
                                                                           137 
                                                                           915 
                                                                          2.6% 
                                      26 
Mississippi 
                                                                           248 
                                                                           191 
                                                                            25 
                                                                           166 
                                                                          0.5% 
                                      27 
Missouri 
                                                                         1,503 
                                                                          1157 
                                                                           150 
                                                                         1,007 
                                                                          2.9% 
                                      28 
Montana 
                                                                            66 
                                                                            51 
                                                                             7 
                                                                            44 
                                                                          0.1% 
                                      29 
Navajo Nation 
                                                                             6 
                                                                             5 
                                                                             1 
                                                                             4 
                                                                          0.0% 
                                 Exhibit 2-7 
Count of SQGs who Manifest for Shipments of Hazardous Waste Off-Site, by State 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      D 
                                      E 

                                    State 
Estimated 
                                Count of SQGs 
                                  Estimated 
                                   Count of 
                                     SQGs 
                         Shipping OffSite (B * 0.77) 
Estimated Count of 
                                SQGs Shipping 
                                 Off-Site for 
                               Reclamation and 
                              Recovery (B * 0.1) 
                              Estimated Count of 
                                   SQGs who 
                                   Manifest 
                                  (C  -  D) 
                              % Total (D/35,330) 
                                      30 
Nebraska 
                                                                           250 
                                                                           193 
                                                                            25 
                                                                           167 
                                                                          0.5% 
                                      31 
Nevada 
                                                                           238 
                                                                           183 
                                                                            24 
                                                                           159 
                                                                          0.5% 
                                      32 
New Hampshire 
                                                                           201 
                                                                           155 
                                                                            20 
                                                                           135 
                                                                          0.4% 
                                      33 
New Jersey 
                                                                           850 
                                                                           655 
                                                                            85 
                                                                           570 
                                                                          1.6% 
                                      34 
New Mexico 
                                                                           196 
                                                                           151 
                                                                            20 
                                                                           131 
                                                                          0.4% 
                                      35 
New York 
                                                                         2,619 
                                                                          2017 
                                                                           262 
                                                                         1,755 
                                                                          5.0% 
                                      36 
North Carolina 
                                                                         1,478 
                                                                          1138 
                                                                           148 
                                                                           990 
                                                                          2.8% 
                                      37 
North Dakota 
                                                                            70 
                                                                            54 
                                                                             7 
                                                                            47 
                                                                          0.1% 
                                      38 
Ohio 
                                                                         2,641 
                                                                          2034 
                                                                           264 
                                                                         1,769 
                                                                          5.0% 
                                      39 
Oklahoma 
                                                                           441 
                                                                           340 
                                                                            44 
                                                                           295 
                                                                          0.8% 
                                      40 
Oregon 
                                                                           260 
                                                                           200 
                                                                            26 
                                                                           174 
                                                                          0.5% 
                                      41 
Pennsylvania 
                                                                         3,507 
                                                                          2700 
                                                                           351 
                                                                         2,350 
                                                                          6.7% 
                                      42 
Puerto Rico 
                                                                           106 
                                                                            82 
                                                                            11 
                                                                            71 
                                                                          0.2% 
                                      43 
Rhode Island 
                                                                           700 
                                                                           539 
                                                                            70 
                                                                           469 
                                                                          1.3% 
                                      44 
South Carolina 
                                                                           604 
                                                                           465 
                                                                            60 
                                                                           404 
                                                                          1.1% 
                                      45 
South Dakota 
                                                                           219 
                                                                           169 
                                                                            22 
                                                                           147 
                                                                          0.4% 
                                      46 
Tennessee 
                                                                           576 
                                                                           444 
                                                                            58 
                                                                           386 
                                                                          1.1% 
                                      47 
Texas 
                                                                         1,818 
                                                                          1400 
                                                                           182 
                                                                         1,218 
                                                                          3.4% 
                                      48 
Trust Territories 
                                                                             4 
                                                                             3 
                                                                             0 
                                                                             3 
                                                                          0.0% 
                                      49 
Utah 
                                                                           190 
                                                                           146 
                                                                            19 
                                                                           127 
                                                                          0.4% 
                                      50 
Vermont 
                                                                           218 
                                                                           168 
                                                                            22 
                                                                           146 
                                                                          0.4% 

                                        
     

                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      D 
                                      E 

                                    State 
Estimated 
                                Count of SQGs 
                                  Estimated 
                                   Count of 
                                     SQGs 
                         Shipping OffSite (B * 0.77) 
Estimated Count of 
                                SQGs Shipping 
                                 Off-Site for 
                               Reclamation and 
                              Recovery (B * 0.1) 
                              Estimated Count of 
                                   SQGs who 
                                   Manifest 
                                  (C  -  D) 
                              % Total (D/35,330) 
                                      51 
Virgin Islands 
                                                                             6 
                                                                             5 
                                                                             1 
                                                                             4 
                                                                          0.0% 
                                      52 
Virginia 
                                                                         1,652 
                                                                          1272 
                                                                           165 
                                                                         1,107 
                                                                          3.1% 
                                      53 
Washington 
                                                                           568 
                                                                           437 
                                                                            57 
                                                                           381 
                                                                          1.1% 
                                      54 
West Virginia 
                                                                           328 
                                                                           253 
                                                                            33 
                                                                           220 
                                                                          0.6% 
                                      55 
Wisconsin 
                                                                         1,227 
                                                                           945 
                                                                           123 
                                                                           822 
                                                                          2.3% 
                                      56 
Wyoming 
                                                                            87 
                                                                            67 
                                                                             9 
                                                                            58 
                                                                          0.2% 
                                        
                                                                         Total 
                                                                        52,732 
                                                                        40,604 
                                                                         5,273 
                                                                        35,330 
                                                                        100.0% 
 
Six states require manifests for SQG-generated hazardous waste shipped off-site for reclamation and recovery. The entity counts affected by these requirements are estimated in Section 2.1.2.5. 
 
National and State Quantities of Hazardous Waste shipped offsite for treatment by SQGs 
 
Waste tonnage data for SQGs is not consistently available in the RCRA Biennial Report. EPA's 2015 Improvements to the Hazardous Waste Generator Regulatory Program proposed rule RIA provides estimates of waste tonnage shipped by SQGs, but does not do so on a state-by-state basis. An interpolation of the methodology in that RIA on a state-by-state basis is presented in Appendix A.  
 
2.1.2.3 Conditionally Exempt Small Quantity Generators 
 
Conditionally Exempt Small Quantity Generators (CESQGs) produce hazardous waste in quantities less than or equal to 100 kilograms in a month. CESQGs are the most numerous of all generator types. While RCRA does not require reporting by CESQGs at the national level, 14 authorized state RCRA programs require CESQGs to notify and report their waste activity. 
Estimates of the number of CESQGs are interpolated from these state counts up to the national level. This RIA uses ratios of LQGs to CESQGs and SQGs to CESQGs developed in the Improvements to the Hazardous Waste Generator Regulatory Program proposed rule RIA to estimate a national universe of CESQGs. These ratios are based on the number of CESQGs reported by 14 states. Exhibit 2-8 reproduces Exhibit 2-2 from the Improvements to the Hazardous Waste Generator Regulatory Program proposed rule RIA and documents these ratios. 
 	
                                 Exhibit 2-8 
                      Ratios of CESQGs to SQGs and LQGs 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                                    State 
                                   Count of 
 LQGs 
                                Count of SQGs 
Count of 
CESQGs 
                           Ratio of CESQGs to SQGs 
                                   Ratio of 
 CESQGs to 
LQGs (E/B) 



                                     Low 
                                     High 

                                  Low (E/D) 
High (E/C) 

                                      1 
Alabama 
                                                                           223 
                                                                         1,226 
                                                                         1,226 
                                                                         3,390 
                                                                           2.8 
                                                                           2.8 
                                                                         15.2  
                                      2 
Arizona 
                                                                           210 
                                                                           511 
                                                                           770 
                                                                         1,774 
                                                                           2.3 
                                                                           3.5 
                                                                          8.4  
                                      3 
California 
                                                                         1,223 
                                                                         5,915 
                                                                         5,915 
                                                                        21,000 
                                                                           3.6 
                                                                           3.6 
                                                                         17.2  
                                      4 
Florida 
                                                                           279 
                                                                         3,800 
                                                                         3,800 
                                                                        19,350 
                                                                           5.1 
                                                                           5.1 
                                                                         69.4  
                                      5 
Hawaii 
                                                                            31 
                                                                           122 
                                                                           165 
                                                                           692 
                                                                           4.2 
                                                                           5.7 
                                                                         22.3  
                                      6 
Massachusetts 
                                                                           402 
                                                                         2,683 
                                                                         2,683 
                                                                        12,559 
                                                                           4.7 
                                                                           4.7 
                                                                         31.2  
                                      7 
Maine 
                                                                            52 
                                                                           304 
                                                                           304 
                                                                           949 
                                                                           3.1 
                                                                           3.1 
                                                                         18.3  
                                      8 
Minnesota 
                                                                           320 
                                                                         1,366 
                                                                         1,366 
                                                                        21,743 
                                                                          15.9 
                                                                          15.9 
                                                                         67.9  
                                      9 
Nevada 
                                                                            68 
                                                                           196 
                                                                           280 
                                                                         3,187 
                                                                          11.4 
                                                                          16.3 
                                                                         46.9  
                                      10 
New Hampshire 
                                                                           100 
                                                                           201 
                                                                           201 
                                                                         1,818 
                                                                           9.0 
                                                                           9.0 
                                                                         18.2  
                                      11 
New Jersey 
                                                                           575 
                                                                           850 
                                                                           850 
                                                                         9,000 
                                                                          10.6 
                                                                          10.6 
                                                                         15.7  
                                      12 
Rhode Island 
                                                                            65 
                                                                           700 
                                                                           700 
                                                                         2,100 
                                                                           3.0 
                                                                           3.0 
                                                                         32.3  
                                      13 
Washington 
                                                                           412 
                                                                           532 
                                                                           604 
                                                                        22,315 
                                                                          36.9 
                                                                          41.9 
                                                                         54.2  
                                      14 
Wisconsin 
                                                                           394 
                                                                         1,227 
                                                                         1,227 
                                                                         9,323 
                                                                           7.6 
                                                                           7.6 
                                                                         23.7  
                                      15 
Total 
                                                                         4,354 
                                                                        19,633 
                                                                        20,091 
                                                                       129,200 
                                                                           6.4 
                                                                           6.6 
                                                                         29.7  
Source: 2015 Improvements to the Hazardous Waste Generator Regulatory Program proposed rule RIA, Exhibit 2-2. Available at: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2012-0121-0002.  
 
To estimate national counts of CESQGs, this RIA applies the ratios of CESQGs to low estimates of SQGs, high estimates of SQGs, and LQGs for each state. These ratios are 6.4, 6.6, and 29.7 respectively (see Exhibit 2-8). After multiplying these ratios by state counts of SQGs and LQGs, this RIA takes the lowest and highest estimate for each state and calculates the average. This average is used throughout the rest of this RIA. Note that this extrapolation approach only applies to states for which no CESQG counts exist; the universes noted for the 14 states in Exhibit 2-8 are directly applied. 
 
Exhibit 2-9 below displays this analysis and its results. Column B provides state counts of LQGs, and columns C and D show estimates of SQGs. Columns, E, F, and G display the products of different state counts of SQGs and LQGs with the range of ratios determined in Exhibit 2-8. Columns H and I display the lowest and highest estimates of CESQGS for each state from columns E, F, and G, respectively. Column I displays the highest estimate of CESQGs for each state from columns E, F, and G. Column J displays the average of columns H and I. Ultimately, based on this analysis, this RIA employs a national CESQG count of approximately 381,000. 
 
 
 
 
 




                                     Exhibit 2-9 
                               Estimated Counts of CESQGs 



Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 
                                      I 
                                      J 
                                      K 

                                    State 
                                   Count of 
LQGs 
                                Count of SQGs 
                               Count of CESQGS 
                                 CESQG Range 
                               Average (H+I)/2 
                             % Total (J/381,145) 



                                     Low 
                                     High 
                                   C x 6.4 
                                   D x 6.6 
B x 29.7 
                                     Low 
                                     High 


                                      1 
Alabama* 
                                                                           223 
                                                                         1,226 
                                                                         1,226 
                                                                         3,390 
                                                                         3,390 
                                                                         3,390 
                                                                         3,390 
                                                                         3,390 
                                                                         3,390 
                                                                          0.9% 
                                      2 
Alaska 
                                                                            27 
                                                                            96 
                                                                           143 
                                                                           617 
                                                                           941 
                                                                           801 
                                                                           617 
                                                                           941 
                                                                           779 
                                                                          0.2% 
                                      3 
Arizona* 
                                                                           210 
                                                                           511 
                                                                           770 
                                                                         1,774 
                                                                         1,774 
                                                                         1,774 
                                                                         1,774 
                                                                         1,774 
                                                                         1,774 
                                                                          0.5% 
                                      4 
Arkansas 
                                                                           123 
                                                                           256 
                                                                           318 
                                                                         1,646 
                                                                         2,093 
                                                                         3,650 
                                                                         1,646 
                                                                         3,650 
                                                                         2,648 
                                                                          0.7% 
                                      5 
California* 
                                                                         1,223 
                                                                         5,915 
                                                                         5,915 
                                                                        21,000 
                                                                        21,000 
                                                                        21,000 
                                                                        21,000 
                                                                        21,000 
                                                                        21,000 
                                                                          5.5% 
                                      6 
Colorado 
                                                                           107 
                                                                           434 
                                                                           482 
                                                                         2,791 
                                                                         3,172 
                                                                         3,175 
                                                                         2,791 
                                                                         3,175 
                                                                         2,983 
                                                                          0.8% 
                                      7 
Connecticut 
                                                                           278 
                                                                           756 
                                                                         1,092 
                                                                         4,862 
                                                                         7,186 
                                                                         8,249 
                                                                         4,862 
                                                                         8,249 
                                                                         6,555 
                                                                          1.7% 
                                      8 
Delaware 
                                                                            49 
                                                                           155 
                                                                           218 
                                                                           997 
                                                                         1,435 
                                                                         1,454 
                                                                           997 
                                                                         1,454 
                                                                         1,225 
                                                                          0.3% 
                                      9 
District of Columbia 
                                                                            23 
                                                                            36 
                                                                            74 
                                                                           232 
                                                                           487 
                                                                           682 
                                                                           232 
                                                                           682 
                                                                           457 
                                                                          0.1% 
                                            
                                            


                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

                                       
                                       

                                       
                                       
                                       
                                       
                                       



                                       
                                       
                                       
                                       

                                       
                                       














                                      10 
Florida* 
                                                                           279 
                                                                         3,800 
                                                                         3,800 
                                                                        19,350 
                                                                        19,350 
                                                                        19,350 
                                                                        19,350 
                                                                        19,350 
                                                                        19,350 
                                                                          5.1% 
                                      11 
Georgia 
                                                                           334 
                                                                           900 
                                                                         1,288 
                                                                         5,788 
                                                                         8,476 
                                                                         9,911 
                                                                         5,788 
                                                                         9,911 
                                                                         7,849 
                                                                          2.1% 
                                      12 
Guam 
                                                                             8 
                                                                             3 
                                                                             8 
                                                                            19 
                                                                            53 
                                                                           237 
                                                                            19 
                                                                           237 
                                                                           128 
                                                                          0.0% 
                                      13 
Hawaii* 
                                                                            31 
                                                                           122 
                                                                           165 
                                                                           692 
                                                                           692 
                                                                           692 
                                                                           692 
                                                                           692 
                                                                           692 
                                                                          0.2% 
                                      14 
Idaho 
                                                                            19 
                                                                            79 
                                                                            89 
                                                                           508 
                                                                           586 
                                                                           564 
                                                                           508 
                                                                           586 
                                                                           547 
                                                                          0.1% 
                                      15 
Illinois 
                                                                           641 
                                                                         2,958 
                                                                         4,897 
                                                                        19,022 
                                                                        32,226 
                                                                        19,021 
                                                                        19,021 
                                                                        32,226 
                                                                        25,623 
                                                                          6.7% 
                                      16 
Indiana 
                                                                           503 
                                                                           790 
                                                                         1,156 
                                                                         5,080 
                                                                         7,607 
                                                                        14,926 
                                                                         5,080 
                                                                        14,926 
                                                                        10,003 
                                                                          2.6% 
                                      17 
Iowa 
                                                                           128 
                                                                           471 
                                                                           675 
                                                                         3,029 
                                                                         4,442 
                                                                         3,798 
                                                                         3,029 
                                                                         4,442 
                                                                         3,735 
                                                                          1.0% 
                                      18 
Kansas 
                                                                           170 
                                                                           480 
                                                                           680 
                                                                         3,087 
                                                                         4,475 
                                                                         5,045 
                                                                         3,087 
                                                                         5,045 
                                                                         4,066 
                                                                          1.1% 
                                      19 
Kentucky 
                                                                           269 
                                                                           355 
                                                                           469 
                                                                         2,283 
                                                                         3,086 
                                                                         7,982 
                                                                         2,283 
                                                                         7,982 
                                                                         5,133 
                                                                          1.3% 
                                      20 
Louisiana 
                                                                           331 
                                                                           705 
                                                                         1,068 
                                                                         4,534 
                                                                         7,028 
                                                                         9,822 
                                                                         4,534 
                                                                         9,822 
                                                                         7,178 
                                                                          1.9% 
                                      21 
Maine* 
                                                                            52 
                                                                           304 
                                                                           304 
                                                                           949 
                                                                           949 
                                                                           949 
                                                                           949 
                                                                           949 
                                                                           949 
                                                                          0.2% 
                                      22 
Maryland 
                                                                           132 
                                                                           974 
                                                                         1,780 
                                                                         6,264 
                                                                        11,714 
                                                                         3,917 
                                                                         3,917 
                                                                        11,714 
                                                                         7,815 
                                                                          2.1% 
                                      23 
Massachusetts* 
                                                                           402 
                                                                         2,683 
                                                                         2,683 
                                                                        12,559 
                                                                        12,559 
                                                                        12,559 
                                                                        12,559 
                                                                        12,559 
                                                                        12,559 
                                                                          3.3% 
                                      24 
Michigan 
                                                                           342 
                                                                         1,486 
                                                                         2,194 
                                                                         9,556 
                                                                        14,438 
                                                                        10,148 
                                                                         9,556 
                                                                        14,438 
                                                                        11,997 
                                                                          3.1% 
                                      25 
Minnesota* 
                                                                           320 
                                                                         1,366 
                                                                         1,366 
                                                                        21,743 
                                                                        21,743 
                                                                        21,743 
                                                                        21,743 
                                                                        21,743 
                                                                        21,743 
                                                                          5.7% 
                                      26 
Mississippi 
                                                                           128 
                                                                           210 
                                                                           286 
                                                                         1,350 
                                                                         1,882 
                                                                         3,798 
                                                                         1,350 
                                                                         3,798 
                                                                         2,574 
                                                                          0.7% 
                                      27 
Missouri 
                                                                           282 
                                                                         1,279 
                                                                         1,727 
                                                                         8,225 
                                                                        11,365 
                                                                         8,368 
                                                                         8,225 
                                                                        11,365 
                                                                         9,795 
                                                                          2.6% 
                                      28 
Montana 
                                                                            41 
                                                                            55 
                                                                            77 
                                                                           354 
                                                                           507 
                                                                         1,217 
                                                                           354 
                                                                         1,217 
                                                                           785 
                                                                          0.2% 
                                      29 
Navajo Nation 
                                                                             1 
                                                                             6 
                                                                             6 
                                                                            39 
                                                                            39 
                                                                            30 
                                                                            30 
                                                                            39 
                                                                            35 
                                                                          0.0% 
                                      30 
Nebraska 
                                                                            64 
                                                                           226 
                                                                           273 
                                                                         1,453 
                                                                         1,797 
                                                                         1,899 
                                                                         1,453 
                                                                         1,899 
                                                                         1,676 
                                                                          0.4% 
                                      31 
Nevada* 
                                                                            68 
                                                                           196 
                                                                           280 
                                                                         3,187 
                                                                         3,187 
                                                                         3,187 
                                                                         3,187 
                                                                         3,187 
                                                                         3,187 
                                                                          0.8% 
                                      32 
New Hampshire* 
                                                                           100 
                                                                           201 
                                                                           201 
                                                                         1,818 
                                                                         1,818 
                                                                         1,818 
                                                                         1,818 
                                                                         1,818 
                                                                         1,818 
                                                                          0.5% 
                                      33 
New Jersey* 
                                                                           575 
                                                                           850 
                                                                           850 
                                                                         9,000 
                                                                         9,000 
                                                                         9,000 
                                                                         9,000 
                                                                         9,000 
                                                                         9,000 
                                                                          2.4% 
                                      34 
New Mexico 
                                                                            39 
                                                                           156 
                                                                           236 
                                                                         1,003 
                                                                         1,553 
                                                                         1,157 
                                                                         1,003 
                                                                         1,553 
                                                                         1,278 
                                                                          0.3% 
                                      35 
New York 
                                                                         1,471 
                                                                         1,983 
                                                                         3,255 
                                                                        12,752 
                                                                        21,420 
                                                                        43,650 
                                                                        12,752 
                                                                        43,650 
                                                                        28,201 
                                                                          7.4% 
                                      36 
North Carolina 
                                                                           437 
                                                                         1,169 
                                                                         1,786 
                                                                         7,518 
                                                                        11,753 
                                                                        12,967 
                                                                         7,518 
                                                                        12,967 
                                                                        10,243 
                                                                          2.7% 
                                      37 
North Dakota 
                                                                            19 
                                                                            62 
                                                                            78 
                                                                           399 
                                                                           513 
                                                                           564 
                                                                           399 
                                                                           564 
                                                                           481 
                                                                          0.1% 
                                      38 
Ohio 
                                                                           716 
                                                                         2,041 
                                                                         3,240 
                                                                        13,125 
                                                                        21,322 
                                                                        21,246 
                                                                        13,125 
                                                                        21,322 
                                                                        17,223 
                                                                          4.5% 
                                      39 
Oklahoma 
                                                                           179 
                                                                           379 
                                                                           502 
                                                                         2,437 
                                                                         3,304 
                                                                         5,312 
                                                                         2,437 
                                                                         5,312 
                                                                         3,874 
                                                                          1.0% 
                                      40 
Oregon 
                                                                           181 
                                                                           235 
                                                                           285 
                                                                         1,511 
                                                                         1,876 
                                                                         5,371 
                                                                         1,511 
                                                                         5,371 
                                                                         3,441 
                                                                          0.9% 
                                      41 
Pennsylvania 
                                                                           671 
                                                                         2,721 
                                                                         4,293 
                                                                        17,498 
                                                                        28,251 
                                                                        19,911 
                                                                        17,498 
                                                                        28,251 
                                                                        22,875 
                                                                          6.0% 
                                      42 
Puerto Rico 
                                                                            80 
                                                                            96 
                                                                           115 
                                                                           617 
                                                                           757 
                                                                         2,374 
                                                                           617 
                                                                         2,374 
                                                                         1,496 
                                                                          0.4% 
                                      43 
Rhode Island* 
                                                                            65 
                                                                           700 
                                                                           700 
                                                                         2,100 
                                                                         2,100 
                                                                         2,100 
                                                                         2,100 
                                                                         2,100 
                                                                         2,100 
                                                                          0.6% 
                                      44 
South Carolina 
                                                                           257 
                                                                           485 
                                                                           722 
                                                                         3,119 
                                                                         4,751 
                                                                         7,626 
                                                                         3,119 
                                                                         7,626 
                                                                         5,373 
                                                                          1.4% 
                                      45 
South Dakota 
                                                                            33 
                                                                           182 
                                                                           256 
                                                                         1,170 
                                                                         1,685 
                                                                           979 
                                                                           979 
                                                                         1,685 
                                                                         1,332 
                                                                          0.3% 
                                      46 
Tennessee 
                                                                           334 
                                                                           442 
                                                                           710 
                                                                         2,842 
                                                                         4,672 
                                                                         9,911 
                                                                         2,842 
                                                                         9,911 
                                                                         6,377 
                                                                          1.7% 
                                      47 
Texas 
                                                                         1,006 
                                                                         1,471 
                                                                         2,164 
                                                                         9,460 
                                                                        14,241 
                                                                        29,852 
                                                                         9,460 
                                                                        29,852 
                                                                        19,656 
                                                                          5.2% 
                                      48 
Trust Territories 
                                                                             1 
                                                                             3 
                                                                             5 
                                                                            19 
                                                                            33 
                                                                            30 
                                                                            19 
                                                                            33 
                                                                            26 
                                                                          0.0% 
                                      49 
Utah 
                                                                           111 
                                                                           174 
                                                                           205 
                                                                         1,119 
                                                                         1,349 
                                                                         3,294 
                                                                         1,119 
                                                                         3,294 
                                                                         2,206 
                                                                          0.6% 
                                      50 
Vermont 
                                                                            39 
                                                                           185 
                                                                           250 
                                                                         1,190 
                                                                         1,645 
                                                                         1,157 
                                                                         1,157 
                                                                         1,645 
                                                                         1,401 
                                                                          0.4% 
                                      51 
Virgin Islands 
                                                                             2 
                                                                             6 
                                                                             5 
                                                                            39 
                                                                            33 
                                                                            59 
                                                                            33 
                                                                            59 
                                                                            46 
                                                                          0.0% 
                                      52 
Virginia 
                                                                           219 
                                                                         1,274 
                                                                         2,029 
                                                                         8,193 
                                                                        13,352 
                                                                         6,499 
                                                                         6,499 
                                                                        13,352 
                                                                         9,925 
                                                                          2.6% 
                                          Exhibit 2-9 
                                  Estimated Counts of CESQGs 


Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 
                                      I 
                                      J 
                                      K 

                                    State 
                                   Count of 
LQGs 
                                Count of SQGs 
                               Count of CESQGS 
                                 CESQG Range 
                               Average (H+I)/2 
                             % Total (J/381,145) 



                                     Low 
                                     High 
                                   C x 6.4 
                                   D x 6.6 
B x 29.7 
                                     Low 
                                     High 


                                      53 
Washington* 
                                                                           412 
                                                                           532 
                                                                           604 
                                                                        22,315 
                                                                        22,315 
                                                                        22,315 
                                                                        22,315 
                                                                        22,315 
                                                                        22,315 
                                                                          5.9% 
                                      54 
West Virginia 
                                                                            98 
                                                                           280 
                                                                           376 
                                                                         1,801 
                                                                         2,474 
                                                                         2,908 
                                                                         1,801 
                                                                         2,908 
                                                                         2,354 
                                                                          0.6% 
                                      55 
Wisconsin* 
                                                                           394 
                                                                         1,227 
                                                                         1,227 
                                                                         9,323 
                                                                         9,323 
                                                                         9,323 
                                                                         9,323 
                                                                         9,323 
                                                                         9,323 
                                                                          2.4% 
                                      56 
Wyoming 
                                                                            15 
                                                                            75 
                                                                            99 
                                                                           482 
                                                                           651 
                                                                           445 
                                                                           445 
                                                                           651 
                                                                           548 
                                                                          0.1% 
                                                                       Totals: 
                                                                        14,262 
                                                                        45,762 
                                                                        59,702 
                                                                       297,229 
                                                                       389,870 
                                                                       423,209 
                                                                       292,911 
                                                                       469,380 
                                                                       381,145 
                                                                          100% 
* Actual counts of CESQGs within these states are available in Exhibit 2-8 and are not extrapolated. 


 
As with SQGs, this rule affects only facilities that must manifest shipments of hazardous waste and as most CESQGs are not required to manifest their hazardous waste shipments, the above estimate is an overestimate of the affected CESQG universe for this rule. Furthermore, even if CESQGs were required to manifest hazardous waste shipments, not all CESQGs that generated hazardous waste would also be hazardous waste shippers; correspondingly, this RIA applies the 77 percent proportion of SQGs that ship waste off-site to CESQGs as well.  
 
Only one state, Arkansas, requires CESQGs to manifest shipments of hazardous waste. 
Correspondingly, the universe of CESQGs assumed to be affected by the manifest rule is thus 
2,039, reflecting the assumption that, 77 percent of the 2,648 CESQGs in Arkansas as shown in Exhibit 2-9 (or 2,039 CESQGs), are shipping hazardous waste off-site and must manifest.  
 
Because CESQGs are subject to few reporting requirements, it is necessary to extrapolate estimates of the average number of tons generated per CESQG from states where that data is available. EPA's Improvements to the Hazardous Waste Generator Regulatory Program proposed rule RIA provides estimates of waste tonnage generated and shipped by CESQGs, but does not do so on a state-by-state basis. For additional information, see Appendix A.  
 
2.1.2.4 Generators of State Hazardous Wastes 
 
The previous sections on generators have examined facilities that generate and ship hazardous waste as defined in the federal RCRA regulations. Most states have been delegated authority to enforce RCRA as well as to add additional requirements unique to the state. Some states have elected to list additional wastes as hazardous, necessitating a manifest whenever these state hazardous wastes are shipped offsite. As the e-Manifest system will be the exclusive terminus for all hazardous waste manifests, it will accept manifests accompanying shipments of state hazardous wastes. As a result, the facilities that generate these state hazardous wastes must be counted as a part of the affected universe for this rulemaking. 

To determine the universe of state hazardous waste generators, this RIA first examined state RCRA requirements to determine which states had listed additional wastes as hazardous. Of the states, 19 have listed additional wastes as state hazardous wastes. These 19 states are listed in Exhibit 2-10 below. 
 
As there is little information on the counts of state hazardous waste generators, this RIA makes the simplifying assumption that the count of state hazardous waste generators is equal to the count of CESQGs in a state. Exhibit 2-10 displays the estimated count of state waste generators in each of these 19 states, as seen in Column J of Exhibit 2-9. As applied to CESQG shippers above, this RIA assumes that 77 percent of CESQGs ship hazardous waste off-site. This proportion is applied below to yield an estimate of the state hazardous waste generators in each of the 19 states. Overall, this RIA estimates 145,522 generators who ship state hazardous wastes offsite for treatment will be affected by the proposed rule. 
 	 
                                 Exhibit 2-10 
Estimated Counts of State Hazardous Waste Generators Affected by the Proposed 
                                     Rule 
                                     Item 
                                      A 
                                      B 
                                      C 

                                    State 
                             Count of Generators 
                            (assumed to be CESQGs) 
                         Count of Shippers (B * 0.77) 
                                      1 
California 
                                                                        21,000 
                                                                        16,170 
                                      2 
Colorado 
                                                                         2,983 
                                                                         2,297 
                                      3 
Illinois 
                                                                        25,623 
                                                                        19,370 
                                      4 
Indiana 
                                                                        10,003 
                                                                         7,702 
                                      5 
Kentucky 
                                                                         5,133 
                                                                         3,952 
                                      6 
Louisiana 
                                                                         7,178 
                                                                         5,527 
                                      7 
Maine 
                                                                           949 
                                                                           731 
                                      8 
Maryland 
                                                                         7,815 
                                                                         6,018 
                                      9 
Michigan 
                                                                        11,997 
                                                                         9,238 
                                      10 
Missouri 
                                                                         9,795 
                                                                         7,542 
                                      11 
New Hampshire 
                                                                         1,818 
                                                                         1,400 
                                      12 
New York 
                                                                        28,201 
                                                                        21,715 
                                      13 
Oregon 
                                                                         3,441 
                                                                         2,650 
                                      14 
Rhode Island 
                                                                         2,100 
                                                                         1,617 
                                      15 
South Carolina 
                                                                         5,373 
                                                                         4,137 
                                      16 
Texas 
                                                                        19,656 
                                                                        15,135 
                                      17 
Utah 
                                                                         2,206 
                                                                         1,699 
                                      18 
Vermont 
                                                                         1,401 
                                                                         1,079 
                                      19 
Washington 
                                                                        22,315 
                                                                        17,183 
                                                                         Total 
                                                                       188,987 
                                                                       145,522 
 
2.1.2.5 SQGs Shipping Under Reclamation Agreements 
 
As described in Section 2.1.2.2, not all SQG shippers are required to manifest, because SQGgenerated hazardous waste that is shipped off-site for reclamation and recovery is exempt from manifest requirements under the federal RCRA program. However, as described in Section 2.2 below, six states (Connecticut, Delaware, Kentucky, Maryland, Minnesota, and New Hampshire) require manifests for these shipments despite the federal exemption. Correspondingly, this RIA estimates the count of SQGs that must manifest due these state-specific requirements as part of the affected universe for the proposed rule. This RIA estimates the entity counts associated with these BFRA manifest requirements by simply adding back in the 10 percent of SQGs omitted 


from these six states in Section 2.1.2.2 as SQGs who ship their waste but do not provide accompanying manifests. Exhibit 2-11 below summarizes the estimated entity counts across these six states. Overall, this RIA estimates 447 SQGs that manifest due to these state-specific BFRA manifest requirements. 

                                 Exhibit 2-11 
     Estimated Counts of SQGs who Manifest for Waste Shipped under BFRAs 
                                     Item 
                                      A 
                                      B 
                                      C 

                                    State 
                                     SQGs 
SQGs who Manifest for Waste 
                             Shipped under BFRAs  
                                  (B * 0.1) 
                                      1 
Connecticut 
                                                                           924 
                                                                            92 
                                      2 
Delaware 
                                                                           187 
                                                                            19 
                                      3 
Kentucky 
                                                                           412 
                                                                            41 
                                      4 
Maryland 
                                                                         1,377 
                                                                           138 
                                      5 
Minnesota 
                                                                         1,366 
                                                                           137 
                                      6 
New Hampshire 
                                                                           201 
                                                                            20 
                                                                         Total 
                                                                           447 
 
2.1.3 Transporters 
 
The universe of facilities affected by the proposed rule includes transporters, who haul shipments of hazardous waste from generators to TSDFs. Transporters predominantly use specialized trucks to carry these shipments, but in some cases waste is also hauled by rail and occasionally by barge. As hazardous waste is hauled predominantly by trucks and each shipment (i.e., a truckload or partial truckload) requires a separate manifest, this RIA focuses on the number of hazardous waste hauling trucks, rather than the number of transporter companies or facilities, to estimate the impacts of the proposed rule on transporters of hazardous waste.[34] 
 
To estimate the count of hazardous waste hauling trucks, this RIA uses counts from two Department of Transportation (DoT) surveys of the US national trucking fleet. The first study, from 1996, is the Analysis of the Truck Inventory and Use Survey from the Truck Size and Weight Perspective for Trucks with Four- Axles or Less. A companion study, from 2001, is the Analysis of the Vehicle Inventory and Use Survey for Trucks with Five-Axles or More. Both studies include counts of trucks hauling two categories of hazardous waste: EPA manifested and non-EPA manifested waste.[35] As these surveys were completed before EPA standardized the hazardous waste manifest form in 2005, it is likely that non-EPA manifested hazardous waste is 
                                                                                                                                                                                           
under a BFRA or makes only a portion of its shipments under a BFRA is less salient to cost estimation, as the estimated relative proportion of manifests is covered by BFRAs regardless of how these entities operate. 
 Per the Supporting Statement for Information Collection Request (ICR) Number 801.20 Requirements for 
Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System. April 30, 2015, three percent of manifests accompany water shipments (i.e., shipments by barge) and six percent of manifests accompany rail shipments (i.e., shipments by train). This represents a small proportion (less than ten percent) of the overall universe of hazardous waste shipments requiring manifests. Additionally, as discussed in Chapter 5, this RIA uses the number of hazardous waste hauling trucks to estimate CROMERR compliance costs to industry; because there are likely to be considerably fewer rail and barge operators that must complete CROMERR registration relative to the number of truck drivers hauling hazardous waste shipments (both drivers and companies), additional CROMERR-related costs associated with hazardous waste shipments by truck and rail are expected to be minimal and are not estimated in this RIA. Note that this RIA estimates manifest costs associated with shipments of hazardous waste by barge and rail, including special requirements that apply only to these shipments  -  see Chapters 4 and 5 for additional detail. 
 The surveys define the category into which a truck belongs through its "principal product," which is the product category hauled most often by a given truck. Given that these counts are on a truck-by-truck basis, there is no double-counting possible, as each truck is sorted into only one "principal product" category. Correspondingly, the EPA and non-EPA hazardous waste categories are not duplicative, though a truck's presence in the EPA hazardous waste category does not indicate that it solely hauls EPA hazardous waste. 
waste listed on a state hazardous waste manifest. In this analysis, both categories of waste hauling trucks are counted as within the universe of affected entities.  
 
Critically, the data included in these studies originates from years prior to the study publication date. Specifically, the first study primarily uses data from 1992, while the second study primarily relies on data from 1997. More recent estimates of trucks engaged specifically in hazardous waste hauling are not available. In order to more accurately estimate the number of trucks currently in existence and engaging in hazardous waste hauling, this RIA scales the figures from these two studies. Specifically, this RIA uses employment data from the Economic Censuses from 1992, 1997, and 2012 to derive a scaling factor to apply to the 1992 and 1997 data from DoT surveys based on the number of employees engaged in hazardous waste trucking sectors, as follows: 
 
       1992: 9,270 employees in SIC 4212 (Local Trucking without Storage)  -  Subpart relating to Hazardous Waste Materials;  
       
       1997: 8,468 employees in NAICS 562112 (Hazardous Waste Collection); and 
 
       2012: 9,987 employees in NAICS 562112 (Hazardous Waste Collection). 
 
To adjust the 1992 and 1997 data from DoT surveys to reflect 2012, the corresponding scaling factors are approximately 1.08 for 1992-sourced data (i.e., the 1996 study) and approximately 1.18 for 1997-sourced data (i.e. the 2001 study). Note that while the remainder of this chapter uses data from, or based on, the 2011 Biennial Report cycle, the Economic Census is available only in five-year increments and the 2012 Economic Census represents the closest data source both to present day and the 2011 Biennial Report. 
 
The total count of hazardous waste hauling trucks per the 1996 and 2001 studies is 8,734. Exhibit 2-12 displays the counts of affected trucks by truck type and waste type below, and shows the application of scaling factors derived above to these estimates. The total count of hazardous waste hauling trucks affected by the proposed rule is estimated to be 9,947 in 2012, as shown below. 
 	
 
 
                                 Exhibit 2-12 
                  Counts of Hazardous Waste Hauling Trucks  
                                  Truck Type 
                                   2- axle 
                                    3axle 
                                    4axle 
                                     2+2 
2-S1 
2-S2 
                                     3-S1 
 Truck 
                                      + 
Trailer 
                                   @ 5axle 
                                     3-S2 
Tridem 
                                     Axle 
                                     Semi-
                                   trailer 
                                   4S1/ S2 
                                    Total 
                        EPA Manifested Hazardous Waste 
Truck Counts (1992/1997 data) 
1,097 
                                     454 
                                      15 
                                     105 
                                      24 
                                      99 
                                      22 
                                      0 
                                    3,743 
                                     724 
                                     175 
                                    6,458 
Truck Counts (2012 estimate) 
1,182 
                                     489 
                                      16 
                                     113 
                                      26 
                                     107 
                                      24 
                                      0 
                                    4,414 
                                     854 
                                     206 
                                    7,431 
Percent 
17.0% 
7.0% 
0.2% 
                                     1.6% 
0.4% 
1.5% 
                                     0.3% 
                                     0.0% 
 58.0% 
                                    11.2% 
                                     2.7% 
100.0% 
                      Non-EPA Manifested Hazardous Waste 
Truck Counts (1992/1997 data) 
                                                                         1,202 
                                                                           168 
                                                                             0 
                                                                           105 
                                                                             0 
                                                                           174 
                                                                             0 
                                                                            24 
                                                                           525 
                                                                            78 
                                                                             0 
                                                                         2,276 
Truck Counts (2012 estimate) 
                                                                         1,295 
                                                                           181 
                                                                             0 
                                                                           113 
                                                                             0 
                                                                           187 
                                                                             0 
                                                                            28 
                                                                           619 
                                                                            92 
                                                                             0 
                                                                         2,516 
Percent 
52.8% 
7.4% 
0.0% 
                                                                          4.6% 
0.0% 
7.6% 
                                                                          0.0% 
                                                                          1.1% 
                                                                         23.1% 
                                                                          3.4% 
                                                                          0.0% 
 100.0% 
                                    Totals 
Truck Counts (1992/1997 data) 
                                                                         2,299 
                                                                           622 
                                                                            15 
                                                                           210 
                                                                            24 
                                                                           273 
                                                                            22 
                                                                            24 
                                                                         4,268 
                                                                           802 
                                                                           175 
                                                                         8,734 
Truck Counts (2012 estimate) 
                                                                         2,477 
                                                                           670 
                                                                            16 
                                                                           226 
                                                                            26 
                                                                           294 
                                                                            24 
                                                                            28 
                                                                         5,034 
                                                                           946 
                                                                           206 
                                                                         9,947 
Percent 
26.3% 
7.1% 
0.2% 
                                                                          2.4% 
0.3% 
3.1% 
                                                                          0.3% 
                                                                          0.3% 
                                                                         48.9% 
                                                                          9.2% 
                                                                          2.0% 
 100.0% 
Source: Department of Transportation Vehicle Inventory and Use Surveys. Available at: 
1996 report (1992 data)- https://www.fhwa.dot.gov/reports/tswstudy/rpt6_mai.pdf - provides 2-axle, 3-axle, 4-axle, 2+2, 2-S1, 2-S2, and 3-S1 truck counts. 
2001 report (1997 data) - http://www.fhwa.dot.gov/reports/tswstudy/vius97.pdf - provides truck + trailer @ 5-axle, 3-S2, tride axle semi-trailer, and 4S1/S2 truck counts. 
2012 estimates derived via scaling based on employee counts in hazardous waste trucking industries across the 1992, 1997, and 2012 Economic Censuses. Totals may not sum due to rounding. 
 
2.2 State Governments Potentially Affected by e-Manifest 
 
Nearly all state governments, with the exception of Iowa and Alaska, are authorized to implement and enforce RCRA. As a part of this authorization, the delegated States have the discretion to modify RCRA to suit their specific needs so long as these modifications are consistent with and at least as stringent as the base federal regulations. In practice many states elect to adopt modifications to RCRA that make their programs more stringent than the federal RCRA regulations. These modifications are significant to this rulemaking because they change the contents of, distribution rules for, or reporting rules for hazardous waste manifests. EManifest, as the sole national hazardous waste manifest system, will need to accommodate these state specific manifest requirements. Data on state RCRA program requirements come from the Environmental Compliance Assistance Platform (ENVCAP). ENVCAP is a repository of environmental regulations maintained by the National Center for Manufacturing Sciences and supported by EPA Office of Enforcement Compliance Assurance. 
State programs differ from the federal RCRA program in six ways. They are: 
 
       Inclusion of additional wastes as hazardous. States may specify additional wastes, such as used oil, as hazardous. These wastes are subject to the full requirements of RCRA, including manifests. Currently 19 states have listed additional wastes as hazardous. 
 
       Disallowing federal manifest exemptions. Under federal RCRA regulations SQGs with contractual reclamation agreements with TSDFs do not have to manifest their shipments of hazardous waste. Six states have not adopted this exemption, and require manifests for hazardous waste shipments made under these agreements. 
       
       Requiring copies of the manifest to be distributed to the state. EPA does not collect copies of the manifest from industry. However, 32 states require industry to send them copies of the manifest from shipments originating and/or terminating within their boundaries. 
       
       Requiring additional reports from industry. The federal RCRA program requires industry to make reports to EPA when certain manifest irregularities occur. Seventeen states have listed additional irregularities requiring reports, tightened reporting timetables, or added additional classes of facilities that must report contingencies. 
       
       Requiring industry to keep additional records. The federal RCRA program requires facilities to maintain records of all manifest shipments for three years. Five states have imposed additional recordkeeping requirements. For example:  
       
              Washington requires generators to retain manifests for five years.  
              Kentucky specifies that generators must retain both their original manifest copy and the copy mailed to them by the TSDF. 
              Delaware requires CESQGs to document off-site shipments of hazardous waste and retain those records for three years. 
       
            6. Miscellaneous additional requirements. 22 states have additional requirements that make their programs more stringent than the federal RCRA program, distinct from the additional requirements described in the five items above. For example, Louisiana requires generators to obtain a letter from a receiver TSDF acknowledging that the TSDF can receive the waste before the generator ships it to the TSDF; the generator must retain this letter as a part of recordkeeping. 
       
State specific regulations are significant to this rulemaking because they will affect the universe of facilities and wastes that must report through e-Manifest as well as the functionality of the system. State-specific wastes and the manifests that carry their codes must be recognized, accepted and processed by e-Manifest. The system will need to understand state reporting exemptions and be able to accept manifests that are subject to these exemptions. States that currently require manifests to be submitted to them will in the future rely on e-Manifest to provide them with the data they currently collect. The system must also support the recordkeeping requirements of state programs if it is to successfully serve as the national repository for manifest data. Ultimately, state requirements affect the operational scope of the eManifest system, because the system must incorporate and reflect state-specific requirements; the costs of this interaction will be reflected in the user fees, costs, and benefits attributable to the eManifest program. 
 
With respect to state-listed hazardous wastes, EPA examined existing state hazardous waste programs to determine which states may have additional facilities that would be subject to the proposed rule. Programs were evaluated as presented in the ENVCAP. For each program, EPA evaluated the following three aspects of the state-specific regulations: 
 
       Does the state list additional hazardous wastes which would require manifests? 
       
       Does the state require manifests for wastes excluded under bona fide reclamation agreements 
 
       Does the state require manifests for wastes shipped by CESQGs? 
 
According to the data in ENVCAP and summarized in Exhibit 2-13, 19 states list at least one additional state hazardous waste that is not listed federally. Six states also require manifests for shipments made under a BFRA. Finally, one state requires manifests for CESQGs. As seen in the table below, three states have both state hazardous wastes and requirements for manifests accompanying wastes transported under a BFRA. For further discussion of state programs, including the additional state wastes in each state, see Appendix B. 
 
                                 Exhibit 2-13 
                  States Which Require Additional Manifests 
                     Manifests for State Hazardous Wastes 
                   Manifests for Shipments Made under BFRAs 
Manifests for CESQGS 
CA, CO, IL, IN, KY, LA, ME, 
MD, MI, MO, NH, NY, OR, RI, 
SC, TX, UT, VT, WA 
CT, DE, KY, MD, MN, NH 
AR 
Source: State program data taken from www.envcap.org/statetools/ (Accessed April 2015)  
 
Exhibit 2-14 summarizes the states with additional RCRA requirements that will affect the eManifest system and program. Each column pertains to one of the 6 areas that state programs differ from the federal RCRA program. A designation of "same" indicates that that state does not differ from the federal RCRA program, "differs" indicates that it does, and "-" indicates that that state is not authorized to implement or enforce RCRA and therefore does not differ from the federal program. In all, 33 states have RCRA programs that are more stringent than the federal RCRA program. 
 	
 
 
 
 
 

                                                                              D
Exhibit 2-14 ifferences Between National and State RCRA Programs 


                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 

                                    State 
                              Additional Wastes 
                                  Exemptions 
                                 Distribution 
                                  Reporting 
                                Record keeping 
 Other 
                                      1 
 Alabama 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                      2 
 Alaska 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      3 
 Arizona 
                                     same 
                                     same 
                                   differs 
                                   differs 
                                     same 
                                   differs 
                                      4 
 Arkansas 
                                     same 
                                     same 
                                   differs 
                                   differs 
                                     same 
                                   differs 
                                      5 
 California 
                                   differs 
                                     same 
                                   differs 
                                   differs 
                                     same 
                                   differs 
                                      6 
 Colorado 
                                   differs 
                                     same 
                                   differs 
                                     same 
                                     same 
                                   differs 
                                      7 
 Connecticut 
                                     same 
                                   differs 
                                   differs 
                                     same 
                                     same 
                                   differs 
                                      8 
 Delaware 
                                     same 
                                   differs 
                                   differs 
                                   differs 
                                   differs 
                                     same 
                                      9 
 District of Columbia 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      10 
 Florida 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                      11 
 Georgia 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                   differs 
                                      12 
 Guam 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      13 
 Hawaii 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                      14 
 Idaho 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                      15 
 Illinois 
                                   differs 
                                     same 
                                   differs 
                                     same 
                                     same 
                                     same 
                                      16 
 Indiana 
                                   differs 
                                     same 
                                     same 
                                   differs 
                                     same 
                                   differs 
                                      17 
 Iowa 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      18 
 Kansas 
                                     same 
                                     same 
                                     same 
                                   differs 
                                     same 
                                     same 
                                      19 
 Kentucky 
                                   differs 
                                   differs 
                                   differs 
                                   differs 
                                   differs 
                                     same 
                                      20 
 Louisiana 
                                   differs 
                                     same 
                                     same 
                                     same 
                                   differs 
                                     same 
                                      21 
 Maine 
                                   differs 
                                     same 
                                   differs 
                                     same 
                                     same 
                                     same 
                                      22 
 Maryland 
                                   differs 
                                   differs 
                                   differs 
                                   differs 
                                     same 
                                     same 
                                      23 
 Massachusetts 
                                     same 
                                     same 
                                     same 
                                   differs 
                                     same 
                                   differs 
                                      24 
 Michigan 
                                   differs 
                                     same 
                                   differs 
                                     same 
                                     same 
                                   differs 
                                      25 
 Minnesota 
                                     same 
                                   differs 
                                   differs 
                                   differs 
                                     same 
                                     same 
                                      26 
 Mississippi 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                      27 
 Missouri 
                                   differs 
                                     same 
                                   differs 
                                   differs 
                                     same 
                                   differs 
                                      28 
 Montana 
                                     same 
                                     same 
                                   differs 
                                     same 
                                   differs 
                                     same 
                                      29 
 Navajo Nation 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      30 
 Nebraska 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                      31 
 Nevada 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                      32 
 New Hampshire 
                                   differs 
                                   differs 
                                   differs 
                                   differs 
                                     same 
                                   differs 
                                      33 
 New Jersey 
                                     same 
                                     same 
                                   differs 
                                     same 
                                     same 
                                     same 
                                      34 
 New Mexico 
                                     same 
                                     same 
                                   differs 
                                     same 
                                     same 
                                     same 
                                      35 
 New York 
                                   differs 
                                     same 
                                   differs 
                                     same 
                                     same 
                                   differs 
                                      36 
 North Carolina 
                                     same 
                                     same 
                                   differs 
                                     same 
                                     same 
                                   differs 
                                      37 
 North Dakota 
                                     same 
                                     same 
                                   differs 
                                     same 
                                     same 
                                     same 
                                      38 
 Ohio 
                                     same 
                                     same 
                                   differs 
                                     same 
                                     same 
                                   differs 
                                      39 
 Oklahoma 
                                     same 
                                     same 
                                   differs 
                                     same 
                                     same 
                                   differs 
                                      40 
 Oregon 
                                   differs 
                                     same 
                                   differs 
                                     same 
                                     same 
                                   differs 
                                      41 
 Pennsylvania 
                                     same 
                                     same 
                                   differs 
                                     same 
                                     same 
                                   differs 
                                      42 
 Puerto Rico 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      43 
 Rhode Island 
                                   differs 
                                     same 
                                   differs 
                                   differs 
                                     same 
                                   differs 
                                      44 
 South Carolina 
                                   differs 
                                     same 
                                   differs 
                                     same 
                                     same 
                                   differs 
                                      45 
 South Dakota 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                      46 
 Tennessee 
                                     same 
                                     same 
                                     same 
                                   differs 
                                     same 
                                     same 
                                      47 
 Texas 
                                   differs 
                                   differs 
                                   differs 
                                   differs 
                                     same 
                                   differs 
                                      48 
 Trust Territories 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      49 
 Utah 
                                   differs 
                                     same 
                                   differs 
                                     same 
                                     same 
                                     same 
                                      50 
 Vermont 
                                   differs 
                                     same 
                                   differs 
                                     same 
                                     same 
                                     same 
                                      51 
 Virgin Islands 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      - 
                                      52 
 Virginia 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                   differs 
                                      53 
 Washington 
                                   differs 
                                     same 
                                   differs 
                                   differs 
                                   differs 
                                   differs 
                                      54 
 West Virginia 
                                     same 
                                     same 
                                   differs 
                                     same 
                                     same 
                                     same 
                                      55 
 Wisconsin 
                                     same 
                                     same 
                                   differs 
                                   differs 
                                     same 
                                     same 
                                      56 
 Wyoming 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
                                     same 
 
 
2.3 Summary of Potentially Affected Entities 
This section summarizes the counts of affected industrial entities and states. In all 200,096 industrial entities and 33 state governments are estimated to be affected by the e-Manifest rule. Exhibit 2-15 below displays these counts. 
 
                                 Exhibit 2-15 
                   Summary of Universe of Affected Entities 
                                     Item 
                                      A 
                                      B 
                                      C 

                                 Entity Type 
 Number affected 
                               Source and Notes 
                                      1 
LQG Shippers and nonLQG TSDF Shippers[a] 
                                                                        16,345 
2011 RCRA Biennial Report, Exhibit 3.1 
                                      2 
SQG Shippers (who manifest) 
                                                                        35,330 
Exhibit 2-7, based on calculations from EPA's 
2015 Improvements to the Hazardous Waste Generator Regulatory Program proposed rule RIA. 
                                      3 
CESQG Shippers (who manifest) 
                                                                         2,039 
Section 2.1.2.3, based on calculations from 
EPA's 2015 Improvements to the Hazardous Waste Generator Regulatory Program proposed rule RIA and that only Arkansas requires CESQGs to manifest 
                                      4 
State Waste Shippers (who manifest) 
                                                                       145,522 
Exhibit 2-10, based on calculations from EPA's 
2015 Improvements to the Hazardous Waste 
Generator Regulatory Program proposed rule RIA and states with additional wastes which require manifests for shipment 
                                      5 
SQGs Shipping under BRFAs (who manifest) 
                                                                           447 
Exhibit 2-11, based on calculations from EPA's 
2015 Improvements to the Hazardous Waste 
Generator Regulatory Program proposed rule RIA.and states requiring manifests for BFRA shipments 
                                      6 
Industry Subtotal  - 
Shippers who Manifest 
                                                                       199,683 
 
                                      7 
Receiver TSDFs* 
                                                                           413 
2011 RCRA Biennial Report, Exhibit 3.5 
                                      8 
Industry Subtotal  -  Shippers and Receivers who Manifest 
                                                                       200,096 
 
                                      9 
Transporters (Trucks) 
                                                                         9,947 
Exhibit 2-12, based on 1996 and 2001 DoT Truck Use Surveys based on 1992 and 1997 data, scaled to estimate 2012 truck counts 
                                      10 
Industry Total 
                                                                       210,043 
 
                                      11 
State Governments 
                                                                            33 
ENVCAP data 
[a] The RCRA Biennial Report does not indicate the extent to which the universe of receiver TSDFs overlaps with the universe of non-LQG TSDF shippers of federal hazardous waste. Therefore, the subtotal and total in Rows 8 and 10, respectively, may overstate the total number of industry entities affected. However, any non-LQG TSDF shipper would be affected by the proposed rule via requirements that specifically correspond to shippers of waste, while receiver TSDFs would be affected by the proposed rule's requirements that specifically correspond to receivers of waste. Therefore, even though the total number of entities affected may be overstated, the subtotal and totals in this exhibit accurately portray the number of entity-instances estimated to be affected by the proposed rule, as TSDFs that function as both non-LQG shippers and receivers of waste will be impacted by two different sets of requirements associated with the proposed rule.  
 

                                   Chapter 3 
                       Count of Hazardous Waste Manifests 
                                        
This chapter provides an estimate of the number of manifests likely to be affected by the proposed rule. Because most costs and cost savings associated with the proposed rule accrue on a per-manifest basis, the estimate of manifests is a critical component of the remainder of this RIA. 
 
The annual number of manifests accompanying shipments of hazardous waste represents the basis for establishing e-Manifest user fees, because the bulk of all costs associated with manifests are incurred on a per-manifest Basis. Additionally, all costs and cost savings associated with the proposed rule are driven in large part by the number of manifests.  
 
Specifically, EPA is proposing to establish per manifest user fees that allocate the total annual costs of developing, managing, and supporting the e-Manifest system across the number of manifests handled by the system each year. Likewise, the analyses of baseline costs and system cost savings in this RIA both begin by estimating the per-manifest burden of complying with the manifest regulations, and then scale these estimates up to estimate costs and benefits nationally. Because the annual count of manifests fluctuates from year to year based on the national level of economic activity, the analysis in this RIA considers a number of sources based on 2011 data to estimate and project a "typical" annual count of manifests.[2] 
 
3.1 Prior Estimates of Manifests 
 
Multiple estimates approximate the annual count of hazardous waste manifests. One key source is the Information Collection Request (ICR) that EPA must submit to OMB every three years to continue requiring industry to use manifests. This Hazardous Waste Manifest System ICR, most recently updated in 2015, contains an estimate of the annual count of RCRA manifests associated with the federal program.[4] However, the scope of this ICR does not consider the burden from manifests or activities associated with individual State-specific programs and requirements. Similarly, this ICR estimates only the annual count of manifests bearing federal hazardous waste codes, and omits manifests that bear only state hazardous waste codes. Because the e-Manifest system created by the proposed rule will be the central, national destination for all manifests, regardless of whether they bear state or federal waste codes, the current Hazardous Waste Manifest System ICR undercounts the number of annual manifests that will enter the e-Manifest system, as well as the current volume of manifests created and submitted under Federal and State requirements. Exhibit 3-1 below displays the annual estimate of federal manifests from the last three Hazardous Waste Manifest System ICRs. 
 
                                 Exhibit 3-1 
                ICR Estimate of the Annual Count of Manifests 
                                  ICR Number 
                                     Year 
             Average Annual Estimate of Manifests (Federal only) 
                                    801.20 
                                     2015 
                                  1,407,016 
                                    801.18 
                                     2012 
                                  1,887,404 
                                    801.15 
                                     2004 
                                  1,762,276 
 
EPA also estimated the annual count of manifests in the 2005 Final Revisions to the RCRA Hazardous Waste Manifest Form rule. In this rule, EPA set national standards for the layout of the hazardous waste manifest, which had previously been modified by a number of states to suit the needs of their delegated RCRA programs. Because the RCRA Hazardous Waste Manifest Form rule affected manifests bearing federal waste codes as well as manifests bearing state waste codes, it required a national comprehensive estimate of the count of state and federal manifests. The national count of all manifests for that rule was estimated at between 2.4 million and 5.1 million manifests per year. 
 
3.2 Current Estimate of Manifests 
 
To develop an up-to-date annual count of manifests for the proposed rule, this RIA extrapolates a manifest count from hazardous waste generation and shipping data provided within the 2011 RCRA Biennial Report.[6] Then, in order to validate this estimate, this RIA considers additional methods and data sources. Specifically, this section validates the extrapolated estimate of manifests by examining industry surveys of TSDFs and paper manifest printers. 
 
3.2.1 Extrapolated Estimate of Manifests Based on 2011 RCRA Biennial Report Data 
 
In this section, this RIA estimates the annual number of RCRA hazardous waste manifests produced to accompany shipments of hazardous waste. It estimates manifests accompanying shipments of federally-defined hazardous waste, as well as shipments of state governmentdefined hazardous wastes.  
 
This analysis relies on several different sets of data, and incorporates the universe of facilities that generate, transport, and receive hazardous wastes with manifests and are therefore likely to be affected by the proposed rule as described in Chapter 2. As the Chapter 2 analysis incorporates data from the 2011 RCRA Biennial Report, EPA's 2015 Improvements to the Hazardous Waste Generator Regulatory Program proposed rule RIA, the ENVCAP environmental compliance assistance platform, and the Department of Transportation's Vehicle Inventory and Use Surveys from 1996 and 2001, this section similarly relies on these sources to estimate the annual count of manifests.  
 
To estimate the number of manifests generated by the facilities in the universe, this RIA begins with 2011 RCRA Biennial Report data that group generators of hazardous waste into mutually exclusive ranges based on the quantity of hazardous waste that they report generating.  These ranges are: 
 
       Fewer than 1.1 tons generated (9.80 percent of all generators); 
       1.1 to 13.2 tons generated (35.03 percent of all generators); 
       13.2 to 113.2 tons generated (36.04 percent of all generators); 
       113.2 to 1,113.2 tons generated (14.58 percent of all generators); 
       1,113.2 to 11,113.2 tons generated (3.53 percent of all generators); 
       11,113.2 to 111,113.2 tons generated (0.82 percent of all generators); and 
       Over 111,113.2 tons generated (0.20 percent of all generators).  
 
Additionally, this RIA assumes that hazardous waste shipping trucks have a maximum capacity of 30 tons. 
 
Based on these two key data inputs, this analysis uses waste tonnage data from the 2011 RCRA Biennial Report and entity counts from Chapter 2 to estimate an extrapolated count of manifests used by LQGs and non-LQG TSDF shippers, for whom the most waste data is available via the Biennial Report. This methodology is then applied, in a simplified manner, to other entities: SQGs and state hazardous waste shippers. 
 	 
3.2.1.1 Estimate of Annual LQG and Non-LQG TSDF Shipper Manifests 
 
To estimate the annual count of manifests used by LQGs and non-LQG TSDF shippers, this RIA first apportioned all generating facilities reporting to the 2011 RCRA Biennial Report into groups based on the ranges of hazardous waste tonnage. These groups contained all facilities (i.e., LQGs and non-LQG TSDF shippers) that generate tonnage within a certain range, and for each group, this RIA estimated an average per-facility amount generated.[12] Because, according to the 2011 RCRA Biennial Report, the count of entities generating hazardous waste is not exactly the same as the count of entities shipping hazardous waste off-site, this RIA proportionally scaled the number of entities generating hazardous waste in each tonnage category in order to reflect the universe of LQGs and non-LQG TSDF shippers shipping waste off-site per the 2011 Biennial Report. This RIA then applied a similar calculation to the estimated per-entity generation above to proportionally scale average tons generated to average tons shipped. (Only approximately 17 percent of hazardous waste tonnage is shipped off-site per the 2011 RCRA Biennial Report.) 
 
Given the steps above, this RIA estimated the number of shipping entities (LQGs and non-LQG TSDF shippers only) for each generation tonnage category, and the average annual quantity of hazardous waste shipped, in terms of tonnage, for an entity in each generation tonnage category. For example, this RIA estimated 134 shippers in the 11,113.2 to 111,113.2 tons generated category, and an average annual total shipment of approximately 5,359 tons. 
 
To convert the figures above into estimates of annual manifest counts, this RIA applied three further assumptions:  
 
       Each hazardous waste truck can accommodate a load of up to 30 tons. 
       
       Hazardous waste shipments from each generator are picked up as part of routes that are regularly serviced by transporters occurring either weekly, monthly, or quarterly. 
 
       Each shipment (i.e., one truck carrying one load picked up from one facility) requires its own manifest. 
       
Then, this RIA used the above assumptions along with the calculations described above to estimate the total number of hazardous waste shipments from LQGs and non-LQG TSDF shippers. Specifically, this RIA further calculated that shipments of less than 30 tons would require one truck each, while shipments of over 30 tons would require enough trucks to haul the entire tonnage of a shipment away. Additionally, this RIA calculated the average per-facility number of manifests used by the generators within each tonnage generation group as the number of trucks required to haul away weekly, monthly, and quarterly shipments. 
 
For example, generators in the smallest generation tonnage group (fewer than 1.1 tons generated) were estimated, given the steps above, to have an average shipment of 0.05 tons annually: these generators would thus require 52 manifests if serviced on a weekly basis (a small fraction of the 0.05 tons picked up every week), 12 manifests if serviced on a monthly basis (a bigger fraction of the 0.05 tons picked up every month), or four manifests if serviced on a quarterly basis (an even bigger fraction, specifically a fourth, of the 0.05 tons picked up every quarter).  
 
On the other hand, generators in the second-largest generation tonnage group (11,113.2 to 111,113.2 tons generated) were estimated, given the steps above, to have an average shipment of 5,359 tons annually. These generators would thus require:  
 
       208 manifests if serviced on a weekly basis (5,359 separated into 52 weekly pickups equals 103 tons per pickup, requiring four trucks once a week for 52 weeks); 
       
       180 manifests if serviced on a monthly basis (5,359 separated into 12 monthly pickups equals 447 tons per pickup, requiring 15 trucks once a month for 12 months); or 
 
       180 manifests if serviced on a quarterly basis (5,359 separated into four quarterly pickups equals 1,340 tons per pickup, requiring 45 trucks once a quarter for four quarters). 
 
Generally, shippers in the smaller tonnage generation groups require 52, 12, or four manifests if pickups are assumed to occur on a weekly, monthly, or quarterly basis, respectively. This is because multiple trucks are not required per pickup to service the loads from these generators. 
However, shippers in the larger tonnage generation groups require multiple trucks per pickup to service their loads, and correspondingly require larger quantities of manifests. The frequency of pickups does not substantially alter the number of trucks required to service these shippers, because each pickup will require multiple trucks. 
 
To scale these estimates up to a national count, this RIA then multiplied the amount of manifests estimated per entity by the total number of estimated shipping entities in each tonnage generation category. 
 
Exhibit 3-2 below displays the calculations described above. Columns A through G refer to the seven size categories of generators broken out in the 2011 RCRA Biennial Report. Rows 1-5 contain the total count of generating facilities and shippers in each of the seven groups. Rows 610 contain the estimated average amount waste generated, the total shipped, and the size of weekly, monthly, and quarterly shipments for each group. Rows 11-13 contain the estimates of manifests per facility, assuming weekly, monthly, or quarterly shipments. Rows 14-22 contain annual estimates of manifest usage for each of the seven groups under the weekly, monthly, and quarterly shipping assumptions. 
 
3.2.1.2 Estimate of Annual SQG and State Hazardous Waste Manifests 
 
This RIA uses a similar process to estimate the annual count of manifests used by small quantity generators (SQGs) and generators of state hazardous waste. The key assumption employed by this RIA for these facilities is that the generators in these facility classes produce no more than one load's worth of hazardous waste per shipment. Similarly to the LQG and non-LQG TSDF shipper facilities discussed above, this RIA assumes that these facilities' shipments are picked up as part of weekly, monthly, or quarterly routes by transporters. From these assumptions, the annual number of manifests submitted by these facilities is equal to the product of the number of facilities and the number of shipments under each shipping scenario (i.e., weekly, monthly, or quarterly pickups by transporters). 
                                 Exhibit 3-2 
Estimate of Average Annual Count of Manifests from LQGs and Non-LQG TSDF Shippers 
                                     Item 
               2011 Biennial Report Generation Tonnage Category 
                                    Total 

                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 


0 to 1.1 
                                    1.1 to 
                                     13.2 
                                13.2 to 113.2 
                               113.2 to 1,113.2 
                                  1,113.2 to 
11,113.2 
                                 11,113.2 to 
111,113.2 
                            111,113.2 and greater 

Generator Facility Counts 
                                      1 
Generators[a] 
                                                                         1,612 
                                                                         5,761 
                                                                         5,927 
                                                                         2,398 
                                                                           581 
                                                                           135 
                                                                            33 
                                                                        16,447 
                                      2 
% of Facilities[a] 
                                                                         9.80% 
                                                                        35.03% 
                                                                        36.04% 
                                                                        14.58% 
                                                                         3.53% 
                                                                         0.82% 
                                                                         0.20% 
                                                                       100.00% 
                                      3 
LQG Shippers[b] 
                                                                         1,389 
                                                                         4,965 
                                                                         5,108 
                                                                         2,067 
                                                                           501 
                                                                           116 
                                                                            28 
                                                                        14,174 
                                      4 
 Non-LQG TSDF 
Shippers[b] 
                                                                           213 
                                                                           760 
                                                                           782 
                                                                           317 
                                                                            77 
                                                                            18 
                                                                             4 
                                                                         2,171 
                                      5 
All Shippers in BR[b] 
                                                                         1,602 
                                                                         5,725 
                                                                         5,890 
                                                                         2,384 
                                                                          577  
                                                                           134 
                                                                            33 
                                                                        16,345 
LQG Hazardous Waste Tonnage 
                                      6 
Avg Annual Generation[c] 
                                                                           0.3 
                                                                           3.6 
                                                                          31.8 
                                                                         308.3 
                                                                       3,073.2 
                                                                      30,722.9 
                                                                     831,886.2 
                                                                    34,334,072 
                                      7 
Avg Shipped[d] 
                                                                           0.1 
                                                                           0.6 
                                                                           5.5 
                                                                          53.8 
                                                                         536.0 
                                                                       5,358.7 
                                                                     145,097.9 
                                                                     5,951,421 
                                      8 
Avg Weekly[e] 
                                                                         0.001 
                                                                          0.01 
                                                                           0.1 
                                                                           1.0 
                                                                          10.3 
                                                                         103.1 
                                                                       2,790.3 
                                                                               
                                      9 
Avg Monthly[e] 
                                                                         0.004 
                                                                          0.05 
                                                                           0.5 
                                                                           4.5 
                                                                          44.7 
                                                                         446.6 
                                                                      12,091.5 
                                                                               
                                      10 
Avg Quarterly[e] 
                                                                          0.01 
                                                                           0.2 
                                                                           1.4 
                                                                          13.4 
                                                                         134.0 
                                                                       1,339.7 
                                                                      36,274.5 
                                                                               
LQG Manifest Counts (Per BR Facility)[f] 
                                      11 
Weekly 
                                                                            52 
                                                                            52 
                                                                            52 
                                                                            52 
                                                                            52 
                                                                           208 
                                                                         4,888 
                                                                               
                                      12 
Monthly 
                                                                            12 
                                                                            12 
                                                                            12 
                                                                            12 
                                                                            24 
                                                                           180 
                                                                         4,848 
                                                                               
                                      13 
Quarterly 
                                                                             4 
                                                                             4 
                                                                             4 
                                                                             4 
                                                                            20 
                                                                           180 
                                                                         4,840 
                                                                               
LQG Manifest Counts (All BR Facilities)[g] 
                                      14 
LQG Weekly 
                                                                        72,228 
                                                                       258,171 
                                                                       265,610 
                                                                       107,463 
                                                                        26,037 
                                                                        24,199 
                                                                       139,012 
                                                                       892,730 
                                      15 
LQG Monthly 
                                                                        16,671 
                                                                        59,578 
                                                                        61,295 
                                                                        24,799 
                                                                        12,017 
                                                                        20,942 
                                                                       137,874 
                                                                       333,175 
                                      16 
LQG Quarterly 
                                                                         5,557 
                                                                        19,859 
                                                                        20,432 
                                                                         8,266 
                                                                        10,014 
                                                                        20,942 
                                                                       137,646 
                                                                       222,176 
                                      17 
Non-LQG TSDF Weekly 
                                                                        11,076 
                                                                        39,543 
                                                                        40,683 
                                                                        16,460 
                                                                         3,988 
                                                                         3,707 
                                                                        21,292 
                                                                       136,737 
                                      18 
Non-LQG TSDF Monthly 
                                                                         2,553 
                                                                         9,125 
                                                                         9,388 
                                                                         3,798 
                                                                         1,841 
                                                                         3,208 
                                                                        21,118 
                                                                        51,032 
                                      19 
Non-LQG TSDF 
Quarterly 
                                                                           851 
                                                                         3,042 
                                                                         3,129 
                                                                         1,266 
                                                                         1,534 
                                                                         3,208 
                                                                        21,083 
                                                                        34,113 
                                      20 
Subtotal Weekly 
                                                                        83,304 
                                                                       297,714 
                                                                       306,293 
                                                                       123,923 
                                                                        30,025 
                                                                        27,906 
                                                                       160,304 
1,029,468 
                                      21 
Subtotal Monthly 
                                                                        19,224 
                                                                        68,703 
                                                                        70,683 
                                                                        28,598 
                                                                        13,858 
                                                                        24,149 
                                                                       158,992 
                                                                       384,206 
                                      22 
Subtotal Quarterly 
                                                                         6,408 
                                                                        22,901 
                                                                        23,561 
                                                                         9,533 
                                                                        11,548 
                                                                        24,149 
                                                                       158,729 
                                                                       256,829 
Totals may not sum due to rounding. 
 2011 RCRA Biennial Report, Exhibit 1.5. 
 The total of 16,345 shipping entities, 14,174 of which are LQGs and 2,171 of which are non-LQG TSDF shippers taken from Exhibit 3.1 of the 2011 RCRA Biennial Report. Values in Rows 3 and 4 calculated by applying the percentage in Row 2 to the total value of Rows 3, 4, and 5. c Calculated by applying a scaling factor to the midpoint of each generation tonnage range to ensure that total generated tonnage equaled the total generated tonnage in Exhibit 1.1 of the 2011 RCRA Biennial Report. This scaling factor leads to the use of roughly the 25[th] percentile of the range, e.g., 0 to 1.1 has a range of 1.1 x 0.25 = 0.275, etc. This scaling factor does not apply to Column G, for which actual tonnages were taken directly from Exhibit 1.4 of the 2011 RCRA Biennial Report. d Calculated by multiplying Row 6 by the ratio of the total of Row 7 (Exhibit 3.1 of the 2011 RCRA Biennial Report) to the total of Row 6 (Exhibit 1.1 of the 2011 RCRA Biennial Report). 
 Calculated by multiplying Row 7 by 52 (52 weeks in a year), 12 (12 months in a year), or 4 (four quarters in a year), respectively. 
 Calculated to be the total shipments required by a facility in a given generation tonnage category as [Row 8 Value / 30], rounded up, x [52, 12, or 4, respectively]. g Calculated as [Row 3, 4, or 5] x [Row 11, 12, or 13]. 
 
 	 
Exhibit 3-3 below contains a summary of the estimate of SQG, state hazardous waste, and SQG shippers operating under reclamation agreements. Rows 1-3 contain the facility counts and manifest estimates for each of these three facility types. Column B contains the facility counts for each category of shipper, and column C contains average annual manifest estimates for each category under the three shipping scenarios. 
 
                                 Exhibit 3-3 
Estimate of Average Annual Count of Manifests from SQGs, State Hazardous Waste Shippers, and 
                      Federally Exempt Waste Facilities 
                                     Item 
                                      A 
                                      B 
                                      C 

                               Shipper Category 
                            Shipper Facility Counts 
                               Manifest Counts 



                                    Weekly 
                                   Shipping 
                                   (B x 52) 
                                   Monthly 
                                   Shipping 
                                   (B x 12) 
                                  Quarterly 
                                   Shipping 
                                   (B x 4) 
                                      1 
 SQGs 
                                                                        35,330 
                                                                     1,837,183 
                                                                       423,965 
                                                                       141,322 
                                      2 
 State Hazardous Wastea 
 	148,008 
                                                                     7,696,398 
                                                                     1,776,092 
                                                                       592,031 
                                      3 
 Federally Exempt SQGs  -  reclamation agreements (nonmanifesters)[b] 
                                                                         4,827 
                                                                       250,981 
                                                                        57,919 
                                                                        19,306 
                                      4 
                                                                         Total 
                                                                       188,165 
                                                                     9,533,581 
                                                                     2,200,057 
                                                                       733,352 
 a Consists of 145,522 state waste shippers plus 2,039 CESQG shippers required to manifest per state-specific requirements plus 447 SQG shippers operating under bona-fide reclamation agreements not exempt from federal manifest requirements due to state-specific regulations. See Chapter 2 and Exhibits 2-14 and 2-15 for additional information. b This category pertains to a class of SQG facilities who are exempt from manifest because their shipments of hazardous waste are covered under reclamation agreements. Note that within six States, State-specific regulations require even these shippers to conduct manifest activities; these facilities are included as State Hazardous Waste shippers in Row 2 due to these manifest requirements. It is not included in the manifest count in the total row, because manifests are not required for these facilities and their shipments. 
 
The total number of manifests under each shipping scenario is equal to the sum of the totals from Exhibits 3-2 and 3-3.  
 
       The total annual count of manifests under the weekly shipping scenario is 10,563,048. 
       The total annual count of manifests under the monthly shipping scenario is 2,584,263.  
       The total annual count of manifests under the quarterly shipping scenario is 990,182.  
 
There exists insufficient information to determine the shipment and pickup schedules under which generators and transporters of hazardous waste function. The majority of manifests correspond to shipments from SQGs and generators of state hazardous waste. This is not surprising as the entity counts for these facility classes greatly exceed the number of LQGs and non-LQG TSDF currently shipping waste off-site. However, this RIA assumes that LQGs and non-LQG TSDFs ship waste on a weekly pickup schedule, an intuitive assumption as bigger generators generating more waste will be more likely to require more frequent pickups. As a conservative (high-cost) assumption, this RIA also assumes that SQGs and state hazardous waste generators ship waste on a monthly pickup schedule, as they generate relatively less waste than LQG and non-LQG TSDFs. Additionally, it is likely that different SQGs ship wastes under all three shipping scenarios; the monthly scenario represents an average of the three scenarios. Based on these assumptions, this RIA estimates 1,029,468 manifests from LQGs and non-LQG TSDF shippers (see the highlighted figure in Exhibit 3-2) and 2,200,057 manifests from SQGs and state hazardous waste generators (see the highlighted figure in Exhibit 3-3), for a total of 3,229,525 manifests generated annually. Of these 3,229,525 manifests, 1,453,433 manifests are federal manifests (LQG, non-LQG TSDF shipper, and SQG-originated manifests), while the remaining 1,776,092 manifests are state manifests (state hazardous waste manifests from Exhibit 3-3). 
 
This RIA's estimate of 3.2 million annual manifests falls within the range of manifests estimated in the 2005 Revisions to the RCRA Hazardous Waste Manifest Form final rule. Chapter 6 includes an evaluation of additional scenarios under alternate annual counts of manifests. 
 
3.2.2 Estimate of Manifests based on Industry Responses 
This section attempts to validate or benchmark the estimate of approximately 3.2 million annual manifests using two surveys of hazardous waste management industry participants. 
 
3.2.2.1 Manifest Estimate from TSDF Responses 
 
In an effort to confirm or refine the estimate of the number of manifests based on Biennial Report tonnages and facility populations, EPA asked nine of the largest TSDF companies to report the number of manifests they used annually for the past three years. In response to the survey, six firms provided counts of the manifests they used, displayed in Rows 1 through 6 and Columns B through D in Exhibit 3-4 below. Additional information on this survey and TSDF companies' responses is available in Appendix C. 
 
To derive a national estimate of manifests from this sample, EPA scaled the responses using market concentration ratios from the 2007 Economic Census. Market concentration ratios indicate the percentage of total sales, receipts, or revenue of an industry that accrue to a given number of firms in a specified six-digit NAICS code. The concentration ratio for NAICS 562211, hazardous waste treatment and disposal, was 44.6 percent for the four largest firms in the industry, and 59.2 percent for the eight largest firms in 2007, the most recent year available.[20] Assuming that market concentration scales perfectly with manifest use (i.e., companies making up 50 percent market concentration use 50 percent of manifests) and that the six firms that reported to the survey represent a market concentration between that of the top four and the top eight in the industry, a range of average annual manifest use can be extrapolated. Under these assumptions, the national total count of manifests may be between 1.3 million and 1.8 million manifests per year. 
 
 
                                                                                                                                                                                           
pickup schedule is conservative, and results in lower cost savings, than if this RIA assumed a weekly pickup schedule for all generators. This RIA assesses the impacts of alternate pickup schedules for all entity classes in Chapter 6. 
[20] See: 
http://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ECN_2007_US_56SSSZ6&prodT ype=table 
 

                                 Exhibit 3-4 
  Reported Manifest Usage by 6 TSDF Companies for the Years 2011 through 2013 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 

                                   Company 
                                  Count 2013 
                                  Count 2012 
                                  Count 2011 
                                      1 
Veolia 
                                                                       100,000 
                                                                       100,000 
                                                                       100,000 
                                      2 
Tradebe 
                                                                        45,000 
                                                                        46,000 
                                                                        45,000 
                                      3 
Clean Harbors Environmental Services 
                                                                       561,761 
                                                                       569,507 
                                                                       572,290 
                                      4 
Ross Environmental Services, Inc. 
                                                                        14,448 
                                                                        13,592 
                                                                        12,782 
                                      5 
Heritage Environmental Services 
                                                                        50,200 
                                                                        42,700 
                                                                        49,700 
                                      6 
Systech Environmental Corporation 
                                                                        21,470 
                                                                        22,982 
                                                                        19,629 
                                      7 
                                                                         Total 
                                                                       792,879 
                                                                       794,781 
                                                                       799,401 
                                      8 
National Total Using 4-Firm Concentration Ratio (44.6%) 
                                                                     1,777,756 
                                                                     1,782,020 
                                                                     1,792,379 
                                      9 
National Total using 8-Firm Concentration Ratio (59.2%) 
                                                                     1,339,323 
                                                                     1,342,535 
                                                                     1,350,340 
 
The estimates derived from this methodology are consistent with the results from the various federal manifest ICRs (see Exhibit 3-1) but fall below the range of manifests estimated in the 2005 Final Revisions to the RCRA Hazardous Waste Manifest Form rule. Most telling, the most recent Hazardous Waste Manifest System ICR only accounts for only federal hazardous waste manifests. Also this survey-derived estimate falls below the range estimated in the 2005 Final Revisions to the RCRA Hazardous Waste Manifest Form (see Section 3.1); this suggests that these estimates likely understate total manifest numbers, potentially because survey respondents' responses only estimated the number of federal manifests used. It is also potentially possible that the scaling factors are not appropriate for the firms represented here, i.e., these firms are not the largest firms in the industry, or manifest usage accrues to firms in other six-digit NAICS codes. Alternately, manifest usage may simply not scale proportionally to market concentration. 
 
3.2.2.2 Manifest Estimate from Manifest Printer Responses 
 
EPA does not print and distribute copies of the manifest, but authorizes specific companies to print the specialized form. Currently, 13 companies are approved by EPA to print the manifest. Nine of these companies offer manifests for sale, and four are TSDF companies that print manifests for their own use. For this estimate, EPA contacted nine manifest printers and asked them to report the number of manifests they sell annually. Five of these companies responded (see Exhibit 3-5). Respondents sent in figures for single years, multiple years, and averages; Exhibit 3-5 reflects annual averages of manifests sold. Three of the TSDF companies with totals displayed in Exhibit 3-4, Stericycle/PSC, Veolia, and Tradebe, are also registered printers of the manifest.  
 
 
 
 
 
 
                                 Exhibit 3-5 
             Average Annual Sales Printed of Manifest Paper Forms 
                                     Item 
                                   Company 
                                Average Annual 
                               Printed Manifest 
 Paper Form Sales 
                                      1 
JJ Keller 
                                                                     1,500,000 
                                      2 
Flesh Co 
                                                                     1,120,400 
                                      3 
Welsh & Associates 
                                                                        60,000 
                                      4 
Genoa Forms 
                                                                       300,000 
                                      5 
                                                           Subtotal (Printers) 
                                                                     2,980,400 
                                      6 
Stericycle / PSC 
                                                                       305,909 
                                      7 
Veolia 
                                                                       100,000 
                                      8 
Tradebe  
                                                                        45,000 
                                      9 
                Total (Printers and TSDFs who print for manifests for own use) 
                                                                    3,431,309  
 
This combined estimate of manifests printed and sold annually is 3.4 million  -  roughly similar to the 3.2 million manifests estimated in Section 3.2.1 above. This count may overestimate the total number of manifests used, because more manifests are likely sold than used in a given year, which affords generators a buffer to ensure that they do not run out of manifests before purchasing more. This count may underestimate the total number of manifests used because Exhibit 3-6 does not capture four of the nine companies currently selling manifests.  
 

                                 Exhibit 3-6 
                  Summary of Annual Manifest Count Estimates 
Item 
                                    Source 
Annual Manifest Estimate 
                                    Notes 
                                      1 
EPA Hazardous Waste Manifest System ICRs 
                           1,407,016  -  1,887,404 
Federal manifests only, 2004-2015 
                                      2 
Final Revisions to the RCRA 
Hazardous Waste Manifest Form rule 
                           2,400,000  -  5,100,000 
Federal and state manifests, 2005 
                                      3 
RIA primary estimate 
                                  3,229,525 
Federal and state manifests 
                                      4 
Extrapolated estimate from TSDF survey 
                           1,339,323  -  1,792,379 
May include only federal manifests, 2011-2013 
                                      5 
Manifest printer responses 
                                  3,431,309 
Federal and state manifests 
 
The cost impacts and related analyses in the remainder of this RIA rely on the annual manifest count of approximately 3.2 million. Sensitivity analyses considering alternate annual manifest counts are included in Chapter 6. This estimate appears to be similar to an independent assessment of the number of manifests sold by manifest printers annually, and exceeds an estimate from a survey of TSDF manifest users, which may not have included state manifests in their responses. 

                                   Chapter 4 
          Baseline (Paper) Manifest Activities in the Hazardous Waste 
                              Management Industry 
                          The paper manifest process 
                                        
A manifest form contains identifying information about a hazardous waste shipment as well as the entities handling the waste, from origin point to final destination. A paper copy must accompany the shipment of hazardous waste. The form contains signature lines for all entities that handle the waste. Under the current paper manifest system: 
 
       Generators that ship hazardous waste off-site initiate a manifest(s) for a shipment, potentially with the assistance of a transporter or receiver TSDF. A generator fills out this six-ply form with facility identification information and waste descriptions (including waste quantity, type, and container descriptions), signs the document, and pulls off and retains a copy. 
       
       The transporter that picks up the hazardous waste shipment from the generator facility must also supply identifying information, sign the form, and retain a copy. 
       
       All waste handlers, including subsequent transporters and the final receiver TSDF receiving the waste also fill out identifying information, sign the manifest, and retain a copy. 
       
       The receiver TSDF ultimately receiving the waste sends a copy of the complete manifest with all signatures back to the original generator. In some states, this TSDF is also responsible for sending a copy of the complete manifest to a state regulatory authority. 
       
       All waste handlers must retain their manifest copies for at least three years. Although the current manifest form is a paper six-ply form, many waste handlers, as well as some states that collect manifest data, also have their own IT systems to store manifest data electronically (e.g., scanned image or XML format). These systems are not currently used to comply with the manifest requirements for hazardous waste under RCRA. However, they may be adaptable to that purpose after the launch of the e-Manifest system. 
       
In the case of discrepancies between the physical waste cargo and the information on the manifest form, shipments of waste may be sent back to the original generator facility. 
 
For a detailed description of the set of activities that constitute the full paper manifest process, see Appendix D. 
                                        
This chapter characterizes baseline practices associated with the manifest process within the hazardous waste management industry. This chapter addresses the following broad categories of baseline practices and separately characterizes the costs for each: 
 
       Paper manifest costs accruing to industry: federal manifests. This category pertains to the cost to industry to comply with the federally-required paper manifest process, including all aspects of manifest completion, transmittal, discrepancy resolution, and similar activities. For the unit costs associated with these activities, this RIA uses the latest (2015) Information Collection Request (ICR) for the RCRA Hazardous Waste 
      Manifest System (the "HWMS ICR"). This RIA assumes that these costs accrue to the set of 1,453,433 federal manifests described in Chapter 3. 
       
       Paper manifest costs accruing to industry: state-specific manifests. This category pertains to the cost to industry to comply with non-federal (state-specific) paper manifest requirements. Given the degree of variability in state requirements, as a simplifying assumption, this RIA assumes that the unit costs associated with the paper manifest process for federal manifests similarly apply to state-specific manifests. This RIA therefore scales the total costs associated with the 1,453,433 federal manifests to reflect the 1,776,092 state-specific and federally-exempt manifests (see Chapter 3).   
       
       EPA burden to process paper manifests (Agency burden). This category addresses costs that EPA incurs to conduct activities associated with federal paper manifests. Although EPA does not collect or directly process paper manifests in the baseline, the Agency does engage in activities such as reviewing exception reports and receiving discharge notifications from hazardous waste transporters. For the unit costs associated with these activities, this RIA again uses the HWMS ICR. This Agency burden only reflects the activities associated with federal manifests. Under the proposed rule, EPA will implement and maintain an e-Manifest system that will substantially alter the Agency burden associated with hazardous waste manifest processes. 
       
       Burden accruing to states to process paper manifests (state burden). This category pertains to the costs that states incur to receive, process, and conduct other activities associated with both federal and state-specific manifests. To estimate state burden costs, this RIA collected information on the nature and extent of state activities in collecting and processing manifests. Based on this information, this RIA models the costs of manifest collection and processing for the set of 23 states for which information is available about manifest processing-related activities. While these activities are not directly required by the RCRA statute, it is possible that the proposed rule's creation of an e-Manifest system will change (and reduce) state burden by transferring these activities to EPA's centralized system. 
       
       Burden accruing to industry to comply with Hazardous Waste Report (Biennial Report, or BR) reporting. This category pertains to the requirements for private facilities to submit reports to EPA or the states at least every two years that document the quantities and nature of hazardous waste generated during a given year and the 
      disposition of these hazardous wastes. For the unit costs and counts associated with these activities, this RIA uses the latest Information Collection Request (ICR) for the RCRA Hazardous Waste Report (the "BR (Biennial Report) ICR"). Because this RIA assumes that the proposed e-Manifest system will reduce industry burden associated with Hazardous Waste Report reporting, the baseline burden associated with these activities is included as a baseline cost. 
       
       Burden accruing to states to comply with Hazardous Waste Report (Biennial Report) reporting. States also engage in a number of activities to collect information associated with industry Hazardous Waste Report reporting, such as assisting respondents, entering report submissions, and performing quality assurance. The BR ICR is similarly used to track unit costs and counts associated with these activities carried out by the states. Because this RIA assumes that the proposed e-Manifest system will reduce the state burden associated with Hazardous Waste Report reporting, the baseline burden associated with these activities is considered in this chapter as a baseline cost. 
 
4.1 Key Assumptions for Baseline Cost Estimation 
 
This RIA makes three overarching assumptions governing the baseline costs estimated in this chapter. This section documents these assumptions. 
 
4.1.1 Exclusion of Baseline Costs Not Impacted by the Proposed Rule 
 
Hazardous waste management and transport consists of a number of activities, only some of which directly relate to the manifest process. This chapter addresses only costs associated with manifest preparation, not other costs associated with packing and shipping waste. 
 
Furthermore, not all activities described in the RCRA HWMS ICR will be directly impacted by the proposed rule. Specifically, the HWMS ICR includes two substantial components that are separate from the items included in this chapter: 
 
       Reading the regulations. While hazardous waste shippers, transporters, and receivers may need to read new regulations associated with changes to the manifest process, this RIA assumes that they have already read the current regulations and are not doing so regularly. Correspondingly, this activity is not included in the assessment of baseline costs in this chapter.  
       
       Costs accruing to registrant organizations (manifest printers). A distinct group of actors associated with the manifest process are the registrant organizations that apply to, and are authorized by, EPA to print hazardous waste manifests. Because paper manifests will still be available even in the post-rule scenario where the e-Manifest system has been enacted, this RIA does not assume that the proposed rule will have any impact on 
      registrant organizations. Correspondingly, baseline costs associated with registrant organization activities are not included in the assessment of baseline costs in this chapter. Note that given the low magnitude of costs associated with registrant organization activities per the HWMS ICR (under $3,000 per year), this assumption does not substantially impact the calculus for baseline or post-rule costs associated with the proposed rule. 
 
Additionally, the BR ICR estimates costs to EPA to compile the Hazardous Waste Report. While these costs are minor, this RIA does not expect these costs to be substantially altered by the propose rule's creation of an e-Manifest system; correspondingly, these costs are not included as baseline Agency burden costs in this chapter. 
 
Finally, there are a handful of activities included, but not burdened, in the HWMS ICR. These activities pertain to compliance with state, rather than federal, manifest program requirements. As the HWMS ICR ascribes no burden to these activities, this chapter similarly does not include them. 
 
4.1.2 State-Specific Manifest Activity Costs Accruing to Industry 
 
As mentioned above, this RIA assumes that industry's unit costs for the paper manifest process from the HWMS ICR are equally applicable to federal manifests (those directly addressed in the HWMS ICR) and state-specific manifests. In reality, state-specific manifests may have fewer requirements than federal manifests, or additional requirements not captured within the HWMS ICR. Also, many industry burden costs in the HWMS ICR rely on calculations or assumptions regarding the proportion of the manifest or shipment universe that meet certain criteria (e.g., the proportion of hazardous waste shipments made by water or rail, or the proportion of manifests where the receiving TSDF assists the generator with manifest completion) that may not be equivalent across federal manifests and state-specific manifests. 
 
However, given the absence of available unit cost information on industry compliance with statespecific manifest regulations, this RIA assumes that both the unit costs and proportions from the HWMS ICR are applicable to both federal and state-specific manifests. The impact of this uncertainty is unclear. To the extent that state-specific manifests have fewer requirements for completion than federal manifests, this assumption may overstate baseline costs; it may understate baseline costs where state-specific manifests have more and/or costlier compliance requirements than federal manifests. 
 
4.1.3 Complete Use of Paper Manifests in the Baseline 
 
A central assumption of this RIA is that, in the baseline, all manifests are completed in accordance with the complete set of activities listed in the HWMS ICR. That is, this baseline analysis assumes that each shipment is accompanied by a fully-completed paper manifest. This is consistent with current regulations pertaining to hazardous waste transport and management. 
 
While some larger generators and receivers may use electronic or proprietary systems to internally manage manifest-related workflow or data, they are still required to use and complete paper manifests. This RIA does not consider the capital and operating costs of electronic systems to be a required baseline cost, nor does it consider any baseline differences in unit costs associated with manifest completion in these systems. EPA does not know whether or how many businesses will continue to or cease to operate such electronic systems after the implementation of the proposed rule. It seems possible that some businesses will be able to rely on the e-Manifest system to replace internal electronic systems. Due to the voluntary nature of these systems, and that EPA has no data on how many will continue to or cease to use these systems, this RIA does not estimate a change in costs associated with use of these systems due to the proposed rule.  Correspondingly, this chapter captures the baseline costs in the scenario that all manifests are fully completed in paper form, consistent with the assumptions made in the latest Hazardous Waste Manifest System ICR. 
 
4.2 Baseline Costs Accruing to Industry  -  Federal Manifests 
 
The 2015 HWMS ICR provides a comprehensive set of unit costs and frequencies associated with the activities required to complete a federal paper manifest. These activities include both basic tasks (e.g., signing and dating the manifest) as well as responses to issues or discrepancies (e.g., preparing exception reports, contacting generators for further instructions in instances of undeliverable shipments, etc.).  
 
Five distinct entity types develop and use federal manifests: three generator types (LQGs, nonLQG TSDF shippers, and SQGs), transporters, and TSDF receivers. The burden (cost) differs across entity types. For example, TSDF receivers bear the greatest costs associated with manifest completion activities, while transporters incur the highest costs associated with undeliverable shipments. 
 
Exhibit 4-1 below summarizes baseline costs accruing to industry for federal manifests by entity type as well as a broad activity category. While the HWMS ICR included a variety of specific activities associated with each aspect of the manifest process, these are condensed below for illustrative purposes. For a detailed walkthrough of costs by individual activity included in the HWMS ICR as calculated for this RIA, see Appendix D. All unit costs and other proportional assumptions (e.g., the proportion of shipments involving rejected wastes, etc.) used to generate the figures in Exhibit 4-1 are taken from the HWMS ICR, though the costs are presented on the basis of 1,453,433 federal manifests, as indicated in Chapter 3. 
 
                                 Exhibit 4-1 
Baseline Costs Accruing to Industry for Activities Associated with Federal Manifests 
                     (2014$, millions of $, annual costs) 
 Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 

                              Activity Category 
                                 Entity Type 
                                    Total 


                          Generators who Ship Waste 
Transporters 
                                     TSDF 
                                  Receivers 



 LQGs 
                                    NonLQG 
 TSDFs 
                                     SQGs 



                                      1 
Manifest completion, transmittal, and recordkeeping 
                                                                         $15.1 
                                                                         $3.53 
                                                                         $4.21 
                                                                         $16.3 
                                                                         $39.6 
                                                                         $78.9 
                                      2 
Discrepancy / exception reports 
                                                                         $1.13 
                                                                       $0.0462 
                                                                       $0.0661 
                                     N/A 
                                                                         $1.95 
                                                                         $3.20 
                                      3 
Undeliverable shipments 
                                                                    < $0.01 
                                                                    < $0.01 
                                                                    < $0.01 
                                                                    < $0.01 
                                     N/A 
                                                                       $0.0123 
                                      4 
Rejected shipments 
                                                                    < $0.01 
                                                                    < $0.01 
                                                                    < $0.01 
                                                                       $0.0177 
                                                                         $1.30 
                                                                         $1.33 
                                      5 
Notifications of discharge[a] 
                                     N/A 
                                     N/A 
                                     N/A 
                                                                       $0.0497 
                                     N/A 
                                                                       $0.0497 
                                      6 
                                                                         Total 
                                                                         $16.3 
                                                                         $3.58 
                                                                         $4.28 
                                                                         $16.4 
                                                                         $42.9 
                                                                         $83.3 
Totals may not sum due to rounding. 
Sources: Unit costs and proportions: Supporting Statement for Information Collection Request (ICR) Number 801.20 Requirements for Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System. April 30, 2015. Manifest counts: see Chapter 3, manifest counts at maximum shipping frequencies assumed to be weekly for LQGs and non-LQG TSDF shippers and monthly for all other entity types, including generators of State-specific hazardous wastes. Specifically, per Chapter 3, this RIA uses estimates of 892,370 LQG-originated manifests, 136,737 non-LQG TSDF shipperoriginated manifests, and 423,965 SQG-originated manifests; these entities are the only ones originating federal manifests. 
a This activity category applies only to transporters because discharges at shipping or receiving facilities would not be directly manifest-related and paperwork burdens associated with those discharges would fall under requirements associated with other aspects of RCRA. 
 
Per Exhibit 4-1, total baseline industry burden costs associated with federal manifests are approximately $83 million (2014$) annually. The majority of these costs, approximately 95 percent, accrue to activities associated with manifest completion, transmittal, and recordkeeping. This result is intuitive because all manifests have associated completion, transmittal, and recordkeeping requirements; the remaining five percent of industry burden costs accrue to those activities which only occur intermittently. For example, per the HWMS ICR, fewer than two percent of LQG shipper-originated manifests require the LQG shipper to develop an exception report, and less than one percent of manifests received by receiver TSDFs require a full-fledged discrepancy report filing.  
 
The majority of the costs (approximately 51 percent) in Exhibit 4-1 accrue to TSDF receivers. A substantial proportion of these costs (approximately 34 percent of overall TSDF receiver costs) are driven by instances where a "designated" TSDF assists a generator with manifest completion. This scenario, which occurs for 42 percent of LQG-originated manifests and 80 percent of SQGoriginated manifests per the HWMS ICR, apportions a high degree of burden onto designated TSDF receivers; if these designated TSDFs did not assist LQGs and SQGs with manifest completion, the majority of costs would accrue to LQG, non-LQG TSDF, and SQG shippers that originate waste shipments instead. 
Note that the $83 million total estimated for the proposed rule baseline is similar to the approximately $86 million total included on Exhibit 18 of the HWMS ICR. The slight differential occurs for the following reasons:  
 
       The HWMS ICR calculates total industry burden on the basis of 1,407,016 federal manifests. This figure is approximately three percent lower than the RIA's basis of 1,453,433 federal manifests. This increases the RIA's costs in the baseline scenario accruing to federal manifests relative to costs in the HWMS ICR. (Another difference is that the HWMS ICR does not include costs associated with state-specific manifests, which are addressed in Section 4.3 below.) 
       
       This RIA does not include costs to registrant organizations (manifest printers) or costs associated with reading the regulations, as described in Section 4.1 above. This decreases the RIA's costs relative to costs in the HWMS ICR; the HWMS ICR includes over $4 million in costs associated with these items. 
 
4.2.1 Baseline Capital Costs  -  Federal Manifests 
 
In addition to the costs in Exhibit 4-1, which are based on unit costs for labor hours and operations and maintenance (O&M) expenses, the HWMS ICR also includes an estimate of capital costs associated with the manifest process. These baseline capital costs specifically address the acquisition of file cabinets to store manifests and other reports required by the regulations.  
 
This RIA applies a similar methodology to estimate baseline capital costs, but revises one assumption in the HWMS ICR. Specifically, the HWMS ICR assumes (p. 34) that the purchase price of a file cabinet should be annualized over the "three-year effective life of this ICR." However, the effective life of a file cabinet is likely longer than three years; this RIA therefore amortizes the purchase price of a file cabinet over seven years, consistent with the Internal Revenue Service's guidelines for  useful life of "office furniture, fixtures, and equipment" assets.  
 
This RIA estimates that approximately 5.8 million manifests and reports will need to be filed and retained by industry each year; this figure is calculated by considering the sum of manifestrelated paperwork and records that must be retained by industry as required by the regulations. Applying the proportion of federal manifests to total manifests estimated in Chapter 3 yields approximately 2.6 million federal manifests and federal manifest-related reports that must be stored in accordance with manifest requirements. However, because each report must be kept for three years, the total storage requirement is three times the annual figure (or 7.8 million manifests). The HWMS ICR assumes that approximately 490 standard-size, five-drawer, lateral file cabinets (holding 16,000 documents each) will meet the capacity required, at a cost approximately $830 each. The corresponding total cost for 490 such cabinets is approximately $410,000. However, amortized over seven years under a seven percent discount rate, the annual cost of this storage requirement for federal manifests is approximately $76,000. This estimate is conservative in that it does not account for the value of office space occupied by the file cabinets. 
 
4.2.2 Additional Costs Associated with Reclamation Agreements 
 
As discussed in Chapter 2, some SQG shippers of hazardous waste are exempt from most manifest requirements if their waste is shipped under a reclamation agreement. While formal manifests are not required for these shipments, these SQG shippers must retain copies of the reclamation agreements, while the transporters that take on these shipments must still record the information, carry a record of the shipment, and retain the record.  
 
Per Chapter 2, this RIA estimates that ten percent of all SQGs, or approximately 5,300 SQGs, ship hazardous waste under a reclamation agreement. Assuming that each such SQG sends one shipment monthly, this entails approximately 63,000 such shipments annually. However, as shown in Exhibit 2-17, approximately 450 of these SQGs are located in states where SQGs shipping hazardous waste under reclamation agreements are not exempt from manifest requirements.  This RIA therefore estimates that approximately 4,800 SQGs and 58,000 annual shipments are under reclamation agreements to which a limited set of manifest costs (as opposed to the complete set of manifest costs for other federal manifests) apply. The remaining 5,400 manifests are state-specific manifested shipments (see Section 4.3). 
 
Exhibit 4-2 summarizes these additional baseline costs associated with shipments made under reclamation agreements, which total approximately $3 million annually. Note that the majority of these costs accrue to transporters, who must, according to the HWMS ICR, record the waste information in addition to transporting and retaining the record. SQGs must retain a copy of the reclamation agreement (a relatively low-burden activity). 
 
                                 Exhibit 4-2 
Baseline Costs Accruing to Industry for Activities Associated with Reclamation Agreements 
                     (2014$, millions of $, annual costs) 
 Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 

                              Activity Category 
                                 Entity Type 
                                    Total 


                       Generators who Ship Waste (SQGs) 
Transporters 
Receivers 

                                      1 
Reclamation agreement-specific recordkeeping activities 
                                                                        $0.130 
                                                                         $3.18 
                                     N/A 
                                                                         $3.31 
Totals may not sum due to rounding. 
Sources: Unit costs and proportions: Supporting Statement for Information Collection Request (ICR) Number 801.20 
Requirements for Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System. April 30, 2015. Manifest counts: see Chapter 3, manifest counts at maximum shipping frequencies assumed to be monthly. 
 
4.3 Baseline Costs Accruing to Industry  -  State Manifests 
 
As described at the beginning of this chapter, this RIA assumes that industry activities described in the HWMS ICR are applicable to both federal manifests and state-specific manifests. This RIA therefore calculates baseline costs accruing to industry for state manifest requirements by scaling the costs estimated in Exhibit 4-1. Specifically, as seen in Chapter 3 (specifically Exhibit 3-3), this RIA estimates that 1,453,433 federal manifests and 1,776,092 manifests for state wastes (i.e., state-specific manifests) are generated annually.[,] This means that for every federal manifest, approximately 1.22 state-specific manifests incur similar unit costs. 
 
Exhibit 4-3 provides the calculations associated with applying federal manifest unit costs and assumptions in the HWMS ICR to the 1,776,092 state manifests. Note that because the definitions of LQGs, SQGs, and TSDF shippers specifically apply to generators of federal hazardous waste, Exhibit 4-3 aggregates all shippers together for illustrative purposes, rather than speculating regarding the extent to which state-specific manifests originate from different classes of facilities. 
 
 
 
 
 
 
 
                                 Exhibit 4-3 
Baseline Costs Accruing to Industry for Activities Associated with State-Specific Manifests 
                     (2014$, millions of $, annual costs) 
 Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 

                              Activity Category 
                                 Entity Type 
                                    Total 


                          Generators who Ship Waste 
Transporters 
                                  Receivers 

                                      1 
Manifest completion, transmittal, and recordkeeping 
                                                                         $28.0 
                                                                         $19.9 
                                                                         $48.4 
                                                                         $96.5 
                                      2 
Discrepancy / exception reports 
                                                                         $1.52 
                                     N/A 
                                                                         $2.38 
                                                                         $3.91 
                                      3 
Undeliverable shipments 
                                                                    < $0.01 
                                                                    < $0.01 
                                     N/A 
                                                                       $0.0150 
                                      4 
Rejected shipments 
                                                                    < $0.01 
                                                                       $0.0215 
                                                                         $1.59 
                                                                         $1.62 
                                      5 
Notifications of discharge[a] 
                                     N/A 
                                                                       $0.0607 
                                     N/A 
                                                                       $0.0607 
                                      6 
                                                                         Total 
                                                                         $29.5 
                                                                         $20.0 
                                                                         $52.4 
                                                                          $102 
Totals may not sum due to rounding. 
Sources: Unit costs and proportions: Supporting Statement for Information Collection Request (ICR) Number 801.20 
Requirements for Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System. April 30, 2015. Manifest counts: see Chapter 3 manifest counts at maximum shipping frequencies assumed to be weekly for LQGs and non-LQG TSDF shippers and monthly for all other entity types, including generators of state-specific hazardous wastes. Figures above reflect figures from Exhibit 4-1 multiplied by 1.22, which is the ratio of state manifests to federal manifests (1,776,092 / 1,453,433). a This activity category applies only to transporters because discharges at shipping or receiving facilities would not be directly manifest-related and paperwork burdens associated with those discharges would fall under separate RCRA requirements. 
 
The relative magnitudes of the individual values within Exhibit 4-3 are consistent with those in Exhibit 4-1, reflecting the extrapolation. Overall, baseline industry costs associated with statespecific manifests are estimated at approximately $102 million annually. Thus, baseline labor and O&M-related costs adding together federal and state-specific manifests accruing to industry total approximately $185 million annually. The inclusion of state-specific manifests leads to baseline costs substantially higher than the approximately $86 million estimated in the HWMS ICR, which included only federal manifests. 
 
4.3.1 Baseline Capital Costs  -  State Manifests 
 
Similarly to baseline capital costs for federal manifests, this RIA also calculates comparable costs for state manifests by scaling the capital costs for federal manifests by the same factor of approximately 1.22.  
 
This RIA estimates that approximately 5.8 million total manifests and reports will need to be kept by industry, annually (see Section 4.2.1). Applying the proportion of state-specific manifests to total manifests estimated in Chapter 3 yields approximately 3.2 million statespecific manifests and associated reports that must be stored as part of the manifest system requirements. However, because each report must be kept for three years, annual storage requirements are three times this figure. The number of individual documents stored annually is therefore approximately 9.6 million. Per the HWMS ICR's assumptions that a standard-size, five-drawer, lateral file cabinet holds 16,000 documents, approximately 600 such cabinets will be required to meet the capacity required at a price of $830 apiece. Using the same assumptions as for federal manifests (Section 4.2.1) the amortized annual cost of this storage requirement for state-specific manifests is approximately $92,000. 
 
4.4 Baseline Costs Accruing to EPA 
 
The RCRA Hazardous Waste Manifest System ICR accrues relatively few costs to EPA. This is because the current regulations require states, rather than EPA, to collect hazardous waste manifests. (Baseline state burden is considered in Section 4.5 below). The HWMS ICR details only the following EPA activities associated with the manifest process:  
 
       Review of exception reports from generators; 
       Receipt of notifications of discharge from transporters; and 
       Receipt of import manifests, discrepancy reports, and unmanifested waste reports from receiver TSDFs. 
 
In addition, each of the above activities pertains only to exceptions that do not regularly occur in the manifest system. The HWMS ICR estimates that exception reports occur to fewer than two percent of manifests originating at LQG shippers. Correspondingly, this RIA estimates total baseline Agency burden of approximately $0.9 million annually (Exhibit 4-4). Approximately two-thirds of this burden reflects review of exception reports. 
 
                                 Exhibit 4-4 
       Baseline Costs Accruing to EPA for Manifest-Related Activities  
                     (2014$, millions of $, annual costs) 
 Item 
                                   Activity 
Estimated Cost to EPA 
                                      1 
Review of exception reports from generators 
                                                                        $0.600 
                                      2 
Receive notifications of discharge from transporters 
                                                                       $0.0448 
                                      3 
Receive import manifests from receiver TSDFs 
                                                                       $0.0815 
                                      4 
Review discrepancy reports from receiver TSDFs 
                                                                        $0.176 
                                      5 
Review unmanifested waste reports from receiver TSDFs 
                                                                    < $0.01 
                                      6 
                                                                         Total 
                                                                        $0.907 
Totals may not sum due to rounding. 
Sources: Unit costs and proportions: Supporting Statement for Information Collection Request (ICR) 
Number 801.20 Requirements for Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System. April 30, 2015. Manifest counts: see Chapter 3, manifest counts at maximum shipping frequencies assumed to be weekly for LQGs and TSDF shippers and monthly for all other entity types, including generators of state-specific hazardous wastes. 
 
4.5 Baseline Costs Accruing to States 
 
In the baseline, states that operate hazardous waste programs under RCRA incur a range of costs associated if they engage in activities related to collecting and processing manifests. These baseline activities are separate from the state-specific manifest requirements for generators, transporters, and receiver TSDFs (Section 2.2). This section focuses on the cost (burden) to states of processing and reviewing hazardous waste manifests if they do so in the baseline. The e-Manifest system anticipated in the proposed rule will substantially impact the baseline state burden of collecting and processing manifests. Chapter 5 describes in more detail the eManifest system that will eliminate the need for state manifest collection and processing activities.   
 
A full description of the method through which this RIA estimates the baseline costs associated with state manifest collection and processing activities is available in Appendix E. The remainder of this section provides a summary of the key assumptions and calculations. 
 
To calculate baseline costs accruing to states, this RIA:  
 
       Estimates the total number of manifests processed by states in the baseline; 
       Estimates the burden, per hour, required by state staff to process and analyze manifests, and extrapolates that to all manifests processed by states; and 
       Monetizes the burden by applying labor rates from the Biennial Report ICR (see Section 4.7), for consistency with other calculations in this chapter. 
 
4.5.1 Number of Manifests Processed by States in the Baseline 
 
Per Chapter 3, this RIA estimates that a total of approximately 3.2 million manifests are created, filled out, and submitted annually. Of those, this RIA estimates that approximately 1.8 million are state-specific manifests, while approximately 1.5 million are federal manifests.  
 
In 2014, EPA conducted several analyses to identify current (baseline) state manifest processing practices and activities. Data were gathered and analyzed through review of state programs and meetings and conference calls with state representatives. A total of 23 states provided information to EPA documenting  their manifest processing activities. These analyses also revealed that states have varying approaches to receiving, reviewing, analyzing, and correcting manifests. Some states identified specific practices for manifest receipt, data entry, and followup for identified errors, while other states provided more general information.  
 
EPA's data collection effort did not identify the number of manifests processed by each of the responding state programs. Correspondingly, this RIA estimates this number as follows: 
 
       The 2011 Biennial RCRA Report provides state-by-state estimates for the amount of hazardous waste received in each state; from this the RIA calculates the share of hazardous waste received nationally accruing to the 23 states identified as engaging in manifest processing. This calculation makes two assumptions: 1) states with manifest processing programs process both federal and state-specific manifests; and, 2) the number of manifests processed by a state is directly proportional to the hazardous waste tonnage received by that state. The 23 states examined represent approximately 44 percent of national hazardous waste tonnage received. 
       
       This RIA conducts a similar calculation for state manifests but considers a universe of 31 states (the 23 states already identified, and eight additional states identified as requiring manifests for state hazardous wastes in Exhibit 2-13). This RIA assumes that these 31 states are the only ones with any state-specific manifests and are the only ones who engage in any processing of manifests.  
 
Separately, EPA received manifest processing count estimates from two states, Michigan and New York. These estimates are 290,000 manifests processed annually by Michigan, and 70,000 manifests processed annually by New York. This RIA uses these estimates in lieu of extrapolated manifest processing estimates for these two states. By removing these two states from the proportions of hazardous waste received by the subset of 23 states, this RIA uses a proportion of approximately 39 percent of federal manifests and 52 percent state-specific manifests processed by the 21 states for which this RIA had no specific estimates of manifest count. As a validation of this RIA's method, the non-extrapolated manifest counts for New York and Michigan are slightly higher than their extrapolated estimates would be. Specifically, Michigan's self-reported manifest count is approximately five percent higher than an extrapolated total of manifests for the state based on hazardous waste tonnage received; New York's self-reported manifest count is approximately 27 percent higher. If a similar relationship holds for the remaining 21 states, this RIA's estimation of baseline state costs  may underestimate the total number of manifests processed by states in the baseline (and therefore the potential cost savings associated with changing to e-Manifest). 
 
In total, this RIA estimates that the 23 manifest-processing states process approximately 1.7 million manifests annually, or 52 percent of the annual manifests estimated in Chapter 3 (Exhibit 4-5). 
 
                                 Exhibit 4-5 
    Estimate of Manifests Processed by Annually by States in the Baseline 
Item 
                               Geographic Unit 
                              Federal Manifests  
                           State-Specific Manifests 
                               Total Manifests 
                                      1 
National 
                                                                     1,453,433 
                                                                     1,776,092 
                                                                     3,229,525 
                                      2 
National Share 
                                     45% 
                                     55% 
                                     100% 
                                      3 
New York[a] 
                                                                        31,503 
                                                                        38,497 
                                                                        70,000 
                                      4 
Michigan[a] 
                                                                       128,894 
                                                                       157,508 
                                                                       286,402 
                                      5 
Remaining National [1  -  3  -  4]  
                                                                     1,293,036 
                                                                     1,580,087 
                                                                     2,873,123 
                                      6 
Share of manifests in other 21 states 
                                     39% 
                                     52% 
                                     N/A 
                                      7 
Other 21 states processing manifests [2 x 6][b] 
                                                                       500,755 
                                                                       822,815 
                                                                     1,323,570 
                                      8 
                                         Total Manifests Processed [3 + 4 + 7] 
                                                                       661,152 
                                                                     1,018,820 
                                                                     1,679,972 
[a] State Government Annual Costs for Collecting & Processing Completed Hazardous Waste Paper Manifests: Summary of Cost Data from Two Case Studies Supplied to Office of Solid Waste in 2007. Summarized by Mark Eads, economist, Office of Resource Conservation and Recovery, May 5, 2009. [b] "State Manifest Program Summary BAH 3-28-14," prepared by Booz Allen Hamilton for U.S. EPA, March 28, 2014, and  notes from an April 23, 2014 meeting with state program representatives, prepared by Booz Allen Hamilton for U.S. EPA. The former data source identified 23 states with manifest programs and an additional 15 states without a manifest program; data were not collected on the remaining 12 states, which are assumed to lack a state-specific manifest program. 
 
Approximately one million of the 1.7 million manifests are for state-specific wastes; this represents approximately 57 percent of all state-specific manifests estimated in Chapter 3. This RIA assumes that the remaining manifests (23 percent of all manifests; 43 percent of statespecific manifests) are not processed or reviewed in any way, and does not burden any costs to states associated with these collection or receipt activities. 
 
4.5.2 Per-Manifest Burden for States in the Baseline 
 
In 2014, EPA developed a paper processing cost model to estimate the potential costs to EPA associated with processing paper manifests; this section applies the methodology of that model to estimate state manifest processing costs in the baseline. The details of this model are discussed in Appendix E. This model identifies ten distinct activities in the manifest receipt and processing process (e.g., preparation: sorting mail and separating supplemental documents, corrections, scanning of manifest documents, electronic archiving, etc.) and five "failure scenarios" necessitating additional follow-up (e.g., invalid identifying information for generator, transporter, or TSDF receiver, unresolved corrections, etc.), and assigns hourly cost estimates to each activity and failure scenario. Not every activity and failure scenario applies to every manifest: for example, the model assumes that only six percent of manifests have supplemental documentation requiring additional effort (see Appendix E for additional information). 
 
Because state information on processing activities and costs was incomplete, this RIA applies a basic set of processing assumptions for the approximately 1.7 million manifests estimated to be processed by states in the baseline. While some states may engage in more or fewer activities than estimated by EPA's model, given an absence of complete state-specific information, this RIA applies the model's standard estimates across all affected manifests. In other words, this RIA assumes that state manifest processing activities in the baseline are roughly comparable to EPA manifest processing activities estimated within its paper processing cost model. 
 
EPA's paper processing cost model assigns all standard manifest processing steps to a basic level of program staff; this RIA assumes that clerical labor will complete these tasks. Similarly, the model assumes that activities associated with failure scenarios require more expensive analyst staff to investigate and resolve issues; this RIA assumes that technical labor will complete these tasks. Based on the paper processing cost model's assumptions, this RIA assumes that approximately 0.26 hours (approximately 16 minutes) are currently required to process each manifest, with an additional burden of 0.096 hours (approximately six minutes) to investigate and resolve failure scenarios. Note that both of these estimates are meant to reflect the average amount of time needed to complete a given task: in reality, especially for failure scenarios, most manifests will require no analyst time to investigate and resolve issues, while a minority of manifests may require considerably more than six minutes of analyst time to be fully processed with all issues resolved. 
 
As described in more detail in Appendix E, the paper processing cost model indicates that the majority of time associated with manifest processing activities accrues to data entry. Of nonfailure scenario-related activities, the model estimates that over half of total manifest processing burden accrues to data entry tasks, as opposed to other activities such as billing, validating, correcting, or archiving manifests. Similarly, the model estimates that over half of the total processing burden for analysts accrues to the scenario where billing information (for statespecific manifest and/or hazardous waste fees) is not included along with manifest transmission. 
 
4.5.3 Total Burden for State Manifest Processing 
 
For consistency with additional calculations in this chapter (see Section 4.7), this RIA applies labor rates from the Biennial Report ICR for state employees to monetize the total baseline costs associated with state manifest processing activities: clerical staff ($21.70 per hour) for basic activities and technical staff ($34.20 per hour) for response to problems. On a per-manifest basis, manifest processing activities accrue approximately $5.68 in costs, and failure scenariorelated activities accrue approximately $3.27 in costs, or a total of $8.95 in state costs for processing a given manifest, on average. 
 
This yields a total baseline cost to states for manifest processing of approximately $15 million ($8.95 x approximately 1.7 million manifests from Exhibit 4-5). 
4.6 Baseline Costs to Industry  -  Hazardous Waste Reporting 
 
RCRA requires that hazardous waste generators and TSDFs submit reports to EPA or the states at least every two years documenting the quantities and nature of hazardous waste generated during a given year, as well as the disposition of these hazardous wastes. The information from these reports is published by EPA in the National Biennial RCRA Hazardous Waste Report. EPA anticipates that the e-Manifest system will reduce the industry burden associated with Biennial Report reporting; the baseline burden associated with these activities is therefore considered in this chapter. 
 
The 2015 BR ICR re-estimated the total burden to industry associated with collecting and submitting Biennial Report information. This ICR estimates both the number of facilities expected to engage in each hazardous waste reporting activity, as well as the unit costs associated with each activity. This RIA uses the BR ICR estimates of burden hours and entity counts but uses industry labor rates from the HWMS ICR for consistency with other baseline costs (Section 4.2). These labor rates differ in slight ways: for example, the BR ICR's hourly labor rate for clerical labor is $34.39 compared with $22.40 from the HWMS ICR; meanwhile, BR ICR applies $76.73 hourly for managerial labor while the HWMS ICR uses $81.73. 
 
In total, baseline industry costs for contributing to the Biennial Report are approximately $10 million annually (Exhibit 4-6). The largest individual activity is the preparation of Form WR (waste received from off-site); other activities, such as report submission and recordkeeping, are less burdensome. 
 	 
                                 Exhibit 4-6 
 Baseline Costs Accruing to Industry for Hazardous Waste Reporting Activities 
                     (2014$, millions of $, annual costs) 
 Item 
                                   Activity 
                          Estimated Cost to Industry 
                                      1 
Read Hazardous Waste Report instructions 
                                                                         $1.60 
                                      2 
Revise data systems to include new data items not part of facility's general business operations 
                                                                        $0.136 
                                      3 
Prepare Site ID Form 
                                                                        $0.129 
                                      4 
Prepare Form GM 
                                                                         $2.26 
                                      5 
Prepare Form WR 
                                                                         $4.69 
                                      6 
Prepare Form OI[a] 
                                     N/A 
                                      7 
Submit report to the state or EPA Regional Office 
                                                                         $0.93 
                                      8 
Maintain a copy of each form for three years 
                                                                        $0.659 
                                      9 
                                                                         Total 
                                                                         $10.4 
Totals may not sum due to rounding. 
Sources: Unit costs and activity counts: Supporting Statement for Information Collection Request (ICR) Number 
0976.17 2015 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste 
Permit Application and Modification. January 22, 2015. Labor rates: Supporting Statement for Information Collection Request (ICR) Number 801.20 Requirements for Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System. April 30, 2015. 
a Per the BR ICR, Form OI is a state-optional form that is not expected to be submitted by any entities.  
 
Because of the different labor rates used, this $10 million annual industry burden estimate for Biennial Report preparation is lower than the BR ICR estimate of roughly $12 million. 
 
4.7 Baseline Costs to States  -  Hazardous Waste Reporting 
 
States must also engage in a number of activities to collect Biennial Report information, and the e-Manifest system anticipated under the proposed rule will reduce these costs.  
 
To estimate baseline state costs associated with Biennial Report activities, , this RIA again relies on the BR ICR used to estimate unit burden and associated costs for specific activities. However, in this case this RIA also uses state government labor rates from the BR ICR (p. 48). 
 
Total baseline costs accruing to states associated with Biennial Report activities are approximately $9 million (Exhibit 4-7). Quality assurance constitutes the largest individual activity and over 90 percent of overall baseline state burden associated with Hazardous Waste Reporting activities. 
 
 
 
 
 
 
                                 Exhibit 4-7 
  Baseline Costs Accruing to States for Hazardous Waste Reporting Activities 
                     (2014$, millions of $, annual costs) 
 Item 
                                   Activity 
                           Estimated Cost to States 
                                      1 
Distribute Hazardous Waste Report forms and instructions 
                                                                        $0.241 
                                      2 
Assist respondents 
                                                                        $0.226 
                                      3 
Key entry of report submissions 
                                                                       $0.0928 
                                      4 
Perform quality assurance 
                                                                         $8.18 
                                      5 
                                                                         Total 
                                                                         $8.74 
Totals may not sum due to rounding. 
Sources: Unit costs and activity counts: Supporting Statement for Information Collection Request (ICR) Number 
0976.17 2015 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste 
Permit Application and Modification. January 22, 2015. Labor rates: Supporting Statement for Information Collection Request (ICR) Number 801.20 Requirements for Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System. April 30, 2015. 
a Per the BR ICR, Form OI is a state-optional form that is not expected to be submitted by any entities.  
 
As discussed in Section 4.1, this RIA does not include baseline costs associated with EPA's Agency burden pertaining to Hazardous Waste Report activities. These activities are not expected to be impacted by the proposed rule's creation of an e-Manifest system, and are thus not burdened or estimated in this chapter. 
 
4.8 Summary of Baseline Costs 
 
Exhibit 4-8 below summarizes the various cost components discussed in this chapter. Overall, this RIA estimates baseline costs of $224 million annually. 
 
                                 Exhibit 4-8 
                          Summary of Baseline Costs 
                     (2014$, millions of $, annual costs) 
Item 
                                Cost Category 
                                     Cost 
                             Source within Ch. 4 
                                      1 
Industry  -  manifest activities for federal manifests 
                                                                         $83.3 
Exhibit 4-1 and Section 4.2.1 
                                      2 
Industry  -  reclamation agreement-specific recordkeeping activitiesa 
                                                                         $3.31 
Exhibit 4-2 
                                      3 
Industry  -  manifest activities for state-specific manifests 
                                                                          $102 
Exhibit 4-3 and Section 4.3.1 
                                      4 
EPA  -  agency burden for receipt/review of federal manifests 
                                                                        $0.907 
Exhibit 4-4 
                                      5 
States  -  burden for processing manifests 
                                                                         $15.0 
Section 4.5.3 
                                      6 
Industry  -  hazardous waste reporting 
                                                                         $10.4 
Exhibit 4-6 
                                      7 
States  -  hazardous waste reporting 
                                                                         $8.74 
Exhibit 4-7 
                                      8 
                                           Total  -  Industry [1 + 2 + 3 + 6]  
                                                                          $199 
 
                                      9 
                                                      Total  -  States [5 + 7] 
                                                                         $23.8 
 
                                      10 
                                                             Total  -  EPA [4] 
                                                                        $0.907 
 
                                      11 
                                                                   Grand Total 
                                                                          $224 
 
Totals may not sum due to rounding. 
[a] These costs represent costs to industry entities shipping under BFRAs that are not exempt from manifest requirements due to state-specific regulations. See Section 4.2.2 for additional information. 
 
 

                                   Chapter 5 
                Costs and Cost Savings of the e-Manifest System 
                                        
               Electronic manifests under the e-Manifest system 
                                        
An electronic manifest will contain the same information fields as a paper form. Hazardous waste shipments with an electronic manifest created through the e-Manifest system will still need to be accompanied by a printed paper copy to comply with DoT requirements. Under the e-Manifest system: 
 
       Generators that ship hazardous waste off-site initiate a manifest through the e-Manifest system for a shipment, potentially in coordination with any transporters or receiver TSDFs that conduct business using the e-Manifest system. An electronic record is created with facility identification information and waste descriptions (including waste quantity, type, and container descriptions). Upon shipment, the generator attaches their electronic signature to the record. The live electronic manifest is housed within the e-Manifest system, and can be accessed online. 
       
       The transporter that picks up the hazardous waste shipment from the generator facility will open the electronic manifest, supply identifying information, and attach their electronic signature to it. To fulfill DoT requirements, a current printed paper copy of the manifest record must accompany the shipment throughout the journey. 
       
       All waste handlers, including subsequent transporters and the final receiver TSDF receiving the waste also fill out identifying information and electronically sign the manifest. 
       
       The receiver TSDF ultimately receiving the waste attaches a CROMERR-compliant signature to the electronic manifest. The closed manifest, with completed shipment information, is housed within the e-Manifest system. Waste handlers, states, and EPA can access manifest data through the e-Manifest system without additional data entry. 
       
Receiver TSDFs will send completed, signed manifests created outside of the e-Manifest system directly to EPA. EPA will process these non-electronic manifests and incorporate their manifest data into the e-Manifest system. 
 
This chapter characterizes the costs and costs savings associated with the proposed rule's creation of an e-Manifest system. In establishing an e-Manifest system that will serve as a clearinghouse, on a going-forward basis, for all federal and state manifests, the proposed rule will impose costs for creating the system, and will result in cost savings from reduced burden relative to the baseline system of paper manifest creation, processing, recordkeeping and hazardous waste reporting. 
 
Specifically, this chapter considers the following sources of costs: 
 
       The cost of developing and maintaining the e-Manifest system (EPA). A majority of the costs associated with the proposed rule correspond to EPA's development costs for the e-Manifest system. These costs include expenses for both initial system creation and ongoing maintenance, as well as additional costs for activities such as running a help desk to assist users of the system, and certain Cross-Media Electronic Reporting Rule (CROMERR)-based requirements associated with the system's use.  
             
       The cost of collecting and processing manifests (EPA). In addition to the development, operations, and maintenance costs associated with the e-Manifest system, EPA will also collect and process manifests within the e-Manifest system. These costs apply specifically to manifests submitted non-electronically; these manifests must undergo additional processing and data entry tasks before their information can be uploaded to the system and stored in a format akin to those manifests submitted electronically through the e-Manifest system.  
             
       Manifest fees (industry). To recoup e-Manifest system development and maintenance costs, the proposed rule will apply fees, on a per-manifest basis, to the hazardous waste industry. Effectively, these fees are equivalent to the sum of EPA's system development and maintenance costs (above) and represent a transfer of those costs to industry. Associated with these fees are additional costs to EPA for payment collection; these costs are imputed into the overall system development and maintenance costs recouped through fees to industry. 
 
This RIA also considers costs associated with CROMERR requirements for the hazardous waste industry. 
             
Additionally, this chapter includes the following sources of cost savings: 
       Time and materials savings to industry. The e-Manifest system will allow manifests to be created and submitted through electronic means, rather than with the current paper form that must be printed (or purchased), completed, transmitted, submitted, and stored in the baseline. This RIA estimates that manifest activities done through the e-Manifest system result in substantial time and materials savings relative to these activities being performed with paper manifests. 
             
       Cost savings accruing to states. The proposed e-Manifest system will obviate the need for states to collect and process manifests. While states may still wish to do so to meet their own regulatory, enforcement, or data needs, manifest collection and processing activities will be conducted for all manifests by EPA through the e-Manifest system (and ancillary systems to handle non-electronic manifests received on a going-forward basis). The burden reduction associated with reduced state-level manifest collection and processing represents a cost savings to these states. 
             
       Cost savings associated with Biennial Report burden. As described in Chapter 4, the hazardous waste industry currently undertakes a number of recordkeeping and reporting activities associated with the RCRA Biennial Report. The e-Manifest system will reduce this burden by automatically collecting some information through manifests submitted to the system; this represents a cost savings both to industry and states which currently receive and process this reported information in the baseline. 
 
5.1 Key Assumptions for e-Manifest System Cost and Cost Savings Estimation 
 
The cost analyses in this chapter rely on a handful of key assumptions that pertain to the universe affected by the proposed rule, the types of electronic manifest submission methods modeled in this chapter, and the adoption rate of the e-Manifest system and other electronic submission methods by industry after the proposed rule goes into effect. 
 
5.1.1 Universe Impacts of the Proposed Rule 
 
This RIA assumes that the proposed rule and the creation of an e-Manifest system do not impact 
  
       the number of entities currently functioning in the hazardous waste management industry, or 
       the number of manifests currently used by this industry.  
             
Specifically, this RIA does not estimate or otherwise model any changes to the affected universe of hazardous waste generating, transporting, and receiving entities stemming from the e-Manifest system, or any changes to hazardous waste shipping patterns or quantities. 
 
The e-Manifest system pertains to the manner in which manifests are created, transmitted, submitted, and processed. It does not address industrial processes or storage requirements, and it does not affect the number of hazardous waste shipments that must be made. The extent to which manifest fees associated with the e-Manifest system may impact small entities is assessed in Chapter 7; this analysis does not predict any market exits as a result of the proposed rule. This RIA therefore assumes that the number of manifests used annually remains consistent with the estimates in Chapter 3. 
 
5.1.2 Manifest Creation and Submission Methods  
 
Chapter 4's estimate of baseline burden of manifest creation, completion, and transmittal activities models all manifest activities as handled in a uniform, paper-based process, consistent with the activities described in the Hazardous Waste Manifest System ICR. This scenario reflects the standardized requirements related to manifests under RCRA. 
 
In addition to meeting these requirements, however, many TSDFs have implemented electronic systems for initiating, tracking, and reporting shipments of waste that support their manifest requirements. While these systems are separate from baseline requirements and costs, the eManifest system and the post-rule scenario in this RIA address the fact that manifest generators opt to continue this baseline practice (i.e., continue to use a paper system), or may create, complete, and transmit manifests directly through the e-Manifest system. In addition, EPA's proposed rule allows for several "alternative paper submissions" that allow entities in the hazardous waste management industry (primarily receiver TSDFs, who have the final 
responsibility for transmitting the manifest to the regulator) to use their current systems to submit "paper" manifests in an electronic, less burdensome way. This RIA therefore considers the relative costs and cost savings of several alternative "paper" submissions, including submission of scanned images of manifests along with the paper manifest, and submission of manifest data electronically in addition to the paper manifest. 
 
However, the proposed rule requires that for all manifests not directly associated with the eManifest system, all activities applicable to paper manifests in the baseline continue to apply. In other words, if a manifest is not submitted through the e-Manifest system, all requirements applicable to and required for paper manifests continue to apply, even if the manifest in question is created and handled in a way that is different from a wholly paper manifest system (e.g., through a TSDF's proprietary internal electronic system). For any manifest that is not created and managed through the e-Manifest system, all hazardous waste industry entities continue to incur the burden associated with the paper manifest as detailed in the HWMS ICR, regardless of the files that constitute the final submission (i.e., a paper manifest, or a paper manifest with additional, non-required documentation). Correspondingly, the suite of manifest activities and submission options considered in this RIA, and specifically this chapter, is as follows: 
 
        Paper manifest creation, completion, and submission  -  "paper" variant. Under this variant, all manifest activities accrue as described in the HWMS ICR. There are no time and materials burden reductions associated with this variant, as it is identical to the manifest activities modeled in the baseline. This includes the manifest processing cost associated with received manifests, which is consistent with the per-manifest processing burden described in Section 4.5. In other words, this RIA models manifests under this variant as identical to those considered in the baseline scenario, with the exception of any applicable manifest fees associated with the e-Manifest system. 
               
        Manifest submission via scanned manifest image  -  "image" variant. This variant is similar to the paper variant above, but manifest submittal is accompanied by an electronically-transmitted scanned image of the manifest. Because the proposed rule requires that for all manifests not directly associated with the e-Manifest system, all activities applicable to paper manifests continue to apply regardless of submission method, there are no time and materials burden reductions associated with this variant that accrue to industry. This RIA correspondingly models manifests under this variant as identical to those considered in the baseline scenario, with the exception of any applicable manifest fees associated with the e-Manifest system. Specifically, some TSDFs may already manage manifests in ways that involve creating electronic images of manifests by scanning them. Submitting an electronic image does not change costs to TSDFs, but reduces EPA's processing burden, as this RIA assumes that EPA will scan all paper manifests, and this step will not be necessary if TSDFs submit scanned images. Therefore, relative to the paper variant, manifests submitted with accompanying scanned images have reduced processing burdens as they require slightly fewer processing activities by EPA.  
               
        Manifest submission via Extensible Markup Language (XML) schema  -  "XML" variant. This variant is similar to the paper and image variants above, but manifest submittal is accompanied by an electronically-transmitted XML schema which contains the relevant and appropriate manifest information. Again, the RIA models manifests under this variant as identical to those considered in the baseline scenario, with the exception of any applicable manifest fees associated with the e-Manifest system. However, relative to the paper and image variants, manifests submitted with accompanying scanned images have reduced processing burdens as they require fewer processing activities. Specifically, manifests submitted with accompanying XML schema do not require data entry activities associated with manifest processing, which constitute a substantial portion of the overall processing burden.  
             
        Manifests through the e-Manifest system  -  "electronic" variant. This variant consists of manifest creation, completion, and submission through the e-Manifest system. While the specifics of the system and its functionality have not yet been determined, this RIA assumes that manifest activities in this variant will be easily accessible through a simple user interface, akin to a web-enabled application. This RIA assumes that manifest activities associated with this variant result in time and materials burden reductions relative to the other variants, as certain manual tasks (e.g., filling in specific information on the manifest) will be expedited or automated via the system, and materials costs (e.g., mailing costs and postage fees) will no longer be required. Fees associated with the e-Manifest system will apply to this variant; manifest processing associated with this variant is considered in aggregate with e-Manifest system operations. 
 
For the remainder of this chapter and this RIA, manifests created and submitted under these variants are referred to as paper, image, XML, and electronic manifests, respectively.  
 
5.1.3 Adoption Rate 
 
To estimate the costs and especially cost savings associated with the proposed rule over time, this RIA assumes a specific adoption rate of the e-Manifest system and other manifest submission methods that changes over the first few years after the creation of the e-Manifest system. This RIA considers the effects of other potential adoption rates on costs and cost savings in Chapter 6.  
 
The adoption rates illustrated in this section are based on responses to a 2014 EPA survey of large TSDFs (see Section 3.2.2.1) and insights from conversations between EPA and the Environmental Technology Council (ETC), an industry trade group which represents many firms with TSDF facilities. The organizing principles of these adoption rates include: 
 
       The assumption that industry entities will prioritizeeliminating paper manifests in favor of XML, image, or electronic manifests; 
             
       The assumption that industry adopts electronic manifests gradually over a four-year period, with slow initial adoption; and 
 
       The assumption that a minority of paper manifests may continue to exist for the foreseeable future.  
 
In addition, to operationalize these assumptions, this RIA applies the following: 
 
       A proportion of the industry currently has the capacity to provide XML schema submissions in the baseline, based on the presence of sophisticated electronic systems currently in place and used by TSDFs, including the respondents to EPA's 2014 survey. These industry entities may be handling manifests in an XML export-ready framework in the baseline; this RIA assumes that this proportion of the industry will either continue to handle manifests in this manner and submit XML-variantmanifests, or adopt electronic manifests starting in the second year after the creation of the e-Manifest system. Since these entities have invested in technology capable of delivering XML submissions, we assume that it will be most cost effective for these entities to use XML or electronic manifests following the implementation of the proposed rule. 
             
       Some entities using paper manifests in the baseline will move towards the use of image manifests after the implementation of the proposed rule. However, entities with the capacity to use XML manifests in the baseline will not scan manifests prior to submission, as this would increase their costs. 
 
Exhibit 5-1 below summarizes the adoption rates used for the remainder of this chapter across the four manifest variants described in Section 5.1.2 in a tabular format. Exhibit 5-2 displays these adoption rates visually, both in terms of all four manifest variants, and in terms of electronic manifests (i.e., use of the e-Manifest system) relative to all other manifest types (i.e., paper manifests potentially accompanied by image or XML schema submission). Note that for consistency with EPA's projected development timeline for the e-Manifest system, adoption rates are shown for a six-year period; however, this RIA assumes that adoption stabilizes in the fourth year following implementation of the proposed rule. 
 
For the purposes of this RIA and the proposed rule, development of the e-Manifest system is expected to occur over the 2016-2018 period, with the system going live and accessible to users in 2018. Correspondingly, Year 1 in Exhibits 5-1 and 5-2 refers to 2018, the first year that the eManifest system will be fully in place and ready for use. This convention holds throughout the rest of this chapter. 
 	 
                                 Exhibit 5-1 
Adoption Rates of Manifest Creation and Submission Systems  -  Tabular Summary 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                               Manifest Variant 
                    Baseline (Year 0, pre-implementation) 
               Year (following implementation of proposed rule) 



Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
Year 6 
                                      1 
Paper 
Manifest 
Process 
Paper submission 
                                   100.00% 
52.75% 
37.50% 
11.25% 
 1.25% 
 1.25% 
 1.25% 
                                      2 

Scanned image submission 
                                    0.00% 
 4.75% 
18.75% 
11.25% 
 1.25% 
 1.25% 
 1.25% 
                                      3 

XML schema submission  
                                    0%[a] 
37.50% 
18.75% 
22.50% 
 2.50% 
 2.50% 
 2.50% 
                                      4 
e-Manifest System Process (electronic manifest) 
                                     N/A 
 5.00% 
25.00% 
55.00% 
95.00% 
95.00% 
95.00% 
[a] As indicated in Section 4.1.3, this RIA assumes complete use of paper manifests in the baseline. However, responses to EPA's 2014 survey of TSDFs and EPA's conversations with an industry trade group suggest that approximately 40 percent of hazardous waste generators and receiver TSDFs may already have and use electronic and/or proprietary systems to internally manage manifest-related workflow or data, and are capable of submitting manifests in the XML schema format. Per current RCRA requirements, these entities may not do so and must use paper manifests in the baseline, but are modeled as submitting XML variant manifests once they are allowed to do so following implementation of the proposed rule. Note that this RIA also assumes that the proportion of the industry with these systems in place will continue to handle manifests in this manner or adopt electronic manifests, rather than switching to handling manifests in paper or scanned image formats.  
                                        
                                 Exhibit 5-2 
Adoption Rates of Manifest Creation and Submission Systems  -  Visual Summary 












































%
0.00
%
20.00
40.00
%
%
60.00
%
80.00
%
100.00
Baseline
Year 1
Year 2
Year 3
Year 4
Year 5
Year 6
Paper Manifest
Process
Electronic (e-
Manifest)
0.00
%
20.00
%
%
40.00
%
60.00
%
80.00
%
100.00
Baseline
Year 1
Year 2
Year 3
Year 4
Year 5
Year 6
Paper
Image
 
The remainder of this chapter presents annual costs for Years 1 through 6 after e-Manifest system launch, as well as annualized costs estimates over this period, where relevant. This period captures all variability in costs and cost savings as introduced through the various parameters and assumptions relied upon throughout this chapter. Specifically, this period captures both the stabilization of the adoption rates shown in Exhibits 5-1 and 5-2 and covers periods both before and after all system development costs incurred by EPA have been recouped via manifest fees (see below). 
 
5.2 e-Manifest System Costs to EPA  -  Development and Operations 
 
This section details this RIA's estimation of the development and maintenance costs associated with the e-Manifest system. The estimates in this section rely primarily on EPA estimates of system development costs, though some components are estimated through other estimates from Chapters 2, 3, and 4. 
 
This section considers two types of system costs. Setup costs pertain to activities undertaken and costs incurred prior to the launch of the e-Manifest system; operations costs pertain to activities undertaken while the system is functional. While this distinction is not directly salient for the discussion of EPA costs that proceeds throughout this section, this RIA distinguishes these two costs because they have differing effects on the manifest fees that will be applied to the hazardous waste industry to recoup these costs. Specifically, all setup costs will be considered on a lump-sum basis and recouped over a designated payback period after system launch, while the fees will aim to recoup all operations costs on an annual basis (i.e., the fee in a given year is structured such that it will recoup all operations costs incurred by EPA in that year). 
 
5.2.1 System Development Costs 
 
This cost category directly pertains to the activities involved in developing and deploying the eManifest electronic system. The primary activities associated with this cost category include planning, design, construction, testing, integration, and piloting of the e-Manifest system.Costs will also be incurred for the integration of Cross-Media Electronic Reporting Rule (CROMERR) requirements with the e-Manifest system, the development of a processing center to handle manifests submitted without use of the e-Manifest system, and the development of a help desk to assist users with the e-Manifest system. 
 
In 2009, EPA analyzed the potential development and operations and maintenance (O&M) costs for a commercial off-the-shelf (COTS) e-Manifest system. In carrying forward the estimates in this analysis to 2013, EPA estimated that over a three-year development period, costs would be $6.0 million in the first development year, $6.5 million in the second development year, and $14.5 million in the third, and final, year of development (all costs in 2013 dollars). This RIA inflates these costs to 2014 dollars to arrive at a total 2014 dollar-denominated estimate of approximately $27 million in system development costs.[,] Because the 2009 analysis indicated that these costs would accrue over a three-year period, this RIA models these costs as occurring in the period encompassing two years before system launch through the first year of system launch. Costs ramp up in the year of system launch as system development activities transition into system integration, testing, and deployment activities. 
 
5.2.2 Operations and Maintenance (O&M) Costs 
 
EPA's 2009 analysis of the costs associated with a COTS e-Manifest system, described in Section 5.2.1 above, also estimated the costs associated with operating and maintaining the system. This estimate accounts for both the physical materials associated with keeping the system operational (e.g., hardware, servers, office space) as well as program-related and technical/information technology-related support for the system. Carrying this analysis forward to 2013 indicated an annual O&M cost of $14.5 million for the e-Manifest system (2013 dollars). Applying the same calculations to this estimate as to the system development costs yields a 2014 dollar-denominated cost of $14.7 million annually in e-Manifest system O&M costs. This RIA applies this cost in perpetuity, beginning with the year of system launch. 
 
5.2.3 Paper Manifest Processing-related Costs 
 
The e-Manifest system will require some capacity to receive and process manifests submitted under the paper process, including paper manifests, image manifests, and XML manifests, as described above. This RIA estimates a $1 million annual cost to manage specific considerations pertaining to these manifests. Note that this figure pertains to non-labor costs pertaining to processing manifests submitted through formats other than the e-Manifest system, such as necessary capital and equipment costs, storage space, utility and lease costs for the physical location where the paper manifest processing will occur, and so on; this RIA estimates the direct costs (i.e., labor) associated with processing manifests submitted under the baseline paper process in Section 5.3. This RIA applies this cost in perpetuity, beginning with the year of system launch. 
 
5.2.4 e-Manifest System Call Center Costs 
 
As part of e-Manifest system functionality, EPA will staff and operate a call center to assist users. This RIA estimates that these call center costs scale to some extent with the proportion of the universe actively using the e-Manifest system. Appendix E, EPA's Technical Architecture Helpdesk Operations document, provides additional detail on the specific call center costs used in this RIA. Specifically, this RIA estimates approximately $820,000 in fixed costs associated with the call center, which recur annually regardless of system usage. Additionally, this RIA estimates that each additional percentage point of e-Manifest system usage in a given year (e.g., five percent of manifests are created and submitted via the e-Manifest system in 2018, etc.) results in approximately $17,000 in additional call center costs in that year. This RIA therefore estimates costs of between approximately $900,000 and $2.5 million for the call center in a given year, based on the proportion of the universe adopting the e-Manifest system for the first time in a given year, consistent with the adoption rates displayed in Exhibit 5-1. This RIA applies this cost in perpetuity, beginning with the year of system launch, though costs in a given year vary based on the proportion of the universe that has adopted use of the e-Manifest system in that year. After e-Manifest adoption plateaus, this RIA estimates the call center cost at approximately $2.5 million annually. 
 

5.2.5 e-Manifest System CROMERR-Related Costs 
 
The e-Manifest system will require industry entities to comply with Cross-Media Electronic Reporting Rule (CROMERR) standards when submitting information to EPA. These standards require users to obtain and use user-specific accounts when submitting information, a process which EPA manages (these requirements, as they apply to industry, are covered in greater detail in Section 5.4.2 below). Entities that will use the e-Manifest system following the implementation of the proposed rule represent an influx of new users to the CROMERR system; the e-Manifest system will therefore result in higher EPA costs due to the additional burden of managing an additional set of CROMERR registrations and user actions. 
 
In 2004, EPA analyzed the costs of CROMERR-related activities as part of a broader costbenefit activities of CROMERR and its standards. These standards identified four specific EPA CROMERR-related activities that scale with the number of CROMERR-registered users (or facilities) that this RIA considers in estimating CROMERR-related costs associated with use of the e-Manifest system: 
 
        Receipt, processing, review, approval, and filing of CROMERR subscriber agreements (i.e., user registrations)  -  this activity varies with the number of unique users registering with the CROMERR system; 
        
        Identification and resolution of CROMERR-related, facility-specific problems  -  this activity varies with the number of unique facilities registered with the CROMERR system; 
       
        Response to CROMERR-related information requests posed to EPA from registered CROMERR users  -  this activity varies with the number of unique users registered with the CROMERR system; and 
       
        Operation of the CROMERR help desk, which assists users with difficulties they may encounter during registration or other activities  -  this activity varies with the number of unique users registered with the CROMERR system. 
 
To assess additional CROMERR-related costs to EPA resulting from the addition of users to the CROMERR system, this RIA assigns costs to these activities as described below. 
 
Broadly, this RIA assumes that CROMERR-related requirements will apply to receiver TSDFs and transporters, who will be legally able to sign the manifest on behalf of their generator customers so long as documentation of a contractual relationship between the TSDF and generator company exists, and will not be imposed on the complete suite of generators that generate hazardous waste for off-site shipment. Therefore, CROMERR costs accrue only to a limited set of industry entities and their employees. This RIA assumes that each receiver TSDF will seek CROMERR registrations for five employees, while each truck engaged in shipping hazardous waste is operated by two drivers, each of whom will require a CROMERR registration to complete manifest activities through the e-Manifest system. The total set of users considered in the calculations below is therefore approximately 22,000: five employees at each of 413 receiver TSDFs plus two drivers at each of 9,947 trucks (see Chapter 2). Due to the relatively low number of receiver TSDFs, truck drivers make up the majority of the new CROMERR user registrations required. For simplicity, this RIA assumes that each facility operates its own hazardous waste shipping truck. This may be a conservative (i.e., high-cost) assumption if multiple trucks are aggregated at a single establishment or facility; in that case, the EPA costs of CROMERR activities due to the proposed rule may be overstated. 
 
This RIA assesses the costs under alternative assumptions governing CROMERR, such as scenarios where CROMERR is required for generators in addition to TSDF receivers and transporters, in Chapter 6. 
 
5.2.5.1 CROMERR User Registration Costs to EPA 
 
The CROMERR Cost Benefit Analysis estimated approximately 10 minutes (0.17 hours) for EPA to process a single CROMERR user registration. However, user registrations will be required not only for users at facilities adopting use of the e-Manifest system in a given year, but also for a proportion of new users at facilities that had already adopted the e-Manifest system (i.e., as a result of user turnover) and for a proportion of new facilities that did not previously operate in the market (i.e., as a result of facility turnover). As a conservative (high-cost) assumption, this RIA assumes that 25 percent of facilities turn over each year. This assumption is most applicable to trucks, as they may enter or leave the hazardous waste shipment market with relatively few barriers. This RIA further assumes that 20 percent of employees at existing facilities (i.e., drivers at an existing set of trucks) turn over every year, and will also require new CROMERR registrations. 
 
Correspondingly, the cost of CROMERR user registrations in a given year can be expressed as: 
 
       The cost to register new users at new facilities adopting use of the e-Manifest system in that year; plus 
       The cost to register users at new facilities (i.e., those that just entered the market) in a given year, assuming the same proportion of these facilities use the e-Manifest system as the remainder of the universe (i.e., existing facilities); plus 
       The cost to register new users at existing facilities in that year. 
 
For example, in the first year of the e-Manifest system, this RIA assumes five percent adoption of the system (see Exhibit 5-1). Per the fully-loaded labor rates from the HWMS ICR, 0.17 hours of technical labor equals $9.53; multiplying this figure by approximately 22,000 new CROMERR registrations required across the universe, and then by five percent, yields approximately $10,000 in first-year CROMERR user registration costs to EPA.  
 
Similarly, in the second year, new user registrations apply to 20 percent of facilities (25 percent adoption per Exhibit 5-1 less the five percent of facilities with users registered in the previous year). This equals approximately $42,000 (22,000 total possible registrations x 20 percent x $9.53). Additionally, 25 percent of facilities with previously-registered users turn over and must fully register new users, for a cost of approximately $3,000 (five percent of the universe of previous year facilities x 25 percent facilities turnover x $9.53 x 22,000 total possible registrations). Lastly, 20 percent of the users at the facilities with previously-registered users turn over and must be replaced with new registrations for new users, for a cost of approximately $2,000 (five percent of the universe of previous year facilities x 75 percent facilities nonturnover x 20 percent user turnover x $9.53 x 22,000 total possible registrations). The total cost of CROMERR user registrations in the second year is therefore approximately $46,000. 
 
Per the CROMERR Cost Benefit Analysis, users who remain registered for three years must renew their CROMERR registration in the third year. These re-registration costs apply only to users at existing facilities, two years after those facilities are estimated to have adopted the eManifest system. Correspondingly, these registration renewal costs apply only beginning in the third year after system implementation. 
 
This RIA applies the same process to all other years. CROMERR costs associated with user registrations range from approximately $10,000 in the first year to approximately $170,000 in the sixth year after system implementation (95 percent adoption), and remain constant at $140,000 annually thereafter. 
 
5.2.5.2 Cost to EPA of Resolving CROMERR Facility Registration Issues 
 
The CROMERR Cost Benefit Analysis estimated approximately one hour for EPA to directly engage facilities to investigate facility-specific registration issues, and indicated that such activities would apply only for three percent of facilities each year. Correspondingly, this RIA estimates costs for this activity in a given year as total facilities/trucks x three percent x the adoption rate in that year x $56.05 (the cost for one hour of EPA technical labor per the HWMS ICR). Costs range from approximately $1,000 to approximately $17,000 as the adoption rate increases over time, and remain constant at approximately $17,000 annually thereafter.  
 
The costs associated with this activity are especially sensitive to the assumption that each truck is its own facility; however, as costs associated with this activity are low even under this conservative (high-cost) assumption, altering it is unlikely to result in substantial cost impacts. 
 
5.2.5.3 Cost to EPA for Information Request Responses 
 
The CROMERR Cost Benefit Analysis estimated that the CROMERR system responds to requests, inquiries, budget updates, and similar queries from both internal (EPA-originated) and external (industry-originated) sources, and indicated that such activities were expected to apply to three percent of registered users in a given year. The RIA estimates costs for this activity similarly to those for facility registration issues, with the key differences being that this item applies on a per-user basis, rather than a per-facility basis, and that the CROMERR Cost Benefit Analysis estimated 1.5 hours to respond to each request, rather than one hour to investigate and resolve facility registration issues. 
 
This RIA estimates that costs for this activity in a given year equal total possible registered users (approximately 22,000) x three percent x the adoption rate in that year x $84.08 (the cost for 1.5 hours of EPA technical labor per the HWMS ICR). Costs range from approximately $3,000 to approximately $53,000 as the adoption rate increases over time, and remain constant at approximately $53,000 annually thereafter. 
 
5.2.5.4 Cost to EPA for CROMERR Help Desk Calls Related to e-Manifest 
 
The CROMERR Cost Benefit Analysis estimated approximately eight minutes (0.13 hours) for EPA to respond to a single help desk call, on average.[14] It also assumed that such calls would specifically be related to registration, and that, on average, each registering user would make one such call to the CROMERR help desk in the course of registration. Because of facility and user turnover, this cost applies to more than just the set of users at facilities newly-adopting the eManifest system in a given year. The calculations for this cost item are similar to that for user registrations, but use 0.13 hours of EPA technical labor rather than 0.17 hours per instance. Correspondingly, CROMERR costs associated with the help desk range from approximately 
$8,000 in the first year to approximately $61,000 in the sixth year after system implementation (95 percent adoption), with higher costs in some interim years to account for large numbers of first-time user registrations in those years. The annual costs for this activity total approximately $61,000 after e-Manifest adoption plateaus. 
 
5.2.5.5 Summary of CROMERR-Related Costs to EPA 
 
Exhibit 5-3 summarizes the CROMERR-related costs accruing to EPA estimated by this RIA as a result of the implementation of the e-Manifest system. The cumulative e-Manifest system adoption rate drives these costs, but the fourth year of system operation results in the highest costs in these period due to a large increase in e-Manifest adoption between this year and the previous year. Overall, CROMERR-related costs range from approximately $22,000 to approximately $330,000, depending on the cumulative and incremental adoption rates of eManifest in a given year. This RIA applies these costs in perpetuity, beginning with the year of system launch and reaching a final constant cost of approximately $270,000 after Year 6. However, costs in a given year vary based on the proportion of the universe that has adopted use of the e-Manifest system in that year and previous years, as shown in Exhibit 5-3. 


                                   Exhibit 5-3 
                          CROMERR-Related Costs to EPA  
                      (2014$, thousands of $, undiscounted) 

Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                        CROMERR-Related Cost Category 
              Year (following e-Manifest system implementation) 
                                    Total 
                             (Years 1 through 6) 


 Year 1 
 Year 2 
 Year 3 
 Year 4 
 Year 5 
 Year 6 

                                      1 
e-Manifest System Adoption Rate 
                                      5% 
                                     25% 
                                     55% 
                                     95% 
                                     95% 
                                     95% 
                                     N/A 
                                      2 
User Registration Costs 
                                                                        $10.5  
                                                                        $46.0  
                                                                         $91.5 
                                                                         $161  
                                                                         $134  
                                                                         $175  
                                                                          $618 
                                      3 
Facility Registration Issue Costs 
                                                                       $0.871  
                                                                        $4.36  
                                                                        $9.58  
                                                                         $16.5 
                                                                        $16.5  
                                                                        $16.5  
                                                                         $64.5 
                                      4 
Information Request Response Costs 
                                                                        $2.77  
                                                                        $13.8  
                                                                        $30.5  
                                                                        $52.6  
                                                                        $52.6  
                                                                        $52.6  
                                                                          $205 
                                      5 
Help Desk Costs 
                                                                        $8.00  
                                                                        $35.2  
                                                                        $64.0  
                                                                        $99.2  
                                                                         $60.8 
                                                                        $60.8  
                                                                         $64.0 

                                                                         Total 
                                                                         $22.1 
                                                                        $99.4  
                                                                         $196  
                                                                         $329  
                                                                         $264  
                                                                         $305  
                                                                        $1,220 
        
       5.2.6 e-Manifest System Billing Costs 
        
       To recoup the e-Manifest system costs described in Section 5.2, the proposed rule will apply fees, on a per-manifest basis, to the hazardous waste industry. In addition to the fees themselves, EPA must also undertake a set of billing and invoicing activities to collect the fees. The costs to collect these manifest fees are part of the set of costs that is recovered through the fees. In other words, the fees applied by the proposed rule reflect the costs of collecting these fees from industry. 
        
       This RIA assumes that the proposed rule will require TSDF receivers to pay for each manifest submitted. It is likely that TSDFs will pass through all or part of the fee to generators and/or transporters as part of the waste management and disposition services they provide more efficiently than any fee-collection system that would require thousands of generators to submit payment.  
        
       All manifests will be subject to fees under the proposed rule; the fee will vary according to the type of manifest submitted, reflecting the different costs associated with processing paper and electronically-submitted manifests, but billing and payment collection activities are not expected to differ across types of manifests submitted. 
        
       EPA's costs for billing TSDFs for manifest fees reflect four distinct activities: 
        
              Generate a list of operating TSDFs that have submitted manifests with contact information for invoicing; 
              
              Generate an invoice for each TSDF; 
              
              Send each TSDF a unique access code (in the form of a PIN or password) that allows for each TSDF to view their bill;[17] and 
              
              After payment has been processed through pay.gov, send each TSDF a receipt confirming that payment has been accepted and processed. 
        
       To estimate billing costs to EPA, this RIA uses EPA labor rates from the HWMS ICR and burden hours from the Pesticide Registration Fees Program (PRFP) ICR from 2010, which details a set of activities similar to those that will be required to collect payments from TSDFs.[18] 
        
       Correspondingly, this RIA estimates total EPA costs associated with billing and payment collection of manifest fees under the proposed rule as described below.[19] 
        
       Per Chapter 2, this RIA estimates that a universe of 413 active receiver TSDFs will be invoiced. Using fully-loaded EPA labor rates from the HWMS ICR, this RIA estimates annual listing generation costs of approximately $830 (16 hours of clerical labor at $23.92 and eight hours of technical labor at $56.05), approximately $140,000 in invoicing costs (0.5 hours of technical labor x 413 TSDFs x 12 monthly instances of invoicing in a year), and approximately $24,000 each in costs to send access codes and receipts to TSDFs (0.2 hours of clerical labor x 413 TSDFs x 12 monthly instances of sending access codes or receipts). Total billing and payment collection costs are approximately $190,000 annually. This RIA applies this cost in perpetuity, beginning with the year of system launch. 
        
                                                                
        It is possible that this activity could be automated through the system which directly handles the processing of TSDF payments. However, as a conservative assumption, this possibility is not considered in this chapter. 
        Supporting Statement for Information Collection Request (ICR) Number 2330.01 Pesticide Registration Fees Program, November 2, 2010. For the billing associated with manifest fees, EPA is proposing to use the pay.gov system, which is also used for the payment of the fees required by the Pesticide Registration Fees Program. Use of pay.gov to collect payment for manifest fees would not require additional development costs to EPA associated with the creation of an additional billing and payment collection system. 
        Specifically, the PFRP ICR estimates the following burden hours for the four activities described above as follows: 
               Generate listings  -  eight hours of EPA technical labor and 16 hours of EPA clerical labor per instance, based on Table 7, line item "Generate listings/mass mailings" from the PFRP ICR. This activity occurs just once annually when EPA generates a list of active TSDFs that will incur manifest fees from manifest submission. 
               Generate invoices  -  0.5 hours of EPA technical labor per instance, based on Table 7, line item "Reconcile discrepancies" from the PFRP ICR. All TSDFs will be invoiced on a monthly basis. While the activity of reconciling discrepancies does not directly pertain to invoice generation, the hourly burden associated with reconciling discrepancies per the PFRP ICR represents a middle-ground assumption for the burden associated with generating invoices that does not skew towards a burden more appropriate to other more involved or less burdensome activities.  
               Send unique access codes to TSDFs  -  0.2 hours of EPA clerical labor, based on Table 7, line item "Enter data into tracking system" from the PFRP ICR. All TSDFs must pay on a monthly basis; this activity will occur monthly for each TSDF. 
               Send receipt to TSDFs  -  0.2 hours of EPA clerical labor, based on Table 7, line item "Verify payment" from the PFRP ICR. All TSDFs must pay on a monthly basis; receipts will be sent monthly to each TSDF following payment. 
       5.2.7 EPA Additional Program Costs 
        
       This RIA estimates that EPA will incur an annual cost of approximately $2.7 million to manage aspects of the e-Manifest system not otherwise covered by the six cost categories discussed above. These costs occur throughout both the development process and active life of the eManifest system. This RIA considers the program costs occurring prior to system launch as setup costs  -  it aggregates this portion of the setup cost over four years and treats it as a lump sum cost for the purpose of cost recoupment. Additionally, this RIA applies the program costs occurring following system launch in perpetuity, beginning with the year of system launch, treating them as operations costs. 
        
       Prior to system launch, these costs include EPA activities related to designing the e-Manifest system, designing the e-Manifest help desk, designing the broader e-Manifest program, designing the fees associated with the e-Manifest system, conducting economic analyses regarding the e-Manifest system, conducting rulemakings to establish the e-Manifest system and its associated fees, and establishing various oversight bodies required for the e-Manifest program. Following system launch, these costs include compiling necessary reports for the Federal Advisory Committee Act (FACA), the EPA Inspector General (IG), and Congress, as well as designing any necessary upgrades to the e-Manifest system. 
        
       5.2.8 EPA Additional Indirect Costs 
        
       EPA will incur indirect costs on and above the direct program activities performed by e-Manifest system staff and the Office of Resource Conservation and Recovery (ORCR). Other EPA offices and Regions will incur costs relating to promulgation of the e-Manifest and e-Manifest fee rules, supporting procurement and acquisition of the e-manifest system, participating in the e-Manifest advisory board, and assisting with the operations and maintenance of the e-Manifest system in a broad capacity. 
        
       Indirect costs can be difficult to track because they are incurred as part of the normal course of operations at many offices across EPA. Additionally, the level of e-Manifest system-related costs incurred by a particular EPA office may change over time as the program develops and its needs change. For these reasons, this RIA accounts for indirect costs using an indirect cost factor proportionate to other EPA system costs. This factor is based on EPA's Office of Financial Management (OFM) indirect cost methodology, as required by the Federal Accounting Standards 
       Advisory Board's Statements of Federal Financial Accounting Standards #4: Managerial Cost Accounting Standards and Concepts. OFM publishes, on an annual basis, an indirect cost rate for each of the Regional Offices and Program Offices within EPA; this RIA uses the indirect cost factor of 19.74 percent for EPA's Office of Land and Emergency Management (OLEM), the highest-level program office within which ORCR resides.  
        
       For setup costs, this factor is applied on and above the aggregated, lump-sum measure of system costs. For operations costs, this factor is applied to the sum of operations costs incurred in a given year. This calculus ensures that the manifest fees applied to the hazardous waste industry adequately recoup the indirect cost component of each system cost over the appropriate recoupment period for that cost. 
        
       5.2.9 Summary of EPA Costs 
        
       Exhibits 5-4 and 5-5 summarize the costs to EPA associated with the e-Manifest system. Exhibit 5-4 pertains to the setup costs incurred prior to system launch; Exhibit 5-5 details the operations costs incurred following system launch over a six-year time horizon.  
        
                                 Exhibit 5-4 
               Summary of e-Manifest System Setup Costs to EPA 
                     (2014$, millions of $, undiscounted) 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 

                           e-Manifest Cost Category 
Year 
                                      -4 
Year 
                                      -3 
                                   Year  -2 
                                    Year 1 
                            Year 1 (system launch) 
                              Total Setup Costs 
                                      1 
System development 
 N/A 
 N/A 
                                                                         $6.10 
                                                                         $6.61 
                                                                         $14.7 
                                                                         $27.4 
                                      2 
Additional program costs 
$2.65 
$2.65 
                                                                         $2.65 
                                                                         $2.65 
                                     N/A 
                                                                         $10.6 
                                      3 
                                              Subtotal  -  direct EPA costs[a] 
                                                                         $38.0 
                                      4 
                                                  Additional indirect costs[b] 
                                                                         $7.51 
                                      5 
                                                                      Total[a] 
                                                                         $45.5 
Source: System development costs reflect those used in U.S. EPA, e-Manifest Alternatives Analysis Document, Final Version 4.0, November 11, 2009. Additional program costs are based on actual EPA expenditures from the e-Manifest M3 appropriation account.  a Because setup costs are incurred largely prior to system launch, they are not considered on an annual basis by this RIA. Rather, for the purpose of manifest fee calculation, these costs are aggregated and recouped through the fees over a specified payback period. b Calculated as 19.74 percent of total direct setup costs, based on the most recent indirect cost rate for EPA OLEM published by EPA 
OFM. 
        
       Setup costs, inclusive of the indirect cost factor, total approximately $46 million. Over two-thirds of the direct setup costs pertain to system development, rather than pre-launch program costs. 
        	 
                                 Exhibit 5-5 
             Summary of e-Manifest System Operations Costs to EPA 
                     (2014$, millions of $, undiscounted) 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                           e-Manifest Cost Category 
                                    Year  1 
                                    Year  2 
                                   Year  3 
                                   Year  4 
                                   Year  5 
                                   Year  6 
                          Total  (Years 1 through 6) 
                                      1 
Operations and maintenance 
                                                                         $14.7 
                                                                         $14.7 
                                                                         $14.7 
                                                                         $14.7 
                                                                         $14.7 
                                                                         $14.7 
                                                                         $88.4 
                                      2 
Paper manifest processing O&M 
                                                                         $1.00 
                                                                         $1.00 
                                                                         $1.00 
                                                                         $1.00 
                                                                         $1.00 
                                                                         $1.00 
                                                                         $6.00 
                                      3 
Call center 
                                                                        $0.902 
                                                                         $1.25 
                                                                         $1.77 
                                                                         $2.46 
                                                                         $2.46 
                                                                         $2.46 
                                                                         $11.3 
                                      4 
CROMERR-related costs 
$0.0221 
                                                                       $0.0994 
$0.196 
                                                                        $0.329 
$0.264 
$0.305 
                                                                         $1.22 
                                      5 
Billing 
                                                                        $0.187 
                                                                        $0.187 
$0.187 
                                                                        $0.187 
$0.187 
$0.187 
                                                                         $1.12 
                                      6 
Additional program costs 
                                                                         $2.65 
                                                                         $2.65 
                                                                         $2.65 
                                                                         $2.65 
                                                                         $2.65 
                                                                         $2.65 
                                                                         $15.9 
                                      7 
Subtotal  -  direct EPA costs 
                                                                         $19.5 
                                                                         $19.9 
                                                                         $20.5 
                                                                         $21.4 
                                                                         $21.3 
                                                                         $21.3 
                                                                          $124 
                                      8 
Additional indirect costs[a] 
                                                                         $3.85 
                                                                         $3.93 
                                                                         $4.05 
                                                                         $4.22 
                                                                         $4.20 
                                                                         $4.21 
                                                                         $24.5 
                                      9 
                                                                         Total 
                                                                         $23.3 
                                                                         $23.9 
                                                                         $24.6 
                                                                         $25.6 
                                                                         $25.5 
                                                                         $25.5 
                                                                          $148 
a Calculated as 19.74 percent of all other costs incurred in a given year, based on the most recent indirect cost rate for EPA OLEM published by 
EPA OFM. 
        
       Operations costs, inclusive of indirect costs, range from approximately $23 million to $26 million annually in the six-year period following system launch, and are approximately $26 million annually thereafter. These costs vary based on the cumulative and incremental (i.e., relative to the previous year) adoption of the e-Manifest system in a given year. For example, costs in Year 4 are marginally higher than costs in Years 5 and 6 due to higher incremental adoption of e-Manifest in that year leading to higher CROMERR-related costs associated with initial user registrations. Overall, operations costs across this six-year period total approximately $150 million, inclusive of indirect costs.  
        
       5.3 Manifest Processing Costs to EPA 
        
       In addition to the design, development, and implementation of the e-Manifest system, under the proposed rule, EPA will collect and process all manifests created and submitted by the hazardous waste industry. The e-Manifest system will be designed in such a way that manifests submitted electronically through the system ("electronic manifests") will not require any additional effort or activity from EPA in order for their data to be fully captured by the system. However, as the proposed rule continues to allow for submission of non-electronic manifests in various formats, EPA will incur costs associated with receiving and processing these manifests and entering their data into the e-Manifest system.  
        
       In Section 4.5, this RIA estimated that approximately 1.7 million manifests, or approximately 52 percent of the total estimate of 3.2 million annual manifests used by the hazardous waste industry, are currently collected and processed by states. Therefore, under the proposed rule, EPA will assume responsibility for processing these 1.7 million manifests, in addition to the 1.5 million manifests not currently verified as collected or processed by states. While increasing costs to EPA, this has the effect of reducing costs to states (see Section 5.6 for additional information). 
        
       To estimate the costs associated with EPA manifest processing activities, this RIA uses the 2014 paper processing cost model also used in Chapter 4 to estimate the state burden associated with manifest processing. The details of this model are discussed in Appendix D. This model identifies ten distinct activities in the manifest receipt and processing process (e.g., preparation: sorting mail and separating supplemental documents, corrections, scanning of manifest documents, electronic archiving, etc.) and five "failure scenarios" necessitating additional follow-up (e.g., invalid identifying information for generator, transporter, or TSDF receiver, unresolved corrections, etc.), and assigns hourly cost estimates to each activity and failure scenario. Not every activity and failure scenario applies to every manifest: for example, the model assumes that only six percent of manifests have supplemental documentation requiring additional effort.  
        
       Additionally, in accordance with Section 5.1.2, this chapter estimates manifest collection and processing costs under three distinct manifest submission formats: the paper format, the image format, and the XML format. Specifically, paper variant manifest processing applies the same assumptions from the paper processing cost model as this RIA used to estimate state manifest processing burden in Chapter 4, while image and XML variant manifests result in lower overall burden to account for the additional information submitted with these manifests, which lowers processing time and the incidence of certain failure scenarios. Lastly, given the assumed design of the e-Manifest system, this RIA does not estimate any cost to EPA associated with the processing of electronic manifests, which will directly provide their data to the e-Manifest system without the need for additional actions by EPA staff. 
        
       The paper processing cost model assigns all standard manifest activities to a basic level of program staff; in Chapter 4, this RIA used the Biennial Report ICR fully-loaded rates for state clerical labor, but this section applies fully-loaded EPA clerical labor rates from the HWMS ICR ($23.92 per hour), for consistency with the remainder of the RIA where EPA costs are estimated. Similarly, fully-loaded EPA technical labor rates from the HWMS ICR ($56.05 per hour) are used for activities associated with failure scenarios. The EPA labor rates from the HWMS ICR are higher than the state labor rates applied in Section 4.5.2 ($21.70 per hour for clerical staff and $34.02 per hour for technical staff). 
        
       The assumptions and calculations within the paper processing cost model indicate that permanifest processing burdens vary across manifest format, as follows: 
        
              Paper variant  -  approximately 0.26 hours of clerical labor and approximately 0.096 hours of technical labor (consistent with Chapter 4); overall per-manifest cost of $11.67 under EPA fully-loaded labor rates from the HWMS ICR. 
              
              Image variant  -  approximately 0.19 hours of clerical labor and approximately 0.036 hours of technical labor; overall per-manifest cost of $6.52 under EPA fully-loaded labor rates from the HWMS ICR. 
              
              XML variant  -  approximately 0.056 hours of clerical labor and 0.014 hours of technical labor; overall per-manifest cost of $2.12 under EPA fully-loaded labor rates from the 
             HWMS ICR. 
        
       Based on the adoption rates used in this chapter, the overall manifest processing cost to EPA varies based on the number of manifests of each type (variant) received. As the adoption rate of the e-Manifest system increases, paper manifest processing costs to EPA are expected to drop sharply. Exhibit 5-6 details the annual costs based on the per-manifest costs described above and the adoption rate scenario from Section 5.1.3. 
        

                                 Exhibit 5-6 
           Summary of Manifest Processing Costs to EPA by Manifest Variant  
                     (2014$, millions of $, undiscounted) 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                               Manifest Variant 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
Year 6 
                          Total (Years 1 through 6) 
                                      1 
Paper 
Manifest 
Process 
Paper submission 
                                                                        $19.9  
                                                                        $14.1  
                                                                        $4.24  
$0.471  
$0.471  
$0.471  
                                                                        $39.7  
                                      2 

Scanned image submission 
                                                                        $1.00  
                                                                        $3.95  
                                                                        $2.37  
$0.263  
$0.263  
$0.263  
                                                                        $8.11  
                                      3 

XML schema submission 
                                                                        $2.57  
                                                                        $1.28  
                                                                        $1.54  
$0.171  
$0.171  
$0.171  
                                                                        $5.90  
                                      4 
e-Manifest System Process (electronic manifest) 
                                                                        $0.00  
                                                                        $0.00  
                                                                        $0.00  
                                                                        $0.00  
                                                                        $0.00  
                                                                        $0.00  
                                                                        $0.00  
                                      5 
                                                                         Total 
                                                                        $23.5  
                                                                        $19.4  
                                                                        $8.15  
$0.905  
$0.905  
$0.905  
                                                                        $53.7  
        
       The proportion of manifests received in the paper variant substantially drive EPA's manifest processing costs. Costs in Year 1 (approximately 53 percent of manifests submitted as the paper variant) for manifest processing total approximately $23 million; by Year 4, where 95 percent of manifests are submitted electronically and 1.25 percent are submitted as paper, paper processing costs total under $1 million. 
        
       In accordance with Section 5.2.8, this RIA also applies the 19.74 percent indirect cost factor for OLEM to the manifest processing costs displayed in Exhibit 5-6. The application of this factor directly increases the manifest processing costs by 19.74 percent (Exhibit 5-7). 
        
       Despite the higher labor rates used in this analysis, the inclusion of the indirect cost factor, and the greater volume of manifests processed by EPA relative to baseline state paper manifest processing detailed in Section 4.5, cumulative EPA processing costs dip below the less comprehensive cumulative baseline state manifest processing costs in Year 5, the second year that the adoption scenario estimates e-Manifest system adoption plateauing at 95 percent. This analysis indicates that the e-Manifest system will result in substantial long-term savings in total manifest processing costs, even after accounting for the larger volume of manifests that will be collected in the post-rule scenario. 
        
                                 Exhibit 5-7 
Summary of Manifest Processing Costs to EPA by Manifest Variant, including Indirect Costs[a] 
                     (2014$, millions of $, undiscounted) 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                               Manifest Variant 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
Year 6 
                          Total (Years 1 through 6) 
                                      1 
Paper 
Manifest 
Process 
Paper submission 
                                                                        $23.8  
                                                                        $16.9  
                                                                        $5.08  
$0.564  
$0.564  
                                                                       $0.564  
                                                                        $47.5  
                                      2 

Scanned image submission 
                                                                        $1.20  
                                                                        $4.73  
                                                                        $2.84  
$0.315  
$0.315  
                                                                       $0.315  
                                                                        $9.71  
                                      3 

XML schema submission 
                                                                        $3.07  
                                                                        $1.54  
                                                                        $1.84  
$0.205  
$0.205  
                                                                       $0.205  
                                                                        $7.07  
                                      4 
e-Manifest System Process (electronic manifest) 
                                                                        $0.00  
                                                                        $0.00  
                                                                        $0.00  
                                                                        $0.00  
                                                                        $0.00  
                                                                        $0.00  
                                                                        $0.00  
                                      5 
                                                                         Total 
                                                                        $28.1  
                                                                        $23.2  
                                                                        $9.76  
                                                                        $1.08  
                                                                        $1.08  
                                                                        $1.08  
                                                                        $64.3  
                                      6 
                                                              Cumulative Total 
                                                                        $28.1  
                                                                        $51.3  
                                                                        $61.0  
                                                                        $62.1  
                                                                        $63.2  
                                                                        $64.3  
                                     N/A 
                                      7 
          Cumulative Total of Baseline State Processing Costs (Exhibit 4-8)[b] 
                                                                        $15.0  
                                                                        $30.0  
                                                                        $45.0  
                                                                        $60.0  
                                                                        $75.0  
                                                                        $90.0  
                                     N/A 
Totals may not sum due to rounding. 
[a] Calculated as 19.74 percent of all costs incurred, based on the most recent indirect cost rate for EPA OLEM published by EPA OFM. [b] Estimated cost of $15.0 million annually per Exhibit 4-8 in Chapter 4. 
        
       5.4 Cost and Cost Savings to Industry  -  Manifest Completion and Submittal 
        
       The proposed rule will have several impacts on the hazardous waste industry related to manifest completion and submittal. Broadly, this RIA estimates that industry time and material burden associated with manifest completion tasks will decrease under the e-Manifest system. However, these cost savings will be offset in part by the manifest fees, and by CROMERR requirements applicable to subsets of the industry. 
        
       5.4.1 Reduced Manifest Completion and Submittal Burden 
        
       This RIA estimates that submission of fully-electronic manifests through the e-Manifest system will provide substantial cost savings to generators, transporters, and receivers of hazardous waste, who will no longer need to rely on a manual, paper system with multiple physical copies distributed to waste management and regulatory entities throughout the process. The RIA bases this estimate on expected changes to the various manifest-related activities. Specifically, this RIA groups activities described in Chapter 4 and the HWMS ICR into two categories: 
        
              Activities with major burden reductions achieved through electronic manifests  -  this category pertains to activities which are greatly expedited or obviated through the use of electronic manifests. Examples of these types of activities include manifest completion (by generators who do not currently use any proprietary electronic systems to generate and complete manifests), manifest storage and recordkeeping and manifest transmittal to other industry or regulatory entities. This RIA assumes that these activities experience an 80 percent burden reduction when associated with electronic manifests. 
        
              Activities with minimal burden reductions achieved through electronic manifests  -  this category pertains to activities which are only marginally expedited through the use of electronic manifests. Many manifest-related activities fall into this category, including most activities associated with rejected wastes, undeliverable shipments, exception reports, or other potential issues encountered in the process of hazardous waste transportation. Additionally, activities that are likely to be completed by TSDFs (which may already have proprietary electronic systems to generate and complete manifests) are grouped into this category, as the use of electronic manifests would not significantly change baseline practices. This RIA assumes that these activities experience a five percent burden reduction when associated with electronic manifests.  
        
       Additionally, a minority of manifest-related activities, namely those related to notifications of hazardous waste discharges, are not assumed by this RIA to have any burden reduction associated with electronic manifests, as they do not directly pertain to paperwork requirements for the manifest.  
        
       Exhibits 5-8 and 5-9 present the cost savings to industry based on the application of these reductions. These reductions apply only to the proportion of manifests submitted as electronic manifests, based on the adoption rate presented in Section 5.1.3, in a given year. Exhibit 5-8 displays baseline costs and corresponding reductions on an entity basis, while Exhibit 5-9 presents these items on an activity basis. Note that while the corresponding Exhibits 4-1 and 4-3 disaggregated the savings across federal and state manifests for illustrative purposes, Exhibits 58 and 5-9 aggregate the baseline costs into one row to allow for easier comparisons between the baseline and post-rule scenarios. 
        
                                            Exhibit 5-8 
                      Costs to Industry for Manifest Activities, Entity Basis  
                                   (2014$, millions of $, undiscounted) 


Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                                 Entity Type 
                    Baseline (0% electronic manifests)[a] 
                       Year 1 (5% electronic manifests) 
                      Year 2 (25% electronic manifests) 
                      Year 3 (55% electronic manifests) 
                      Year 4 (95% electronic manifests) 
                      Year 5 (95% electronic manifests) 
                      Year 6 (95% electronic manifests) 
                                      1 
Generators who Ship Waste 
                                                                        $53.6  
                                                                        $51.9  
                                                                        $44.9  
                                                                        $34.1  
                                                                        $20.5  
                                                                        $20.5  
                                                                        $20.5  
                                      2 
Transporters 
                                                                        $36.4  
                                                                        $34.9  
                                                                        $29.1  
                                                                        $20.4  
                                                                         $8.9  
                                                                         $8.9  
                                                                         $8.9  
                                      3 
Receivers 
                                                                        $95.3  
                                                                        $90.0  
                                                                        $84.1  
                                                                        $70.6  
                                                                        $52.7  
                                                                        $52.7  
                                                                        $52.7  
                                      4 
                                                                         Total 
                                                                         $185  
                                                                         $180  
                                                                         $158  
                                                                         $125  
                                                                        $81.7  
                                                                        $81.7  
                                                                        $81.7  
[a] Calculated as the sum of the total rows (Row 6 in both exhibits) in Exhibits 4-1 and 4-3.  


        
       On an entity basis, transporters of hazardous waste enjoy the greatest burden reduction, followed by shippers. TSDF receivers of hazardous waste enjoy the smallest relative burden reduction from the adoption and use of electronic manifests, because many of the activities with major burden reductions do not apply to these entities, and because in many cases they are already using proprietary electronic systems in the baseline. In contrast, transporter and shipper activities emphasize manifest completion, storage, and transmittal activities, all of which have major burden reductions. 
        	 
                                           Exhibit 5-9 
                    Costs to Industry for Manifest Activities, Activity Basis  
                                 (2014$, millions of $, undiscounted) 


Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                                Activity Type 
                                   Baseline 
                                     (0% 
                           electronic manifests)[b] 
                                    Year 1 
                                     (5% 
                            electronic manifests) 
                                    Year 2 
                                     (25% 
                            electronic manifests) 
                                    Year 3 
                                     (55% 
                            electronic manifests) 
                                    Year 4 
                                     (95% 
                            electronic manifests) 
                                    Year 5 
                                     (95% 
                            electronic manifests) 
                                    Year 6 
                                     (95% 
                            electronic manifests) 
                                      1 
Manifest 
Completion[a] 
                                                                         $175  
                                                                         $169  
                                                                         $148  
                                                                         $115  
                                                                        $72.1  
                                                                        $72.1  
                                                                        $72.1  
                                      2 
Discrepancy / 
Exception Reports 
                                                                        $7.09  
                                                                        $7.07  
                                                                        $7.00  
                                                                        $6.89  
                                                                        $6.75  
                                                                        $6.75  
                                                                        $6.75  
                                      3 
Undeliverable Shipments 
                                                                        $0.03  
                                                                        $0.03  
                                                                        $0.03  
                                                                        $0.03  
                                                                        $0.03  
                                                                        $0.03  
                                                                        $0.03  
                                      4 
Rejected 
Shipments / 
Wastes 
                                                                        $2.94  
                                                                        $2.94  
                                                                        $2.91  
                                                                        $2.86  
                                                                        $2.80  
                                                                        $2.80  
                                                                        $2.80  
                                      5 
Notifications of Discharge 
                                                                        $0.11  
                                                                        $0.11  
                                                                        $0.11  
                                                                        $0.11  
                                                                        $0.11  
                                                                        $0.11  
                                                                        $0.11  
                                      6 
                                                                         Total 
                                                                         $185  
                                                                         $180  
                                                                         $158  
                                                                         $125  
                                                                        $81.7  
                                                                        $81.7  
                                                                        $81.7  
[a] Includes all activities pertaining to manifest completion, transmittal, and recordkeeping. [b] Calculated as the sum of the total rows (Row 6 in both exhibits) in Exhibits 4-1 and 4-3.  


        
       On an activity basis, the largest burden reductions accrue to manifest completion activities, which also include all transmittal and recordkeeping requirements. This intuitively follows from the nature of electronic manifests and the e-Manifest system, as activities in this category represent routine tasks most easily expedited through automation or near-automation, and fall into the major burden reduction category. The remaining activities are exclusively those in the minimal reduction category, and achieve cost savings of under five percent even as electronic manifest use plateaus at 95 percent in Years 4, 5, and 6. The majority of industry cost savings accrue to manifest completion, transmittal, and recordkeeping activities: in Years 4 through 6, overall (undiscounted) cost savings relative to the baseline for manifest activities are approximately $100 million; over 99 percent of this total accrues to manifest completion, transmittal, and recordkeeping activities. 
        
       Based on Exhibits 5-8 and 5-9, Exhibit 5-10 summarizes cost savings to industry in Years 1 through 6. On a non-discounted basis, relative to baseline costs for manifest-related activities estimated in Chapter 4, this RIA estimates approximately $400 million in savings to industry over the first six years following e-Manifest system launch. Annually, undiscounted cost savings over this period range from approximately $5 million to approximately $100 million. The approximately $100 million in cost savings occurs annually in perpetuity after the adoption rate plateaus. On a discounted basis, with discounting at a seven percent discount rate applied to 2014 and assuming that the e-Manifest system launches in 2018, cost savings total approximately $240 million instead.  
        
        
        
        
        
                                 Exhibit 5-10 
    Cost Savings to Industry Associated with Use of Electronic Manifests  
                            (2014$, millions of $) 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                                     Cost 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
Year 6 
                           Total (Years 1 through 6) 
                                      1 
% of electronic manifests 
                                      5% 
                                     25% 
                                     55% 
                                     95% 
                                     95% 
                                     95% 
                                     N/A 
                                      2 
Baseline Cost[a] 
                                                                          $185 
                                                                          $185 
                                                                          $185 
                                                                         $185  
                                                                          $185 
                                                                          $185 
                                                                       $1,110  
                                      3 
Post-Rule Cost 
                                                                         $180  
                                                                         $158  
                                                                         $125  
                                                                         $81.7 
                                                                        $81.7  
                                                                        $81.7  
                                                                         $707  
                                      4 
Cost Savings (undiscounted) 
                                                                         $5.44 
                                                                        $27.2  
                                                                        $59.8  
                                                                         $103  
                                                                         $103  
                                                                         $103  
                                                                         $402  
                                      5 
Cost Savings  
(3% discount rate)[b] 
                                                                         $4.83 
                                                                         $23.4 
                                                                         $50.1 
                                                                         $84.0 
                                                                         $81.5 
                                                                         $79.2 
                                                                          $323 
                                      6 
Cost Savings  
(7% discount rate)[b] 
                                                                        $4.15  
                                                                        $19.4  
                                                                        $39.8  
                                                                        $64.3  
                                                                        $60.1  
                                                                        $56.2  
                                                                         $244  
Totals may not sum due to rounding. Discounting applied under the assumption that 2014 is the base year and Year 1, the first year of e-Manifest system operation, occurs in 2018. Correspondingly, the six years in this table are discounted by four through nine years, respectively. [a] Values in this column represent the sum of Rows 1 and 3 from Exhibit 4-8 in Chapter 4. [b] Cost savings in out years are less heavily discounted under a lower discount rate. 
        
       5.4.2 CROMERR Costs to Industry 
        
       As described in Section 5.2.5, the e-Manifest system will require e-Manifest system users to comply with CROMERR standards when submitting information to EPA. To submit information, employees of entities using the e-Manifest system must be registered in the CROMERR system; use of the e-Manifest system will therefore result in additional industry costs associated with CROMERR registration. 
        
       EPA's 2004 cost-benefit analysis of CROMERR identified five registration activities required to use the e-Manifest system: 
        
               Registering with CROMERR, including preparing, submitting, mailing to EPA, and filing a wet-ink signature agreement as part of the registration process; 
               
               Placing a phone call to the CROMERR help desk for assistance with the registration process; 
              
               Additional registration with EPA's Central Data Exchange (CDX); 
              
               Obtaining digital signature certifications for users that may potentially submit enforcement-sensitive information; and 
              
               Identification and resolution of problems pertaining to CROMERR registration. 
        
       This RIA assumes that CROMERR will apply to all receiver TSDFs and transporters, but not to generators. Consistent with the estimates of EPA CROMERR-related costs, this RIA assumes that each of the 413 receiver TSDFs will seek CROMERR registrations for five employees, while each of the 9,947 trucks engaged in shipping hazardous waste is operated by two drivers, each of whom will require a CROMERR registration to complete manifest activities through the e-Manifest system, for a total of approximately 22,000 users (see Chapter 2). For simplicity, this RIA assumes that each facility operates its own hazardous waste shipping truck; to the extent that this is a high-cost assumption because multiple trucks are aggregated at a single establishment or facility, the costs of CROMERR registration to industry would be lower. 
        
       This RIA assesses the costs under alternative assumptions governing CROMERR, such as scenarios where CROMERR is required for generators in addition to TSDF receivers and transporters, in Chapter 6. 
        
       The methodology for estimating CROMERR costs to industry is broadly similar to the methodology used to estimate CROMERR-related e-Manifest system costs to EPA in Section 5.2.5. Therefore, this section briefly explains the cost associated with each of the five industry CROMERR registration activities noted above, making reference to the specific calculations as described in more detail in Section 5.2.5 where relevant. 
        
       5.4.2.1 CROMERR User Registration  -  Industry Costs 
        
       Consistent with Section 5.2.5.1, industry costs for CROMERR registration include: 15 minutes (0.25 hours) for a single employee to register with CROMERR, including preparation, submitting, and filing of the necessary wet-ink signature agreements, and a $2.50 (2003$) charge for postage, which equals $3.24 in 2014$. Users must register not only at those facilities that adopt use of the e-Manifest system registrations but also for a proportion of new users at facilities that had already adopted the e-Manifest system (i.e., as a result of user turnover) and for a proportion of new facilities that did not previously operate in the market (i.e., as a result of facility turnover). Additionally, users who remain registered for three years must renew their CROMERR registration in the third year. These re-registration costs apply only to users at existing facilities, two years after those facilities are estimated to have adopted the e-Manifest system. 
        
       Costs of user registration to industry are similar to the costs of processing user registrations to EPA because they reflect the other side of the same interaction (Section 5.2.5.1), though the cost of $13.35 per user registration is based on the industry technical labor rate of $40.44 from the HWMS ICR and $3.24 in postage fees and 0.25 hours, rather than 0.17 hours, for the registration process. 
        
       This RIA estimates annual costs to industry for user registrations of approximately $15,000 in the first year after e-Manifest system launch (five percent e-Manifest system adoption) and approximately $240,000 in the sixth year after e-Manifest system launch (95 percent e-Manifest system adoption), and approximately $190,000 annually in perpetuity. These costs vary based on cumulative and incremental e-Manifest system adoption in a given year. It is possible that some hazardous waste truckers and many employees at receiver TSDFs are already registered with CROMERR; to the extent that this is the case, these costs may be an overestimate. 
        
       5.4.2.2 CROMERR Help Desk  -  Industry Costs 
        
       Consistent with EPA's costs, the CROMERR Cost Benefit Analysis estimated approximately eight minutes (0.13 hours) for industry to place and complete a help desk call, on average. It also assumed that such calls would specifically be related to registration, and that, on average, each registering user would make one such call to the CROMERR help desk in the course of registration. Because of facility and user turnover, this cost applies to more than just the set of users at facilities newly-adopting the e-Manifest system in a given year. The calculations for this cost item are similar to that for user registrations, but use 0.13 hours of industry technical labor rather than 0.25 hours per instance.  
        
       Correspondingly, CROMERR costs to industry associated with the help desk range from approximately $6,000 in the first year to approximately $44,000 in the sixth year after system implementation (95 percent adoption) and annually thereafter, with higher costs in some interim years to account for large numbers of first-time user registrations in those years. 
        
       5.4.2.3 CDX Registration 
        
       Each registering employee must register with the CDX system once as part of CROMERR registration; the CROMERR Cost Benefit Analysis estimates that this registration takes three minutes (0.05 hours) to complete. Due to facility and user turnover, this cost applies to more than just the set of users at facilities newly-adopting the e-Manifest system in a given year. The calculations for this cost item are similar to that for help desk calls, but use 0.05 hours of industry technical labor rather than 0.13 hours per instance.  
        
       Costs to industry associated with CDX registration range from approximately $2,000 in the first year to approximately $17,000 in the sixth year after e-Manifest system implementation and annually thereafter, with highest costs in some interim years to account for large numbers of first-time user registrations in those years. 
        
       5.4.2.4 Digital Signature Certification 
        
       The CROMERR Cost Benefit Analysis also assumes that 20 percent of employee registrations would be required to submit enforcement-sensitive information to EPA. In order to preserve the integrity of these data, the analysis assumes that these registrants obtain and install a digital electronic signature certificate on their browser, which requires 30 minutes of industry technical labor. Similar to the broader CROMERR registration, this must be renewed every two years after the first year. The calculations for this item are similar to those for CROMERR registration (Section 5.4.2.1) but use 0.5 hours of industry technical labor instead for 20 percent of employee registrations instead.  
        
       Costs to industry associated with this activity range from approximately $4,000 in the first year to approximately $74,000 in the sixth year after e-Manifest system implementation, with an annual cost in perpetuity of approximately $59,000.[33] 
        
       5.4.2.5 CROMERR Facility Registration Issues 
        
       The CROMERR Cost Benefit Analysis estimates approximately one hour for industry staff to investigate registration issues or respond to EPA queries, and indicates that such activities apply to three percent of facilities each year. This RIA estimates costs for this activity in a given year as total facilities/trucks x the adoption rate in that year x $40.44 (the cost for one hour of industry technical labor per the HWMS ICR). Costs range from approximately $600 to approximately $12,000 as the adoption rate increases over time, and at $12,000 annually thereafter.  
        
       The costs associated with this activity are especially sensitive to the assumption that each truck is its own facility; however, as costs associated with this activity are low even under this conservative assumption, altering it is unlikely to result in substantial cost impacts. 
        
       5.4.2.5 Summary of CROMERR-Related Costs to Industry 
        
       Exhibit 5-11 summarizes the CROMERR-related costs to industry estimated by this RIA. The cumulative e-Manifest system adoption rate drives these costs, but the fourth year of system operation results in the highest costs in this period due to a large increase in e-Manifest adoption between this year and the previous year. Overall, CROMERR registration costs for industry range from approximately $28,000 to approximately $400,000, depending on the cumulative and incremental adoption rates of e-Manifest in a given year. Following Year 6, these costs are approximately $330,000 in perpetuity. 
        
        
        
                                 Exhibit 5-11 
             CROMERR Registration and Related Costs to Industry  
                    (2014$, thousands of $, undiscounted) 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                               CROMERR-Related 
                                   Activity 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
Year 6 
                          Total  (Years 1 through 6) 
                                      1 
% of electronic manifests 
                                      5% 
                                     25% 
                                     55% 
                                     95% 
                                     95% 
                                     95% 
                                     N/A 
                                      2 
CROMERR Registration 
                                                                        $14.7  
                                                                        $65.2  
                                                                         $128  
                                                                         $226  
                                                                         $188  
                                                                         $245  
                                                                         $867  
                                      3 
Help Desk 
                                                                        $5.77  
                                                                        $25.4  
                                                                        $46.2  
                                                                        $71.6  
                                                                        $43.9  
                                                                        $43.9  
                                                                         $237  
                                      4 
CDX Registration 
                                                                        $2.22  
                                                                        $9.77  
                                                                        $17.8  
                                                                        $27.5  
                                                                        $16.9  
                                                                        $16.9  
                                                                        $91.0  
                                      5 
Digital Signature Certification 
                                                                        $4.44  
                                                                        $19.8  
                                                                        $38.9  
                                                                        $68.4  
                                                                        $57.1  
                                                                        $74.2  
                                                                         $263  
                                      6 
Facility Registration Issues 
                                                                        $0.63  
                                                                        $3.14  
                                                                        $6.91  
                                                                        $11.9  
                                                                        $11.9  
                                                                        $11.9  
                                                                          $47  
                                      7 
                                                                         Total 
                                                                        $27.7  
                                                                         $123  
                                                                         $238  
                                                                         $405  
                                                                         $318  
                                                                         $392  
                                                                       $1,500  
Totals may not sum due to rounding. 
        
       5.4.3 System Investment by Industry 
        
       This RIA considers only the cost savings associated with the use of electronic manifests and the costs associated with CROMERR for TSDF receivers and transporters as non-manifest fee cost impacts to industry from the e-Manifest system. 
        
       Under certain specifications of the e-Manifest system, industry entities may need to invest in internal system upgrades or hardware in order to use the e-Manifest system. These types of upgrades may range from programming to align existing proprietary systems with the e-Manifest system to a requirement to purchase smartphones or tablets in order to use the e-Manifest system at the point of waste transfer, or while the waste is in transit. 
        
       This RIA assumes that the e-Manifest system implemented under the proposed rule will not require any such investment in either hardware or software by firms or facilities in the hazardous waste industry. To the extent that this is not the case, costs to industry associated with the proposed rule may be understated. This RIA further assumes that the e-Manifest system will be web-based, and that costs incurred voluntarily by industry to connect internal or proprietary systems to the e-Manifest system will reflect opportunities for cost savings or functionality beyond the scope of this RIA. This RIA therefore considers such activities to bear a net cost of zero  -  if net costs were high, industry actors would not undertake these activities. 
        
       Reflecting this assumption, the adoption rates in Exhibits 5-1 and 5-2 used throughout this chapter indicate near-universal adoption of electronic manifests over a period of four years. In other words, this RIA assumes that the majority of industry entities eventually adopt the use of electronic manifests in part because the one-time costs associated with adoption, if any, are offset by cost savings. Due to a lack of information on what implementation costs may be if they are not minimal, this RIA instead assesses the possibility that industry entities would have to incur significant adoption costs using a sensitivity analysis in Chapter 6 that focuses on adoption rates for the electronic manifests. The sensitivity analysis considers a scenario where ultimate adoption of electronic manifests is considerably lower than the primary analysis in this chapter. 
        
       5.5 Manifest Fees to Industry 
        
       Under the proposed rule, e-Manifest fees effectively function as a transfer between EPA and industry, as EPA transfers the system development and operations costs it incurs, in full, to industry. All costs described in Section 5.2 and 5.3 will be recouped through these manifest fees. Over a six-year period of analysis, the total amount to be recouped by these fees is consistent with the total costs incurred by EPA for system development and maintenance in this period; in other words, the fees recoup the sum of the totals in Exhibits 5-4, 5-5, and 5-7. 
        
       5.5.1.1 Principles Guiding Proposed Manifest Fee Options 
        
       In considering fee structures to recoup e-Manifest system costs under the proposed rule, EPA conducted a review of relevant literature sources and federal guidance documents, especially Office of Management and Budget (OMB) Circular A-25 and numerous reports from the Government Accountability Office (GAO). Based on these source and other fee design considerations, EPA has distilled six principles of fee design that bound and guide the development of EPA's proposed manifest fee options included in this RIA: 
        
              Ensure that administrative (e.g., fee collection) costs are not a significant portion of total EPA system costs. OMB Circular A-25 emphasizes the need to ensure that the cost of collecting the fee does not represent a significant proportion of the fee itself. 
              
              Align fee burden with users receiving the most extensive services and/or cost savings. A key principle in economic theory, and one emphasized in GAO's Federal User Fees: A Design Guide, is that prices for government services should be set such that each individual user offsets the costs incurred for providing a service to the user. Users who impose the greatest costs on the e-Manifest systems hould pay higher fees and the fees should reflect the costs imposed.  
              
              Consider whether the market is segmented in a way that requires a tiered fee structure. If the market structures of the relevant industries reveal significant differentiated use of services, costs and benefits to users are likely segmented as well. Alignment of fees with these costs and benefits should take market segmentation into account. 
              
              Agencies should consider system users that are less able to pay when designing a fee structure. While fees that accurately reflect the costs incurred by the system through each individual user are generally both efficient and equitable, economics and GAO also consider distributional impacts across users, and explicitly note that the burden of the fee should be borne by the users better able to pay. 
              
              The fee structure should address variability in fee receipts relative to costs. 
             Variability in fee receipts relative to program costs can be a major challenge in designing 
             fees. For example, over time, the relative numbers of electronic and non-electronic manifest may change, as well as their costs. If programs fail to address this variability, fees can either fail to recover costs or recover too much and lead to an excessive burden on users of the service.  
              
              Fee design should encourage adoption of the system with the greatest net benefits. In accordance with overall economic efficiency, fee designs should align private user incentives to promote actions that present the least cost and greatest benefits to the system as a whole. The design considerations here build on assumptions that show that use of the e-Manifest system represents the lowest per-manifest (and total) cost option for EPA (Exhibit 5-6) and a lower per-manifest cost for regulated entities as well (Exhibits 5-8 and 5-9). The impact of fixed costs on adoption rates for electronic manifests should continue to be a focus in assessing the costs of regulatory options. 
        
       Based on the above principles, EPA developed four fee options, presented in the following section.  
        
       5.5.2 Fee Options for the Proposed Rule 
        
       This section presents EPA's four fee options for the proposed rule. Three of these options represent distinct methods of assessing fees across manifest submission options, while the fourth, EPA's preferred option, is a hybrid of two options that does not require a separate modeling and estimation effort. This RIA does not estimate that the different fee options will result in different total costs collected and recouped via the manifest fees, as the full cost recovery principle remains in effect for each option discussed below. Rather, these options change only the distribution of how the cost recovery burden falls on different manifest variants. 
        
       5.5.2.1 Shared Assumptions across Fee Options 
        
       The fee options presented in this RIA incorporate the following set of underlying assumptions: 
        
              All fee options are designed to fully recover EPA's costs to design, build, and run the e-Manifest system and program, consistent with the Electronic Manifest Establishment Act requirement. Each fee option therefore is designed to recover the same cost, and relies on some of the same underlying parameters and other information to estimate fees, though each option uses different calculations to arrive at final fee amounts. 
              
              All fee options assign fees on a per-manifest basis. EPA considered assigning fees in other ways, such as annual subscriptions, but determined that per-manifest fees are best to ensure that users bear the costs of supporting the e-Manifest system in proportion to their use of it. The heaviest users of the system will submit the most manifests, realize the most benefits, and also bear the largest share of the burden of supporting the system. Less frequent users will also realize benefits and bear costs in proportion to their use.  
              
              All fee options assume that TSDFs pay the fees. 
              
              All fee options assume that manifests may be submitted to the system in accordance with one of the four manifest variants discussed in Section 5.1.2 (paper, image, XML, or electronic). Each fee option assigns fees to these manifest variants in a different manner; this assignment protocol is the distinguishing feature of each option. 
              
              All fee options assume that setup costs are distributed across a predetermined payback period, and will cease being recovered after that period ends. Correspondingly, fees will be lower after this period has ended, as setup costs will cease being recovered at this point. This RIA assumes this payback period to be five years; costs under alternate payback scenarios are considered in Chapter 6. 
        
       5.5.2.2 Option 1  -  Uniform Cost Fee 
        
       Under this fee option, this RIA assigns a single, uniform fee to all manifest variants. This RIA first estimates a weighted average marginal cost by considering the relative prevalence of each manifest variant in a given year (per the assumed adoption rate in Section 5.1.3) as well as the marginal cost to process that manifest variant per Section 5.3. This weighted average marginal cost ranges from $8.69 in the first year after e-Manifest system launch to $0.34 in the fourth year after system launch. Under the statute, EPA must alter the fee to reflect different levels of adoption, but the fee at any given point in time would not vary across manifest variants (i.e., paper, image, XML, etc.). 
        
       Under this option, this RIA then evenly divides all remaining costs to EPA (Section 5.2) across all manifests. Setup costs are divided by a factor of five (due to a payback period length of five years) and each fifth of the overall setup costs is applied to the total sum that must be recovered in a given year (for the first five years, only). Exhibit 5-12 illustrates the calculation of the fee, breaking it down into the components that it recovers. Exhibit 5-13 then illustrates the total amount estimated to be collected through this fee option.  
        

                                 Exhibit 5-12 
        Option 1  -  Uniform Cost Fee Estimation, Manifest Fee Basis  
                             (2014$, undiscounted) 

Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 

                                   Category 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
Year 6 
                                      1 
Marginal Processing Cost 
                                                                        $8.69  
                                                                        $7.18  
                                                                        $3.02  
                                                                        $0.34  
                                                                        $0.34  
                                                                        $0.34  
                                      2 
Setup Cost (per manifest) 
                                                                        $2.82  
                                                                        $2.82  
                                                                        $2.82  
                                                                        $2.82  
                                                                        $2.82  
                                                                        $0.00  
                                      3 
O&M Cost (per manifest) 
                                                                        $7.23  
                                                                        $7.39  
                                                                        $7.61  
                                                                        $7.92  
                                                                        $7.90  
                                                                        $7.91  
                                      4 
                                                   Total Fee for All Manifests 
                                                                       $18.74  
                                                                       $17.39  
                                                                       $13.46  
                                                                       $11.08  
                                                                       $11.05  
                                                                        $8.25  
        
        
        
        

                                     Exhibit 5-13 
                Option 1  -  Uniform Cost Fee, Total Fee Levied  
                    (2014$, millions of $, undiscounted) 


Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                                     Cost 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
Year 6 
                                    Total 
                                      1 
Marginal Processing Cost 
                                                                         $28.1 
                                                                         $23.2 
                                                                         $9.76 
                                                                         $1.08 
                                                                         $1.08 
                                                                         $1.08 
                                                                         $64.3 
                                      2 
Setup Cost (per manifest) 
                                                                         $9.11 
                                                                         $9.11 
                                                                         $9.11 
                                                                         $9.11 
                                                                         $9.11 
                                                                         $0.00 
                                                                         $45.5 
                                      3 
O&M Cost (per manifest) 
                                                                         $23.3 
                                                                         $23.9 
                                                                         $24.6 
                                                                         $25.6 
                                                                         $25.5 
                                                                         $25.5 
                                                                          $148 
                                      4 
                                                              Total Fee Levied 
                                                                         $60.5 
                                                                         $56.2 
                                                                         $43.5 
                                                                         $35.8 
                                                                         $35.7 
                                                                         $26.6 
                                                                          $258 
        
       Over the six-year period presented, the total amount recovered is approximately $258 million, consistent with the sum of the total costs incurred by EPA across Exhibits 5-4, 5-5, and 5-7. The columns in Exhibit 5-13 specifically pertain to these exhibits: the total in Column B of approximately $64 million matches the corresponding total from Exhibit 5-7; the totals in Columns C and D similarly pertain to the totals of Exhibits 5-4 and 5-5, respectively.  
        
       This option is the most simple of those presented in this RIA. Industry feedback has indicated that industry would prefer such a fee in the early years of the system due to its simplicity; however, this option is the most likely to over- or under-collect fees, because it requires EPA to accurately estimate the adoption rate in order to accurately estimate the weighted average marginal cost to process a manifest. Therefore, this option is least likely to fulfill EPA's statutory requirement to fully recover costs each year, though it does so in this RIA, where the adoption rate is assumed to be known and rigid.  
        
       This option also subsidizes users who submit manifests that are relatively costly for EPA to process at the expense of users submitting other manifest variants. It is less efficient than the other options because the users do not internalize the costs they actually impose. Thus, it will not given an efficient incentive to users to discontinue submitting paper variant manifests and switch to the e-Manifest system. 
       5.5.2.3 Option 2  -  Marginal Cost Fee 
        
       For this option, this RIA assigns differential fees to each manifest variant, based on the different marginal costs to EPA associated with processing each manifest variant. This RIA then distributes the remaining costs (setup costs, operations costs) equally across each manifest type, similar to Option 1. The resulting fee for each manifest variant under this option is equal to the marginal cost of processing that manifest variant (per Section 5.3), plus a uniform portion of the setup and operations costs. Exhibits 5-14 and 5-15 display the per-manifest fee and the total amount recovered, respectively, for each manifest variant. Again, note that the total amount recovered is approximately $258 million, and the amount recovered for each cost type incurred by EPA, while not shown in these exhibits, is similarly to that shown in Exhibit 5-13. The fees collected in each year similarly track with the figures in Exhibit 5-13, which is a necessary condition of the fee design to fully recover operations costs, processing (marginal) costs and a portion of setup costs in each year, regardless of the fee structure. 
        

                                 Exhibit 5-14 
          Option 2  -  Marginal Cost Fee, Manifest Basis by Manifest Variant  
                            (2014$, undiscounted) 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 

                               Manifest Variant 
                                    Year 1 
                                    Year 2 
                                    Year 3 
                                    Year 4 
                                    Year 5 
                                    Year 6 
                                      1 
Paper 
Manifest 
Variants 
Paper Variant 
                                                                       $24.03  
                                                                       $24.18  
                                                                       $24.41  
                                                                       $24.72  
                                                                       $24.69  
                                                                       $21.89  
                                      2 

Image Variant 
                                                                       $17.86  
                                                                       $18.01  
                                                                       $18.24  
                                                                       $18.55  
                                                                       $18.52  
                                                                       $15.72  
                                      3 

XML Variant 
                                                                       $12.59  
                                                                       $12.74  
                                                                       $12.97  
                                                                       $13.28  
                                                                       $13.25  
                                                                       $10.45  
                                      4 
e-Manifest 
Electronic Variant 
                                                                       $10.05  
                                                                       $10.21  
                                                                       $10.43  
                                                                       $10.74  
                                                                       $10.72  
                                                                        $7.91  
        

                                      Exhibit 5-15 
         Option 2  -  Marginal Cost Fee, Total Fee Levied by Manifest Variant  
                          (2014$, millions of $, undiscounted) 

Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                               Manifest Variant 
 Year 1 
                                    Year 2 
Year 3 
                                    Year 4 
                                    Year 5 
                                    Year 6 
                                    Total 
                                      1 
Paper 
Manifest 
Variants 
Paper Variant 
                                                                        $40.9  
                                                                        $29.3  
                                                                        $8.87  
                                                                       $0.998  
                                                                       $0.997  
                                                                       $0.884  
                                                                        $82.0  
                                      2 

Image Variant 
                                                                        $2.74  
                                                                        $10.9  
                                                                        $6.63  
                                                                       $0.749  
                                                                       $0.748  
                                                                       $0.634  
                                                                        $22.4  
                                      3 

XML Variant 
                                                                        $15.2  
                                                                        $7.72  
                                                                        $9.43  
                                                                        $1.07  
                                                                        $1.07  
                                                                        $0.84  
                                                                        $35.4  
                                      4 
e-Manifest 
Electronic Variant 
                                                                        $1.62  
                                                                        $8.24  
                                                                        $18.5  
                                                                        $33.0  
                                                                        $32.9  
                                                                        $24.3  
                                                                         $118  
                                      5 
                                                              Total Fee Levied 
                                                                        $60.5  
                                                                        $56.2  
                                                                        $43.5  
                                                                        $35.8  
                                                                        $35.7  
                                                                        $26.6  
                                                                         $258  
        
       Option 2 is more likely than Option 1 to fully recover EPA's costs because it does not rely on correct predictions of the e-Manifest adoption rate to accurately assess marginal costs that are considered part of the fee for each manifest variant in this fee option. By virtue of higher fees accruing to manifests which require a higher burden to process, it also provides market signaling information that will encourage users to switch towards electronic manifests. 
        
       5.5.2.4 Option 3  -  Marginal Cost Differentiated Fee 
        
       The Marginal Cost Differentiated Fee option is similar to Option 2, except that paper manifest processing operations costs (Section 5.2.3) are distributed only across paper manifest variants (paper, image, and XML manifest submissions), and do not accrue to electronic manifests. In other words, whereas in Option 2, non-labor costs for EPA's paper processing center were distributed across all manifest variants, under Option 3, these costs are distributed across paper manifest variants only. Because the annual cost of these non-labor paper manifest processing operations is fairly low ($1 million annually), this does not substantially change the cost calculus of this option relative to Option 2. However, it does slightly apportion costs away from electronic manifests and towards the other manifest variants. Similar to Option 2, this fee option is more likely than Option 1 to fully recover EPA's costs, as it does not rely on long-term predictions regarding the adoption rate to levy marginal processing costs for different manifest variants. It encourages switching towards electronic manifests slightly more than Option 2, by apportioning more of the costs of paper processing specifically to paper manifest variants, causing their prices to be higher relative to electronic manifests.. Exhibits 5-16 and 5-17 display the per-manifest fee and the total amount recovered, respectively, for each manifest variant under this option. Again, note that the total amount recovered is approximately $258 million. 
        

                                  Exhibit 5-16 
     Option 3  -  Marginal Cost Differentiated Fee, Manifest Basis by Manifest Variant  
                             (2014$, undiscounted) 

Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 

                               Manifest Variant 
                                    Year 1 
                                    Year 2 
                                    Year 3 
                                    Year 4 
                                    Year 5 
                                    Year 6 
                                      1 
Paper 
Manifest 
Variants 
Paper Variant 
                                                                       $24.05  
                                                                       $24.31  
                                                                       $24.86  
                                                                       $31.76  
                                                                       $31.74  
                                                                       $28.93  
                                      2 

Image Variant 
                                                                       $17.87  
                                                                       $18.14  
                                                                       $18.69  
                                                                       $25.59  
                                                                       $22.57  
                                                                       $22.76  
                                      3 

XML Variant 
                                                                       $12.61  
                                                                       $12.87  
                                                                       $13.42  
                                                                       $20.32  
                                                                       $20.30  
                                                                       $17.49  
                                      4 
e-Manifest 
Electronic Variant 
                                                                        $9.68  
                                                                        $9.84  
                                                                       $10.06  
                                                                       $10.37  
                                                                       $10.35  
                                                                        $7.54  
        

                                 Exhibit 5-17 
     Option 3  -  Marginal Cost Differentiated Fee, Total Fee Levied by Manifest Variant  
                     (2014$, millions of $, undiscounted) 

Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                               Manifest Variant 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
                                    Year 6 
                                    Total 
                                      1 
Paper 
Manifest 
Variants 
Paper Variant 
                                                                        $41.0  
                                                                        $29.4  
                                                                        $9.03  
                                                                        $1.28  
                                                                        $1.28  
                                                                        $1.17  
                                                                        $83.2  
                                      2 

Image Variant 
                                                                        $2.74  
                                                                        $11.0  
                                                                        $6.79  
                                                                        $1.03  
                                                                        $1.03  
                                                                       $0.919  
                                                                        $23.5  
                                      3 

XML Variant 
                                                                        $15.3  
                                                                        $7.79  
                                                                        $9.75  
                                                                        $1.64  
                                                                        $1.64  
                                                                        $1.41  
                                                                        $37.5  
                                      4 
e-Manifest 
Electronic Variant 
                                                                        $1.56  
                                                                        $7.94  
                                                                        $17.9  
                                                                        $31.8  
                                                                        $31.7  
                                                                        $23.1  
                                                                         $114  
                                      5 
                                                                         Total 
                                                                        $60.5  
                                                                        $56.2  
                                                                        $43.5  
                                                                        $35.8  
                                                                        $35.7  
                                                                        $26.6  
                                                                         $258  
        
       This option redistributes about $4 million in fees over six years away from electronic manifests and toward paper manifests, relative to Option 2. Overall, on an annual basis, fees range from approximately $61 million to approximately $27 million, and are approximately $27 million in perpetuity as the payback period ends and fees are required only to recoup ongoing e-Manifest system operations and processing costs. 
        
       5.5.2.4 Option 4  -  Proposed Option 
        
       For the remainder of this RIA, the Proposed Option is a hybrid of Option 2 and Option 3. Specifically, the Proposed Option consists of initially assessing fees under Option 2. Then, if adoption of electronic manifests does not surpass a predetermined threshold (75 percent) after a specified amount of time (five years), fees would begin to be levied under Option 3 instead. Option 3 slightly incentivizes adoption of electronic manifests relative to Option 2. Thus the Proposed Option should increase e-Manifest system use more than Option 2 in case initial electronic manifest adoption is slower than expected, creating inefficiencies in EPA operations and raising overall costs. 
        
       This RIA considers a threshold electronic manifest adoption rate of 75 percent after five years of e-Manifest system operation. The assumed adoption rate per Section 5.1.3 meets this threshold in which case Option 3 fee pricing would not be triggered. As a result, this RIA assesses fees under Option 2. However, Chapter 6 analyzes scenarios where the adoption rate differs, and the switch to Option 3 fees takes effect. 
        
       Regardless of the fee option, the annual fees collected, shown in Exhibits 5-13, 5-15, and 5-17, apply in Years 1 through 6 of e-Manifest system operations, offsetting EPA's e-Manifest system development and operation costs, as well as cost savings to industry described in Exhibit 5-10. 
       Exhibit 5-18 below summarizes the aggregate costs and cost savings to industry as described so far in this chapter. 
        
                                             Exhibit 5-18 
                         Summary of Select Costs and Cost Savings to Industry  
                                        (2014$, millions of $) 



Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 
                                      I 

                                Cost Category 
                                   Baseline 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
Year 6 
                             Total (Years 1 - 6) 
                                      1 
Industry Manifest activities (Exhibit 5-10) 
                                                                          $185 
                                                                          $180 
                                                                          $158 
                                                                          $125 
                                                                         $81.7 
                                                                         $81.7 
                                                                         $81.7 
                                                                          $708 
                                      2 
CROMERR Costs to Industry (Exhibit 5-11) 
                                                                         $0.00 
$0.0277 
$0.0123 
$0.238 
                                                                        $0.405 
 $0.318 
$0.392 
                                                                         $1.50 
                                      3 
Manifest fees (Exhibit 5-15) (calculated to recoup system setup and operations costs to EPA) 
                                                                         $0.00 
                                                                         $60.5 
                                                                         $56.2 
                                                                         $43.5 
                                                                         $35.8 
                                                                         $35.7 
                                                                         $26.6 
                                                                          $258 
                                      4 
                                                                   Total Costs 
                                                                          $185 
                                                                          $240 
                                                                          $214 
                                                                          $169 
                                                                          $118 
                                                                          $118 
                                                                          $109 
                                                                          $968 
Costs (Cost Savings) Relative to Baseline 



                                      5 
Industry Manifest activities 
                                                                       ($5.44) 
                                                                       ($27.2) 
($59.8) 
                                                                        ($103) 
                                                                        ($103) 
                                                                        ($103) 
                                                                        ($402) 
                                      6 
CROMERR Costs to Industry 
$0.0277 
$0.0123 
$0.238 
                                                                        $0.405 
 $0.318 
$0.392 
                                                                         $1.50 
                                      7 
Manifest fees (calculated to recoup system setup and operations costs to EPA) 
                                                                         $60.5 
                                                                         $56.2 
                                                                         $43.5 
                                                                         $35.8 
                                                                         $35.7 
                                                                         $26.6 
                                                                          $258 
                                      8 
                                     Total Costs (Cost Savings) (undiscounted) 
                                                                         $55.1 
                                                                         $29.1 
($16.1) 
                                                                       ($67.1) 
($67.3) 
($76.3) 
                                                                        ($143) 
                                      9 
Total Costs (Cost Savings) (3% discount rate) 
                                                                         $49.0 
                                                                         $25.1 
($13.5) 
                                                                       ($54.6) 
($53.1) 
($58.4) 
                                                                        ($106) 
                                      10 
Total Costs (Cost Savings) (7% discount rate) 
                                                                         $42.1 
                                                                         $20.7 
($10.7) 
                                                                       ($41.8) 
($39.2) 
($41.5) 
                                                                       ($70.4) 
        
       Over the six-year period, undiscounted cost savings to industry, accounting for burden reductions in manifest activities as well as cost increases due to manifest fees and CROMERR requirements total approximately $140 million. On an annual basis, undiscounted, incremental costs range from approximately $55 million to approximately $76 million in cost savings; approximately $76 million in annual savings to industry occurs in perpetuity as the payback period ends and fees recoup only ongoing operations costs incurred by EPA.  
        
       On a discounted basis under a seven percent discount rate, where out-year costs are discounted back to 2014 and the first year of e-Manifest system operation is assumed to be 2018, cost savings are approximately $70 million instead. This represents an annualized cost savings associated with these three items of approximately $15 million. 
        
       However, in addition to the cost components detailed in Exhibit 5-18, this RIA also assesses a number of other costs and cost savings resulting from the proposed rule and the implementation of the e-Manifest system. 
        
       5.6 Cost Savings to States 
        
       In Chapter 4, this RIA detailed and estimated the baseline costs associated with a number of activities carried out by states to collect and process federal and state manifests. This RIA estimated these costs at approximately $15 million annually (Exhibit 4-8). Following the implementation of the proposed rule, states will no longer need to collect and process manifests, as this will be handled by the e-Manifest system for both electronic and paper manifests. The states will be able to access data stored in the e-Manifest system at no charge. This RIA assumes that to the extent that states will wish to continue to collect and process manifests to meet statespecific regulatory, enforcement, or data needs, they will be able to do so through the e-Manifest system. Correspondingly, this RIA assumes that states incur no costs to collect and process manifests in the post-rule scenario, and therefore that they enjoy approximately a $15 million cost savings annually as a result of the proposed rule. 
        
       5.7 Hazardous Waste Reporting Costs 
        
       Chapter 4 assessed baseline costs of hazardous waste reporting to both industry and states (Sections 4.6 and 4.7, respectively). This RIA assumes that the e-Manifest system will reduce the burden associated with hazardous waste reporting by reducing the number of individual reporting activity instances that take place in a given (biennial) reporting cycle.  
        
       5.7.1 Hazardous Waste Reporting Costs to Industry 
        
       This RIA estimates the following impacts to hazardous waste reporting activities and costs due to implementation of the e-Manifest system: 
        
              As TSDFs will be submitting the final manifest with all attendant data to EPA, other entities will no longer be directly required to specially prepare specific reporting forms, such as the site ID form or read the reporting instructions. Similarly, only receiver TSDFs will be required to submit any reports, rather than receivers and generators. 
              
              Under the proposed rule, this RIA assumes that TSDFs will not need to revise their data systems to include new reporting items, as this will be handled by the e-Manifest system architecture. 
              
              Generators will not need to specially fill out and file a GM (Generation and Management) Form, as this information will be automatically collected and populated by the e-Manifest system based on submitted manifests. 
              
              The burden associated with creating and submitting WR (Waste Received) Forms will accrue only to receiver TSDFs, rather than all receivers of hazardous waste, as assumed in the BR ICR. This reduces the burden associated with WR Forms by removing the costs associated with non-TSDF receivers creating and submitting these forms.  
              
       The overall impact of these changes to industry reporting in the post-rule scenario is summarized in Exhibit 5-19 below. Overall, this RIA estimates approximately $6 million in annual cost savings to industry associated with reduced burden for hazardous waste reporting activities. 
        
                                 Exhibit 5-19 
Baseline and Post-Rule Costs Accruing to Industry for Hazardous Waste Reporting Activities 
                     (2014$, millions of $, annual costs) 
Item 
                                   Activity 
Estimated Cost to Industry 
                  Estimated Incremental Cost (Cost Savings) 


                                   Baseline 
                                  Post-Rule 

                                      1 
Read Hazardous Waste Report instructions 
                                                                         $1.60 
                                                                      $0.00323 
                                                                       ($1.57) 
                                      2 
Revise data systems to include new data items not part of facility's general business operations 
                                                                        $0.136 
                                                                         $0.00 
                                                                      ($0.136) 
                                      3 
Prepare Site ID Form 
                                                                        $0.129 
                                                                      $0.00259 
                                                                      ($0.126) 
                                      4 
Prepare Form GM 
                                                                         $2.26 
                                                                         $0.00 
                                                                       ($2.26) 
                                      5 
Prepare Form WR 
                                                                         $4.69 
                                                                         $4.21 
                                                                      ($0.479) 
                                      6 
Prepare Form OI[a] 
                                                                           N/A 
                                                                           N/A 
                                                                           N/A 
                                      7 
Submit report to the state or EPA Regional Office 
                                                                         $0.93 
                                                                       $0.0189 
                                                                      ($0.915) 
                                      8 
Maintain a copy of each form for three years 
                                                                        $0.659 
                                                                        $0.486 
                                                                      ($0.173) 
                                      9 
                                                                         Total 
                                                                         $10.4 
                                                                         $4.75 
                                                                       ($5.66) 
Totals may not sum due to rounding. 
Baseline sources: Unit costs and activity counts: Supporting Statement for Information Collection Request (ICR) Number 
0976.17 2015 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit 
Application and Modification. January 22, 2015. Labor rates: Supporting Statement for Information Collection Request (ICR) Number 801.20 Requirements for Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System. April 30, 2015. 
Post-rule values based on EPA assumptions regarding burden changes associated with implementation and functioning of the e-Manifest system. a Per the BR ICR, Form OI is a state-optional form that is not expected to be submitted by any entities.  
        
       5.7.2 Hazardous Waste Reporting Costs to States 
        
       Similarly, this RIA also estimates a set of reduction in burden accruing to states, again stemming from a reduced number of activities. Specifically, as only TSDFs will submit information to the e-Manifest system, this RIA estimates that states will conduct relevant activities in support of receiver TSDFs only, rather than TSDFs and generators. Additionally, this RIA assumes that states will enjoy a reduced burden associated with quality assurance checks on received submissions, as only TSDF receivers of hazardous waste will submit WR Forms in the post-rule scenario, as compared to all receivers of hazardous waste assumed to do so per the BR ICR. 
        
       The overall impact of these changes to industry reporting in the post-rule scenario is summarized in Exhibit 5-20 below. Overall, this RIA estimates approximately $3 million in annual cost savings to states associated with reduced burden for hazardous waste reporting activities. 
        
        
                                                                                                                                                                                                  
              waste and 460 total receivers of hazardous waste, hence, approximately 10 percent of the costs (47/460) associated with this item per the BR ICR are removed in the post-rule scenario. 
        
                                 Exhibit 5-20 
Baseline and Post-Rule Costs Accruing to States for Hazardous Waste Reporting Activities 
                     (2014$, millions of $, annual costs) 
Item 
                                   Activity 
                           Estimated Cost to States 
                  Estimated Incremental Cost (Cost Savings) 


Baseline 
                                  Post-Rule 

                                      1 
Distribute Hazardous Waste Report forms and instructions 
                                                                        $0.241 
                                                                      $0.00489 
                                                                      ($0.236) 
                                      2 
Assist respondents 
                                                                        $0.226 
                                                                      $0.00461 
                                                                      ($0.222) 
                                      3 
Key entry of report submissions 
                                                                       $0.0928 
                                                                      $0.00171 
                                                                     ($0.0911) 
                                      4 
Perform quality assurance 
                                                                         $8.18 
                                                                         $6.04 
                                                                       ($2.14) 
                                      5 
                                                                         Total 
                                                                         $8.74 
                                                                         $6.05 
                                                                       ($2.69) 
Totals may not sum due to rounding. 
Baseline Sources: Unit costs and activity counts: Supporting Statement for Information Collection Request 
(ICR) Number 0976.17 2015 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and Modification. January 22, 2015. Labor rates: Supporting 
Statement for Information Collection Request (ICR) Number 801.20 Requirements for Generators, 
Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System. April 30, 2015. 
Post-rule values based on EPA assumptions regarding burden changes associated with implementation and functioning of the e-Manifest system. a Per the BR ICR, Form OI is a state-optional form that is not expected to be submitted by any entities.  
        
       In aggregate, cost savings associated with reduced burden for hazardous waste reporting are estimated at approximately $8 million annually across both states and industry. 
        
       5.8 Summary of Costs and Cost Savings  
        
       This section summarizes the costs and cost savings to EPA, industry, and states as described throughout this chapter. As presented below, costs to EPA detailed in this chapter are assumed by this RIA to be directly offset by manifest fees to industry. These fees, in turn, initially exceed but eventually only partially offset the cost savings accruing to industry associated with less burdensome manifest activities stemming from the use of electronic manifests. 
        
       All costs included in the exhibits below are based on the adoption rate depicted in Section 5.1.3.  
        
       In a few cases, this RIA does not anticipate that certain baseline costs will be affected by the proposed rule. These costs include EPA-specific agency burden for receipt and review of paperwork associated with federal manifest (see Exhibit 4-4, under $1 million annually) and industry costs associated with recordkeeping activities for hazardous waste shipments made under reclamation agreements (see Exhibit 4-2, approximately $3 million annually). 
       Additionally, while the capital costs of obtaining file cabinets may be lessened in the post-rule scenario as manifests are handled electronically and require less physical storage, these costs are assumed to stay constant in the post-rule scenario, an assumption which may slightly understate the cost savings of the proposed rule. 
        
       Exhibit 5-21 presents an overall summary of the baseline, post-rule, and incremental (post-rule less baseline) costs (and cost savings) of the proposed rule. Compared to baseline costs of approximately $224 million, post-rule costs range from $255 million in the first year of system launch to $124 million in the sixth year of system launch. Exhibit 5-22 displays the incremental discounted costs of the rule (using three percent and seven percent discount rates), including the annualized incremental costs of the proposed rule. This RIA estimates approximately $34 million in annualized cost savings under a seven percent discount rate and approximately $41 million in annualized cost savings over this period under a three percent discount rate, though the rule results in overall costs in the first two years and cost savings in the following four years.[,42] 
        
       Note that extending the period of analysis forward in time under the adoption rate assumptions presented in this chapter would increase the cost savings estimate, because the highest cost savings accrue after the system implementation costs have been fully accounted for (in the sixyear period and afterward). Additional years would continue to reveal substantial cost savings rather than net costs. Therefore, the estimate of a $34 million annualized cost savings can be thought of as a low-end estimate for the long-term savings associated with a functioning eManifest system. For example, extending the period of analysis to ten years from system launch, and assuming that net cost savings in Years 7 through 10 are similar to those experienced in Year 6 leads to an annualized cost savings estimate of approximately $49 million instead.
        
        
                                 Exhibit 5-21 
Summary of Costs and Cost Savings of the Proposed Rule and e-Manifest System  
                            (2014$, millions of $) 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                                 Cost Category 
Baseline 
                    Post-Rule (e-Manifest System Launched) 


Annual 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
Year 6 
                         Baseline and Post-Rule Costs 
Costs to EPA 
                                      1 
Receipt/review of federal manifests[a] 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                      2 
e-Manifest system  -  annual payment for setup costs ($45.5M total)[b] 
                                                                         $0.00 
                                                                         $9.11 
                                                                         $9.11 
                                                                         $9.11 
                                                                         $9.11 
                                                                         $9.11 
                                                                         $0.00 
                                      3 
e-Manifest system  -  operations costs[c] 
                                                                         $0.00 
                                                                         $23.3 
                                                                         $23.9 
                                                                         $24.6 
                                                                         $25.6 
                                                                         $25.5 
                                                                         $25.5 
                                      4 
e-Manifest system  -  manifest processing costs[c] 
                                                                         $0.00 
                                                                         $28.1 
                                                                         $23.2 
                                                                         $9.76 
                                                                         $1.08 
                                                                         $1.08 
                                                                         $1.08 
                                      5 
                                                                      Subtotal 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
                                                                        $0.907 
Costs to Industry 
                                      6 
Manifest activities[d] 
                                                                          $189 
                                                                          $183 
                                                                          $161 
                                                                          $129 
                                                                         $85.2 
                                                                         $85.2 
                                                                         $85.2 
                                      7 
CROMERR 
                                                                         $0.00 
$0.0277 
                                                                        $0.123 
                                                                        $0.238 
                                                                        $0.405 
                                                                        $0.318 
                                                                        $0.392 
                                      8 
Manifest fees[e] 
                                                                         $0.00 
                                                                         $60.5 
                                                                         $56.2 
                                                                         $43.5 
                                                                         $35.8 
                                                                         $35.7 
                                                                         $26.6 
                                      9 
Hazardous waste reporting activities 
                                                                         $10.4 
                                                                         $4.75 
                                                                         $4.75 
                                                                         $4.75 
                                                                         $4.75 
                                                                         $4.75 
                                                                         $4.75 
                                      10 
                                                                      Subtotal 
                                                                          $199 
                                                                          $248 
                                                                          $222 
                                                                          $177 
                                                                          $126 
                                                                          $126 
                                                                          $117 
Costs to States 
                                      11 
Manifest receipt and processing[f] 
                                                                         $15.0 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                      12 
Hazardous waste reporting activities 
                                                                         $8.74 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                      13 
                                                                      Subtotal 
                                                                         $23.8 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                                                         $6.05 
                                      14 
                                                                   Total Costs 
                                                                          $224 
                                                                          $255 
                                                                          $229 
                                                                          $184 
                                                                          $133 
                                                                          $133 
                                                                          $124 
           Incremental Costs (Post-Rule Costs Less Baseline Costs) 
                                      15 
                                                      Incremental Costs to EPA 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                                                         $0.00 
                                      16 
                                                 Incremental Costs to Industry 
                                                                         $49.5 
                                                                         $23.4 
                                                                       ($21.8) 
                                                                       ($72.8) 
                                                                       ($72.9) 
                                                                       ($81.9) 
                                      17 
                                                   Incremental Costs to States 
                                                                       ($17.7) 
                                                                       ($17.7) 
                                                                       ($17.7) 
                                                                       ($17.7) 
                                                                       ($17.7) 
                                                                       ($17.7) 
                                      18 
                         Total Incremental Costs (Cost Savings) (undiscounted) 
                                                                         $31.7 
                                                                         $5.71 
($39.5) 
($90.5) 
($90.7) 
($99.6) 
                                      19 
                  Total Incremental Costs (Cost Savings) (3% discount rate)[g] 
                                                                         $28.2 
                                                                         $4.93 
($33.1) 
($73.6) 
($71.6) 
($76.4) 
                                      20 
                  Total Incremental Costs (Cost Savings) (7% discount rate)[g] 
                                                                         $24.2 
                                                                         $4.07 
($26.3) 
($56.4) 
($52.8) 
($54.2) 
[a] This RIA assumes that the proposed rule has no impact on this cost item. For more information on the activities involved, see Exhibit 4-4. [b] The cost for this item is $45.5 million, per Exhibit 5-4, and is incurred by in years prior to e-Manifest system launch. This cost is apportioned into five equivalent payments of $9.11 million to evidence how the fee will be applied to industry to recoup this cost. Note that the entirety of this cost is offset by fees, and it is not included in the total row. c The entirety of this cost is offset by fees, and it is not included in the total row. [d] Includes costs for federal and state manifests, capital costs to store manifests, and reclamation agreement-specific recordkeeping activities. This RIA assumes that the proposed rule has no impact on capital costs associated with storing manifests in file cabinets and recordkeeping activities for shipments under reclamation agreements; the difference between ba seline and post-rule costs results from the difference in the burden associated with manifest activities for federal and state manifests only. 
 Amount equivalent to the total fee accrued in a given year, as shown in Rows 2 through 4. 
 This RIA assumes that states do not undertake any manifest receipt and processing activities in the post-rule scenario, as the necessary data would be accessible through the e-Manifest system to states at no charge.  [g] Figures discounted back to 2014$. That is, the value in Column C is discounted by four years (2018  -  2014), the value in Column D is discounted by five years, and so on. 
                                 Exhibit 5-22 
Summary of Costs and Cost Savings of the Proposed Rule and e-Manifest System, Discounted and Annualized  
                            (2014$, millions of $) 
 Item 
                                      A 
                                      B 
                                      C 
                                      D 
 	 E  
                                       F 
                                      G 
                                      H 
                                      I 

 e-Manifest System Year 
 Year 1 
 Year 2 
 Year 3 
 Year 4 
 Year 5 
 Year 6 
                                    Total 
                             (Years 1 through 6) 
                                  Annualized 
                Incremental Cost (Cost Savings) (Years 1 - 6) 

                                Calendar Year 
                                     2018 
                                     2019 
                                     2020 
                                     2021 
                                     2022 
                                     2023 


                                      1 
 Incremental 
 Costs (Cost 
 Savings)  -  
 Undiscounted 
 EPA 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                      2 

 Industry 
                                                                        $49.5  
                                                                         $23.4 
 ($21.8)
 ($72.8)
 ($72.9)
 ($81.9)
                                                                        ($176) 
                                                                       ($29.4) 
                                      3 

 States 
 ($17.7)
 ($17.7)
 ($17.7) 
 ($17.7) 
 ($17.7) 
 ($17.7) 
                                                                        ($106) 
                                                                       ($17.7) 
                                      4 

                                                                         Total 
                                                                       $31.7   
                                                                       $5.71   
 ($39.5) 
 ($90.5) 
 ($90.7) 
 ($99.6) 
                                                                        ($283) 
                                                                       ($47.1) 
                                      5 
                                                      Discounted Total (3%)[a] 
                                                                        $28.2  
                                                                        $4.93  
 ($33.1) 
 ($73.6) 
 ($71.6) 
 ($76.4) 
                                                                        ($221) 
                                                                    ($40.9)[c] 
                                      6 
                                                      Discounted Total (7%)[a] 
                                                                        $24.2  
                                                                        $4.07  
 ($26.3) 
 ($56.4) 
 ($52.8) 
 ($54.2) 
                                                                        ($161) 
                                                                    ($33.8)[b] 
Totals may not sum due to rounding. 	 	 	 	 
 [a] Figures discounted back to 2014$. That is, the value in Row 1 is discounted by four years (2018  -  2014), the value in Row 2 is discounted by five years, and so on. 
 	 
       5.9 Unquantified Benefits of the e-Manifest System  
        
       EPA expects that electronic manifests will enhance many stakeholders' abilities to track and extract data on waste shipments by storing and distributing this data in a central, accessible location. EPA has identified seven stakeholder groups that may benefit from better access to manifest shipping data: 
        
        Members of industry that use the manifest for tracking waste shipments; 
        Federal and state government RCRA enforcement officials; 
        Emergency responders; 
        Foreign governments; 
        Research institutions;  
 Communities near RCRA-regulated facilities; and 
        Other federal agencies 
        
       This RIA does not attempt to quantify the value of this benefit. 
        
       5.10 Caveats: Other Parameters not Considered in this Analysis  
        
       This RIA acknowledges, but does not incorporate into its estimation of the proposed rule's economic impacts, a set of additional considerations, as described below. 
        
        Penalties. Under the proposed rule, EPA will also apply costs, in the form of penalties, to hazardous waste industry entities that burden the non-electronic manifest processing functions of the e-Manifest system by mailing non-manifest documents. If, for example, a regulated entity opts to mail facility permit or other information required for separate submission to EPA's e-Manifest center, EPA will incur costs to receive, open, review, and return this information to the sender. EPA therefore expects to apply a penalty to such actions.  
              
        Alteration of the fee. The regulatory framework surrounding the e-Manifest system, including this proposed rule, allows for alteration of the manifest fees applied to industry in order to prevent over-recovery or under-recovery of the system's setup and operation costs beyond a certain amount. This RIA, functioning under assumptions of certainty in the adoption rate and thus achievable full cost recovery, does not model potential alterations in the fee, though the costs associated with this process are included in EPA's costs. However, to the extent that the actual adoption rate differs from EPA's assumed adoption rate, or to the extent that EPA's system development and operations costs, including non-electronic manifest processing costs, differ from EPA's a priori estimates of these parameters, the fee may need to be altered to prevent under- or over-recovery. In these cases, fees can again be reestablished for full cost recovery using the guidelines and calculations set out in this chapter, though they may also need to be adjusted upward or downward to account for under- or over-collection that has accrued to date. EPA's burden associated with tracking the total amount collected through fees and considering alterations to the fee, including potentially calculating new fee levels, is covered under the "additional program costs" category in Section 5.2.7. 
              
        Enforcement actions due to non-payment of fees. This RIA does not consider the costs of payment collection or other enforcement actions for TSDFs that do not provide payment of fees in a timely manner. This is considered to be an area of non-compliance outside the purview of this RIA, which considers costs and benefits under full compliance with the proposed rule. However, given that payment will be directly requested only from the small universe of receiver TSDFs, this is considered to be a relatively unlikely outcome, as these TSDFs interact with EPA and other regulatory agencies on a regular basis. 

                                   Chapter 6 
          Sensitivity Analyses of Proposed Rule Costs and Cost Savings 
 
Certain aspects of EPA's compliance cost estimates are characterized by significant uncertainty and are sufficiently large that deviations from chosen assumptions may have a measurable impact on cost estimates. In this section, the analysis evaluates the sensitivity of certain results to variation in key parameters. These sensitivity analyses include evaluations of: 
 
        Number of manifests. The analysis evaluates the effect of assuming increased hazardous waste shipping frequencies and consequently more manifests in the system. 
       
        Adoption rate. Because cost savings result from adoption of electronic manifests, adoption patterns drive the magnitude of cost and cost savings.  
 
        Materials costs. The analysis characterizes cost impacts on a more detailed level, specifically assuming that materials costs will be eliminated for manifests generated and submitted electronically. 
 
        CROMERR. Chapter 5 of this RIA assumes that CROMERR applies only to TSDFs and transporters. If CROMERR applied to generators, a large number of additional facilities would incur costs related to this aspect of electronic manifest submission. 
 
        Payback period. Because of the statutory requirement for the manifest fee to recover EPA's costs, the period over which these costs are recovered impacts the level of the fee, and in turn, industry costs. 
 
6.1 Number of Manifests 
 
In Chapter 3, the current number of manifests used in the main analysis assumes that LQG and TSDF shippers operate under a weekly pickup schedule and that SQGs and state hazardous waste generators operate under a monthly pickup schedule. That is, this RIA assumes that a minimum of one truck arrives weekly to haul away hazardous waste from LQGs and TSDF shippers, and a minimum of one truck arrives monthly to haul away hazardous waste from SQGs and state hazardous waste generators. This assumption underpins EPA's primary estimate of 3.2 million manifests annually. However, other methods and assumptions for estimating manifests yield different numbers, and can have important impacts on total costs and cost savings.  
 
While a number of different parameters drive the numbers of manifests, to evaluate the impact of the number of manifests on cost and cost savings, this RIA considers alternative assumptions regarding minimum shipment frequency for LQGs/TSDF shippers and SQGs/state waste shippers. The manifest count is especially sensitive to the minimum shipment frequency of SQGs and state waste shippers because of the large number of these entities relative to LQGs and TSDF shippers. For example, assuming that every shipper has waste collected at least weekly changes the total estimate from 3.2 million manifests to 10.6 million manifests annually. This jump is driven largely by an increase in state waste manifests from 1.8 million to 7.7 million, as changing the assumption from monthly to weekly increases the number of shipments and manifests fourfold. 
 
                                 Exhibit 6-1 
       Estimate of Number of Manifests By Shipping Frequency Assumption 
           Minimum Shipment Frequency Number of Manifests (millions) 
                       LQGs and TSDF Shipper Frequency 

                                    Weekly 
                                   Monthly 
                                  Quarterly 
                        SQGs and State Waste Shippers 
                                    Weekly 
                                                                          10.6 
                                                                          9.92 
                                                                          9.79 

                                   Monthly 
                                                                          3.23 
                                                                          2.58 
                                                                          2.46 

                                  Quarterly 
                                                                          1.76 
                                                                          1.12 
                                                                         0.990 
Note: Blue highlighted value reflects the primary estimate used in this RIA. 
 
As shown in Exhibit 6-1, estimated total annual manifests range from: 
 
        1.0 million to 1.8 million, assuming that SQGs and state waste shippers ship at least quarterly, 
        2.5 million to 3.2 million, assuming that SQGs and state waste shippers ship at least monthly, and 
        9.8 million to 10.6 million, assuming that SQGs and state waste shippers ship at least weekly.  
 
As shown in Exhibit 6-2, cost savings increase with the number of manifests, as burden reductions to industry and states scale up proportionally. Under low shipping frequency assumptions and fewer manifests, e-Manifest system costs (which are fixed costs that do not vary by number of manifests) can outweigh per-manifest burden reductions, leading to positive net costs over the six year period. Over a longer timeframe, net cost savings may still be achieved as cost savings continue to accrue, assuming that no further system development costs are incurred. Given all other current assumptions, the proposed rule would result in net cost savings after approximately eight years. 
 
                                 Exhibit 6-2 
Total Incremental Costs (Savings) of the Proposed Rule by Shipping Frequency Assumptions 
                   (2014$, millions of $, 7% discount rate) 
                          Minimum Shipment Frequency 
                    Annualized Costs (Cost Savings) at 7% 
                           Discount Rate, Years 1-6 
                            LQGs and TSDF Shippers 

                                    Weekly 
                                   Monthly 
                                  Quarterly 
                        SQGs and State Waste Shippers 
                                    Weekly 
                                                                        ($147) 
                                                                        ($133) 
                                                                        ($130) 

                                   Monthly 
                                                                       ($33.8) 
                                                                       ($22.4) 
                                                                       ($20.0) 

                                  Quarterly 
                                                                       ($10.4) 
                                                                        $0.336 
                                                                         $2.54 
Note: Blue highlighted value reflects the primary estimate used in this RIA. Red highlighted value shows assumptions not resulting in overall cost savings over the Year 1 through 6 period. 
 
6.2 Adoption Rate of the e-Manifest System 
 
The switch from paper to electronic manifests drives cost savings under this proposed rule. 
Therefore, e-Manifest adoption patterns drive the overall magnitude of cost and cost savings. This assumption generally encompasses additional unknown factors (e.g., the cost of switching to electronic submission, the influence of key market actors, etc.) and exhibits significant uncertainty. 
To analyze the sensitivity of cost and cost savings to adoption rates, EPA considered a scenario with low adoption rates for the e-Manifest system, shown in Exhibit 6-3. These adoption patterns are based on several pessimistic assumptions: 
 
        Lack of information, unwillingness to change systems, and/or costs associated with the adoption and use of electronic manifest systems result in an e-Manifest adoption rate that is half what the primary analysis assumes. 
        Entities using capable of using XML submission in the baseline through internal electronic systems do not transition to fully electronic manifests. 
        The rate at which entities transition from paper submission to scanned image submission rate is half that which the primary analysis assumes, and no entities transition from paper to XML submission.  
        EPA fee adjustments to incentivize e-Manifest adoption do not increase e-Manifest adoption. In other words, even if implemented as described in the Proposed Option, EPA's fee adjustment to highly differentiated fees does not impact the total fee revenue recovered, but places additional cost burdens on paper manifest users. 
 
                                 Exhibit 6-3 
Alternate Adoption Rates of Manifest Creation and Submission Systems  -  Tabular Summary 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 

                               Manifest Variant 
                    Baseline (Year 0, pre- implementation) 
  Year 1 
                                    Year 2 
                                    Year 3 
Year 4 
Year 5 
                                    Year 6 
                                      1 
Paper 
Manifest 
Process 
Paper submission 
                                    60.00% 
55.125% 
38.125% 
26.875% 
11.25% 
11.25% 
11.25% 
                                      2 

Scanned image submission 
                                    0.00% 
                                    2.375% 
 9.375% 
5.625% 
 1.25% 
1.25% 
                                    1.25% 
                                      3 

XML schema submission 
                                   0.00%[a] 
                                    40.00% 
 40.00% 
40.00% 
40.00% 
40.00% 
40.00% 
                                      4 
e-Manifest System Process (electronic manifest) 
                                     N/A 
                                    2.50% 
 12.50% 
27.50% 
47.50% 
47.50% 
47.50% 
a As indicated in Section 4.1.3 and Exhibit 5-1, this RIA assumes complete use of paper manifests in the baseline. However, responses to EPA's 2014 survey of TSDFs and EPA's conversations with an industry trade group suggest that approximately 40 percent of hazardous waste generators and receiver TSDFs may already have and use electronic and/or proprietary systems to internally manage manifest-related workflow or data, and are capable of submitting manifests in the XML schema format. These entities are modeled as submitting XML variant manifests once they are allowed to do so following implementation of the proposed rule. 
 
With these lower adoption rates, annualized cost savings over six years fall from $34 million to $5 million, an 85 percent reduction in cost savings (Exhibit 6-4). Industry does not experience net cost savings in the first six years. Given all other current assumptions, the proposed rule would result in net cost savings after approximately nine years (undiscounted) or 10 years (discounted at a seven percent rate) in this scenario. However, this low-adoption scenario still results in net cost savings across the economy after five years, largely driven by burden reduction to states.  
 
                                 Exhibit 6-4 
Summary of Costs and Cost Savings of the Proposed Rule under Alternate (Lower) Adoption Rate, Discounted and Annualized 
                            (2014$, millions of $) 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 
                                      I 

                                   Category 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
Year 6 
                                    Total 
                             (Years 1 through 6) 
                                  Annualized 
Incremental Cost 
                                (Years 1 - 6) 
                                      1 
Calendar Year 
                                     2018 
                                     2019 
                                     2020 
                                     2021 
                                     2022 
                                     2023 
                                     N/A 
                                     N/A 
                                      2 
                                 Incremental 
                                 Costs (Cost 
                           Savings) - Undiscounted 
EPA 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                     N/A 
                                      3 

Industry 
                                                                        $52.8  
                                                                        $36.3  
                                                                         $14.4 
($14.9) 
($15.0) 
($24.0) 
                                                                        $49.6  
                                     N/A 
                                      4 

States 
($17.7) 
($17.7) 
($17.7) 
($17.7) 
($17.7) 
($17.7) 
                                                                        ($106) 
                                     N/A 
                                      5 

                                    Total 
                                                                        $35.1  
                                                                        $18.6  
($3.32) 
($32.6) 
($32.7) 
($41.7) 
                                                                       ($56.8) 
                                     N/A 
                                      7 
Costs (Cost Savings) 7% Discount Rate 
                                                                        $26.7  
                                                                        $13.2  
($2.22) 
($20.3) 
($19.1) 
($22.7) 
                                                                       ($24.3) 
                                                                    ($5.10)[c] 
Totals may not sum due to rounding. Adoption rates corresponding to above estimates based on those portrayed in Exhibit 6-3. 
[a] Figures discounted back to 2014$. That is, the value in Row 1 is discounted by four years (2018  -  2014), the value in Row 2 is discounted by five years, and so on. [c] Calculated as the annual payment that would need to be made, cognizant of discounting, to reach a total value of $24.6 million after six years. If the period were extended to ten years (i.e., the total period over which e-Manifest system costs are incurred, including pre-launch setup costs, plus the six-year period analyzed here), the annualized cost savings would be approximately $3.46 million instead.  
 
As noted in Section 5.4.3, this RIA assumes that the e-Manifest system implemented under the proposed rule will not require any significant investment in either hardware or software by firms or facilities in the hazardous waste industry. To the extent that this is not the case, this sensitivity analysis considers the scenario in which investment costs faced by industry entities to adopt electronic manifests deter widespread adoption of the e-Manifest system. As shown in Exhibit 64, even under the assumption that ultimate adoption of electronic manifests is only half of what this RIA assumes in the primary analysis (Chapter 5), the proposed rule results in net cost savings over the six-year period following system launch and in perpetuity thereafter. 
 
6.3 Materials Costs 
 
The primary analysis estimates e-Manifest labor and materials cost savings by assuming that certain activities experience either an 80 percent burden reduction or five percent burden reduction. Because no data sources provide more detailed information about burden reductions, these values are used to approximate "major reductions" and "minimal reductions," respectively. These reductions do not distinguish between materials costs and labor costs.  
 
However, EPA expects that many materials costs (e.g., postage, filing cabinets, etc.) may be completely eliminated by electronic manifests. To assess the impact that this set of assumptions has on net costs and cost savings, EPA considered the effect of: 
 
        Removing all materials costs in the post-rule period, 
        Removing just materials costs associated with major reductions in the main analysis, and 
        Removing just materials costs associated with major reductions in the main analysis but assuming all minor reductions do not enjoy any reduction in materials costs. 
 
Overall materials costs (not including capital costs for file cabinets) are a small portion of overall baseline costs, totaling approximately $2 million in the baseline, compared to overall baseline costs of approximately $189 million (approximately one percent). Thus, the effects of alternative assumptions do not change net costs or cost savings to a large extent. Sensitivity analyses regarding materials costs find that: 
 
        Removing all materials costs in the post-rule scenario increases annualized cost savings by approximately $1.5 million (less than five percent). 
        Removing only those materials costs associated with major reductions increases cost savings by just approximately $0.3 million (less than one percent), on an annualized basis. 
        Removing materials costs associated with major reductions and assigning full materials costs to activities with minor reductions increases cost savings by approximately $0.2 million (less than one percent). 
 
Materials costs are a very small component of overall costs associated with manifest activities. Altering how these costs are handled by the RIA in terms of the cost reduction calculations does not substantially impact the cost savings estimated by this RIA. 
 
6.4 CROMERR 
 
The required CROMERR registration and associated activities represent a cost to both EPA and industry that is associated with the e-Manifest system. In the main analysis, CROMERR requirements apply only to TSDFs and transporters and do not apply to generators that ship waste off-site, the largest population in the affected universe.  
 
This RIA considers the impact of assuming that all entities in the affected universe, including generators shipping hazardous waste off-site, are be subject to CROMERR requirements upon adopting use of the e-Manifest system (i.e., use of electronic manifests). This increases the number of entities subject to CROMERR, and corresponding costs, by a factor of approximately 45 (Exhibit 6-5). For the purpose of this sensitivity analysis, all generators are assumed to have five employees that must register for CROMERR, similar to receiver TSDFs in the primary analysis. Unit costs are unchanged. 
 
The expansion of the types of entities facing CROMERR requirements has a two-fold effect:  
 
       Increase in costs to industry directly from more CROMERR registrations; and 
       Increase in costs to industry because of higher manifest fees to recover additional EPA CROMERR-related costs. 
       

                                          Exhibit 6-5 
                          CROMERR Costs, By Assumption of Applicable Entities  
                          (2014$, millions of $, undiscounted) 



Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 
                                      I 

                                   Analysis 
                                     Cost 
                                    Year 1 
 Year 2 
 Year 3 
 Year 4 
 Year 5 
 Year 6 
                                    Total 
                                      1 
Primary Analysis 
(CROMERR for Receivers and Transporters only) 
EPA 
$0.0221 
$0.0994 
                                    $0.196 
                                    $0.329 
                                    $0.264 
                                    $0.305 
                                                                         $1.22 
                                      2 

Industry 
$0.0277 
                                    $0.123 
                                    $0.238 
                                    $0.405 
                                    $0.318 
                                    $0.392 
                                                                         $1.50 
                                      3 

                                                                         Total 
                                                                       $0.0498 
                                                                        $0.223 
                                                                        $0.434 
                                                                        $0.735 
                                                                        $0.582 
                                                                        $0.697 
                                                                         $2.72 
                                      4 
Sensitivity Analysis 
(CROMERR for Receivers, 
Transporters, and Generators) 
EPA 
                                    $1.00 
                                    $4.51 
                                    $8.84 
                                    $14.9 
                                    $11.9 
                                    $13.7 
                                                                         $54.8 
                                      5 

Industry 
                                    $1.27 
                                    $5.65 
                                    $10.9 
                                    $18.5 
                                    $14.5 
                                    $17.9 
                                                                         $68.7 
                                      6 

                                                                         Total 
                                                                         $2.28 
                                                                         $10.2 
                                                                         $19.7 
                                                                         $33.4 
                                                                         $26.3 
                                                                         $31.7 
                                                                          $123 
 
As shown in Exhibit 6-6 below, overall undiscounted costs increase by approximately $120 million over six years as a result of this change in assumptions. The overall impact is approximately a 50 percent reduction in annualized cost savings. However, the proposed rule remains a net cost-saving rule, as electronic manifest adoption results in burden reductions that outweigh CROMERR costs. For example, in Year 4, CROMERR costs in this analysis increase by $33 million over the primary analysis, but manifest activity-related cost savings are over $100 million in that year (per Exhibit 5-21, where Year 4 manifest activity costs to industry are approximately $85 million relative to baseline costs of $189 million). CROMERR costs are the highest in the later years, when electronic adoption is the highest. 
 	 
                                 Exhibit 6-6 
Summary of Costs and Cost Savings of the Proposed Rule and e-Manifest System if CROMERR required for Receivers, 
                     Transporters, and Generators, Discounted and Annualized  (2014$, millions of $) 
Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 
                                      H 
                                      I 

                                   Category 
Year 1 
Year 2 
Year 3 
Year 4 
Year 5 
                                    Year 6 
                                    Total 
                             (Years 1 through 6) 
                                  Annualized 
Incremental Cost 
                                (Years 1 - 6) 
                                      1 
Calendar Year 
                                     2018 
                                     2019 
                                     2020 
                                     2021 
                                     2022 
                                     2023 
                                                                           N/A 
                                     N/A 
                                      2 
Incremental 
Costs (Cost 
Savings) - 
Undiscounted 
EPA 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                Offset by fee 
                                     N/A 
                                      3 

Industry 
                                                                        $51.9  
                                                                        $34.2  
($0.78) 
($37.2) 
($44.9) 
                                                                       ($48.3) 
                                                                       ($45.1) 
                                     N/A 
                                      4 

States 
($17.7) 
($17.7) 
($17.7) 
($17.7) 
($17.7) 
                                                                       ($17.7) 
                                                                        ($106) 
                                     N/A 
                                      5 

Total 
                                                                        $34.2  
                                                                        $16.5  
($18.5) 
($55.0) 
($62.6) 
                                                                       ($66.1) 
                                                                        ($151) 
                                     N/A 
                                      6 
Costs (Cost Savings)  7% discount rate[a] 
                                                                        $26.1  
                                                                        $11.8  
($12.3) 
($34.2) 
($36.5) 
                                                                       ($35.9) 
                                                                       ($81.1) 
                                                                    ($17.0)[c] 
                                      7 
Costs (Cost Savings)  -  Primary Analysis  
7% discount rate[b] 
                                                                        $24.2  
                                                                        $4.07  
($26.3) 
($56.4) 
($52.8) 
                                                                       ($54.2) 
                                                                        ($161) 
                                                                       ($33.8) 
Totals may not sum due to rounding. [a] Figures discounted back to 2014$. That is, the value in Row 1 is discounted by four years (2018  -  2014), the value in Row 2 is discounted by five years, and so on. [b] Assumes that CROMERR is not required for generators. Figures in this column are consistent with those in Exhibit 5-22. c Calculated as the annual payment that would need to be made, cognizant of discounting, to reach a total value of $81.7 million after six years. If the period were extended to ten years (i.e., the total period over which e-Manifest system costs are incurred, including pre-launch setup costs, plus the six-year period analyzed here), the annualized cost savings would be approximately $11.5 million instead.  
 
6.5 Payback Period 
    
EPA charges manifest fees to fulfill the statutory requirement to recover all costs incurred from developing and operating the e-Manifest system. The payback period over which these costs are recovered affects the level of the fees levied on industry. A longer payback period means lower fees as costs are spread over a longer time period and more manifests, while a shorter payback period means higher manifest fees. The main analysis assumes a payback period of five years. However, short payback periods can substantially increase the fee. Exhibit 5-14, reproduced as Exhibit 6-7 below, and Exhibit 6-8 illustrate the increase in manifest fees when the payback period is reduced from five years (Exhibit 6-7) to two years (Exhibit 6-8). The payback period does not impact the overall fee revenue and industry cost burden over the six year period if discounting is not considered. Rather, it redistributes the costs accruing to industry in the form of manifest fees over time. Shorter payback periods increase net annualized costs by increasing costs during early years, when costs face less discounting. 
 	 

                                            Exhibit 6-7 
                Fee Option 2 (Marginal Cost Fee)  -  Payback Period = 5 years  
                                       (2014$, undiscounted) 


Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 

                               Manifest Variant 
                                    Year 1 
                                    Year 2 
                                    Year 3 
                                    Year 4 
                                    Year 5 
                                    Year 6 
                                      1 
Paper 
Manifest 
Variants 
Paper Variant 
                                                                       $24.03  
                                                                       $24.18  
                                                                       $24.41  
                                                                       $24.72  
                                                                       $24.69  
                                                                       $21.89  
                                      2 

Image Variant 
                                                                       $17.86  
                                                                       $18.01  
                                                                       $18.24  
                                                                       $18.55  
                                                                       $18.52  
                                                                       $15.72  
                                      3 

XML Variant 
                                                                       $12.59  
                                                                       $12.74  
                                                                       $12.97  
                                                                       $13.28  
                                                                       $13.25  
                                                                       $10.45  
                                      4 
e-Manifest 
Electronic Variant 
                                                                       $10.05  
                                                                       $10.21  
                                                                       $10.43  
                                                                       $10.74  
                                                                       $10.72  
                                                                        $7.91  

                                             
                                                                               
                                             


 

                                       Exhibit 6-8 
                Fee Option 2 (Marginal Cost Fee)  -  Payback Period = 2 years  
                                  (2014$, undiscounted) 


Item 
                                      A 
                                      B 
                                      C 
                                      D 
                                      E 
                                      F 
                                      G 

                               Manifest Variant 
                                    Year 1 
                                    Year 2 
                                    Year 3 
                                    Year 4 
                                    Year 5 
                                    Year 6 
                                      1 
Paper 
Manifest 
Variants 
Paper Variant 
                                                                       $28.26  
                                                                       $28.41  
                                                                       $21.59  
                                                                       $21.90  
                                                                       $21.87  
                                                                       $21.89  
                                      2 

Image Variant 
                                                                       $22.09  
                                                                       $22.24  
                                                                       $15.42  
                                                                       $15.73  
                                                                       $15.70  
                                                                       $15.72  
                                      3 

XML Variant 
                                                                       $16.82  
                                                                       $16.97  
                                                                       $10.15  
                                                                       $10.46  
                                                                       $10.43  
                                                                       $10.45  
                                      4 
e-Manifest 
Electronic Variant 
                                                                       $14.82  
                                                                       $14.44  
                                                                        $7.61  
                                                                        $7.92  
                                                                        $7.90  
                                                                        $7.91  
 
Under a seven percent discount rate, the payback period does not have a very substantial impact on overall cost or cost savings. For example, changing the payback period to a requirement that all setup costs be repaid in the first year decreases the annualized cost savings by less than $1 million over a six-year period.  
 
However, shorter payback periods would result in higher fees to industry in early years, which may potentially affect industry behavior. Higher fees would occur in years that industry may also be incurring other voluntary costs to upgrade systems in order to better use electronic manifests. Under a one-year payback "period," Year 1 manifest fees under Option 2 are $35.31 for paper, $29.14 for image, $23.87 for XML, and $21.33 for electronic manifests. This represents a 47 percent to 111 percent increase in fees, depending on the manifest type, over the primary analysis. At this time, EPA does not have enough information to determine system-wide implications from shorter payback periods, and higher fees. 

 	 
                                   Chapter 7 
                                          Supplemental Analyses 
 
As required by applicable statutes and Executive Orders, this chapter summarizes EPA's analysis of equity considerations and other regulatory concerns associated with the proposed rule. This chapter assesses potential impacts, with respect to the following issues:  
 
           Regulatory planning and review: requires examination and quantification of costs and benefits of regulating with and without the proposed rule; 
           Regulatory flexibility: focuses on the potential effects of the proposed rule on small entities;  
           Employment impacts: assesses the potential impact of the proposed rule on employment;  
           Unfunded mandates: examines the implications of the proposed rule with respect to unfunded mandates;  
           Federalism: considers potential issues related to state sovereignty;  
           Tribal governments: extends the discussion of federal unfunded mandates to include impacts on Native American tribal governments and their communities;  
           Environmental justice: considers potential issues for minority and low-income populations;  
           Children's health protection: examines the potential impact of the proposed rule on the health of children; and 
           Energy Impacts: examines the impacts of the proposed rule on energy use, supply, and distribution. 
           
7.1  	Regulatory Planning and Review 
 
Under Executive Order 12866 [58 FR 51735 (October 4, 1993)], as amended by Executive Order 13563, the Agency, in conjunction with the Office of Management and Budget's (OMB's) Office of Information and Regulatory Affairs (OIRA), must determine whether a regulatory action is "significant" and therefore subject to OMB review and the full requirements of the Executive Order. Executive Order 12866 defines "significant regulatory action" as one that is likely to result in a rule that may:  
 
       Have an annual effect on the economy of $100 million or more or adversely affect in a material way the economy, a sector of the economy, productivity, competition, jobs, the environment, public health or safety, or State, local, or tribal governments or communities; 
  
       Create a serious inconsistency or otherwise interfere with an action taken or planned by another agency;  
 
       Materially alter the budgetary impact of entitlements, grants, user fees, or loan programs or the rights and obligations of recipients thereof; or  
 
       Raise novel legal or policy issues arising out of legal mandates, the President's priorities, or the principles set forth in the Executive Order.  
 
This RIA estimates the potential costs and benefits associated with e-Manifest, described in Chapter 5. This rule is not expected to result in more than $31.7 million in incremental costs across the economy in any given year and results in net cost savings in most years. Manifest fees to industry do not exceed $60.5 million in any year, and are, even in early years with lower adoption rates, at least partially offset by industry and state government cost savings. The cost savings estimated for Year 6, prior to discounting, equal $99.6 million. However, with discounting at a seven percent discount rate, the cost savings for Year 6 are $54.2 million, and the annualized impact of this rule over the adoption period (discounted at seven percent) is $34 million. As a result, this RIA concludes that the e-Manifest system is not an economically significant regulatory action, though it may still be deemed significant due to the novel legal and policy issues it raises. 
 
7.2  	Regulatory Flexibility 
 
The Regulatory Flexibility Act (RFA) as amended by the Small Business Regulatory 
Enforcement Fairness Act of 1996 (SBREFA), 5 USC 601 et seq., generally requires an agency to prepare a regulatory flexibility analysis of any rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or any other statute. This analysis must be completed unless the agency certifies that the rule will not have a significant economic impact on a substantial number of small entities. Small entities include small businesses, small organizations, and small governmental jurisdictions. For this analysis, the proposed rule is not expected to result in a "significant economic impact for a substantial number of small entities" (SISNOSE) if the costs of the regulation per entity do not exceed one percent or three percent of annual revenues for 20 percent of small entities across sectors, or 100 small entities in the affected universe. 
 
This section first discusses the likely impacts of the proposed rule on small entities based on the costs and cost savings estimated in Chapter 5. The section then considers a "worst case" scenario in which small entities continue to use paper manifests and do not pass through any fee-related costs to their customers (generators and transporters). This section finds that the proposed rule will not result in SISNOSE. 
 
7.2.1 Small Entity Impacts based on Costs and Costs Savings Estimates in the Main Analysis 
 
This RIA finds that the proposed rule will not have a significant economic impact on a substantial number of small entities under the RFA. In making this determination, the impact of concern is any significant adverse economic impact on small entities. An agency may certify that a rule will not have a significant economic impact on a substantial number of small entities if the rule relieves regulatory burden, has no net burden or otherwise has a positive economic effect on the small entities subject to the rule. As described in Chapter 5, this RIA estimates that industry time and material burden associated with manifest completion tasks will decrease under the eManifest system. Given adoption rate assumptions over a six-year period, undiscounted net cost savings to industry, accounting for burden reductions in manifest activities as well as cost increases due to manifest fees and CROMERR requirements, total approximately $140 million. On an annualized basis over the same six-year period, undiscounted, incremental cost savings are approximately $24 million. Approximately $76 million in annual savings to industry occurs in perpetuity assuming 95 percent adoption of electronic manifests. Additionally, industry experiences approximately $5.7 million annually in cost savings from reduced hazardous waste reporting activities. This RIA concludes that this action will likely relieve regulatory burden for all directly-regulated small entities. 
 
7.2.2 Distribution of Small Entities Affected 
 
This RIA finds that directly affected entities, both small and non-small, will largely adopt electronic manifests and realize cost savings. Consequently, the proposed rule will not result in SISNOSE. This conclusion is reflected in the adoption rates presented in Section 5.1.3, and is based on consultation with industry representatives. As described in Chapter 1, EPA also intends to adjust the manifest fee structure to incentivize adoption of electronic manifests if necessary. 
 
To the extent that entities do not adopt electronic manifests, however, they may face incremental manifest fees. The small entities potentially affected by the rule are TSDFs who will be required to pay manifest fees. The rule does not impose any direct costs on other industrial entities that elect not to use the e-Manifest system.  
 
The remainder of this section provides information about potentially affected small entities, and examines whether the number of small entities potentially affected by any price increase (however unlikely) would be sufficient even in a worst case scenario to be "substantial." To develop this section, EPA: 
 
       Identified affected entities and industries (Section 7.2.2.1). As described in Chapter 5, EPA expects to levy manifest fees on TSDFs only. Firms only face net incremental costs by continuing to submit paper manifests.  
 
 Estimated the number of entities that are small (Section 7.2.2.2). To identify the number of small entities in the potentially affected universe, this analysis relies on Dun & Bradstreet, Hoover's, and other publicly available data to link TSDF facilities listed in EPA's RCRAInfo database to their corporate ownership. Although small business size standards are specified for individual 6-digit NAICS codes, company-level financial or employment data were not available for most companies. Further, TSDFs do not predominantly fall under any single industry. Therefore, this analysis classifies major TSDF companies, publicly-traded companies, and multinational corporations as "nonsmall" entities. All other entities are considered "potentially small," and it is these entities 
            that are evaluated. The small entities examined in this section are potentially small TSDFs that use paper manifests and pay manifest fees. At most, 74 potentially small entities may be impacted. These entities are spread across 42 sectors with at most 15 potentially small entities in a single sector (NAICS 562211  -  Hazardous Waste Treatment and Disposal). 
 
 
7.2.2.1 Sectors with Potentially Affected Entities 
 
This section identifies the industries (as defined by 6-digit NAICS codes) that contain potentially small businesses. The identification process uses a list of 392 facilities identified in the RCRA Biennial Report that reported receiving waste from off-site in 2011 and were not owned by government entities (federal or state). Using corporate ownership data from Dun & Bradstreet (D&B), these 392 facilities were matched to 183 ultimate corporate entities (i.e., 25 companies owned multiple facilities, and 160 companies owned only one TSDF each).  
 
Exhibit 7-1 shows the range of industries that contain three or more TSDFs and the relevant small business size standard for each industry.[,] Many TSDFs are associated with parent companies operating in industries other than the primary industry identified for the TSDF. Based on the establishment-specific six-digit NAICS classification from D&B, 85 industries are represented, with 14 percent of facilities in NAICS 562211 (Hazardous Waste Treatment and Disposal) and 23 percent of facilities in the broader industry of NAICS 5622 (Waste Treatment and Disposal). Twenty-seven industries have only one TSDF each, and 15 industries have only two TSDFs each. 
 
                                 Exhibit 7-1 
Industries with Three or More Facilities Affected by the Proposed Rule and SBA Size Standards 
NAICS Code 
                              NAICS Description 
                         Small Business Size Standard 


                                   Revenue  
                                 ($ Millions) 
                                  Employees 
                                    213112 
Support Activities for Oil and Gas Operations 
                                     38.5 
                                        
                                    221118 
Other Electric Power Generation 
                                        
                                     250 
                                    238990 
All Other Specialty Trade Contractors 
                                      15 
                                        
                                    324191 
Petroleum Lubricating Oil and Grease Manufacturing 
                                        
                                     750 
                                    325110 
Petrochemical Manufacturing 
                                        
                                    1,000 

                                 Exhibit 7-1 
Industries with Three or More Facilities Affected by the Proposed Rule and SBA Size Standards 
NAICS Code 
                              NAICS Description 
                         Small Business Size Standard 


                                   Revenue  
                                 ($ Millions) 
                                  Employees 
                                    325180 
Other Basic Inorganic Chemical Manufacturing 
                                        
                                    1,000 
                                    325199 
All Other Basic Organic Chemical Manufacturing   
                                        
                                    1,250 
                                    325211 
Plastics Material and Resin Manufacturing 
                                        
                                    1,250 
                                    325212 
Synthetic Rubber Manufacturing 
                                        
                                    1,000 
                                    325320 
Pesticide and Other Agricultural Chemical Manufacturing 
                                        
                                    1,000 
                                    325412 
Pharmaceutical Preparation Manufacturing 
                                        
                                    1,250 
                                    325510 
Paint and Coating Manufacturing 
                                        
                                    1,000 
                                    325612 
Polish and Other Sanitation Good Manufacturing   
                                        
                                     750 
                                    325920 
Explosives Manufacturing 
                                        
                                     750 
                                    325998 
All Other Miscellaneous Chemical Product and Preparation Manufacturing 
                                        
                                     500 
                                    327310 
Cement Manufacturing 
                                        
                                     750 
                                    331410 
Nonferrous Metal (except Aluminum) Smelting and Refining 
                                        
                                    1,000 
                                    331491 
Nonferrous Metal (except Copper and Aluminum) Rolling, Drawing and Extruding 
                                        
                                     750 
                                    331492 
Secondary Smelting, Refining, and Alloying of 
Nonferrous Metal (except Copper and Aluminum)   
                                        
                                     750 
                                    333249 
Other Industrial Machinery Manufacturing 
                                        
                                     500 
                                    335911 
Storage Battery Manufacturing 
                                        
                                    1,250 
                                    336412 
Aircraft Engine and Engine Parts Manufacturing 
                                        
                                    1,500 
                                    336415 
Guided Missile and Space Vehicle Propulsion Unit and Propulsion Unit Parts Manufacturing 
                                        
                                    1,250 
                                    423930 
Recyclable Material Merchant Wholesalers 
                                        
                                     100 
                                    424690 
Other Chemical and Allied Products Merchant Wholesalers 
                                        
                                     150 
                                    424720 
Petroleum and Petroleum Products Merchant Wholesalers (except Bulk Stations and Terminals) 
                                        
                                     200 
                                    523910 
Miscellaneous Intermediation 
                                     38.5 
                                        
                                    532490 
Other Commercial and Industrial Machinery and Equipment Rental and Leasing 
                                     32.5 
                                        
                                    541330 
Engineering Services 
                                      15 
                                        
                                    541380 
Testing Laboratories 
                                      15 
                                        
                                    541620 
Environmental Consulting Services 
                                      15 
                                        
                                    541712 
Research and Development in the Physical, Engineering, and Life Sciences (except Biotechnology) 
                                        
                                    1,000 
                                    561990 
All Other Support Services 
                                      11 
                                        
                                    562112 
Hazardous Waste Collection 
                                     38.5 
                                        
                                    562119 
Other Waste Collection 
                                     38.5 
                                        
                                    562211 
Hazardous Waste Treatment and Disposal 
                                     38.5 
                                        
                                 Exhibit 7-1 
Industries with Three or More Facilities Affected by the Proposed Rule and SBA Size Standards 
NAICS Code 
                              NAICS Description 
                         Small Business Size Standard 


                                   Revenue  
                                 ($ Millions) 
                                  Employees 
                                    562212 
Solid Waste Landfill 
                                     38.5 
                                        
                                    562219 
Other Nonhazardous Waste Treatment and Disposal   
                                     38.5 
                                        
                                    562910 
Remediation Services 
                                     20.5 
                                        
                                    562920 
Materials Recovery Facilities 
                                     20.5 
                                        
                                    562991 
Septic Tank and Related Services 
                                     7.5 
                                        
                                    562998 
All Other Miscellaneous Waste Management Services 
                                     7.5 
                                        
                                    622110 
General Medical and Surgical Hospitals 
                                     38.5 
                                        
 
Ideally, this assessment of the rule's small entity impacts would identify specific entities affected by the rule as small and assess impacts for these entities. However, detailed revenue and employment data necessary for the assessment of regulatory impacts for individual entities are not available. Financial data on the potentially affected universe are limited because (1) for many industries, entities managing hazardous waste represent a small percentage of all entities in their respective industries (thus, industry-wide data may not be generally representative of these particular entities) and (2) many of these entities are privately-held, so financial data are not available.  
 
7.2.2.2 Count of Potentially Small Business Impacted by the Proposed Rule 
 
This RIA relies on information from D&B, Hoover's, and other online financial data sources, including SEC annual reports and company websites, to determine which entities might be small. In the absence of entity-specific revenue or employment data for all entities, this analysis considers any entity to be potentially small if it is not publicly-traded, does not have multinational operations, and does not report confirmed financial data to Hoover's (i.e., if it cannot be verified as large). This analysis also assumes that the six hazardous waste management companies responding to the 2015 EPA questionnaire described in Chapter 3 are not small businesses, as these companies were identified to be the among largest in their industry. These assumptions provide a highly conservative (upper bound) estimate of 74 potentially small entities (approximately 40 percent of entities), corresponding to 89 facilities (approximately 23 percent of facilities). These entities span 42 industries, with only 14 industries having more than one potentially small entity. Exhibit 7-2 shows, by industry, the distribution of potentially small entities. Within each of these industries, only between one and 15 entities are potentially small.  
 	 

                                  Exhibit 7-2 
    Industries of Potentially Small Entities Affected by the Proposed Rule 
                                  NAICS Code 
                               NAICS Description 
                                   Number of 
                               Potentially Small 
                                     Firms 
                                    213112 
Support Activities for Oil and Gas Operations 
                                       1 
                                    238990 
All Other Specialty Trade Contractors 
                                       1 
                                    324191 
Petroleum Lubricating Oil and Grease Manufacturing 
                                       1 
                                    325180 
Other Basic Inorganic Chemical Manufacturing 
                                       1 
                                    325199 
All Other Basic Organic Chemical Manufacturing   
                                       1 
                                    325212 
Synthetic Rubber Manufacturing 
                                       1 
                                       

                                       
                                    325612 
Polish and Other Sanitation Good Manufacturing   
                                       1 
                                    325998 
All Other Miscellaneous Chemical Product and Preparation Manufacturing 
                                       1 
                                    326113 
Unlaminated Plastics Film and Sheet (except Packaging) Manufacturing 
                                       1 
                                    326199 
All Other Plastics Product Manufacturing 
                                       1 
                                       

                                       
                                    331410 
Nonferrous Metal (except Aluminum) Smelting and Refining 
                                       3 
                                    331491 
Nonferrous Metal (except Copper and Aluminum) Rolling, Drawing and Extruding 
                                       2 
                                    331492 
Secondary Smelting, Refining, and Alloying of Nonferrous Metal (except Copper and Aluminum)   
                                       3 
                                    332618 
Other Fabricated Wire Product Manufacturing 
                                       1 
                                       

                                       
                                    333249 
Other Industrial Machinery Manufacturing 
                                       1 
                                       

                                       
                                    334512 
Automatic Environmental Control Manufacturing for Residential, Commercial and Appliance Use 
                                       1 
                                    335911 
Storage Battery Manufacturing 
                                       1 
                                       

                                       
                                    423930 
Recyclable Material Merchant Wholesalers 
                                       4 
                                    423940 
Jewelry, Watch, Precious Stone, and Precious Metal Merchant Wholesalers 
                                       1 
                                    424690 
Other Chemical and Allied Products Merchant Wholesalers 
                                       1 
                                    424720 
Petroleum and Petroleum Products Merchant Wholesalers (except Bulk Stations and Terminals) 
                                       2 
                                    454390 
Other Direct Selling Establishments 
                                       1 
                                    484110 
General Freight Trucking, Local 
                                       1 
                                    484220 
Specialized Freight (except Used Goods) Trucking, Local 
                                       1 
                                    488999 
All Other Support Activities for Transportation 
                                       1 
                                    493110 
General Warehousing and Storage 
                                       1 
                                    522390 
Other Activities Related to Credit Intermediation 
                                       1 
                                    523910 
Miscellaneous Intermediation 
                                       3 
                                    541330 
Engineering Services 
                                       1 
                                    541380 
Testing Laboratories 
                                       2 
                                    541620 
Environmental Consulting Services 
                                       3 
                                    561210 
Facilities Support Services 
                                       1 
                                    561990 
All Other Support Services 
                                       2 
                                 Exhibit 7-2 
    Industries of Potentially Small Entities Affected by the Proposed Rule 
                                  NAICS Code 
                              NAICS Description 
                                  Number of 
                              Potentially Small 
                                    Firms 
                                       

                                       
                                       

                                       
                                       

                                       
                                    561210 
Facilities Support Services 
                                       1 
                                    561990 
All Other Support Services 
                                       2 
                                    562112 
Hazardous Waste Collection 
                                      3 
                                    562119 
Other Waste Collection 
                                      1 
                                    562211 
Hazardous Waste Treatment and Disposal 
                                      15 
                                    562212 
Solid Waste Landfill 
                                      2 
                                    562213 
Solid Waste Combustors and Incinerators 
                                      1 
                                    562219 
Other Nonhazardous Waste Treatment and Disposal   
                                      3 
                                    562910 
Remediation Services 
                                      1 
                                    562920 
Materials Recovery Facilities 
                                      9 
                                    562998 
All Other Miscellaneous Waste Management Services 
                                      1 
                                                                         Total 
                                      74 
*Rows do not sum because some potentially small firms own multiple facilities corresponding to different NAICS codes. 
 
The count of 74 firms in Exhibit 7-2 represents a worst-case, upper bound estimate of potentially small firms that may be impacted by e-Manifest. However, several aspects of this analysis and of the examined industry should be noted to properly contextualize the results in Exhibit 7-2. The count of 74 entities likely includes large, privately-held firms which could not be verified to be small, as well as a number of firms whose primary line of business does not appear to be hazardous waste treatment. The impact of e-Manifest on these large firms is already found in Chapter 5, where it is shown to relieve burden. 
 
Additionally, this analysis assumes that small firms will not be sophisticated enough to transition away from paper manifests to any of the lower-cost options provided by the rule. Hazardous waste treatment and disposal is an inherently technical field. These 74 potentially small firms are therefore likely more sophisticated, and thus more able to adopt electronic manifests, than assumed within this analysis. Finally, this analysis focuses solely on firms that may be adversely impacted by the rule; the many thousands of small firms that will likely be beneficially affected by the rule are not examined in detail here.  
 
7.2.2.3 Screening Assessment Confirming Finding of No SISNOSE 
 
For this analysis, EPA considers estimates of greater than 20 percent of total small entities or 100 small entities in the affected universe as indications that a substantial number of small entities may be affected by the rule. The worst-case, upper bound estimate of small entities that will be required to pay manifest fees (and could therefore potentially experience cost increases) under the rule is 74, as shown in Exhibit 7-2. Exhibit 2-15 summarizes the universe of entities affected by the rule; EPA anticipates that many of these entities (especially generators and transporters) are small entities. EPA also anticipates that a large majority of these small entities will experience cost reductions under the rule by using the e-Manifest system (see Section 5.4.1). Therefore, the 74 
TSDF entities potentially adversely affected by the rule do not represent 20 percent of affected small entities. 
 
EPA conducted a screening-level assessment of these 74 potentially small TSDF entities. To estimate revenues and potential impacts for these 74 potentially small entities, EPA used the following assumptions and steps:   
 
          Since EPA does not have revenue data for these 74 potentially small entities, the Agency uses the conservative assumption that all of them are small. 
          
          EPA assumed that these entities would only use paper manifests, and would incur the entire cost of the paper manifest fee. 
          
          For entities that report NAICS codes with revenue-based small business thresholds, EPA assumes that revenues equal the midpoint of the revenue range for small entities.  For example, for facilities in a NAICS code with a $15 million per-firm revenue SBA threshold, EPA assumed these entities had average revenues of $7.5 million. 
          
          For facilities whose NAICS codes have employment-based small business thresholds, EPA examined 2012 Economic Census data (which lists total revenues for facilities within a range of employment) to identify revenues associated with the mid-point range of employees under the small business threshold, using the method documented in the following example of NAICS 325612 (Polish and Other Sanitation Good Manufacturing): 
                   
 NAICS 325612 has an SBA threshold for small entities of 750 employees. 
 The midpoint of this threshold is 375 employees.  
                    Based on employment size categories used by the Economic Census, the midpoint employment size falls within the "100 to 499 employees" category. 
 Average per-firm revenues within this employment size category for 
           NAICS 325612 are approximately $43 million. Therefore, EPA uses $43 
 million as the estimate of annual revenues received by a small entity that reports this NAICS code. 
 
          For each entity, EPA then calculated a upper-bound cost by multiplying the paper manifest fee by an estimated number of manifests completed by the entity, and compared it to the estimated annual revenues for small entities in that sector.   
          
Using this method, EPA found that paper manifest costs exceed one percent of midpoint-derived revenues only for 10 of the 74 potentially small entities (14 percent). This confirms the finding of no SISNOSE. 
 
7.3 Employment Impact Analysis 
 
Executive Order 13563 "Improving Regulation and Regulatory Review" (76 FR 3821; January 18, 2011) requires Federal agencies to consider the employment impacts of regulatory policy. Specifically, Executive Order 13563 states, "Our regulatory system must protect public health, welfare, safety, and our environment while promoting economic growth, innovation, 
competitiveness, and job creation." Consistent with the requirements of the Executive Order, this RIA considers the employment impacts of the proposed rule. For this rule, EPA presents a qualitative assessment of the potential for employment impacts at regulated facilities.  
 
This section first describes the theoretical framework used to analyze regulation-induced employment impacts, discussing how economic theory alone cannot predict whether such impacts are positive or negative, and concludes with a qualitative description of some labor changes that might occur as a result of the proposed rule. 
 
7.3.1 Economic Theory and Employment 
 	 
Regulatory employment impacts are difficult to disentangle from other economic changes affecting employment decisions over time and across regions and industries. Labor market responses to regulation are complex, and reflect labor demand and supply elasticities, decisions at a firm and industry level to adopt technologies and realign products, and possible labor market imperfections (e.g., wage stickiness, long-term unemployment, etc.). The unit of measurement (e.g., number of jobs, types of jobs, hours worked, and earnings) may affect observability of that response.  
       
Microeconomic theory describes how firms adapt their operations in response to changes in economic conditions. Labor is one aspect of operations, along with capital, energy, and materials; all of these are affected by technology. 
       
In competitive markets, firms choose inputs and outputs to maximize profit as a function of market prices and technological constraints.[11,12] Berman and Bui (2001) adapt this model to analyze how environmental regulations affect labor demand. They model environmental regulation as effectively requiring certain factors of production, such as pollution abatement capital, at levels that firms would not otherwise choose. Berman and Bui (2001) model two components that drive changes in firm-level labor demand: output effects and substitution effects. Regulation affects the profit-maximizing quantity of output by changing the marginal cost of production. If a regulation causes marginal production costs to increase, it will place upward pressure on output prices, leading to a decrease in demand, and resulting in a decrease in production. The output effect describes how, holding labor intensity constant, a decrease in production causes a decrease in labor demand. As noted by Berman and Bui, although many assume that regulations must increase marginal cost, in cases such as the proposed rule, they may decrease it. The proposed rule gives firms the option of converting to a more efficient technology for meeting the same regulatory requirements. Firms may then optimize their internal operations to focus on more profitable operations, or to reduce the costs paid by generators of hazardous wastes. For state governments, the reduction in requirements also allows realignment of labor toward other activities; this is offset nationally by EPA's costs to operate the e-Manifest system. 
       
The substitution effect describes how, holding output constant, regulation affects the laborintensity of production. Berman and Bui (2001) model the substitution effect as the effect of regulation on pollution control equipment and expenditures required by the regulation and the corresponding change in the labor-intensity of production. Under the proposed rule, moving from paper to electronic manifests is expected to reduce the labor intensity of manifest activities of industries generating and handling hazardous wastes. The cost savings could lead affected firms to realign labor toward other production activities. 
       
The proposed rule aims to reduce the effects of regulation on production. In response to the proposed rule, if it is cost effective to do so, entities may undertake a number of labor changes, depending on the type of entity (generator, TSDF, transporter, state) and their use of systems to generate and process manifests in the baseline and post-rule scenarios. Appendix C provides the complete set of activities comprising the manifest process; as described in Chapter 5, this RIA assumes that under an electronic manifest system, these activities take less time (i.e., fewer labor hours) to complete, with the extent of the reduction varying by the specific activity in question. These activities must be completed regardless of an entity's use of electronic manifests; the effect of using electronic manifests, from the entity's perspective, is to reduce the costs associated with completing these activities. Entities that save labor hours as a result of the transition to electronic manifests can allocate these hours to other productive uses within their organization. 
 
This RIA estimates a reduction in labor hours (approximately 22.8 million over six years) and labor costs faced by all affected entities, including states, hazardous waste generators, transporters, and TSDFs. The RIA does not reflect a complete analysis of labor market effects related to the rule, as the effects are spread across hundreds of thousands of firms in different sectors, and responses to cost reductions are likely to be sector- and firm-specific. Neither the data nor methods were available to conduct such an analysis.  
 
7.4 Unfunded Mandates Analysis 
 
Among its other purposes and federal agency rulemaking requirements, the Unfunded Mandates Reform Act (UMRA) requires federal agencies, unless otherwise prohibited by law, to assess the effects of their regulatory actions on state, local, and tribal governments and on the private sector, to determine whether any proposed rulemaking may result in "any Federal mandate that may result in the expenditure by State, local, and tribal governments, in the aggregate, or by the private sector, of $100 million or more in any one year." 
 
Section 202 of UMRA requires federal agencies that proposed rules that are likely to exceed this expenditure threshold to prepare a "Written Statement" containing the following five components, supply the statement to OMB, and summarize it in the Federal Register:  
 



        Identification of the applicable authorizing federal law; 
 
        Qualitative and quantitative assessment of the anticipated costs and benefits of the rule including the costs and benefits to state, local, and tribal governments or the private sector, and an analysis of whether federal resources may be available to pay these costs; 
 
        Estimates of future compliance costs and any disproportionate budgetary effects; 
 
        Estimates of effects on the national economy such as productivity, economic growth, employment, job creation, international competitiveness; and 
 
        Description and summary of agency's prior consultation with elected representatives of the affected state, local, and tribal governments. 
 
The e-Manifest proposed rule does not contain a Federal mandate that may result in expenditures of $100 million or more for State, local, and tribal governments, in the aggregate, or the private sector in any one year. As described in Chapter 5, this RIA estimates that the net impact of eManifest will be to reduce costs to state governments. The e-Manifest rule will not impose any burden on local or tribal governments as they are not stakeholders in the hazardous waste manifest system. Thus, this rule is not subject to the requirements of sections 202 or 205 of 
UMRA. 
       
This rule is also not subject to the requirements of section 203 of UMRA because it contains no regulatory requirements that might significantly or uniquely affect small governments. The current hazardous waste paper manifest system imposes no burden or requirements on small governments. 
 
7.5 Federalism Analysis 
 
The 1999 Federalism Executive Order 13132 furthers the policies of UMRA by establishing federalism principles, federalism policymaking criteria, and a state and local government consultation process for the development of federal regulations with implications for federalism. These include regulations and other federal policies and actions that have substantial direct effects on states, on the relationship between the federal government and the states, or on the distribution of power and responsibilities among the various levels of government.  
Pursuant to the consultation process of Executive Order 13132, this section evaluates whether the proposed rule may "impose substantial direct compliance costs" on state and local governments. EPA's 2008 guidance for compliance with Executive Order 13132 describes two numerical methods for evaluating whether an EPA rule may have federalism implications with respect to "substantial direct compliance costs": 
 
        The $25 million test. Annualized direct compliance cost expenditures to state and local governments in aggregate of $25 million or more. 
       
        The one percent test. Annualized direct compliance costs faced by state and local governments are likely to equal or exceed 1percent of their annual revenues. 
As indicated in the UMRA discussion above, this RIA estimates cost savings for state agencies. Thus, the proposed rule would not result in substantial direct compliance costs, as defined in the EPA guidance, for entities owned by state and local governments.  
 
EPA does not estimate that the proposed rule would affect the relationship between the federal government and the states or on the distribution of power and responsibilities among the various levels of government. In the spirit of Executive Order 13132 and consistent with EPA policy to promote communications between EPA and state and local governments, however, EPA specifically solicits comment on this proposed rule from state and local officials. 
 
 Consultation and Coordination with Indian Tribal Governments 
 
Executive Order 13175, entitled "Consultation and Coordination with Indian Tribal Governments" (65 FR 67249, November 9, 2000), requires EPA to develop an accountable process to ensure "meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications." As indicated in the UMRA discussion above, EPA does not estimate any costs of the proposed rule for state and local governments. Based on these results, the proposed rule is not expected to impose a substantial burden on tribal governments. 
 
 Environmental Justice Analysis 
 
Executive Order 12898 (59 FR 7629, Feb. 16, 1994) directs federal agencies, to the greatest extent practicable and permitted by law, to make environmental justice part of their mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority populations and lowincome populations in the United States. Among other actions, the Order directs agencies to improve research and data collection regarding health and environmental effects in minority and low-income communities. 
 
EPA does not anticipate that the proposed rule would result in disproportionately high or adverse impacts for minority or low-income populations. Overall, the Agency anticipates that the rule will support the safe shipment and management of hazardous waste, which benefits all communities. As the rule encourages environmentally sound recordkeeping of hazardous wastes, it will likely reduce the risks associated with treatment, disposal, and recovery.  
 
 Children's Health Protection Analysis 
 
Executive Order 13045, entitled "Protection of Children from Environmental Health Risks and 
Safety Risks" (62 FR. 19885, April 23, 1997) applies to any rule that: (1) is determined to be "economically significant" as defined under Executive Order 12866, or (2) concerns an environmental health or safety risk that EPA has reason to believe may have a disproportionate effect on children. If the regulatory action meets both criteria, the Agency must evaluate the environmental health or safety effects of the planned rule on children, and explain why the planned regulation is preferable to other potentially effective and reasonably feasible alternatives considered by the Agency.  
 
EPA does not anticipate that the proposed rule would lead to a disproportionate negative impact on children. As described in the Environmental Justice section above, the rule improves the information available to EPA through notification, tracking, and reporting requirements, and provides for environmentally sound disposal and recovery. 
 
 Energy Impact Analysis 
 
Executive Order 13211, "Actions Concerning Regulations that Affect Energy Supply, Distribution, or Use" (May 18, 2001), addresses the need for regulators to more fully consider the potential energy impacts of regulatory action. Under this Executive Order, agencies are required to prepare a Statement of Energy Effects when a regulatory action may have significant adverse effects on energy supply, distribution, or use, including impacts on price and foreign supplies. Additionally, the requirements obligate agencies to consider reasonable alternatives to regulatory actions with adverse effects and the impacts that such alternatives might have on energy supply, distribution, or use. 
 
The proposed rule would not directly regulate energy production or consumption. In addition, with annualized net costs of no more than $31.7 million per year (including both industry and government net costs), this rule is not considered an economically significant action under Executive Order 12866.  
 
Changes in the management of hazardous waste resulting from the proposed rule are not expected to significantly impact energy production or distribution, as these changes relate only to reporting, though the reduction in material (paper) use anticipated under the rule is likely associated with reduced energy demand to manufacture and transport paper. Changes in hazardous waste manifest practices may lead to changes in the management practices of hazardous waste, although the effect of these changes on energy use and generation is uncertain and likely to be minimal. Aside from the potential change in paper use and waste management practices described above, the requirements of the rule would have minimal impact on energy consumption; therefore, the rule is not expected to have a significant adverse effect on energy supply, distribution, or use.  

Sources Cited 
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Hamermesh. 1993. Labor Demand (Princeton, NJ: Princeton University Press), Chapter 2. 
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Layard, P.R.G., and A. A. Walters. 1978. Microeconomic Theory (McGraw-Hill, Inc.), Chapter 
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      http://www.epa.gov/wastes/hazard/transportation/manifest/registry/printers.htm 
U.S. Environmental Protection Agency. Assessment of the Potential Costs, Benefits, and Other Impacts of the Improvements to the Hazardous Waste Generator Regulatory Program, as Proposed. May 2015. Accessed at: 
      https://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2012-0121-0005. 
      U.S. Environmental Protection Agency. Cross-Media Reporting Rule (CROMERR) Cost Benefit Analysis. Final. November 17, 2004.  
      U.S. Environmental Protection Agency. e-Manifest Requirements Meeting Summary, March 8, 2013, p. 2. Accessed at: http://www3.epa.gov/epawaste/hazard/transportation/manifest/pdf/emanfst_%20requirmnts_%20mtg_sum_arlngtn.pdf. 
      U.S. Environmental Protection Agency. e-Manifest Technical Architecture: Helpdesk Operations. Final Version 1.0. November 5, 2014.  
      U.S. Environmental Protection Agency. Environmental Compliance Assistance Program (EnvCAP). Gateway to State Resource Locators. Accessed at: www.envcap.org/statetools/. 
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U.S. Environmental Protection Agency. Final Guidance for EPA Rulewriters: Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement Fairness Act.  November 2006. 
U.S. Environmental Protection Agency. Forms 8700-22 and 8700-22A . 
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      https://www3.epa.gov/epawaste/hazard/transportation/manifest/e-man-pastmeetings.htm. 
      U.S. Environmental Protection Agency. Hazardous Waste Electronic Manifest System ("eManifest"). Accessed at: http://www.epa.gov/osw/hazard/transportation/manifest/eman.htm 
      U.S. Environmental Protection Agency. Hazardous Waste Management System; Modification of the Hazardous Waste Manifest System. Federal Register, May 22, 2001, Vol. 66, pages 28240 -28318.  Accessed at: https://www. federalregister. gov/articles/2001/05/22/0111909/hazardous-waste-management-system-modification-of-the-hazardous-wastemanifest-system. 
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      U.S. Environmental Protection Agency. Hazardous Waste Management System; Modification of the Hazardous Waste Manifest System. Federal Register, April 18, 2006, Vol. 71, pages 
      19842 -19848. Accessed at: https://www.federalregister. gov/articles/2006/04/18/E65745/hazardous-waste-management-system-modification-of-the-hazardous-wastemanifest-system. 
      U.S. Environmental Protection Agency.  Hazardous Waste Management System; Modification of the Hazardous Waste Manifest System.  Federal Register, February 26, 2008, Vol. 73, pages 10204 -10210. Accessed at: https://www.federalregister.gov/articles/2008/02/26/E8-3615/hazardous-wastemanagement-system-modification-of-the-hazardous-waste-manifest-system.  
      U.S. Environmental Protection Agency. Hazardous Waste Management System; Modification of the Hazardous Waste Manifest System. Federal Register, February 7, 2014, Vol. 79, pages 7517-7563. Accessed at: https://www.federalregister.gov/articles/2014/02/07/201401352/hazardous-waste-management-system-modification-of-the-hazardous-wastemanifest-system-electronic.  
      U.S. Environmental Protection Agency, Office of Resource Conservation and Recovery. Budget Office Summary of e-Manifest-related Expenditures for Fiscal Year 2014 Costs.  
U.S. Environmental Protection Agency, Office of Resource Conservation and Recovery. State Government Annual Costs for Collecting & Processing Completed Hazardous Waste Paper Manifests: Summary of Cost Data from Two Case Studies Supplied to Office of Solid Waste in 2007. May 2009.  
U.S. Environmental Protection Agency, Office of Solid Waste, Economics, Methods & Risk 
      Analysis Division. Economics Background Document: Economic Analysis of the USEPA's Final Rule Revisions to the RCRA Hazardous Waste Manifest Form, 2004.  
U.S. Environmental Protection Agency. Supporting Statement for EPA Information Collection Request Number 0976.17 "2015 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A Hazardous Waste Permit Application and Modification. January 22, 2015. 
U.S. Environmental Protection Agency. Supporting Statement for Information Collection Request (ICR) 2330.01: Pesticide Registration Fees Program. November 2010.  
U.S. Environmental Protection Agency. Supporting Statement for Information Collection 
      Request (ICR) 0801.15: Requirements for Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System (Final Rule). March 2005.  
U.S. Environmental Protection Agency. Supporting Statement for Information Collection 
      Request (ICR) 0801.18: Requirements for Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System (Final Rule). February 2012.  
U.S. Environmental Protection Agency. Supporting Statement for Information Collection 
      Request (ICR) 0801.20: Requirements for Generators, Transporters, and Waste Management Facilities under the RCRA Hazardous Waste Manifest System (Final Rule). April 2015.  
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      U.S. Environmental Protection Agency. Webinar 2: e-Manifest Alternatives Analysis Document. Final Version 4.0.  November 11, 2009. 
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U.S. Office of Budget and Management. Federal Collection of Information.  Accessed at:  
      https://www.whitehouse.gov/omb/inforeg_infocoll/. 
      U.S. Office of Management and Budget. Statement No. 4. Managerial Cost Accounting Concepts and Standards for the Federal Government. July 31, 1995. Accessed at: http://www.fasab.gov/pdffiles/sffas-4.pdf.  
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      https://www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf. 
 
 
 
 
 
                                  Appendices 
                                      For 
                          Regulatory Impact Analysis 
   For EPA's 2016 Proposed Rule Establishing User Fees for the RCRA Electronic Hazardous Waste Manifest System (e-Manifest) 
                   U.S. Environmental Protection Agency (EPA) 
              Office of Resource Conservation and Recovery (ORCR) 
                  1200 Pennsylvania Avenue NW (Mailstop 5305P) 
                            Washington DC, 20460 USA 
                                  April 2016 
                              Table of Appendices 
Appendix A. Methodology for Estimating Hazardous Waste Tonnage Shipped by SQGs, 
CESQGs, and Generators of State Hazardous Wastes ...........................A-1 
Appendix B. State Hazardous Waste Programs...................................................  B-1 
Appendix C. 2014 EPA Survey of Hazardous Waste Treatment, Storage, and Disposal 
Companies ............................................................................. C-1 
Appendix D. Manifest-Related Activities from the Hazardous Waste Manifest System 
ICR...................................................................................... D-1 
Appendix E. EPA Paper Processing Cost Model..................................................E-1 
Appendix F. e-Manifest Technical Architecture: Helpdesk Operations.........................F-1 
Appendix G. Industries Potentially Affected by the Proposed Rule and SBA Size 
Standards, by NAICS Code...........................................................G-1  

                                   Appendix A 
  Methodology for Estimating Hazardous Waste Tonnage Shipped by SQGs, CESQGs, and Generators of State Hazardous Wastes 
                                        

This RIA uses data from the 2011 RCRA Biennial Report to estimate hazardous waste tonnage shipped by large quantity generators (LQGs) and treatment, storage, and disposal facilities (TSDFs). However, hazardous waste tonnage data for shipments originating from small quantity generators (SQGs) and conditionally-exempt small quantity generators (CESQGs) is not consistently available via the RCRA Biennial Report.  

This RIA relies on the methodology employed throughout EPA's Hazardous Waste Generator proposed rule Regulatory Impact Analysis (RIA) to estimate hazardous waste tonnage shipped by SQGs and CESQGs. However, this RIA only estimates waste tonnage shipped on a national basis, rather than a state-by-state basis. Correspondingly, this Appendix applies the methodology from the Hazardous Waste Generator proposed rule RIA to estimate state-by-state and total hazardous waste tonnage shipped by SQGs and CESQGs on an annual basis. 

A.1 Small Quantity Generators
 
The Hazardous Waste Generator proposed rule RIA collected data on the number of SQGs and tons of hazardous waste produced by SQGs for Maine, Washington, and other states which had sufficient SQG data in the 2011 RCRA Biennial Report. Exhibit 2-9 from the Hazardous Waste Generator proposed rule RIA is reproduced below as Exhibit A-1. 

                                 Exhibit A-1 
                  SQG Hazardous Waste Generation Quantities 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 

                                    State 
                                     SQG 
Facilities 
Hazardous Waste Generated (Tons) 
Tons per Facility 
                                      1 
2011 RCRA Biennial Report data (excluding ME and WA)[a] 
                                                                         1,051 
                                                                         3,270 
                                                                           3.1 
                                      2 
Maine (data from Maine DEP) 
                                                                           317 
                                                                           461 
                                                                           1.5 
                                      3 
Washington (data from Washington DOE) 
                                                                           559 
                                                                         1,183 
                                                                           2.1 
                                      4 
                                                                         Total 
                                                                         1,927 
                                                                         4,914 
                                                                           2.6 
                                                                (Median = 1.5) 
Source: 2015 Hazardous Waste Generator Standards proposed rule RIA, Exhibit 2-9. Available 
at: http://www.regulations.gov/#!home. Exhibit excludes Column E regarding facility-level waste streams as it is not relevant to the present discussion. 
[a] Data based on analysis of 2011 RCRA Biennial Report database (not National Summary Report). These data exclude facilities that are reported to be SQGs, but exceed the RCRA hazardous waste generation threshold for SQGs. Maine and Washington data were also excluded to avoid double-counting. 

This RIA assumes that per-state hazardous waste generation from SQGs scales linearly with the number of SQGs in a state; the states with the most SQGs are therefore estimated to generate the most hazardous waste. This RIA further assumes that, consistent with Exhibit 2-7, 77 percent of all SQGs ship their hazardous waste off-site, and that ten percent of all SQGs (including those shipping off-site) are doing so for reclamation and recovery and are thus covered by bona-fide reclamation agreements (and are thus exempt from manifesting requirements). This RIA estimates the volume of hazardous waste shipped off-site by SQGs subject to manifest requirements as simply the number of manifesting SQGs per Exhibit 2-7 multiplied by 2.6, the average number of tons generated by an SQG per Exhibit A-1. The results are shown in Exhibit A-2 below. 
 

                                     Exhibit A-2 
                 Estimated Hazardous Waste Tonnage from Manifesting SQGs, by State 


                                      Item 
                                      A 
                                      B 
                                      C 
                                      D 
  
                                        
  
                
          
Item 
                                      A 
                                      B 
                                      C 
                                      D 

                                    State 
                                  Number of 
Manifesting SQGs 
                                (Exhibit 2-7) 
                                     Tons 
                             Generated (B x 2.6) 
                                     % of 
                                    Total 


                                    State 
                                  Number of 
                               Manifesting SQGs 
(Exhibit 2-7) 
                                     Tons 
                             Generated (B x 2.6) 
                                     % of 
                                    Total 
                                      1 
Alabama 
                                                                           821 
                                                                         2,136 
                                                                          2.3% 

                                      30 
Nebraska 
                                                                           167 
                                                                           435 
                                     0.3% 
                                      2 
Alaska 
                                                                            80 
                                                                           208 
                                                                          0.1% 

                                      31 
Nevada 
                                                                           159 
                                                                           415 
                                     0.3% 
                                      3 
Arizona 
                                                                           429 
                                                                         1,116 
                                                                          0.6% 

                                      32 
New 
Hampshire 
                                                                           135 
                                                                           350 
                                     0.3% 
                                      4 
Arkansas 
                                                                           192 
                                                                           500 
                                                                          0.3% 

                                      33 
New Jersey 
                                                                           570 
                                                                         1,481 
                                     1.2% 
                                      5 
California 
                                                                         3,963 
                                                                        10,304 
                                                                          5.7% 

                                      34 
New Mexico 
                                                                           131 
                                                                           341 
                                     0.3% 
                                      6 
Colorado 
                                                                           307 
                                                                           798 
                                                                          0.5% 

                                      35 
New York 
                                                                         1,755 
                                                                         4,562 
                                     3.6% 
                                      7 
Connecticut 
                                                                           619 
                                                                         1,610 
                                                                          1.0% 

                                      36 
North Carolina 
                                                                           990 
                                                                         2,574 
                                     2.1% 
                                      8 
Delaware 
                                                                           125 
                                                                           325 
                                                                          0.2% 

                                      37 
North Dakota 
                                                                            47 
                                                                           122 
                                     0.1% 
                                      9 
District of Columbia 
                                                                            37 
                                                                            96 
                                                                          0.1% 

                                      38 
Ohio 
                                                                         1,769 
                                                                         4,600 
                                     3.9% 
                                      10 
Florida 
                                                                         2,546 
                                                                         6,620 
                                                                          4.0% 

                                      39 
Oklahoma 
                                                                           295 
                                                                           767 
                                     0.7% 
                                      11 
Georgia 
                                                                           733 
                                                                         1,906 
                                                                          1.2% 

                                      40 
Oregon 
                                                                           174 
                                                                           453 
                                     0.4% 
                                      12 
Guam 
                                                                             4 
                                                                            10 
                                                                          0.0% 

                                      41 
Pennsylvania 
                                                                         2,350 
                                                                         6,109 
                                     5.4% 
                                      13 
Hawaii 
                                                                            96 
                                                                           250 
                                                                          0.2% 

                                      42 
Puerto Rico 
                                                                            71 
                                                                           184 
                                     0.2% 
                                      14 
Idaho 
                                                                            56 
                                                                           146 
                                                                          0.1% 

                                      43 
Rhode Island 
                                                                           469 
                                                                         1,219 
                                     1.1% 
                                      15 
Illinois 
                                                                         2,631 
                                                                         6,842 
                                                                          4.3% 

                                      44 
South Carolina 
                                                                           404 
                                                                         1,051 
                                     1.0% 
                                      16 
Indiana 
                                                                           652 
                                                                         1,695 
                                                                          1.1% 

                                      45 
South Dakota 
                                                                           147 
                                                                           381 
                                     0.4% 
                                      17 
Iowa 
                                                                           384 
                                                                           998 
                                                                          0.7% 

                                      46 
Tennessee 
                                                                           386 
                                                                         1,003 
                                     1.0% 
                                      18 
Kansas 
                                                                           389 
                                                                         1,010 
                                                                          0.7% 

                                      47 
Texas 
                                                                         1,218 
                                                                         3,166 
                                     3.1% 
                                      19 
Kentucky 
                                                                           276 
                                                                           718 
                                                                          0.5% 

                                      48 
Trust 
Territories 
                                                                             3 
                                                                             7 
< 0.1% 
                                      20 
Louisiana 
                                                                           594 
                                                                         1,544 
                                                                          1.1% 

                                      49 
Utah 
                                                                           127 
                                                                           330 
                                     0.3% 
                                      21 
Maine 
                                                                           204 
                                                                           530 
                                                                          0.4% 

                                      50 
Vermont 
                                                                           146 
                                                                           379 
                                     0.4% 
                                      22 
Maryland 
                                                                           923 
                                                                         2,399 
                                                                          1.7% 

                                      51 
Virgin Islands 
                                                                             4 
                                                                            10 
                                     0.0% 
                                      23 
Massachusetts 
                                                                         1,798 
                                                                         4,674 
                                                                          3.3% 

                                      52 
Virginia 
                                                                         1,107 
                                                                         2,877 
                                     2.9% 
                                      24 
Michigan 
                                                                         1,233 
                                                                         3,205 
                                                                          2.3% 

                                      53 
Washington 
                                                                           381 
                                                                           989 
                                     1.0% 
                                      25 
Minnesota 
                                                                           915 
                                                                         2,380 
                                                                          1.8% 

                                      54 
West Virginia 
                                                                           220 
                                                                           571 
                                     0.6% 
                                      26 
Mississippi 
                                                                           166 
                                                                           432 
                                                                          0.3% 

                                      55 
Wisconsin 
                                                                           822 
                                                                         2,137 
                                     2.3% 
                                      27 
Missouri 
                                                                         1,007 
                                                                         2,618 
                                                                          2.0% 

                                      56 
Wyoming 
                                                                            58 
                                                                           152 
                                     0.2% 
                                      28 
Montana 
                                                                            44 
                                                                           115 
                                                                          0.1% 

                                      57 
                                                                         Total 
                                                                        35,330 
                                                                        91,859 
100.0% 
                                      29 
Navajo Nation 
                                                                             4 
                                                                            10 
                                                                     < 0.1% 

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
 
Note that, as described in Chapter 3 of this RIA, estimates and assumptions about SQG hazardous waste tonnage generation and shipment are relevant only insofar as they inform the frequency with which pickups of hazardous waste must be made. The estimate of 2.6 tons of hazardous waste generated annually falls well short of this RIA's estimate of 30 tons of waste capable of being carried by one truck; correspondingly, this estimate is consistent with this RIA's methodology of assuming that pickups of hazardous waste from SQGs occur on a routine basis and do not require multiple trucks. 
 
A.2 Conditionally-Exempt Small Quantity Generators 
 
Similar to SQGs, there are few reporting requirements for CESQGs with respect to generation of hazardous waste. Because of this, the Hazardous Waste Generator proposed rule RIA extrapolated estimates of the average number of tons generated per CESQG from states where such data are available. For CESQG hazardous waste tonnage estimation, this RIA uses a similar methodology as for SQGs, as per Exhibit A-2 (which is Exhibit 2-10 in the Hazardous Waste Generator proposed rule RIA). 
 
                                 Exhibit A-2 
                 CESQG Hazardous Waste Generation Quantities 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 

                                    State 
CESQG 
Facilities 
Hazardous Waste Generated (Tons) 
Tons per Facility 
                                      1 
2011 RCRA Biennial Report data (excluding ME and WA)[a] 
                                                                           252 
                                                                            67 
                                                                          0.26 
                                      2 
Maine (data from Maine DEP) 
                                                                           917 
                                                                           161 
                                                                          0.18 
                                      3 
New Jersey (data from New Jersey DEP) 
                                                                         1,224 
                                                                           501 
                                                                          0.41 
                                      4 
Washington (data from Washington DOE) 
                                                                           127 
                                                                            42 
                                                                          0.33 
                                      5 
                                                                         Total 
                                                                         2,520 
                                                                           771 
                                                         0.31  (Median = 0.20) 
Source: 2015 Hazardous Waste Generator Standards proposed rule RIA, Exhibit 2-9. Available 
at: http://www.regulations.gov/#!home. Exhibit excludes Column E regarding facility-level waste streams as it is not relevant to the present discussion. [a] Data based on analysis of 2011 RCRA Biennial Report database (not National Summary Report). These data exclude facilities that are reported to be SQGs, but exceed the RCRA hazardous waste generation threshold for SQGs. Maine and Washington data were also excluded to avoid double-counting. 
 
This RIA uses the mean (average) estimate of 0.31 tons of hazardous waste generation per 
CESQG facility to estimate total hazardous waste tonnage generated by CESQGs. However, 
CESQGs are exempt from manifest requirements unless a state requirement specifically requires CESQG to fill out and submit manifests for hazardous waste shipments (see Section 2.1.2.3). 
Therefore, only the one state that requires CESQGs to manifest shipments of hazardous waste, Arkansas, requires specific CESQG tonnage estimation relevant to this RIA. Given the other assumptions in Section 2.1.2.3, this RIA estimates that 2,039 CESQGs in Arkansas are shipping hazardous waste off-site and must manifest. Using the 0.31 tons per facility multiplier, this RIA estimates that approximately 632 tons of hazardous waste are generated by CESQGs, shipped off-site, and accompanied by federal manifests. 
 
Again, given that the estimation of annual generation by CESQGs is below the number of tons assumed to be carried by a single truck, this calculation is consistent with this RIA's broader estimation of the number of manifests used annually to accompany hazardous waste shipments. 
 
A.3 Generators of State Hazardous Wastes 
 
As described in Section 2.1.2.4, 19 states have listed additional wastes as state hazardous wastes, beyond the requirements of the federal RCRA program. Consistent with Section 2.1.2.4, this RIA assumes that the count of state hazardous waste generators is equal to the count of CESQGs in the state. Exhibit A-3 below summarizes the estimated number of state hazardous waste shippers based on this assumption, as well as their associated tonnage shipped off-site, based on the 0.31 tons per facility multiplier discussed above. 
 
                                 Exhibit A-3 
   Estimated State Hazardous Waste Tonnage from Shippers of State Hazardous 
                               Waste, by State 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 

                                    State 
                       Count of Shippers (Exhibit 2-10) 
                          Tons Generated  (B x 0.31) 
                                     % of 
                                    Total 
                                      1 
California 
                                                                        16,170 
                                                                         5,013 
                                    11.1% 
                                      2 
Colorado 
                                                                         2,297 
                                                                           712 
                                     1.6% 
                                      3 
Illinois 
                                                                        19,370 
                                                                         6,005 
                                    13.3% 
                                      4 
Indiana 
                                                                         7,702 
                                                                         2,388 
                                     5.3% 
                                      5 
Kentucky 
                                                                         3,952 
                                                                         1,225 
                                     2.7% 
                                      6 
Louisiana 
                                                                         5,527 
                                                                         1,713 
                                     3.8% 
                                      7 
Maine 
                                                                           731 
                                                                           227 
                                     0.5% 
                                      8 
Maryland 
                                                                         6,018 
                                                                         1,866 
                                     4.1% 
                                      9 
Michigan 
                                                                         9,238 
                                                                         2,864 
                                     6.4% 
                                      10 
Missouri 
                                                                         7,542 
                                                                         2,338 
                                     5.2% 
                                      11 
New Hampshire 
                                                                         1,400 
                                                                           434 
                                     1.0% 
                                      12 
New York 
                                                                        21,715 
                                                                         6,732 
                                    15.0% 
                                      13 
Oregon 
                                                                         2,650 
                                                                           822 
                                     1.8% 
                                      14 
Rhode Island 
                                                                         1,617 
                                                                           501 
                                     1.1% 
                                      15 
South Carolina 
                                                                         4,137 
                                                                         1,282 
                                     2.8% 
                                      16 
Texas 
                                                                        15,135 
                                                                         4,692 
                                    10.4% 
                                      17 
Utah 
                                                                         1,699 
                                                                           527 
                                     1.2% 
                                      18 
Vermont 
                                                                         1,079 
                                                                           334 
                                     0.7% 
                                      19 
Washington 
                                                                        17,183 
                                                                         5,327 
                                    11.8% 
                                                                         Total 
                                                                       145,522 
                                                                        45,000 
 100% 
 
Again, given that the estimation of annual generation by CESQGs is below the number of tons assumed to be carried by a single truck, this calculation is consistent with this RIA's broader estimation of the number of manifests used annually to accompany hazardous waste shipments. 
 
 
 

                                   Appendix B 
                         State Hazardous Waste Programs 
                                        
 
As described in Section 2.2, some state governments have elected to adopt modifications to RCRA that make their programs more stringent than federal RCRA regulations. To examine in detail the ways in which the proposed rule may result in impacts to state hazardous waste programs, this RIA gathered data on state RCRA program requirements from the Environmental Compliance Assistance Program (ENVCAP), a repository of environmental regulations maintained by the National Center for Manufacturing Sciences and supported by EPA's Office of Enforcement Compliance Assurance. The state government RCRA program requirements can be accessed on ENVCAP's website at http://www.envcap.org/statetools/hzrl/. 
 
Section 2.2 summarizes the key ways in which various state hazardous waste programs differ from the federal RCRA program, and Exhibits 2-12 and 2-13 indicate the specific state differences with potential implications for the proposed rule and this RIA. This Appendix provides greater detail on specific state requirements used to generate the data presented in Exhibits 2-12 and 2-13. 
 
B.1 Additional State Hazardous Wastes  
 
This RIA identified 19 states with additional state hazardous wastes. This section summarizes the available data on the ways in which state hazardous waste programs differ from the federal RCRA program with regard to which wastes are additionally considered hazardous. 
 
       California  -  Used oil is considered a hazardous waste. Additionally, there are multiple additional eligible waste streams for the consolidated manifest, including: o used oil; 
              the contents of an oil/water separator under certain conditions; o solids contaminated with used oil; o brake fluid; 
              antifreeze or antifreeze sludge; 
              parts cleaning solvent, including aqueous cleaning solvents; 
              hydroxide sludge contaminated solely with metals from a wastewater treatment process' paint-related wastes, including paints, thinners, filters, and sludges; 
              spent photographic solutions; o dry-cleaning solvents; 
              filters, lint, and sludges contaminated with dry-cleaning solvent; o asbestos and asbestos-containing materials; o inks from the printing industry; 
              chemicals and laboratory packs collected from K-12 schools; o absorbents contaminated with other eligible wastes; o filters from dispensing pumps for diesel and gasoline fuels; and o disabled vehicle wastes. 
 
       Colorado  -  Colorado does not require use of state-specific waste codes on manifests. However, there are state-specific codes within the state relating to chemical weapons and associated treatment residues and contaminated materials that came in contact with chemical weapons. 
       
       Illinois -- Illinois requires non-hazardous special waste to be manifested on the Uniform Hazardous Waste Manifest. Illinois generators and out-of-state generators sending nonhazardous waste to an Illinois receiving facility must use a manifest for all shipments of nonhazardous special waste.  All nonhazardous special waste should be identified as either Class A or Class B. Copies of these manifests are not to be submitted to the State of Illinois; instead Illinois receiving facilities and Illinois generators who send their waste out-of-state are required to submit summary information in the form of the Nonhazardous Special Waste Annual Report. 
       
       Indiana  -  Chemical munitions are an additional hazardous waste. 
       
       Kentucky  -  Various additional hazardous wastes, including: 
              N001 GB (iso (isopropyl methyl phosphonofluoridate) (H); 
              N002 VX (o-ethyl-S-(2-diisopropyl-aminoethyl)-methyl phosphonothiolate) (H); and  
              N003 H (bis(2-chloroethyl) sulfide) and related compounds (H). 
 
       Louisiana  -  Used oil is considered a hazardous waste. 
       
       Maine -- The waste codes as designated in Maine Rules follow the federal coding conventions (D, F, U and P coding, consistent with federal codes) and as such, the corresponding federal code must be entered on the new federal manifest in Item 13 pursuant to the manifest instructions. However, Maine has state-specific waste codes for "state-listed" hazardous wastes (i.e. "state-regulated only") that are not found in the federal hazardous waste rules (i.e. "not redundant" with federal waste codes). As such, these "state-regulated only/ not redundant" waste codes must be entered on the manifest in Item 13 for shipments of such wastes.  
       
      In addition, the State of Maine does not incorporate many of the federal exemptions and exclusions to the definition of solid waste and hazardous waste. Hazardous waste sent off-site for recycling or reclamation is not exempt from Maine regulations. Hazardous waste being sent for recycling or reclamation must use a uniform hazardous waste manifest to document the shipping. For wastes which are regulated as hazardous waste in Maine, but federally-exempt, the waste codes as designated in Maine Rules must be entered on the manifest in Item 13. Again, Maine Rules identify characteristic hazardous wastes by the same waste codes used under the federal rules (e.g. D001, D002, D003, D004, etc.), and identify listed hazardous waste using the F, P, and U-waste codes similar to the federal coding convention. As noted above, Maine Rules include state-specific wastes, including listings for PCBs (M002) and several P- and U- coded wastes which are not listed federally. For shipment of these wastes in Maine, the waste code as identified in Maine Rules must be entered on the manifest in Item 13. Generators may choose to specify in Item 14 of the manifest that such waste is "state-regulated only", but this is not required.  
       
      The State of Maine regulates batteries, cathode ray tubes, mercury or lead containing lamps, mercury devices, mercury thermostats and motor vehicle mercury switches as universal waste. Generators of universal wastes must ship and track their waste using a hazardous waste manifest, a Uniform Bill of Lading, or an alternative form approved by the Department. If a generator chooses to use a hazardous waste manifest for a universal waste shipment, then item counts of the waste must be supplied in Item 14.  
       
      Universal wastes use the prefix MR followed by the federal or state waste code. For example, mercury containing lamps would use the code MRD009. For additional examples, see Appendix J of the Universal Waste Handbook. Waste oil being transported into Maine from out of state must be accompanied by a hazardous waste manifest. The results from analysis required by the Waste Oil Management Rules, Chapter 860.15(C) may be recorded in Item 14. Special Handling Instructions and Additional Information. If the results are not included on the manifest in Item 14, then a copy of the results must be attached to each copy of the manifest at the time of each copy's distribution. If a shipment of waste oil from a storage facility does not meet the specification described in Chapter 860.4(B), then it must be accompanied by a hazardous waste manifest pursuant to Waste Oil Management Rules, Chapter 860.13(B)(2)(b). The results of the analysis may be recorded in Item 14. Special Handling Instructions and Additional Information. If the results are not included on the manifest in Item 14, then a copy of the results must be attached to each copy of the manifest at the time of each copy's distribution.Additional Wastes: 
       
       Maryland  -- Various additional hazardous wastes, including: 
         o Hazardous Waste From Specific Sources (COMAR 26.13.02.17):  
                    Primary Copper, K064;  
                    Primary Lead, K065;  
                    Primary Zinc, K066;  
                    Primary Zinc, K067;  
                    Primary Zinc, K068;  
                    Ferroalloys, K090 & K091; and 
                    Military K991, K992, K993, K994, K995, K996, K997, K998 and K999.  
              Hazardous Waste from Specific Sources (State) (COMAR 26.13.02.18):   Organic Chemical, MD01; and  Military, MD02 and MD03.  
              Discarded Commercial Chemical Products, Off-Specification Species, Containers, and Spill Residues of These (COMAR 26.13.02.19):  
                    MX 01: "Any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill, into or on any land or water, of any commercial chemical product or manufacturing chemical product or manufacturing chemical intermediate having the generic name listed in §E or G or mixtures containing polychlorinated biphenyls (PCBs) at concentrations greater than 50 ppm.";  
                    M001: Polychlorinated biphenyls (PCB)(above 500 ppm); and   MT01: Polychlorinated biphenyls (50 to 500 ppm). 
 
       Michigan  -  Additional hazardous wastes assigned to numerous waste with Michigan Hazardous Waste numbers, including specific hazardous wastes from specific sources and specific substances. Shipments of liquid industrial waste must be manifested. Some specific types of additional hazardous wastes include: 
           mixed solvents; o pharmaceutical wastes; o crankcase oil; 
           coolants and water soluble oil; o other oil; o brine; o PCBs; 
           other wastes; o antifreeze; o storm sewer cleanouts; o sanitary sewer cleanouts; o x-ray/photo cleaning solutions; o water-based cleaning solutions; o car wash sludges; and o grease trap wastes. 
 
       Missouri  -  State waste codes must be used if federal waste codes do not apply. State waste codes include: o PCB wastes; o dioxin waste; and o disposal of used oil. 
 
       New Hampshire  -  Additional wastes include: 
           federally-exempt due to recycling wastes; o federally-exempt household hazardous waste; o remediation waste; o federally-exempt sludge; 
           federally-exempt municipal solid waste ash; and o federally-exempt shooting range waste. 
 
       New York  -  Generators must complete Block 13 Waste Codes. They may designate up to, but not more than, six Waste Codes. If applicable, NYS DEC's "B" type Waste Codes for PCB wastes must be used. Generators must provide the "old Handling Code" for their wastes in Block 13 in certain cases, or else the waste will be assumed to be landfilled. 
       
       Oregon  -  Oregon has state-specific wastes codes for acute and toxic hazardous wastes. Other additional wastes includes: 
       
              waste pesticide residue, except for those that are managed as universal wastes or whose constituents are listed in the federal regulations, but are below the prescribed regulatory levels; 
              wastes received from out of state that are not regulated in Oregon but are regulated as hazardous waste in state of origin.  
              residues from demilitarization, treatment and testing of blister agents (such as mustard agents), which have been added to and made a part of the list found in the federal regulations; 
              residues from demilitarization, treatment and testing of nerve agents, such as GB (Sarin) and VX; which have been added to and made a part of the list found in the federal regulations; and 
              blister agents, such as mustard agents, which have been added to the list of commercial chemical products found in the federal regulations. 9. P999 Nerve agents, such as GB (Sarin) and VX, which have been added to the list of commercial chemical products found in the federal regulations. 
             
       Rhode Island  -  State codes R001-R010 are to be used if Federal codes do not apply. The state codes will work on the new Uniform Hazardous Waste Manifest in exactly the same way as they functioned on the previous manifest. State codes R011-R016 are to be used for Fee Exempt waste and should be used in addition to federal waste codes. In the event that the waste carries more than six waste codes, the generator should select the most appropriate codes for use.  
 
       South Carolina  -  Additional wastes include: 
              organotins; o tributyltin; 
              any solid waste that the state determines constitutes a hazard and requires greater control; and 
              non-hazardous waste received by a hazardous waste facility. 
 
       Texas  -  Texas has its own 8-digit waste code that identifies each waste stream. The Texas waste code will still go on the manifest - regardless of if the waste is hazardous or not. Use two of the 6 waste code blocks in Item 13 for the Texas Waste Code. For hazardous waste, up to 4 applicable EPA codes (e.g., D001, F001, etc) will go in the remaining waste code boxes. The formula for the Texas waste code is: The 4-digit sequence number + the 3-digit form code + the 1-digit classification code.  
       
       Utah  -  Additional wastes includes two wastes associated with the management of chemical nerve agents. 
       
       Vermont  -  Vermont has seven additional state waste codes. 
       
       Washington  -  Multiple additional state waste codes. Furthermore, shipments of lab packs have special manifesting instructions. 
       
           Removal of Exemptions  
 
This RIA identified six states that remove certain federal exemptions present under federal RCRA regulations. Specifically, these six states remove the exemption for SQGs that have bonafide contractual reclamation agreements (with TSDFs)  -  under federal requirements these SQGs do not have to provide manifests accompanying shipments of their hazardous waste, but in these six states, SQGs must provide accompanying manifests even for these shipments. 
 
These six states are Connecticut, Delaware, Kentucky, Maryland, Minnesota, and New Hampshire.  
 
Texas' state hazardous waste program also removes some exemptions relative to the federal 
RCRA program; however, these do not have direct bearing on the proposed rule or this RIA. 
 
           Distribution Requirements 
 
This RIA identified 32 states that require industry entities to send copies of the manifest from shipments originating and/or terminating within their boundaries to state regulatory agencies.  
 
Note that this set of states does not overlap perfectly with either the set of states with additional state hazardous wastes, nor the 23 states identified in Chapter 4 as collecting and processing manifests in the baseline. 
 
           Additional Reporting Requirements 
 
This RIA identified 17 states have reporting requirements more stringent than the federal RCRA program as pertaining to certain hazardous waste activities. These additional requirements may include additional instances requiring reports, more frequent or shorter reporting timetables, or additional facility classes subject to these requirements. 
 
           Additional Recordkeeping Requirements 
 
This RIA identified five states with additional recordkeeping requirements beyond the federal RCRA requirement to maintain records of all manifest shipments for three years. 
 
           Other Additional Requirements 
 
This RIA identified 22 states with additional requirements beyond the federal RCRA program distinct from the five categories described above. One of these states, Arkansas, requires CESQGs to provide accompanying manifests for hazardous waste shipments. 
 

 	 
  APPENDIX C 2014 EPA Survey of Hazardous Waste Treatment, Storage, and Disposal Companies 
                                        
 
To gather information on the number of manifests nationwide and the manner in which they are handled, EPA asked nine of the largest TSDF companies to respond to a voluntary questionnaire in August 2014. This RIA uses information from the questionnaire to confirm estimates of the number of manifests from other sources, and incorporates manifest handling information into the estimation of baseline costs and post-rule cost and cost savings. In total, six of the nine firms responded to this questionnaire. 
 
Manifests 
 
As shown in Exhibit C-1, these six firms reported receiving approximately 800,000 manifests in total each year, with the total annual number varying by less than 5,000 manifests from year to year. In 2013, these companies received shipments from approximately 140,000 entities (e.g,, generators or transporters). 
 

                                 Exhibit C-1 
  Reported Manifest Usage by Six TSDF Companies for the Years 2011 through 2013 
                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 

                                   Company 
                                  Count 2013 
                                  Count 2012 
                                  Count 2011 
                                      1 
Veolia 
                                                                       100,000 
                                                                       100,000 
                                                                       100,000 
                                      2 
Tradebe 
                                                                        45,000 
                                                                        46,000 
                                                                        45,000 
                                      3 
Clean Harbors Environmental Services 
                                                                       561,761 
                                                                       569,507 
                                                                       572,290 
                                      4 
Ross Environmental Services, Inc. 
                                                                        14,448 
                                                                        13,592 
                                                                        12,782 
                                      5 
Heritage Environmental Services 
                                                                        50,200 
                                                                        42,700 
                                                                        49,700 
                                      6 
Systech Environmental Corporation 
                                                                        21,470 
                                                                        22,982 
                                                                        19,629 
                                      7 
Total 
                                                                       792,879 
                                                                       794,781 
                                                                       799,401 
 
These firms reported submitting copies of manifests to 47 states, and reported paying manifest fees to six states (California, Massachusetts, Michigan, Missouri, New Jersey, and 
Pennsylvania). Overall, approximately 18 percent of manifests in each year carried only state hazardous waste codes (Exhibit C-2). 
 	 
                                     C-1 
 
                                                                               
 	 
 

                                    Exhibit C-2 
              Manifests Carrying Only State Waste Codes For Six TSDF Companies 

                                     Item 
                                      A 
                                      B 
                                      C 
                                      D 

                                   Company 
                                  Count 2013 
                                  Count 2012 
                                  Count 2011 
                                      1 
Veolia 
                                                                        10,000 
                                                                        10,000 
                                                                        10,000 
                                      2 
Tradebe 
                                                                         1,000 
                                                                         1,250 
                                                                         1,000 
                                      3 
Clean Harbors Environmental Services 
                                                                      120,589  
                                                                       134,011 
                                                                       123,862 
                                      4 
Ross Environmental Services, Inc. 
                                                                             1 
                                                                             1 
                                                                             1 
                                      5 
Heritage Environmental Services 
                                                                         9,000 
                                                                         5,800 
                                                                         8,000 
                                      6 
Systech Environmental Corporation 
                                                                           500 
                                                                           500 
                                                                           500 
                                      7 
Total 
                                                                       141,090 
                                                                       151,562 
                                                                       143,363 
 
Existing electronic systems 
 
Five companies reported using their own electronic systems to comply with federal or state RCRA reporting requirements, and invoicing support systems. These included proprietary waste tracking database systems that recorded waste shipments and container movements, as well as customized versions of commercial software (e.g., .NET, SAP, Oracle). For four companies, these electronic systems were closed (i.e., did not presently have the ability to communicate with external systems), while the electronic system used by one company utilized XML web services in order to transfer or receive data from other systems. 
 
None of these five companies reported requiring their customers to use electronic systems. At least one company uploaded scanned paper manifest images and extracted data from these images for incorporation into its electronic system. 
 
Adoption of e-Manifest 
 
All six major TSDF companies indicated their intention to transition from paper to electronic manifests. At least three companies indicated that because of customer demand, the transition to electronic manifests would be gradual, and paper manifests would continue to be supported. Only two companies indicated that they would impose any type of requirement on customers to use electronic manifest systems after the TSDF's transition to the e-Manifest system. One company specifically identified differential pricing for customers using paper or electronic manifests as a potential strategy for encouraging the use of e-Manifest, while one company indicated that differential pricing did not align with its business strategy. 
 
                                     C-2 
 
                                                                               
                                   Appendix D 
                          Manifest-Related Activities 
                                        
 
 
 
This Appendix consists of two sections. Section D.1 provides the set of manifest activities used to estimate baseline and post-rule costs and cost savings within this RIA, based on the activities, hourly labor burdens, and other costs as reported within the 2015 Hazardous Waste Manifest System (HWMS) ICR. Section D.2 then provides two visual summaries of the manifest process which help to illustrate both how industrial entities interact with one another and the manifest in the baseline, and how they may do so under the e-Manifest system via electronic manifests. 
 
D.1 Manifest-Related Activities from the Hazardous Waste Manifest System ICR 
 
As described in Chapter 4, this RIA uses the 2015 Hazardous Waste Manifest System (HWMS) ICR as the main underlying data source for unit costs and frequencies associated with the activities required to complete a federal manifest. These specific assumptions and parameters are summarized in this Appendix. Note that this RIA uses the labor rates from the 2015 HWMS ICR to calculate industry costs associated with manifest-related activities, so the labor rates shown below are consistent with the HWMS ICR. 
 
Exhibit D-1 below replicates the relevant activities and their associated hourly labor burdens and operations and maintenance (O&M) costs as reported within the 2015 HWMS ICR. The columns of Exhibit D-1 provide the following information: 
 
       Column A  -  Describes the manifest-related activity in question. Note that activities are grouped by category and subcategory where appropriate.  
       Columns B through E  -  Provide the number of labor hours necessary to complete the activity for legal, managerial, technical, and clerical labor, respectively. 
       Column F  -  Based on the hourly labor rates provided in the 2015 HWMS ICR and the column headings of Columns B through E, the total labor cost associated with the labor burden shown in Columns B through E. 
       Column G  -  The O&M costs associated with the activity. 
       Column H  -  The proportion of manifests to which the activity applies. Note that a value here does not mean this activity applies to all Federal manifests; rather, this proportion applies only to the subset of manifests as defined in Column I. 
       Column I  -  The subset of manifests to which the activity applies. Some activities apply only to manifests originated by a specific entity (e.g., LQG-originated manifests, SQGoriginated manifests). The majority of activities, however, apply to all manifests; these are designated as "All Federal Manifests" in this column. 
       Column J  -  Per this RIA's methodology to estimate burden reductions as detailed in 
Chapter 5, whether the activity corresponds to a major burden reduction (i.e., 80 percent reduction in overall cost) or a minimal burden reduction (i.e., five percent reduction in overall cost) when electronic manifests are used in lieu of paper manifests. 
 
As described in Chapter 4, the HWMS ICR pertained only to federal manifests. Chapter 4 of this RIA details how the assumptions and parameters from the HWMS ICR, reproduced below, were additionally extrapolated to state manifests. 
 
This RIA made only one alteration to the assumptions and parameters in the HWMS ICR in order to align to calculations used elsewhere in the RIA; this alteration pertained to estimates of the number of hazardous waste discharges. Specifically, the HWMS ICR used approximate figures rather than actual reported numbers for the volume of such discharges in a given year, whereas this RIA uses the actual numbers of highway and marine discharges in lieu of the approximations. Exhibit D-1 reflects this alteration. Because the HWMS ICR and this RIA differ in the total number of annual federal manifests considered, the proportion of manifests associated with a discharge or incident requiring a specific burden activity differs across the HWMS and this RIA, but the underlying figures and calculations have been adjusted so that the overall count of incidents is similar. 
 
                                     D-2 
 


                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

Without TSDF assistance 

LQG - Complete manifest 
                                      0 
                                      0 
                                     0.4 
                                     0.1 
$18.42  
$0.42  
                                    58.0% 
                                 LQG Shipper-
                                  Originated 
                                  Manifests 
                                    Major 
LQG - Complete continuation sheet 
                                      0 
                                      0 
                                     0.19 
                                     0.04 
                                                                        $8.58  
$0.42  
                                     2.9% 
                                 LQG Shipper-
                                  Originated 
                                  Manifests 
                                    Major 
LQG - Subtotal 
                                    Major 
With TSDF assistance 

LQG - Complete manifest 
                                      0 
                                      0 
                                     0.02 
                                     0.01 
                                                                        $1.03  
                                      0 
                                    42.0% 
                                 LQG Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 
TSDF - Complete manifest 
                                      0 
                                      0 
                                     0.43 
                                     0.1 
$19.63  
$0.42  
                                    42.0% 
                                 LQG Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 
TSDF - Complete continuation sheet 
                                      0 
                                      0 
                                     0.18 
                                     0.04 
                                                                        $8.18  
$0.42  
                                     2.1% 
                                 LQG Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 
LQG - Subtotal 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
TSDF Receiver - Subtotal 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
TSDF Shippers - Manifest Completion 

Complete manfiest 
                                      0 
                                      0 
                                     0.43 
                                     0.1 
$19.63  
$0.42  
                                    100.0% 
                                 TSDF Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 
Complete continuation sheet 
                                      0 
                                      0 
                                     0.18 
                                     0.04 
                                                                        $8.18  
$0.42  
                                    5.00% 
                                 TSDF Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 
TSDF Shipper - Subtotal 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
SQG Shippers - Manifest Completion 


                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

Without TSDF assistance 

SQG - Complete manifest 
                                      0 
                                      0 
                                     0.4 
                                     0.08 
$17.97  
$0.42  
                                    20.0% 
                                 SQG Shipper-
                                  Originated 
                                  Manifests 
                                    Major 
SQG - Complete continuation sheet 
                                      0 
                                      0 
                                     0.18 
                                     0.03 
                                                                        $7.95  
$0.42  
                                     1.0% 
                                 SQG Shipper-
                                  Originated 
                                  Manifests 
                                    Major 
SQG - Subtotal 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                    Major 
With TSDF assistance 

SQG - Complete manifest 
                                      0 
                                      0 
                                     0.02 
                                     0.01 
                                                                        $1.03  
                                      0 
                                    80.0% 
                                 SQG Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 
TSDF - Complete manifest 
                                      0 
                                      0 
                                     0.43 
                                     0.1 
$19.63  
$0.42  
                                    80.0% 
                                 SQG Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 
TSDF - Complete continuation sheet 
                                      0 
                                      0 
                                     0.18 
                                     0.04 
                                                                        $8.18  
$0.42  
                                     4.0% 
                                 SQG Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 
SQG - Subtotal 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
TSDF Receiver - Subtotal 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
LQG Shippers - Exception report completion, submission, and recordkeeping 

LQG Shippers 

 Prepare and submit a signed cover letter to EPA explaining the generator's efforts to locate the hazardous waste and the results of those efforts, along with a legible copy of the manifest. 
                                      0 
                                     0.5 
                                     0.5 
                                     0.1 
$63.33  
$0.62  
                                    1.91% 
                                 LQG Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 

                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

Keep a copy of each exception report 
                                      0 
                                      0 
                                      0 
                                     0.1 
                                                                        $2.24  
$0.10  
                                    1.91% 
                                 LQG Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 
LQG - Subtotal 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
TSDF Shippers 

Prepare and submit a signed cover letter to EPA explaining the generator's efforts to locate the hazardous waste and the results of those efforts, along with a legible copy of the manifest 
                                      0 
                                     0.5 
                                     0.5 
                                     0.1 
$63.33  
$0.62  
                                    0.51% 
                                 TSDF Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 
Keep a copy of each exception report 
                                      0 
                                      0 
                                      0 
                                     0.1 
                                                                        $2.24  
$0.10  
                                    0.51% 
                                 TSDF Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 
TSDF Shippers - Subtotal 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
SQG Shippers 

Submit a legible copy of the manifest... 
                                      0 
                                     0.25 
                                     0.25 
                                      0 
$30.54  
$0.62  
                                    0.50% 
                                 SQG Shipper-
                                  Originated 
                                  Manifests 
                                   Minimal 
SQG - Subtotal 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Manifest transmittal and recordkeeping 

All Federal Manifests Together 

Sign the manifest certification and obtain the signature of the initial transporter and date of acceptance on the manifest 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                    100.0% 
                            All Federal Manifests 
                                    Major 
Keep a copy of the manifest and give the remaining copies to the initial transporter 
                                      0 
                                      0 
                                      0 
                                     0.1 
                                                                        $2.24  
$0.00  
                                    100.0% 
                            All Federal Manifests 
                                    Major 

                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

Keep a copy of the manifest returned from the designated facility  
                                      0 
                                      0 
                                      0 
                                     0.1 
                                                                        $2.24  
$0.00  
                                    100.0% 
                            All Federal Manifests 
                                    Major 
For shipments solely by water, send three copies of the manifest, dated and signed, to the designated facility or the last water transporter to handle the waste in the U.S. 
                                      0 
                                      0 
                                      0 
                                     0.16 
                                                                        $3.58  
$0.52  
                                     3.0% 
                            All Federal Manifests 
                                    Major 
For shipments by rail originating at the site of generation, send at least three copies of the manifest to the next non-rail transporter, the designated facility, or the last rail transporter to handle the waste in the U.S. 
                                      0 
                                      0 
                                      0 
                                     0.16 
                                                                        $3.58  
$0.52  
                                     6.0% 
                            All Federal Manifests 
                                    Major 
Exports - Provide the transporter with an EPA Acknowledgment of Consent and an additional copy of the manifest or shipping papers for delivery to the U.S. Customs official at the point the hazardous waste exits the U.S. 
                                      0 
                                      0 
                                      0 
                                     0.25 
                                                                        $5.60  
$0.10  
                                     1.5% 
                            All Federal Manifests 
                                    Major 
Subtotal - LQGs 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                    Major 
Subtotal - TSDF Shippers 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                    Major 
Subtotal - SQGs 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                    Major 
Undeliverable Shipments 

All Federal Manifests Together 

Designate another facility or instruct the transporter to return the waste 
                                      0 
                                      0 
                                     0.08 
                                      0 
                                                                        $3.24  
$0.00  
                                     0.1% 
                            All Federal Manifests 
                                   Minimal 
Subtotal - LQGs 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 

                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

Subtotal - TSDF Shippers 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Subtotal - SQGs 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Rejected waste and container residues 

All Federal Manifests Together 

Sign Item 18c of the manifest, if the transporter returned the shipment using the original manifest 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                    0.015% 
                            All Federal Manifests 
                                   Minimal 
Sign Item 20 of the manifest, if the transporter returned the shipment using a new manifest 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                    0.015% 
                            All Federal Manifests 
                                   Minimal 
Provide the transporter a copy of the manifest 
                                      0 
                                      0 
                                     0.17 
                                      0 
                                                                        $6.87  
$0.00  
                                    0.03% 
                            All Federal Manifests 
                                   Minimal 
Within 30 days of delivery, send a copy to the designated... 
                                      0 
                                      0 
                                      0 
                                     0.15 
                                                                        $3.36  
$0.52  
                                    0.03% 
                            All Federal Manifests 
                                   Minimal 
Retain a copy 
                                      0 
                                      0 
                                      0 
                                     0.17 
                                                                        $3.81  
$0.00  
                                    0.03% 
                            All Federal Manifests 
                                   Minimal 
Subtotal - LQGs 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Subtotal - TSDF Shippers 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Subtotal - SQGs 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Transporters 

Highway Transporters 

Sign and date the manifest 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     91% 
                            All Federal Manifests 
                                    Major 
Return a signed copy of the manifest to the generator 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     91% 
                            All Federal Manifests 
                                    Major 

                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

Ensure that the manifest (or other shipping paper) accompanies the waste to its destination 
                                      0 
                                      0 
                                     0.13 
                                      0 
                                                                        $5.26  
$0.00  
                                     91% 
                            All Federal Manifests 
                                    Major 
Obtain the date of delivery and signature of that transporter or the owner/operator of the facility or alternate facility designated on the manifest 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     91% 
                            All Federal Manifests 
                                    Major 
Retain a copy of the manifest 
                                      0 
                                      0 
                                      0 
                                     0.17 
                                                                        $3.81  
$0.00  
                                     91% 
                            All Federal Manifests 
                                    Major 
Give remaining copies of the manifest to the accepting transporter or facility 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     91% 
                            All Federal Manifests 
                                    Major 
Subtotal - Transporters 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                    Major 
Delivery to initial water transporters 

Obtain the date of delivery and signature of the initial water transporter on the manifest 
                                      0 
                                      0 
                                      0 
                                     0.01 
                                                                        $0.22  
$0.00  
                                      3% 
                            All Federal Manifests 
                                    Major 
Forward the manifest to the designated facility 
                                      0 
                                      0 
                                      0 
                                     0.16 
                                                                        $3.58  
$0.52  
                                      3% 
                            All Federal Manifests 
                                    Major 
Subtotal - Transporters 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                    Major 
Manifest requirements for water (bulk shipment) transporters 

Ensure that the shipping paper (and Acknowledgment of Consent, for exports) accompanies the waste to its destination 
                                      0 
                                      0 
                                     0.13 
                                      0 
                                                                        $5.26  
$0.00  
                                      3% 
                            All Federal Manifests 
                                    Major 

                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

If the delivering (water) transporter, obtain the date of delivery and signature of the owner/operator of the designated facility on either the manifest or shipping paper 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                      3% 
                            All Federal Manifests 
                                    Major 
If the initial water transporter, sign and date the manifest and return it to the delivering transporter so that the manifest can be forwarded to the designated facility owner/operator 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                      3% 
                            All Federal Manifests 
                                    Major 
Retain a copy of the manifest or shipping paper 
                                      0 
                                      0 
                                      0 
                                     0.17 
                                                                        $3.81  
$0.00  
                                      3% 
                            All Federal Manifests 
                                    Major 
Subtotal - Transporters 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                    Major 
Rail Transporters 

When accepting waste from a nonrail transporter, sign and date the manifest and return or transmit a signed copy of the manifest to the non-rail transporter 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                      6% 
                            All Federal Manifests 
                                    Major 
Forward at least three copies of the manifest to either the next non-rail transporter, the designated facility, or the last rail transporter designated to handle the waste in the U.S. 
                                      0 
                                      0 
                                      0 
                                     0.16 
                                                                        $3.58  
$0.52  
                                      6% 
                            All Federal Manifests 
                                    Major 

                                 Exhibit D-1 
Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 
                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 
Ensure a shipping paper containing all the information required on the manifest excluding the U.S. EPA ID number, generator certification, and signatures (and for exports an Acknowledgment of Consent) accompanies the waste 
                                      0 
                                      0 
                                     0.13 
                                      0 
                                                                        $5.26  
$0.00  
                                      6% 
                            All Federal Manifests 
                                    Major 
When delivering hazardous waste to the designated facility or to the next non-rail transporter, obtain the signature and date of delivery of the facility or non-rail transporter on the manifest 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                      6% 
                            All Federal Manifests 
                                    Major 
Retain a copy of the manifest and/or rail shipping paper 
                                      0 
                                      0 
                                      0 
                                     0.17 
                                                                        $3.81  
$0.00  
                                      6% 
                            All Federal Manifests 
                                    Major 
Before accepting hazardous waste from a rail transporter, sign and date the manifest and provide a copy to the rail transporter 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                      6% 
                            All Federal Manifests 
                                    Major 
Subtotal - Transporters 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                    Major 
Transporters importing/exporting waste 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
For imports and exports, sign and date the manifest in the International Shipments block to indicate the date that the shipment left the U.S., as required by section 263.20(g)(1) 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     2.5% 
                            All Federal Manifests 
                                    Major 
For imports and exports, retain a copy of the manifest, as required by section 263.20(g)(2) 
                                      0 
                                      0 
                                      0 
                                     0.17 
                                                                        $3.81  
$0.00  
                                     2.5% 
                            All Federal Manifests 
                                    Major 

                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

For imports give copy of import manifest to TSDF receiving facility 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     1.0% 
                            All Federal Manifests 
                                    Major 
For exports, return a signed copy of the manifest to the generator, as required by section 263.20(g)(3) 
                                      0 
                                      0 
                                      0 
                                     0.01 
                                                                        $0.22  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                    Major 
For exports, give a copy of the manifest to a U.S. Customs official at the point of departure from the 
U.S., as required by section 
263.20(g)(4) 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.10  
                                     1.5% 
                            All Federal Manifests 
                                    Major 
For exports, ensure that copies of the manifest and EPA Acknowledgment of Consent accompanies the waste, as required by section 263.20(a) 
                                      0 
                                      0 
                                     0.13 
                                      0 
                                                                        $5.26  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                    Major 
Subtotal - Transporters 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                    Major 
Undeliverable Shipments 

Contact the generator for further directions and revise the manifest according to the generator's instructions 
                                      0 
                                      0 
                                     0.08 
                                      0 
                                                                        $3.24  
$2.00  
                                     0.1% 
                            All Federal Manifests 
                                   Minimal 
Subtotal - Transporters 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Rejected waste and container residues 

For partially rejected loads made while the transporter is on site, obtain the amended manifest from the facility, keep a copy, and, if receiving the rejected waste, obtain 
the new manifest 
                                      0 
                                      0 
                                     0.1 
                                      0 
                                                                        $4.04  
$0.00  
                                    0.15% 
                            All Federal Manifests 
                                   Minimal 

                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

For fully rejected loads made or container residues identified while the transporter is on site, obtain the original manifest, as amended, from the facility 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Subtotal - Transporters 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Notification of discharge of hazardous waste 

All Transporters 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
Notify local authorities 
                                      0 
                                     0.25 
                                      1 
                                      0 
$60.87  
$0.00  
                                    0.05% 
                            All Federal Manifests 
                                     None 
Subtotal - Transporters 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                     None 
Water (bulk shipment) Transporters 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
Notify NRC, or a predesignated OSC, of the discharge 
                                      0 
                                     0.25 
                                      1 
                                      0 
$60.87  
$0.00  
                                    0.01% 
                            All Federal Manifests 
                                     None 
Subtotal - Transporters 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                     None 
TSDFs - Manifest completion, transmittal and recordkeeping 

Federal Requirements 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
Enter the name of the person accepting the waste and sign and date each copy of the manifest (or shipping paper, if applicable) 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                    99.90% 
                            All Federal Manifests 
                                    Major 
Complete the management method code 
                                      0 
                                      0 
                                     0.02 
                                      0 
                                                                        $0.81  
$0.00  
                                    99.90% 
                            All Federal Manifests 
                                    Major 
Note any discrepancies on each copy of the manifest (or shipping paper, if applicable) 
                                      0 
                                      0 
                                     0.08 
                                      0 
                                                                        $3.24  
$0.00  
                                    24.25% 
                            All Federal Manifests 
                                    Major 

                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

Immediately give the transporter at least one copy of the manifest (or shipping paper) 
                                      0 
                                      0 
                                     0.17 
                                      0 
                                                                        $6.87  
$0.00  
                                    99.90% 
                            All Federal Manifests 
                                    Major 
Within 30 days of delivery, send a copy of the manifest (or shipping paper) to the generator (or to EPAOECA for import manifests) 
                                      0 
                                      0 
                                      0 
                                     0.15 
                                                                        $3.36  
$0.52  
100.00% 
                            All Federal Manifests 
                                    Major 
Retain a copy of the manifest (or shipping paper) for at least three years from the delivery date (includes import manifests) 
                                      0 
                                      0 
                                      0 
                                     0.17 
                                                                        $3.81  
$0.00  
100.00% 
                            All Federal Manifests 
                                    Major 
Subtotal - TSDF Receiver 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                    Major 
Discrepancy report completion and submission 

Attempt to reconcile any discrepancies 
                                      0 
                                      0 
                                     0.08 
                                      0 
                                                                        $3.24  
$2.00  
                                    24.25% 
                            All Federal Manifests 
                                   Minimal 
Prepare and submit a letter to EPA describing the discrepancy and attempts to reconcile it, along with a copy of the manifest or shipping paper at issue 
                                      0 
                                     0.1 
                                     0.17 
                                     0.1 
$17.29  
$0.62  
                                    0.39% 
                            All Federal Manifests 
                                   Minimal 
Subtotal - TSDF Receiver 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Rejected waste and container residues 

Rejection of Waste after the Transporter Leaves the Facility 

Enter the name of the person accepting the waste and sign and date each copy of the manifest (or shipping paper, if applicable) 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Complete the management method code 
                                      0 
                                      0 
                                     0.02 
                                      0 
                                                                        $0.81  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 

                                 Exhibit D-1 
Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 
                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 
Immediately give the transporter at least one copy of the manifest (or shipping paper) 
                                      0 
                                      0 
                                     0.17 
                                      0 
                                                                        $6.87  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Within 30 days of delivery, send a copy of the manifest (or shipping paper) to the generator 
                                      0 
                                      0 
                                      0 
                                     0.16 
                                                                        $3.58  
$0.52  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Contact the generator to obtain the generator's instructions for forwarding the waste to another facility that can manage the waste 
                                      0 
                                      0 
                                     0.08 
                                      0 
                                                                        $3.24  
$2.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Prepare a new manifest for rejected loads or container residues sent to the alternate designated facility or back to the generator 
                                      0 
                                      0 
                                     0.43 
                                     0.1 
$19.63  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Amend the facility's copy of the manifest to indicate the rejected wastes or residues in the discrepancy space of the amended manifest 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Copy the manifest tracking number from Item 4 of the new manifest to the Discrepancy space of the amended manifest 
                                      0 
                                      0 
                                     0.02 
                                      0 
                                                                        $0.81  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Re-sign and date the manifest 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Retain the amended manifest for at 
least three years from the date of the amendment 
                                      0 
                                      0 
                                      0 
                                     0.17 
                                                                        $3.81  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 

                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

Within 30 days, send a copy of the amended manifest to the delivering transporter and to the generator 
                                      0 
                                      0 
                                      0 
                                     0.16 
                                                                        $3.58  
$0.52  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Subtotal - TSDF Receiver 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Rejection of Waste while the Transporter Remains Present at the Facility 

Enter the name of the person accepting the waste and sign and date each copy of the manifest (or shipping paper, if applicable) 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Contact the generator to obtain the generator's instructions for forwarding the waste to another facility that can manage the waste 
                                      0 
                                      0 
                                     0.08 
                                      0 
                                                                        $3.24  
$2.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Complete Item 18a and 18b of the original manifest, as applicable 
                                      0 
                                      0 
                                     0.08 
                                      0 
                                                                        $3.24  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Retain a copy of the manifest (or shipping paper) for at least three years from the date of delivery 
                                      0 
                                      0 
                                      0 
                                     0.17 
                                                                        $3.81  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Give the remaining copies back to the transporter 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     1.5% 
                            All Federal Manifests 
                                   Minimal 
Subtotal - TSDF Receiver 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Manifest completion, transmittal, and recordkeeping by Alternate TSDFs 

Enter the name of the person accepting the waste and sign and date each copy of the manifest (or shipping paper, if applicable) 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                     3.0% 
                            All Federal Manifests 
                                   Minimal 
Complete the management method code 
                                      0 
                                      0 
                                     0.02 
                                      0 
                                                                        $0.81  
$0.00  
                                     3.0% 
                            All Federal Manifests 
                                   Minimal 

                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

Note any discrepancies on each copy of the manifest (or shipping paper, if applicable) 
                                      0 
                                      0 
                                     0.08 
                                      0 
                                                                        $3.24  
$0.00  
                                     3.0% 
                            All Federal Manifests 
                                   Minimal 
Immediately give the transporter at least one copy of the manifest (or shipping paper) 
                                      0 
                                      0 
                                     0.17 
                                      0 
                                                                        $6.87  
$0.00  
                                     3.0% 
                            All Federal Manifests 
                                   Minimal 
Within 30 days of delivery, send a copy of the manifest (or shipping paper) to the generator 
                                      0 
                                      0 
                                      0 
                                     0.16 
                                                                        $3.58  
$0.52  
                                     3.0% 
                            All Federal Manifests 
                                   Minimal 
Retain a copy of the manifest (or shipping paper) for at least three years from the date of delivery 
                                      0 
                                      0 
                                      0 
                                     0.17 
                                                                        $3.81  
$0.00  
                                     3.0% 
                            All Federal Manifests 
                                   Minimal 
Subtotal - TSDF Receiver 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Unmanifested waste report: completion and submission 

Prepare and submit to EPA a letter of the unmanifested waste within 15 days after receiving waste 
                                      0 
                                     0.5 
                                      1 
                                     0.5 
$92.51  
$0.62  
                                    0.01% 
                            All Federal Manifests 
                                   Minimal 
Subtotal - TSDF Receiver 
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                        
                                   Minimal 
Reclamation Agreements 

Retain a copy of each reclamation agreement 
                                      0 
                                      0 
                                      0 
                                     0.1 
                                                                        $2.24  
$0.00  
                                    57,919 
                               Shipments under 
                                 Reclamation 
                                  Agreements 
                                     None 
Record the waste information on a log or shipping paper 
                                      0 
                                     0.25 
                                     0.75 
                                      0 
$50.76  
$0.00  
                                    57,919 
                               Shipments under 
                                 Reclamation 
                                  Agreements 
                                     None 
                                     Exhibit D-1 
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR 

                             Activity Description 
                                    Hours 
                                 Total Labor 
O&M 
 Cost 
                                 Fraction of 
Manifests 
                          Applicable Manifest Subset 
                                   RIA's 
Estimated 
Reduction 

Legal 
Managerial 
Technical 
Clerical 






$96.98  
                                   $81.73  
                                   $40.44  
                                                                       $22.40  





LQG Shippers - Manifest Completion 

Carry the record when transporting waste to the reclamation facility 
                                      0 
                                      0 
                                     0.01 
                                      0 
                                                                        $0.40  
$0.00  
                                    57,919 
                               Shipments under 
                                 Reclamation 
                                  Agreements 
                                     None 
Retain the records 
                                      0 
                                      0 
                                      0 
                                     0.17 
                                                                        $3.81  
$0.00  
                                    57,919 
                               Shipments under 
                                 Reclamation 
                                  Agreements 
                                     None 
 
 	 
D.2 Illustrations of the Manifest Process 
 
                                                                               


                                                                               
 
 

                   APPENDIX E EPA Paper Processing Cost Model 
                                        
 
Note: This Appendix contains the documentation associated with EPA's Paper Processing Cost mode. This RIA uses the model as presented in this Appendix with two alterations: 
 
       The model presented below contains calculations only for a specific electronic manifest adoption rate and under a specific number of total manifests received. This RIA revises both the electronic manifest adoption rate and the count of manifests to align with other assumptions and estimates made in the RIA. Functionally, this alteration includes: 
              Using 3.2 million total manifests rather than 5.1 million total manifests, 
              For non-electronic manifests, using the relative proportions from Chapter 5 rather than assuming that paper variant, XML variant, and image variant manifests are submitted in equal proportions from the universe of non-elctronic manifests, and 
              Using the adoption rate displayed in Chapter 5, rather than the adoption rate assumptions from the model.  
      However, the overall methodology as detailed in the Paper Processing Production and Staffing Projections based on e-Manifest Adoption Rate series of tables remains unchanged. 
       
       The model presented below originally used estimates of $50,000 annual salary for paper processing center staff, and $70,000 annual salary for analyst staff. As described in Chapter 5, to align assumptions with parameters used elsewhere in the RIA, this RIA instead assumes that routine paper processing tasks would be handled by clerical labor, with an hourly labor cost consistent with that used in the 2015 HWMS ICR, and that discrepancy-related tasks requiring analyst labor would be handled by technical labor, again with hourly labor costs consistent with those used in the 2015 HWMS ICR. Correspondingly, this RIA uses hourly labor costs directly, rather than starting with annual salary figures and deriving hourly labor costs from them. 
 
This Appendix consists of two components. The first component (Section E.1) is documentation of EPA's paper processing cost model in a narrative format, referred to as the e-Manifest Paper Processing Operations Document. The second component (Section E.2) consists of replicated tables from the accompanying spreadsheet version of the cost model.  
 
 	 
                                      E-1 
 
                                        
                                        
                                        
                                        
                                       




 
ii
 
 
D. 1 e-Manifest Paper Processing Operations Document and Cost Model 4.1 and 4.2 
                                    e-Manifest 
                          Paper Processing Operations 
 Document and Cost Model 4.1 and 4.2 
 
                                        
                                Draft Version 4 
                                October 30, 2014 
                                        
                                                              Revision History 
 
                                   Version 
                                     Date 
                                Name of Author 
                              Summary of Changes 
                                     1.0 
                                   9/12/14 
                                  Sarah Reeb 
                                   Original 
                                     2.0 
                                   10/3/14 
                                  Sarah Reeb 
Updates to Attachment A; Operational Diagram Updates to Attachment B; Staffing Model 
                                     3.0 
                                    10/21 
                                  Sarah Reeb 
Added Requirements/Edits to Operational Diagram 
                                     4.0 
                                    10/30 
                                  Sarah Reeb 
Revisions to Staffing Model, added 
Performance Standards and text from 4.2   
                                        
                                        
 
 
 
 
 
 
 

                               Executive Summary 
 
After e-Manifest implementation, the system will be optional for the regulated community, which means that the regulated community will have the option to continue to submit manifests on paper or by paper-based submission methods.  EPA will receive all paper submissions, and a paper processing center will be established where staff will manually input data, scan, and upload scanned images of the forms into the e-Manifest system.    
 
This document combines the following deliverables for e-Manifest Technical Architecture Task 4 (Paper Processing): 
 
       Deliverable 4.1: Operational Diagram. 
       Deliverable 4.2: Strategy for Transcription and Submission Options 
 	 
 
Table of Contents 
Executive Summary ........................................................................................................................ 4 
Deliverable 4.1  -  Operational Diagram .......................................................................................... 6 
Deliverable 4.2 - Strategy for Transcription and Submission Options ........................................... 6 
       Operational Diagram ............................................................................................................ 6 
       Overview of Submission Methods ....................................................................................... 6 
       Recommended Components ................................................................................................ 7 
       Production and Staffing Model ............................................................................................ 8 
       Fail Scenarios ....................................................................................................................... 9 
       Performance Standards ...................................................................................................... 10 
 
 	 
 
Deliverable 4.1  -  Operational Diagram 
This document provides an overall operational diagram for how the e-Manifest paper processing center will operate, including inputs, internal processes, and recommended components. EPA anticipates that the number of manifests submitted via the paper process will be the highest at initial system deployment, and then decrease over time as industry continues to adopt the electric system.  This document provides projected components and operations for the paper processing center based on the estimated adoption rate of the e-Manifest system.   
Deliverable 4.2 - Strategy for Transcription and Submission Options 
This document also provides recommendations for paper processing submission and transcription strategies, with a focus on Performance Standards and Operations & Maintenance of the paper processing center, and costs at the per manifest level.  Performance standards are established below for manifest transcription, setting expectations for data quality, image quality, and availability of manifest information. 
 
   1. Operational Diagram 
The attached Operational Diagram provides a process flow to include Submission, Transcription, Quality Assurance/Quality Control, and Archiving procedures for each of the submission methods accepted by the e-Manifest Paper Processing Center.  (Please see "Attachment A  - Paper Processing Operational Diagram.") 
 
   2. Overview of Submission Methods 
e-Manifest Stakeholder outreach included exploration of additional processes to make the paper process more efficient and to accommodate the needs of industry users.  The following options have been identified as acceptable submission methods for manifest submitters using the paper process.   
       Paper Submission.  Paper manifest forms are submitted by postal mail to a designated P.O. Box for retrieval by EPA paper processing staff. 
       Scanned Image Submission.  TSDF registered users with the authorized user roles may submit manifest scanned images in PDF format using CDX file transfer. 
       Scanned Image Submission with accompanying Data Transfer.  TSDF registered users with the authorized user roles may submit manifest scanned images in PDF format, and accompanying metadata in XML format, using CDX file transfer. 
 	 
   3. Recommended Components 
EPA will establish a paper processing center to perform the filing, transcription, scanning, and quality assurance of all manifests submitted through the paper process (by any of the submission methods outlined above).  Below are the recommended staff, hardware, software, and equipment components for the paper processing center e-Manifest adoption rates below are based on the eManifest Analysis of Alternatives to the Hazardous Waste Manifest System, May 15, 2013. 
 
 Component/Year 
 Year 1 
 Year 2 
 Year 3 
 Year 4 
 Year 5 
 Year 6 
 Adoption Rate 
 0% 
 25% 
 55% 
 95% 
 95% 
 95% 
 Manifests Received 
 5100000 
 3825000 
 2295000 
 255000 
 255000 
 255000 
 Staff 

  
 Full Time Staff Members 
 412 
 309 
 185 
 21 
 21 
 21 
 Equipment 

  
 Desk Top Computers 
 412 
 309 
 185 
 21 
 21 
 21 
 Scanners - Desktop :: 	Recommendation: High volume document scanners with auto-feed feature and the ability to process at high speeds, i.e. 130 pages per minute 
    (ppm) 
 20  
 15 
 9 
 1 
 1 
 1 
 Scanners (Handheld) 
 1 
 1 
 1 
 1 
 1 
 1 
 Software 

 Scanning Software Solut
ions, i.e. Kofax or Captiva software to provide the following functions 
 without altering the cont
ent of the original document: 
                                                                           :: 
Large bat
ch scanning 
                                                                           :: 
PDF Con
version 
                                                                           :: 
De-skewi
ng 
                                                                           :: 
Annotatin
g pages 
                                                                           :: 
Image en
hancement 
                                                                           :: 
Limited 
OCR for Manifest ID recognition to separate documents 
                                                                           :: 
Image qu
ality control 
                                                                           :: 
Output to 
backend solutions (i.e., e-Manifest server) 
 Other 


 Office Space  (Operations) 
  
  
  
  
  
  
 Office Supplies 
  
  
  
  
  
  
(Operations: Filing 
Supplies) 






    
   4. Production and Staffing Model 
The attached Production and Staffing Model provides performance metrics for operation of the e-Manifest paper processing center.  Based on rates of production, the model estimates the number of staff needed to process the total inventory of manifests submitted annually through the paper process.  Production and staffing needs are scaled to reflect the estimated adoption rate of the e-Manifest system.  
Please see "Attachment B - Paper Processing Production and Staffing Model.") 
 
Below is an outline of the tasks that make up the attached staffing model, including descriptions of the paper processing staff or analyst activities, and the associated data sources.  
Task 
Action performed by EPA Paper Processing Staff 
Data Source 
1) Prep  - Sort mail, Separate 
                               Supplemental Docs 
Staff retrieves TSDF submissions (see 
1.1  -  Overview of Submission Methods) and removes all documents that are not manifest standard forms, cover letters, correction letters, and continuation sheets.   
    Prep and sorting time is based on data from EPA Region 3 Superfund Records Center  -  Data Entry and Scanning Center.   
    Processing time and volume of Supplemental Documents is based on data from California DTSC outreach meetings.  
2) Process 
   Supplemental Docs (package and return to sender) 
 
All documents not listed above are returned to the submitter.  Mailing envelopes are retained until manifest data is validated. 
Processing time and volume of Supplemental Documents is based on data from California DTSC outreach meetings. 
3) Billing - Validate TSDF Address, 
                              Billing Info/Send 
                               Manifest data to 
   Billing 
Upon successful submission, staff sends manifest data to billing office.  
Processing time estimated. 
4)   Indexing/Data Entry 
 
For paper submissions and scanned image-only submissions, staff enters manifest data into the e-Manifest system  
Data entry time is based on data from EPA Region 3 Superfund Records Center  -  Data Entry and Scanning Center.   
5) Second Key Entry 
According to state outreach, double key entry is often used to increase 
Data entry time is based on data from EPA Region 3 Superfund 
Task 
Action performed by EPA Paper Processing Staff 
Data Source 

data quality. This action is TBD.  
 
Records Center  -  Data Entry and Scanning Center.   
6) Auto Validation 
   (based on e-Manifest Validation Rules) 
       
Staff submits completed data entry form, triggering auto-validation.  For Scanned image submissions, staff may validate TSDF data against registered TSDF user accounts.  For data submissions, most of the validation rules are applied upon submission with schema validation.  See attached e-Manifest Validation Rules. 
Processing time estimated. 
   7) Process Corrections - only validating new image file 
 
Staff validates scanned image uploads and performs corrections 
Volume of Corrections based on data from state outreach webinars. Processing time for corrections is based on data from California DTSC outreach meetings. 
8) Scanning 
 
Staff scans all accepted paper (postal mail) submissions 
Scanning time is based on data from 
EPA Region 3 Superfund Records Center  -  Data Entry and Scanning Center.   
9) Image QA 
For postal mail submissions, staff validates image quality and legibility. 
 
For PDF submissions, staff validates image quality and legibility, and also reviews for supplemental documents 
to return to the submitter 
  
Processing time estimated. 
10)  Rescan postal mailed manifest (if needed) 
 
Images that fail validation (and cannot be repaired digitally) will be queued for re-scanning. 
Processing time estimated. 
11)  Electronic Archiving 
 
Manifest data and content files will be retained for at least 3 years before disposal.  (Exact retention time TBD). 
Processing time estimated. 
 
   5. Fail Scenarios 
In some cases, missing information may disrupt the workflow outlined above.  In the case of missing TSDF contact information, missing billing information, or unresolved corrections, analysts will be employed to contact TSDF users directly and resolve the issues.   The following Fail Scenarios have been identified to define points at which a manifest may be routed to an analyst for processing.   
 
Fail Scenarios 
Action performed by Analyst 
Data Source 
Fail Scenario 1 - No Return Address  
Analyst contacts submitter to collect a valid return mailing address. (Necessary for returning supplemental documents and Generator and Transporter manifest copies to the submitter.) 
Processing time estimated. 
Fail Scenario 2 - TSDF 
Email Address Not 
Valid 
Analyst contacts submitter to collect a valid email address, necessary for returning supplemental documents and sending auto-notifications to trigger the TSDF correction process. 
Processing time estimated. 
Fail Scenario 3 - TSDF Not Registered 
Analyst contacts TSDF to process registration. All submitters using CDX will be unable to submit without registering first.  
Processing time estimated. 
Fail Scenario 4 - TSDF Billing Info Missing 
Analyst contacts TSDF to collect billing information. 
Processing time estimated. 
Fail Scenario 5  - 
Outstanding Corrections (not resolved within 30 days) 
The system auto-reports corrections not resolved within 30 days.  Analyst contacts TSDF to resolve the issue.  
Processing time estimated. 
   6. Performance Standards 
 
The following performance standards apply to paper processing staff handling manifest submission, transcription, and QA.   
 
Performance Requirement 
Performance Standard 
Method of Measurement 
Processing Time  Timetable for data availability in e-
Manifest scanned images and data will be made available in the e-Manifest system no more than 90 days after the 
The system will generate log files to report the timetables of availability of final data in 

Manifest 
 
TSDF signature date (indicating receipt of waste at the storage facility). 
 
Once manifest data is available in the system, states shall be able to access the data immediately for queries/reports. 
 
The system shall provide archived content files within 24 hours of request. 
 
e-Manifest. 
Image Quality Standard Applies to manifests submitted by postal mail and scanned by paper processing staff.   
Scanned images must exhibit a degree of legibility comparable to the source document.  
 
A minimum resolution level of 300 DPI/PPI (grayscale) is required.   
 
After scanning, staff will perform image validation to confirm legibility and general image quality.  Images that fail validation (and cannot be repaired digitally) will be queued for re-scanning.  
Data Entry Accuracy 
Applies to data transcribed by paper processing staff from a manifest in paper or PDF format.  
Minimum acceptable accuracy rate: 99% of the data reported in e-Manifest should be identical to the information on the source documents.  The remaining 1% should be identified in the paper processing validation and correction process.  
 
This standard allows for 1 keystroke error per every two manifest forms processed.*  A keystroke error is defined as a value that: 
       does not match the source document and 
       is not corrected by the original entrant  before auto-validation.  
*There are 52 keystrokes per manifest, according to the ORCR Case Study State Government Annual Costs for 
Collecting & Processing Completed 
RCRA Hazardous Waste Paper Manifests. 
The system will generate log files to report keystroke errors that are identified in autovalidation. 
 

                                                                               
D.2. Spreadsheet Model: eManifest Paper Processing Production and Staffing Model 
 
 Paper Processing Production and Staffing Projections Based on eManifest Adoption Rate
Total # of Manifests
                                                                      5,100,000
 
 Projected eManifest Adoption Rate (source: eManifest Analysis of Alternatives, May 15, 2013)	Equipment Needs

 Fiscal Year
eManifest 
Adoption Rate
# Manifests Received via Paper Process
# of Paper Processing Staff 
Members Needed to Process 
Annual Inventory
Paper Processing 
Staff Labor Cost
# Analysts Needed to process Fails
Analyst Labor Cost (to 
Process Fail 
Scenarios) 
Total Labor 
Cost
 Year 1
                                                                             0%
                                                                      5,100,000
                                     389.4
 $       19,471,410
                                     112.5
 $                7,875,866
 $ 27,347,277
 Year 2
                                                                            25%
                                                                      3,825,000
                                     292.1
 $       14,603,558
                                     84.4
 $                5,906,900
 $ 20,510,457
 Year 3
                                                                            55%
                                                                      2,295,000
                                     175.2
 $         8,762,135
                                     50.6
 $                3,544,140
 $ 12,306,274
Year 4
                                                                            95%
                                                                        255,000
                                     19.5
 $             973,571
                                      5.6
 $                    393,793
 $   1,367,364
 Year 5
                                                                            95%
                                                                        255,000
                                     19.5
 $             973,571
                                      5.6
 $                    393,793
 $   1,367,364
Year 6
                                                                            95%
                                                                        255,000
                                     19.5
 $             973,571
                                      5.6
 $                    393,793
 $   1,367,364


# Desktop 
Computers 
Needed
# Desktop 
Scanners 
Needed
# Handheld 
Scanners 
Needed
                                      502
                                      20
                                                                              1
                                      376
                                      15
                                                                              1
                                      226
                                       9
                                                                              1
                                      25
                                       1
                                                                              1
                                      25
                                       1
                                                                              1
                                      25
                                       1
                                                                              1

 
PP Staff Annual Salary
                                                                         50,000
Analyst Annual Salary
                                                                         70,000
 
 BREAKDOWN OF DATA:
 
 Paper Process Submissions Based on Adoption Rate of eManifest
 
 
Breakdown of 
Submission 
Methods  
(Variable)
Year 1

Year 2

Year 3

Year 4 

Year 5

Year 6
Adoption Rate	


                                                                             0%

                                                                            25%

                                                                            55%

                                                                            95%

                                                                            95%
                                                                            95%
 Total Manifests Received by  Paper Processing Center


5,100,000

                                                                      3,825,000

2,295,000

255,000

 255,000
                                                                        255,000
Paper
                                                                          33.3%

1,698,300

                                                                      1,273,725

 764,235

 84,915

                                                                         84,915
                                                                         84,915
 Scanned Image/No data
                                                                          33.3%

1,698,300

                                                                      1,273,725

 764,235

 84,915

                                                                         84,915
                                                                         84,915
 Scanned Image & XML
                                                                          33.3%

1,698,300

                                                                      1,273,725

 764,235

 84,915

                                                                         84,915
                                                                         84,915
 Hours Needed to Process Total Manifests via Paper Process Each Year


Year 1

Year 2

Year 3
Year 4
Year 5

Year 6
Paper 
                                                                          33.3%

402,198.99

                                                                     301,649.25
                                                                     180,989.55
                                                                      20,109.95

20,109.95
                                                                      20,109.95
 Scanned Image/No data 
                                                                          33.3%

289,630.16

                                                                     217,222.62
                                                                     130,333.57
                                                                      14,481.51

14,481.51
                                                                      14,481.51
 Scanned Image & XML 
                                                                          33.3%

 87,027.26

                                                                      65,270.45
                                                                      39,162.27
                                                                       4,351.36

 4,351.36
                                                                       4,351.36
Total


778,856.41

                                                                     584,142.31
                                                                     350,485.39
                                                                      38,942.82

38,942.82
                                                                      38,942.82
 Staff Needed to Process Total Manifests via Paper Process Each Year

Year 1

Year 2

Year 3
Year 4

Year 5

Year 6
 # Manifests Received

5,100,000

                                                                      3,825,000
                                                                      2,295,000

255,000

 255,000
                                                                        255,000
 # Paper Processing Staff Members Needed

                                                                          389.4

                                                                          292.1
                                                                          175.2

                                                                           19.5

                                                                           19.5
                                                                           19.5
# Analysts Needed

                                                                          112.5

                                                                           84.4
                                                                           50.6

                                                                            5.6

                                                                            5.6
                                                                            5.6
Total FTEs

                                                                          501.9

                                                                          376.5
                                                                          225.9

                                                                           25.1

                                                                           25.1
                                                                           25.1
 
 
# Desktop Computers Needed

                                                                            502
                                                                            376
                                                                            226
                                                                             25
                                                                             25
                                                                             25
# Desktop  Scanners Needed

                                                                             20
                                                                             15
                                                                              9
                                                                              1
                                                                              1
                                                                              1
# Handheld Scanners Needed

                                                                              1
                                                                              1
                                                                              1
                                                                              1
                                                                              1
                                                                              1
 	12 	 
eManifest Paper Processing Production and Staffing Model
Hours to Process Total Inventory of Manifests Submitted via Paper Process

(1) Prep (Sort mail, Separate 
Supplemental 
Docs)
(2) Process 
Supplemental Docs (package and return to sender)
(3) Validate TSDF 
Address and 
Billing Info
(4) 
Indexing/Data 
Entry
(5) Second Key 
Entry
(6) Auto 
Validation (based on e-Manifest Validation Rules)
(7) Process Corrections - validating new image file?
(8) Scanning
(9) Electronic QA (Image quality and data quality)
(10) Archiving
Total Hrs
Paper 
          42,457.5
                                                                      12,737.25
                                                                      13,586.40
         112,918.9
      112,918.9
                           -
                                                                       19,955.0
               45,167.6
      42,457.50
                       -
    402,199.0
Scanned Image/No data 
          42,457.5
                                                                         212.29
                                                                           0.00
         112,918.9
      112,918.9
                           -
                                                                       21,122.6
                            -
                     -
                       -
    289,630.2
Scanned Image & XML 
                       -
                                                                           0.00
                                                                           0.00
                      -
                   -
                           -
                                                                        2,112.3
                         -
        84,915.0
                       -
      87,027.3
Total
          84,915.0
                                                                      12,949.54
                                                                      13,586.40
         225,837.8
      225,837.8
                           -
                                                                       43,189.9
               45,167.6
      127,372.5
                       -
    778,856.4
Hours to Process Fail Scenarios (X Analyst)	Hours to Process Total Inventory (X FTE)	Hours Worked (Industry Standard)

Fail Scenario 1 - No Return 
Address for Gen 
& Transporter 
Copies, 
Supplemental 
Docs
Fail Scenario 2 - 
TSDF Email 
Address Not Valid
Fail Scenario 3 - TSDF Not 
Registered
Fail Scenario 4 - TSDF Billing Info Missing (only applicable to postal mailed manifests)
Fail Scenario 5  





- Outstanding 
Corrections (not resolved within 30 days)
# Fails x Hours per Fail
          8,491.50
            12,737.25
                        -
         84,915.00
    118,881.00






Total Analyst Hours
      225,024.75




Total Hrs
Total Months
Total FTE
Paper
          402,198.99
                5.48
              201.10
Scanned Image/No
          289,630.16
                3.95
              144.82
Scanned Image & X
             87,027.26
                1.19
                43.51
Total
             778,856.4
              10.62
              389.43

                                                                              1
                                                                            440
1 Month
166.6666667
 73333.33333
1 Year
                                                                           2000
                                                                         880000
	FTE	1 FTE	X FTE
                                                                                                   
 
                                      13
DATA SOURCES:
Performance Metrics - Processing Time by Task (Variable, based on Industry Standards)

(1) Prep (Sort mail, Separate 
Supplemental 
Docs)
(2) Process 
Supplemental Docs (package and return to sender)
(3) Billing.  
(Validate TSDF 
Address, Billing 
Info/Send 
Manifest data to 
Billing)
Fail Scenario 1 - No Return 
Address for Gen 
& Transporter 
Copies, 
Supplemental 
Docs
Fail Scenario 2 -
TSDF Email 
Address Not 
Valid
Fail Scenario 3 - TSDF Not 
Registered

Fail Scenario 4 - TSDF Billing Info 
Missing

(4) Indexing/Data 
Entry
(5) Second Key Entry
(6) Auto 
Validation 
(based on e-
Manifest 
Validation 
Rules)
(7) Process Corrections - only 
validating 
new image 
file
Fail Scenario 
5  - 
Outstanding 
Corrections (not resolved within 30 days)
(8) Scanning
(9) QA Image File (postal mailed manifests for image quality, image files sent in XML are reviewed for supplemental docs as well) 
Rescan postal mailed manfiest (if needed)
(10) 
Electronic 
Archiving
Hours/Box
                                                                              2
                                                                            0.6







                                                                              5
                                                                              5
                                                                            1.5
                                                                              2

                                                                              2
                                                                            0.3

                                                                           0.66
Documents/Box
                                                                             80
                                                                            4.8







                                                                           75.2
                                                                           75.2
                                                                           75.2
                                                                           7.52

                                                                           75.2
                                                                           75.2

                                                                             80
Hrs/Manifest (Paper)
                                                                          0.025
                                                                          0.125
                                                                          0.008
                                                                           0.25
                                                                           0.25

0

1
                                                                    0.066489362
 0.066489362
                                                                              0
                                                                          0.125
                                                                              1
0.026595745
                                                                          0.025
 0.02659574
                                                                              0
Hrs/Manifest (Scanned 
Image/No Data)
                                                                          0.025
                                                                          0.025
                                                                              0
                                                                              0
                                                                           0.25

0

0
                                                                    0.066489362
 0.066489362
                                                                              0
                                                                          0.125
                                                                              1
                                                                              0
                                                                              0
                                                                              0
                                                                              0
Hrs/Manifest (Scanned 
Image & XML)
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                           0.25

0

0
                                                                              0
                                                                              0
                                                                              0
                                                                          0.125
                                                                              1
                                                                              0
                                                                           0.05
                                                                              0
                                                                              0
Manifests/Hour
                    40.0
                                                                              8







                        15.0
                 15.0
                    50.1
                                                                           3.76

                37.6
                                                                              0

            100.0

Number of Manifests per Year by Submission Method (Variable)
Total Manifests

                                                                      5,100,000
Paper
                                                                          33.3%
                                                                        1698300
Scanned Image/No data
                                                                          33.3%
                                                                        1698300
Scanned Image & XML
                                                                          33.3%
                                                                        1698300
Supplemental Docs by Submission Method
Supplemental Docs
% of docs received contain supplemental docs
Number of 
Manifests with 
Supplemental 
Docs
Paper
                                                                           6.0%
                                                                         101898
Scanned Image/No data
                                                                           0.5%
                                                                         8491.5
Scanned Image & XML
                                                                           0.5%
                                                                         8491.5
Submission Breakdown (Based on Data from CA DTSC)	Fail Scenarios Per Year (variable)
Scenario
% of  
Manifests 
Failed (Postal 
Mail)
# of Fails 
Annually (Postal 
Mail)
% of  
Manifests 
Failed (Image 
File)
# of Fails 
Annually 
(Image File)
% of  
Manifests 
Failed (Data 
File)
# of Fails 
Annually (Data 
File)
Fail Scenario 1 - 
No Return Address 
for Gen & Transporter 
                                                                             2%
                                                                          33966
                                                                             2%
                                                                          33966
                                                                             2%
                                                                          33966
Copies 
Fail Scenario 2 - 
TSDF Email 
Address Not Valid
                                                                             1%
                                                                          16983
                                                                             1%
                                                                          16983
                                                                             1%
                                                                          16983
Fail Scenario 3 - TSDF Not 
Registered
                                                                             0%
                                                                              0
                                                                             0%
                                                                              0
                                                                             0%
                                                                              0
Fail Scenario 4 - TSDF Billing Info 
Missing
                                                                             5%
                                                                          84915
                                                                             0%
                                                                              0
                                                                             0%
                                                                              0
Fail Scenario 5  - 
Outstanding Corrections (not resolved within 30 days)
                                                                             3%
                                                                          50949
                                                                             3%
                                                                          50949
                                                                             1%
                                                                          16983
Documents/Box*
100% of Documents
                                                                             80
Manifests/Box*
94% of Documents
                                                                           75.2
Supplemental 
Docs/Box*
6% of Documents
                                                                            4.8
Corrections/Box*
10% of 
Manifests
                                                                           7.52
Corrections
% of docs received fail validation (go through correction process)
Number of manifests needing corrections
Paper
                                                                            10%
                                                                       159640.2
Scanned 
Image/No data
                                                                            10%
                                                                      168980.85
Scanned Image & XML (this includes image file QA failures)
                                                                             1%
                                                                      16898.085
Corrections by Submission Method
 * Refers to a File Box, which holds an average of 80 (2-5 paged) documents. Used as a united of measurement for tracking rates of indexing, scanning, and other paper processing tasks. When applied to electronic submissions, a "box" simply means a set of 80 documents. 
      14

       APPENDIX F e-Manifest Technical Architecture: Helpdesk Operations 
                                        
                                        
                                                                             	 
                                      F-1 
 
 
 
                                         
     e-Manifest Technical Architecture  Helpdesk Operations 
                                        
                                        
                                        
                               Final Version 1.0 
                                November 5, 2014 
                                        
                                                              Revision History 
 
                                    Version 
                                     Date 
                                Name of Author 
                              Summary of Changes 
                                     1.0 
                                    8/25/14 
                               Christopher Ludwa 
                                   Original 
                                     1.0 
                                    11/5/14 
                               Christopher Ludwa 
                                    Final 
                                        
                                        
                                        
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                                             	 
                              Executive Summary 
EPA, in coordination with States, industry and related stakeholders, is developing a national electronic manifest (e-Manifest) system that would facilitate the electronic transmission of the uniform manifest form and make the use of the manifest much more cost-effective and convenient for users. The e-Manifest system will have a dedicated Helpdesk to assist users with use of the system and facilitate the reporting of system issues to development staff. 
This document describes the proposed operations of the e-Manifest Helpdesk, including an estimate of tickets that the Helpdesk is likely to receive, the tiering structure, handling of tickets related to the paper manifest, the interface with other helpdesks, the avenues for receiving tickets from users, and a cost estimate to establish and maintain a dedicated Helpdesk. This document also clearly identifies the requirements that will be established in a Request for Proposals (RFP) and resulting contract issued by EPA to operate the e-Manifest Helpdesk. 
 
 	 
 
Table of Contents 
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Executive Summary	4 
1.0  Overall Recommended Layout for the Helpdesk	8 
1.1  Hours of Operation	8 
1.2  Basic Operations	9 
1.3  Coordination with EPA	10 
2.0  Review of Helpdesk Software	10 
2.1  Software Capabilities	11 
2.2  Knowledgebase	11 
3.0  Estimated Ticket Volume and Labor Hours Needed to Resolve the Tickets	12 
3.1  Estimated Ticket Volume	12 
3.2  Labor Hours Needed to Resolve the Tickets	14 
4.0  Tiering Structure	15 
4.1  Basic Tiering Structure	15 
4.2  Responsibilities or Services Provided by Each Tier	16 
5.0  Personnel	17 
5.1  Number of Personnel	17 
5.2  Experience and Education	17 
5.3 Knowledge and Demeanor	17 
5.4 Training	18 
5.5  Identification of Contractor Personnel	18 
6.0  Paper Manifest Processing	19 
7.0  Interface with Central Data Exchange (CDX) Help Desk and Other EPA Helpdesks	20 
8.0  Integration of States to Address Programmatic and State-Specific Questions	21 
9.0  Avenues for Receiving Tickets	22 
9.1 Automated Telephone Response	22 
9.2 Live Telephone Response	23 
9.3 Electronic Correspondence	24 
9.4 Chat	25 
9.5 Directly Through the e-Manifest System	25 
9.6 Social Media	26 
9.7  Mobile Application (App)	26 
10.0  Cost Estimate to Establish and Maintain a Dedicated Helpdesk	27 
10.1  Calculations	27 
10.2  Assumptions	28 
11.0  Scope or Topics Covered	29 
12.0  Quality Control Structure	30 
Appendix A  -  Hazardous Waste Manifest and Continuation Sheet Examples	33 
Appendix B  -  Helpdesk Software	36 
Appendix C  -  Helpdesk Ticket Volumes	38 
Appendix D  -  Cost Estimate	39 


 
EXHIBITS 
 
TABLES 
Table 3-1: Annual Labor Hours at Certain e-Manifest System Adoption Levels.......................14 
Table 5-1: FTE at Certain e-Manifest System Adoption Levels .......................................16 
Table 10-1: Agents Needed at Certain Ticket Levels.................................................... 26 
Table 10-2: Ticket Volume for Each Level of User Adoption......................................... 27 
Table 10-3: Annual Cost for Each Level of User Adoption ............................................ 27 
Table 12-1: Accuracy Payments and Penalties ........................................................... 30 
1.0 	Overall Recommended Layout for the Helpdesk 
EPA, in coordination with States, industry and related stakeholders, is developing a national electronic manifest (e-Manifest) system that would facilitate the electronic transmission of the uniform manifest form. The hazardous waste manifest and manifest continuation sheet, EPA Forms 8700-22 and 8700-22A, are a relatively unique EPA form or report (current example versions provided in Appendix A). It accompanies the transportation of hazardous waste 24 hours a day and requires the signature of all individuals involved in the chain of custody, as opposed to a one-time or annual submission. The manifest requirements also apply to a very wide, diverse range of stakeholders, from large commercial treatment, storage, and disposal facilities (TSDFs) to small, family owned hazardous waste generators. As a result, the e-Manifest system will also be a unique information technology (IT) system with unique functions and requirements. Therefore, it will be important to have a resource dedicated to assisting the wide range of users that will use and interact with the system. 
In order to accommodate the unique aspects of the e-Manifest system, the Helpdesk will need to tailor its operations to provide the best possible support for users. In addition to standard business hours, the Helpdesk may need to be available at some capacity 24 hours a day to support the constant transportation industry (subject to available resources). Along with standard means of receiving tickets from users such as telephone and e-mail, the Helpdesk may need to offer support through chat, directly through the system, social media, and/or a mobile application. The Helpdesk will need to be able to communicate effectively and courteously with the wide range of stakeholders that will be using the e-Manifest system. Finally, as the eManifest system is developed, implemented, and refined, the contractor operating the Helpdesk will need to be flexible and coordinate closely with EPA to ensure a high level of service for users. 
1.1 	Hours of Operation 
As resources allow, EPA currently envisions that the e-Manifest Helpdesk shall be available 24 hours a day, 7 days a week, and 365 days a year to answer questions from the hazardous waste industry. The Helpdesk shall be available Monday through Friday from the hours of 7am to 9pm Eastern Time (ET) for State agencies, consultants, and the general public (peak hours). During off-peak hours, if callers do not identify their organizational affiliation, Helpdesk agents will need to ask their affiliation and direct all non-industry callers to call back during peak hours. Telephone lines will be open to communicate routine information via recorded messages 24 hours a day, 365 days a year. 
Requirement 
Number 
Requirement Description 
TBD 
The Helpdesk telephone lines will provide information via recorded messages 24 hours a day, 365 days a year. 
TBD 
If resources allow and as specified by EPA, Helpdesk agents will be available 24 hours a day, 365 days a year for industry; Monday through Friday, from the hours of 7am to 9pm Eastern Time for States and the general public. 
1.2 	Basic Operations 
During scheduled operational hours, the Helpdesk shall not be shut down without prior approval from the EPA Project Officer or Contracting Officer, except for an emergency, such as a fire or fire alarm in the building, local severe weather conditions, or other local disasters. This requirement will be evaluated using quality control (QC) review methods and the service level agreement (SLA) for call center availability. 
The primary language for spoken and written communication shall be English; however, the contractor shall have the capability to receive and respond to inquiries from Spanish-speaking users.  The contractor doesn't necessarily have to provide real-time assistance or designate a separate Helpdesk agent for Spanish inquiries; this capability may be accomplished through voicemail, a callback system, or other means. 
EPA strongly prefers that the contractor that operates the Helpdesk be an American company and the physical location be in the United States. 
The Helpdesk must be available to support initial testing and development of the e-Manifest system, as well as testing and development of new versions after initial deployment, to identify potential Helpdesk problems or questions and the appropriate means for resolution. 
Requirement 
Number 
Requirement Description 
TBD 
The Helpdesk shall not be shut down for any reason other than a bona fide emergency. 
TBD 
The Helpdesk shall have the ability to communicate in both English and Spanish. 
TBD 
The Helpdesk shall be available to support testing and development of the e-Manifest system. 
1.3 	Coordination with EPA 
Due to the unknown inquiry volume that the Helpdesk is expected to receive, the likely surge of inquiries expected as users initially adapt the e-Manifest and paper processing process, and the unique requirements of the hazardous waste manifest process, the Helpdesk contractor must be flexible and will need to coordinate closely with EPA. Additionally, due to the 24-hour nature of the hazardous waste transportation industry, the contractor must be able to provide support offhours such as weekday nights, weekends, and holidays. 
To facilitate this coordination, during the testing and development phase and for the first 6 months after system launch, the Helpdesk contractor must participate in daily conference calls and weekly in-person meetings. During the testing and development phase, the purpose of these calls will be to identify potential Helpdesk questions or problems that will arise and the appropriate means for resolution. After system launch, the purpose of these meetings will be to go over a weekly status report that should include call metrics, staffing levels, top 10 frequently asked questions (FAQs), and any other questions or concerns. 
The Helpdesk will also provide daily raw call metric reports by 9am ET to the EPA Project Officer and other designated EPA staff as well as summaries on a weekly and monthly basis. Raw call metrics and summaries of call metrics shall include at a minimum call volume, wait times, abandonment rate, and other metrics to be specified by the EPA Project Officer. 
Requirement 
Number 
Requirement Description 
TBD 
The Helpdesk shall be flexible and coordinate closely with EPA. 
TBD 
The Helpdesk shall participate in daily conference calls and weekly in-person meetings. 
TBD 
The Helpdesk shall provide daily raw call metric reports by 9am ET to the EPA Project Officer and designated EPA staff as well as summaries on a weekly and monthly basis. 
TBD 
The Helpdesk shall provide a weekly status report that includes a summary of call metrics, staffing levels, top 10 FAQs or topics, and any other issues or concerns. 
2.0 	Review of Helpdesk Software 
The e-Manifest Helpdesk contractor will need to utilize software to effectively and efficiently perform its operations. Appendix A provides a list of software options, which was developed using a review of the software programs currently in use by other EPA programs and other industry products available.  The Helpdesk contractor must either utilize one of the programs from the list in Appendix A or review the list and state why an alternative, unlisted product is superior to the ones listed in Appendix A. 
Requirement 
Number 
Requirement Description 
TBD 
The Helpdesk must utilize a software program from Appendix A or state why the product that they use is superior. 
2.1 	Software Capabilities 
Based on the expected functions of the Helpdesk, the software will need to have the following capabilities: 
       Ability to accept, process, and send outgoing electronic correspondence 
       Ability to track questions received via telephone including the creation of tickets from voicemails and providing a voicemail to text copy of the voicemails in the ticket 
       Ability to track tickets received electronically and chat sessions 
       Ability to support workflow processes for tickets that requiring escalation 
       Ability to integrate/coordinate with other helpdesks 
       Date- and time-stamp capabilities 
       Ability to create, manage, and publish FAQs to a knowledgebase 
2.2 	Knowledgebase 
As part of its operations, the Helpdesk shall be responsible for using the selected software program to maintain a knowledgebase of FAQs related to the e-Manifests system. During testing and development of the e-Manifest system, the Helpdesk contractor shall work with EPA to develop an initial set of FAQs in the knowledgebase. After initial launch of the e-Manifest system, the contractor will be responsible for maintaining the knowledgebase and creating new FAQs as new questions arise. When writing an FAQ, the contractor must do a review to ensure that the FAQ is not a duplicate or state conflicting information from any other FAQs. 
Also upon activation of the system, all tickets (phone, e-mail, etc.) closed by the helpdesk must refer to at least one knowledgebase FAQ. To measure performance against this requirement, the contractor will be required to track the percentage of tickets that refer to a knowledge base FAQ. For tickets that do not have a relevant knowledge base FAQ that addresses the topic, the contractor must create an FAQ and add it to the ticket. Regardless of the number of tickets that do not have an existing knowledgebase FAQ, the contractor must create at least 3 new FAQs each month. 
Requirement 
Number 
Requirement Description 
TBD 
100% of tickets closed by the Helpdesk must refer to at least one knowledgebase FAQ, unless a relevant one does not exist. 
TBD 
For tickets where a knowledgebase FAQ does not exist, an FAQ must be created and added to the ticket. 
TBD 
The Helpdesk must create at least 3 FAQs each month to ensure that the FAQ database does not go stale and is constantly fresh. 
3.0 	Estimated Ticket Volume and Labor Hours Needed to Resolve the Tickets 
The single most important factor in planning to operate a helpdesk or hotline is the number of tickets that it will receive. The volume of tickets that a helpdesk receives will determine the labor hours needed to the resolve the tickets; the type, size, and cost of software need to respond to inquiries; and the cost to operate the helpdesk. 
3.1 	Estimated Ticket Volume 
In estimating the ticket volume that will be received by the e-Manifest Helpdesk, there are several factors that could significantly affect this volume, including: 
          The percentage of TSDFs that are submitting paper manifests for processing and that contact the Helpdesk 
          The percentage of the total number of manifest stakeholders that adopt use of the eManifest system 
          The number of individual users for each stakeholder that utilizes the system 
          The use of new electronic signature methods to sign the e-manifest that have not been used for signature of EPA forms 
          The percentage of e-Manifest users that contact the Helpdesk 
          The fact that there is a highly variable set of stakeholders, especially small generators 
          A likely initial surge in tickets received by the Helpdesk after the e-Manifest system is launched. 
To extrapolate a reasonable range for the estimated ticket volume that the Helpdesk will receive, a set of statistics from several EPA helpdesks and regulatory call centers is provided in Appendix B. Another solution for estimating ticket volume the e-Manifest Helpdesk will receive is to analyze the volume of tickets received by existing helpdesks that support State manifest systems or hotlines that support State manifest programs. This State data should be used in addition to other methods of estimating the ticket volume for e-Manifest since there is limited data available from the States. During a stakeholder meeting on July 2, 2014, New Jersey indicated that staff respond to 1,300-1,400 calls annually, covering all environmental topics addressed by their hotline. During the same meeting, Michigan, Minnesota, and Maine indicated that the number of staff that supported their hotlines ranged from 8 to 16 to answer all RCRA calls, 5 staff specifically available to answer manifest and site ID questions. 
It should be noted that the volume of tickets received by other EPA helpdesks and call centers and volume received by State helpdesks represents the volume received regarding systems or programs that are at a steady state. In other words, the IT system or regulatory program has been established for a number of years and stakeholders have had time to become familiar with it. Based on this data, it is estimated that the e-Manifest Helpdesk could receive as many as 24,000 tickets annually once the e-Manifest system reaches a steady state (the CDX Help Desk received a higher volume, but it covers over 70 systems either in production or test). Until the e-Manifest system reaches this steady state, the number of tickets received by the Helpdesk will likely be higher upon initial deployment of the e-Manifest system but will also be largely dependent on the percentage of users that adopt use of the system. 
Another option for estimating the ticket volume that the e-Manifest Helpdesk will receive is to estimate the number of users of the e-Manifest system and how many will subsequently contact the Helpdesk. The e-Manifest cost benefit analysis (CBA) estimates that there will be 171,941 stakeholders in 2015, assumed to be the year that the e-Manifest Helpdesk will begin operations to provide support during development of the e-Manifest system. This stakeholder number includes hazardous waste generators, transporters, and TSDFs, as well as brokers or service providers that support these parties. There will be some stakeholders that will have more than one individual user of the system; however, it is unknown how many stakeholders will have multiple users and therefore the total number of industry users is also unknown. Also, even if multiple users exist for a given stakeholder, only one user may contact the Helpdesk for assistance such as in the case of a question or problem with the submission of a particular electronic manifest. Therefore, the total number of possible users of the e-Manifest system in 2015 is assumed to be the same as the number of industry stakeholders, 171,941. Applying assumed values for the percentage of users that actually adopt the use of the system, the number of adopted users that contact the Helpdesk, and a likely initial increase or surge due to the system being new, an estimate of the number of tickets can be developed. Table 10-2 presents three estimates based on the percentage of system adoption: the estimated ticket volume for a 10% adoption level is approximately 9,585; the volume for a 25% adoption level is 23,963; and the volume for a 40% adoption level is 38,340. 
In addition to industry users, there will also likely be at least one user per State and EPA 
Regional office that will be using the e-Manifest system and potentially contacting the Helpdesk. Again, the exact number of State and EPA Regional users of the system is currently unknown. In addition, even if there are multiple users per State or EPA Region, this number will be minor compared to the number of industry users and therefore is not included in calculating the estimated ticket volume. 
3.2 	Labor Hours Needed to Resolve the Tickets 
Due to the difficulty in developing a reliable estimate of the number of tickets that the e-Manifest Helpdesk will receive, EPA could benefit from implementing a banding strategy when issuing the RFP for operation of the Helpdesk. In this strategy, EPA would request the contractor to provide a cost estimate for certain bands, or levels, of service. EPA could develop these bands based on a number of assumptions (provided in Section 10.2) and possible levels of adoption of the e-Manifest system. Using this strategy, Table 3-1 presents the annual number of labor hours that would be needed to meet the Helpdesk performance requirements (primarily the percentage of calls answered within a specified time). These hours were developed as part of the cost estimates in Appendix C. 
Table 3-1: Annual Labor Hours at Certain e-Manifest System Adoption Levels 
Metric 
10% Adoption 
25% Adoption 
40% Adoption 
Tier 1 Hours, 7am-9pm, M-F 
      6,652.8 
     9,979.2 
     13,305.6 
Tier 1 Hours, All Other Times 
      4,708.8 
     4,708.8 
     4,708.8 
Total Tier 1 Hours 
     11,361.6 
     14,688.0 
     18,014.4 
Tier 2 Hours, 7am-9pm, M-F 
       739.2 
     1,108.8 
     1,478.4 
Tier 2 Hours, All Other Times 
       523.2 
       523.2 
       523.2 
Total Tier 2 Hours 
      1,262.4 
     1,632.0 
     2,001.6 
Total Tier 1 and 2 Hours 
     12,624.0 
     16,320.0 
     20,016.0 
4.0 	Tiering Structure 
In order to efficiently route tickets to individuals that are best suited to handling them, the Helpdesk shall establish an appropriate tiering structure. 
4.1 	Basic Tiering Structure 
Based on the expected range of possible tickets that the e-Manifest Helpdesk would need to handle, the Helpdesk contractor shall establish two tiers, Tier 1 and Tier 2, to handle tickets and be able to coordinate with the e-Manifest development team (Tier 3).  Tier 1 Helpdesk agents shall receive and initially attempt to resolve all tickets and should be adequately trained to recognize tickets that would more appropriately handled by Tier 2 Helpdesk agents or that should be referred to Tier 3.  Upon award of the Helpdesk contract, the contractor shall work with EPA to develop a standard operating procedure (SOP) for triaging calls amongst different tiers of Helpdesk level. 
Under this tiering structure, 90% of total contacts must be resolved at the Tier I level. First contact completion applies when the first person that the customer reaches answers the question, resolves the problem or dispatches service where appropriate. 
Requirement 
Number 
Requirement Description 
TBD 
90% of total contacts must be resolved at the Tier I level. 
TBD 
The Helpdesk shall create an SOP for triaging calls. 
4.2 	Responsibilities or Services Provided by Each Tier 
Based on an analysis of the types of calls that the Helpdesk may receive, the contractor can expect to address the following topics under each service Tier: 
 
Tier 1 
    Password resets 
    User account maintenance 
    Basic electronic manifest creation, transmission, and submission 
    General questions about where to send paper manifests, data files, and images 
    General questions about how to submit paper manifests, e.g. which documents to send 
    Confirmation of known system tickets and any possible workarounds 
    Data access and reporting 
    Other paper documents received with the paper manifest 
    Electronic signatures Tier 2 
    Fee questions 
    Lost manifests Tier 3 
    Technical issues or glitches that require system or development changes 
    Questions or comments regarding a new system release 
    Issues identified by the paper processing center such as incorrect validation rules and issues with XML 
Although this list provides a general approach, questions regarding an individual topic would not always be handled by the same Tier. The need to escalate a call or ticket would depend on several question-specific factors, such as the urgency of the question, the circumstances of the topic, and whether it has been reported previously. 
5.0 	Personnel 
The operation of a Helpdesk relies on effective communication and customer service; therefore, the people that are selected to operate the Helpdesk are the most important factor in ensuring successful operations. 
5.1 	Number of Personnel 
As described above in Section 3.2, estimates for labor hours were developed for three levels of adoption of the e-Manifest system. These labor hours can then be used to determine the full-time equivalent (FTE) personnel needed for each level of the Helpdesk: 
Table 5-1: FTE at Certain e-Manifest System Adoption Levels 
Metric 
10% Adoption 
25% Adoption 
40% Adoption 
Total Tier 1 FTE 
        5.5 
                                        7.1 
        8.7 
Total Tier 2 FTE 
        0.6 
                                        0.8 
        1.0 
 
Based on the need to operate the Helpdesk 24 hours a day, 7 days a week for industry, the labor hours would likely need to spread over several more manageable Helpdesk shifts handled by multiple personnel, as displayed in the cost estimates in Appendix C. 
5.2 	Experience and Education 
All personnel assigned to the Helpdesk shall have appropriate professional experience and education to ensure that the contractor meets the performance standards, requirements, and SLAs described in this document and specified in the Helpdesk contract. 
 
Requirement 
Number 
Requirement Description 
TBD 
All Helpdesk personnel shall have appropriate professional experience and education to ensure that the contractor meets the contractual performance standards, requirements, and SLAs. 
5.3 	Knowledge and Demeanor 
In addition to education and experience, the contractor shall ensure that all personnel assigned to the e-Manifest Helpdesk are proficient in reading, writing and speaking English, and be able to communicate clearly and effectively with users.  As noted in Section 1.2, the Helpdesk shall have the ability to receive and respond to inquiries from Spanish-speaking users; therefore, at least one individual should be proficient in reading, writing, and speaking Spanish. 
Personnel shall also possess the requisite knowledge and skills to receive tickets, perform required processing and research functions (including the ability to read and comprehend EPA technical documents), and provide complete, accurate, and concise responses. Personnel shall also have demeanors that are conducive to this type of work (i.e., customer service focus, professionalism, cooperativeness, a positive attitude, and a willingness to provide assistance). EPA will evaluate this requirement using QC review methods, e.g., EPA will evaluate customer service during test calls and have the ability to administer or receive audio copies of these test calls. 
Requirement 
Number 
Requirement Description 
TBD 
All Helpdesk personnel shall have the appropriate knowledge, demeanor, and training conducive to operating the Helpdesk. 
TBD 
All Helpdesk personnel shall be proficient in reading, writing and speaking English, and be able to communicate clearly and effectively with users. 
TBD 
At least one Helpdesk agent should be proficient in reading, writing, and speaking Spanish. 
TBD 
EPA shall have the ability to administer or receive audio copies of test calls. 
5.4 	Training 
The contractor shall ensure their employees have adequate training to carry out all requirements associated with operating the Helpdesk and will be responsible for training Helpdesk staff to respond to information requests on all technical topics covered by the Helpdesk. EPA will evaluate this requirement using QC review methods, e.g., EPA may join and audit contractor trainings. 
Requirement 
Number 
Requirement Description 
TBD 
The contractor shall ensure their employees have adequate training to carry out all requirements associated with operating the Helpdesk. 
5.5 	Identification of Contractor Personnel 
At the commencement of all interactions, contractor personnel shall identify themselves as EPA contractors. This applies to both oral and written communications. It is especially relevant when answering the telephone (a recorded message at the beginning of each Helpdesk call shall be used for identification purposes), placing follow-up calls to requesters, or when placing "research calls" to gather information for a response. 
Requirement 
Number 
Requirement Description 
TBD 
Contractor personnel shall identify themselves as EPA contractors in all oral and written communications through the Helpdesk. 
6.0 	Paper Manifest Processing 
The e-Manifest system will be optional for the regulated community, which means that the regulated community will have the option to continue to submit manifests on paper. Users will be required to submit the paper manifests to EPA, whereas the paper manifests are currently being submitted to the States. To handle the paper manifests, EPA will establish a Paper 
Processing Center to manually input data from typed or handwritten manifests into the eManifest system. To effectively support the processing of paper manifests that EPA will continue to receive, the e-Manifest Helpdesk will need to be familiar with the basic process for submitting paper manifests and coordinate closely with the staff that operates the manifest Paper Processing Center. 
Calls received based on the paper manifest shall be initially processed in much the same manner as calls related to electronic manifests: Tier 1 agents will attempt to assist the user with the question and escalate any tickets that cannot be resolved to the Tier 2 level. The Helpdesk can provide assistance with general questions about where to send paper manifests, data files, and images and general questions about how to submit paper manifests, e.g., which documents to send. However, the Helpdesk will not answer questions about specific paper manifests; the Paper Processing Center will be in charge of issues identified with specific manifests. Therefore, any questions or tickets regarding receipt of specific paper manifests by the EPA Paper Processing 
Center will require the Helpdesk to route the question to the Paper Processing Center. The Helpdesk should also direct any questions regarding the quality assurance and correction processes for paper manifests to the Paper Processing Center. Additional information about the procedures for the Paper Processing Center is available in the e-Manifest Paper Processing Operations Document and Cost Model. 
To improve coordination with the Paper Processing Center, the Helpdesk shall designate at least one individual to serve as a coordinator with the center and maintain a close working relationship. 
Furthermore, the e-Manifest Helpdesk will not answer questions about the completion of specific fields on the paper manifest. Such questions should be transferred or referred to either the EPA regulatory resource described above or to the State contract, as described in Section 8.0 below. 
Requirement 
Number 
Requirement Description 
TBD 
The Helpdesk shall coordinate closely with the manifest Paper Processing Center. 
TBD 
The Helpdesk shall designate at least one individual to serve as a coordinator with the Paper Processing Center and maintain a close working relationship. 
7.0 Interface with Central Data Exchange (CDX) Help Desk and Other EPA Helpdesks 
EPA requires the e-Manifest Helpdesk contractor to establish a set of SOPs for interfacing with other EPA helpdesks and hotlines. Due to the fact that the e-Manifest system will utilize CDX, the most frequent interactions will most likely involve the CDX Help Desk. Examples of topics that might require interaction with the CDX Help Desk include but are not limited to user registration and electronic signatures. Furthermore, the e-Manifest system may make use of CDX 
Web Services; if those services are down, the e-Manifest Helpdesk would need to be notified so Helpdesk personnel can help users. In general, the e-Manifest Helpdesk must be constantly aware of areas of the system that may not be functioning on a daily basis and report any CDX services that are not functioning to the CDX Help Desk. 
The Helpdesk contractor shall add a message on the phone tree and establish a standard procedure for Helpdesk agents to direct callers with CDX issues to contact the CDX Help Desk. For better customer service, EPA requires that e-Manifest Helpdesk agents provide an option to directly connect callers to the CDX Help Desk. For tickets or other electronic correspondence regarding a CDX issue, e-Manifest Helpdesk agents shall directly transfer the tickets if both helpdesks are using the same software; otherwise, they will need to send the ticket via e-mail to the CDX Help Desk. The e-Manifest Helpdesk shall follow the same procedures when transferring callers or tickets to other EPA helpdesks or hotlines. 
Requirement 
Number 
Requirement Description 
TBD 
Helpdesk agents must directly connect callers when transferring to another EPA helpdesk and remain on the line to ensure that the person is connected. 
8.0 	Integration of States to Address Programmatic and StateSpecific Questions 
EPA requires the e-Manifest Helpdesk contractor to establish an SOP for addressing RCRA regulatory or programmatic questions and State-specific questions. EPA requires the Helpdesk contractor to add a message on the phone tree and establish a standard procedure for Helpdesk agents to direct callers with hazardous waste manifesting or general RCRA regulatory or programmatic questions related to national policy, or callers that wish to contact EPA regarding RCRA regulatory or programmatic questions, to the appropriate resource for these questions.  
This resource is currently the Waste Department of EPA's Electronic Customer Service Solution (ECSS) at http://waste.supportportal.com. For tickets or other electronic correspondence regarding RCRA regulatory or programmatic questions that should be addressed by EPA, eManifest Helpdesk agents shall directly transfer the tickets if both helpdesks are using the same software; otherwise, they will need to send the ticket to the Waste Department of ECSS via email. 
For questions related to the implementation of the RCRA regulations or program, as well as callers with State-specific questions, Helpdesk agents should direct callers to the appropriate contact or Website. Upon initial system development, States will provide the appropriate contact information to EPA and the Helpdesk. The Helpdesk shall maintain this list of State contacts and verify the information every six months. For better customer service, EPA requires that Helpdesk agents look up the relevant State contact or Website and provide an option to directly connect callers if it is a telephone number. 
The e-Manifest Helpdesk shall not provide assistance with the completion of specific manifest fields, whether the manifest was completed electronically or by paper. Such questions should be transferred or referred to either the EPA regulatory resource described above or to the State contract, as appropriate.  
Requirement 
Number 
Requirement Description 
TBD 
The Helpdesk shall direct callers and tickets with EPA RCRA regulatory or programmatic issues to the appropriate resource as directed by EPA. 
TBD 
The Helpdesk shall maintain a list of State contacts and verify the information every 6 months. 
TBD 
The Helpdesk shall direct callers and tickets with issues related to RCRA 
implementation or State-specific requirements to the appropriate resource as provided by the State. 
TBD 
The Helpdesk shall not provide assistance with the completion of specific manifest fields. 
9.0 	Avenues for Receiving Tickets 
Helpdesk agents shall provide accurate, complete, courteous and expeditious responses to inquiries via the following avenues: 
       Automated telephone response and voicemail 
       Live telephone response 
       Electronic correspondence 
       Chat (optional) 
       Directly through the e-Manifest system (optional) 
       Social media (optional) 
9.1 	Automated Telephone Response 
Telephone lines shall be open twenty-four (24) hours a day to communicate routine information via recorded messages. These messages can provide information about outages, known issues, and other hot topics related to the e-Manifest system, and direct users to the ORCR website, FAQs, or other sources for additional information. Upon award, the contractor shall coordinate with EPA to develop the phone tree and any applicable messages. Users should also be given the option to leave a voicemail, which will be returned during normal hours of operation. The Helpdesk must respond to 100% of voicemails within 24-48 hours from receipt. 
 
Requirement 
Number 
Requirement Description 
TBD 
The Helpdesk shall coordinate with EPA to develop the phone tree and any applicable messages. 
TBD 
The Helpdesk must respond to 100% of voicemails within 24-48 hours from receipt. 
9.2 	Live Telephone Response 
Although live telephone responses are often thought of as being a time-intensive avenue for handling inquiries, in our experience, live telephone responses can actually be a more efficient mechanism than electronic responses. Through a conversation with the caller, a Helpdesk agent is able to ask follow up questions to gather additional information and facts and diagnose the problem or answer the question in a timelier manner. To establish the e-Manifest Helpdesk telephone option, EPA will need to establish a toll-free telephone number and the toll-free number will redirect to a local number operated by the Helpdesk contractor. 
To minimize wait times for callers, the Helpdesk must answer 85% of calls within 2 minutes, measured by the length of time it takes a user to connect with a customer service representative (CSR). Additionally, no more than 5% of calls may be abandoned or transferred to voicemail, measured by the percentage of calls that come into the Helpdesk that hang up, are disconnected, or transferred to voicemail before the service provider's agent answers the phone. The Helpdesk phone system must be available for 99.9% of the hours of operation, as measured by the total available hours divided by the total hours in the measurement period. 
In order to document the interaction with the user and maintain contact information for followup, Helpdesk personnel must collect a phone number and e-mail address or corporate e-mail address. The Helpdesk must collect a phone number for 95% of calls and an e-mail address for 75% of calls. This metric will be measured by the percentage of phone tickets with a valid phone number or e-mail address. Additionally, the Helpdesk must summarize all calls in the electronic database and share the summary with the user. If a call is interrupted or dropped before the ticket is resolved, the Helpdesk agent will attempt to contact the user via telephone. If live contact cannot be reestablished, the Helpdesk agent should note this in the ticket and send an e-mail to the user. 
Any threats received by the Helpdesk must be taken seriously and reported to the appropriate authorities, if necessary, and to the EPA Project Officer. 
Requirement 
Number 
Requirement Description 
TBD 
85% of calls must be answered by the Helpdesk within 2 minutes. 
TBD 
No more than 5% of calls may be abandoned or transferred to voicemail before a Helpdesk agent answers the phone. 
TBD 
The Helpdesk phone system must be available for 99.9% of the hours of operation. 
TBD 
Helpdesk personnel must collect a phone number for 95% of calls. 
TBD 
Helpdesk personnel must collect an e-mail address for 75% of calls. 
TBD 
The Helpdesk shall summarize all calls in the electronic database and share the summary with the user. 
TBD 
If a call is interrupted or dropped before the ticket is resolved, the Helpdesk agent will contact the user via telephone or e-mail. 
9.3 	Electronic Correspondence 
The Helpdesk will receive inquiries electronically (tickets, equivalent to e-mails) twenty-four (24) hours a day via the selected helpdesk software program. Contact information and ticket submission capabilities will be included on all EPA-developed e-Manifest interfaces. The Helpdesk will respond to electronically received questions during the applicable hours of operation noted in Section 1.2; i.e., the Helpdesk shall respond to questions received from industry 24 hours a day, 7 days a week, and 365 days a year. The Helpdesk must provide a notice of receipt, which may be automated, to let the user know that their e-mail was received and that they should expect a response within 8-24 hours. The Helpdesk must also provide at least an initial response for all tickets, regardless of Tier, within 24 hours; therefore, for tickets that have not been resolved within 24 hours, the Helpdesk must send an initial response with an update on the status of the ticket. The Helpdesk must track how long tickets remain unresolved, or ticket "open time", and resolve 90% of Tier 1 tickets within 8 hours and 100% of Tier 1 tickets within 24 hours. Tickets that require Tier 2 or Tier 3 support may take longer, especially if a bug is identified from the ticket; in those cases, the ticket will require EPA to direct the system contractor to fix the bug before the ticket can be closed. The Helpdesk may not escalate a ticket appropriately handled at the Tier 1 level to another Tier simply to consider it resolved; EPA will monitor appropriate escalation using the quality control methods identified in Section 12.0. All times specified for resolution are measured using hours that the Helpdesk is in operation. 
 
 
Requirement 
Number 
Requirement Description 
TBD 
For all tickets, the Helpdesk must send a notice of receipt with an estimated time for resolution. 
TBD 
100% of tickets must have an initial response within 24 hours. 
TBD 
The Helpdesk must resolve 90% of Tier 1 tickets within 8 hours and 100% of Tier 1 tickets within 24 hours. 
9.4 	Chat 
In coordination with EPA, the Helpdesk contractor shall explore the use of a chat function to answer questions from e-Manifest users. Upon contract award, the contractor shall prepare an analysis of the cost associated with using the function and deliver to EPA. If executed, EPA will announce the option to chat with the Helpdesk in the e-Manifest system and the contractor will begin using the function. During any period in which chat is used, the contractor shall provide any available metrics on the frequency, length, and topics of chat sessions. If the usage does not justify the cost of the feature, EPA may direct the contractor to discontinue its use. During its use, the contractor shall record all chat sessions. Chat sessions will be counted as tickets and follow the same requirement for resolution, i.e., the Helpdesk must track how long questions from chat sessions remain unresolved and resolve 90% of Tier I chat session questions within 8 hours and 100% within 24 hours. Chat sessions that require Tier 2 or Tier 3 support may take longer, especially if a bug is identified from the chat session; in those cases, EPA will need to direct the system contractor to fix the bug before the chat sessions can be resolved. The Helpdesk may not escalate a chat session issue appropriately handled at the Tier 1 level to another Tier simply to consider it resolved; EPA will monitor appropriate escalation using the quality control methods identified in Section 12.0. All times specified for resolution are measured using hours that the Helpdesk is in operation. 
Requirement 
Number 
Requirement Description 
TBD 
The Helpdesk must record all chat sessions. 
TBD 
The Helpdesk must resolve 90% of chat session questions within 8 hours and 100% of chat session questions within 24 hours. 
9.5 	Directly Through the e-Manifest System 
Pending system development and in coordination with EPA and system developers, the Helpdesk contractor shall explore the use of a function to answer questions submitted directly through the e-Manifest. This functionality could be similar to a component of RCRAInfo, the User Support Issue Tracking System (USITS). USITS is the tool used by the entire RCRAInfo user community to initiate a request for change as part of the RCRAInfo Change Management Process (CMP). USITS allows the RCRAInfo user community to enter and track the status of all issues, change requests, and system bugs. As the RCRAInfo user community submits requests for change through the CMP, the USITS System Administrator (SA) reviews the changes and categorizes them into the appropriate change management types. 
If executed and developed in the e-Manifest system, EPA will announce the option to submit questions to the Helpdesk directly through the system and the contractor will begin using the function. During any period in which this function is used, the contractor shall provide any available metrics on the frequency and topics of questions submitted directly through the system. If the usage does not justify the cost of the feature, EPA may direct the contractor to discontinue its use. There will be no specific requirements or SLAs initially established for answering questions submitted directly through the e-Manifest system. 
9.6 	Social Media 
In coordination with EPA, the Helpdesk contractor shall explore the use of social media to communicate information with e-Manifest users. For example, EPA may request that the Helpdesk establish and maintain a Twitter account to send out updates to followers of the account with information about system outages or upgrades. If executed, EPA will announce the option to communicate with the Helpdesk via social media in the e-Manifest system and the contractor will begin using the function. During any period in which this function is used, the contractor shall provide any available metrics on the frequency and topics of questions submitted through social media. If the usage does not justify the cost of the feature, EPA may direct the contractor to discontinue its use. There will be no specific requirements or SLAs initially established for answering questions received via social media. 
9.7 	Mobile Application (App) 
In the event that EPA develops a mobile app for the e-Manifest system, the Helpdesk contractor shall explore the ability to provide assistance to e-Manifest users through the app, such as an "Ask Us" or "Contact Us" form that would be submitted to the Helpdesk. If executed, EPA will announce the option to communicate with the Helpdesk via the mobile app in the e-Manifest system and the contractor will begin using the function. During any period in which this function is used, the contractor shall provide any available metrics on the frequency and topics of questions submitted through the app. If the usage does not justify the cost of the feature, EPA may direct the contractor to discontinue its use. There will be no specific requirements or SLAs initially established for answering questions received via the mobile app. 
10.0 Cost Estimate to Establish and Maintain a Dedicated Helpdesk 
As described in Section 3, it is difficult to estimate the volume of tickets that the e-Manifest Helpdesk will receive and the resulting labor hours; likewise, it is difficult to develop an accurate estimate of the cost to operate the Helpdesk. Using a similar banding strategy as described for the labor hours, cost estimates can be developed for differing bands of service based on the percentage of users that adopt the system. 
10.1 Calculations 
To calculate the labor hours and cost for each band of the Helpdesk, the number of agents needed for the peak hours (7am-9pm) was first determined. Using the Erlang equation, a formula that calculates a statistical equation to predict queuing times, agent workloads, and optimal agent levels, the Helpdesk would need to provide the staffing levels identified in Table 10-1 to meet the performance requirements specified in this Operations Document. 
Table 10-1: Agents Needed at Certain Ticket Levels 
                                Ticket Volume 
                                    Agents 
                                 0  -  3,641 
                                      1 
                               3,642  -  14,867 
                                      2 
                              14,868  -  28,793 
                                      3 
                              28,794  -  44,046 
                                      4 
Next, an estimate of the number of tickets for each band of user adoption was developed, applying several modifying factors and based on the assumptions in Section 10.2. Using the information in Table 10-1, the number of agents needed at each band can be determined. This information is provided in Table 10-2. 
 
Table 10-2: Ticket Volume for Each Level of User Adoption 
                                Adoption Rate 
                               Potential Users 
                    Number Adopted (Users * Adoption Rate) 
                   Helpdesk Contacts (Adopted Users * 30%) 
                    Initial Increase (1.86 * Steady State) 
Agents 
                                     10% 
                                   171,941 
                                   17,194.1 
     5,158.2 
                                   9,585.0 
                                      2 
                                     25% 
                                   171,941 
                                   42,985.3 
    12,895.6 
                                   23,962.6 
                                      3 
                                     40 % 
                                   171,941 
                                   68,776.4 
    20,632.9 
                                   38,340.1 
                                      4 
With the number of agents determined for peak hours, a cost estimate can be developed for each band of user adoption, as displayed in Appendix C. A summary of the cost for each band of user adoption levels is provided in Table 10-3. 
Table 10-3: Annual Cost for Each Level of User Adoption 
Adoption Rate 
                                     Cost 
10% 
    $988,414.86 
25% 
                                 $1,247,689.26 
40 % 
                                 $1,506,963.66 
10.2 Assumptions 
The following assumptions apply to the cost estimate described above and provided in Appendix C. 
       The Helpdesk will begin operations in 2015 to provide support during system development 
       As resources allow, the Helpdesk will be open 24 hours/day, 365 days/year for industry; 7am-9pm, Monday-Friday for States and public 
       From the hours of 7am-9pm, Monday through Friday, SLA is 85% of calls must be answered in 2 minutes 
       From the hours of 7am-9pm, Monday through Friday, the Helpdesk would be required to have either 2, 3, or 4 agents available, depending on adoption rate and subsequent call volume 
       From the hours of 7pm-9am, Monday through Friday, and Saturday and Sunday, the Helpdesk would be required to have 1 agent available 
       The total number of potential users that would contact the Helpdesk is equal to the number of industry stakeholders as identified in the 2013 e-Manifest CBA 
       Average call length is 8 minutes 
       The type of users (e.g., generator versus transporter versus State employee) will likely affect the call length, but the likely distribution spread among the types of users will not impact the overall average call length 
       Calls are distributed equally throughout the month and year 
       Tier 1 CSRs would earn $50,000/year 
       Tier 2 CSRs would earn $65,000/year 
       Tier 1 CSRs will handle approximately 90% of calls, Tier 2 CSRs will handle the remaining 10% (does not include tickets escalated to EPA SMEs or developers, which is considered Tier 3) 
       The system administrator would be necessary to operate and maintain phone system equipment and would earn $115,000/year; this cost would be shared with any other helpdesks operated by the contractor and is assumed to be 500 hours per year specifically for the e-Manifest Helpdesk 
       Helpdesk management hours are 5% of total hours 
       Cost estimate does not include hardware such as computers and telephones and basic computer software, which would be provided by contractor and not charged to the contract 
       Cost estimate does not distinguish between calls and emails or other electronic correspondence; the way the cost model is set up, it is providing a service level for a hypothetical range of inquiries, which could also be emails, chat sessions, etc. 
       Upon initial launch, 30% of users will have questions and contact the Helpdesk 
       At initial launch, the amount of inquiries will be 1.86 times higher than when the system reaches a steady state. 
11.0 Scope or Topics Covered 
Based on our analysis and feedback from potential stakeholders, we have determined that the scope of the e-Manifest Helpdesk will include, but not limited to, the following topics that are likely to arise within the system: 
             User accounts 
             Usernames and passwords 
             Creation and transmission of electronic manifests 
             General questions about the submission of paper manifests, images, and data files 
             Lost and duplicate manifests 
             Electronic signature 
             Digitized signature pads 
             Unregistered users attempting to sign electronic manifests 
             Fee collection 
             Errors in data 
             System issues 
             Support during system development 
             How to complete the e-Manifest or web form :: Biennial report questions (not included in Phase 1). 
The Helpdesk contractor shall track the topics of all tickets received at the Helpdesk and provide this information to EPA in the weekly status report. 
The scope of the Helpdesk will include all users of the e-Manifest system, including the hazardous waste industry (generators, transporters, and TSDFs), State government employees, EPA employees, and the general public. The Helpdesk should be aware of the differences in the type of support needed among the different types of users that contacts the Helpdesk. In addition, the Helpdesk shall track the types of users that contact the Helpdesk and provide the information to EPA in the weekly status report. EPA may specify that the Helpdesk establish a separate queue or line for specific users that may need specialized assistance due to the nature of their inquiry (e.g., transporters on the side of the road or temporarily stopped at another site). 
Requirement 
Number 
Requirement Description 
TBD 
The Helpdesk shall track the topics of all tickets and include the information in the weekly status report. 
TBD 
The Helpdesk shall track the type of users and include the information in the weekly status report. 
12.0 Quality Control Structure 
EPA will monitor all Helpdesk operations performed by the contractor for compliance with the terms and conditions of the contract and performance requirements specified in this document. 
In addition to the performance requirements for timeliness of responses, the Helpdesk must also meet a performance standard for accuracy. To review performance against this stand, EPA will conduct random test calls and review contractor-generated electronic correspondence to analyze for accuracy and consistency of information. This criteria does not simply mean that a given answer or information was wholly inaccurate; also counting towards incorrect responses would include tickets that were not appropriately escalated to a higher Tier, referrals to the incorrect external helpdesk or State contact, or poor grammar in written electronic responses. 
The Helpdesk contractor will receive an incentive payment as applied to their fixed monthly payment if random sampling by the EPA Project Officer determines that over a certain percentage (see table 12-1) of information provided was accurate and consistent with established technical specification, Web content, and response guidance. Conversely, the Helpdesk contractor will incur a penalty, or reduction in their fixed monthly payment, if random sampling determines that over a certain percentage (see table 12-1) of information provided was inaccurate or inconsistent. 
Table 12-1: Accuracy Payments and Penalties 
Percentage Correct 
Incentive or Penalty (% of monthly payment) 
                                97% or higher 
                                      3% 
                                     96% 
                                      2% 
                                     95% 
                                      1% 
                                     90% 
                                     -1% 
                                     87% 
                                     -2% 
                                     85% 
                                     -3% 
                                        
In addition to accuracy, the Helpdesk must maintain high levels of customer service. Therefore, the Helpdesk may receive no more than 5 valid complaints about the service provided on calls or tickets per month. 
Throughout the period of performance, the contractor shall provide access, upon reasonable notice, to the EPA Project Officer and other authorized EPA staff members to observe the Helpdesk's operations, including the receipt, management, and response to inquiries.  EPA will also conduct random test calls and have the ability to administer or receive audio copies of these test calls. 

Requirement 
Number 
Requirement Description 
TBD 
The Helpdesk may receive no more than 5 valid complaints about the service provided per month. 
TBD 
The Helpdesk contractor will receive either an incentive payment or penalty based on Government review of accuracy and consistency of information. 
TBD 
EPA will conduct random test calls and have the ability to administer or receive audio copies of these test calls. 

Appendix A  -  Hazardous Waste Manifest and Continuation Sheet Examples 
 	 





Appendix B  -  Helpdesk Software 
 
Software 
Benefits 
Drawbacks 
Costs 
Environment 
Website 
Parature Customer 
Service Software 
(from Microsoft) 
Currently used Agency-wide to manage FAQs and respond to tickets, including by ORCR for RCRA questions 
(http://waste.supportportal.com); would allow Helpdesk agents to easily transfer tickets from e-Manifest Helpdesk to Waste queue for regulatory or programmatic questions 
Somewhat limited functionality 
Small Office (6 customer service representatives 
(CSRs)) - $6,468/year 
Medium Office (18 CSRs) 
- $30,861/year 
Additional CSRs are an additional $1200/year Service is ordered through the Working Capital Fund 
Cloud Based 
http://www.parature.com/ 
Oracle RightNow 
Contact Center 
Experience 
Extensive functionality and customization; currently in use by CDX Help Desk, which would allow Helpdesk agents to easily transfer tickets from e-Manifest Helpdesk to CDX Help Desk for system issues 
Functionality available well beyond what is needed for basic Help Desk ticketing; expensive 
No price on website 
Cloud Based 
http://www.oracle.com/us/products/app lications/rightnow/contact-centerexperience/overview/index.html 
 
https://cloud.oracle.com/service?tabID
=1383678932050 
Request Tracker 
Good at tracking the history of a ticket 
  
Open source, so the software is free; hosting partnership with Gossamer 
Threads that ranges from 
$125/month to 
$3250/month, depending on ticket volume 
On-Premises or Cloud Based 
https://www.bestpractical.com/rt/ 
Microsoft Dynamics 
CRM 
Interoperability with Office 365, can integrate with Social Media, and can prioritize tickets by using SLAs  
Price based on user 
$65/user/month 
On-Premises 
http://www.microsoft.com/enus/dynamics/crm.aspx 
Footprints 
Customization, extensive reports, various user access roles 
Slow; expensive 
$6900/year for 5 fixed and 
8 concurrent licenses 
On-Premises 
http://www.bmc.com/it-
solutions/footprints-service-core.html 

JIRA 
SLA reporting, customizable team queues, real-time reporting; JIRA Agile project management tool available 
Cumbersome; hosted pricing expensive 
$745/month (for eRule); more pricing breakdowns on the website which vary based on number of users and cloud vs. server based 
On-Premises or Cloud Based 
  
Zendesk 
Cheaper, more simplistic packages available, can integrate with social media 
No custom roles/permissions for cheaper options 
$25/user/month to 
$195/user/month based on services 
On-Premises 
http://www.zendesk.com 
Freshdesk 
Cheap; real time chat 
Relatively basic 
$16/agent/month to 
$70/agent/month 
On-Premises 
http://freshdesk.com/helpdeskmanagement/ticketing-system 
Happyfox 
Catered towards government; cheap 
Relatively basic 
$9/agent/month to 
$29/agent/month 
Cloud Based 
https://www.happyfox.com 
IssueTrak 
Used by USDA, ARMY. Can access through mobile phone or web browser, highly customizable, secure  
Likely expensive and challenging to set up 
Can install on own servers and pay once, lease on your own servers and pay annual, or install on the cloud and pay monthly. 
On-Premises or Cloud Based 
http://www.issuetrak.com/help_desk 
Novo Solutions 
Used by NOAA, NAVY, ARMY, 
DOJ; both Intranet and Extranet use; robust functionality 
Expensive, requires at least five users 
Professional Plan (5 - 10 users) - Base $795 plus $350/User for On-Premises hosting; $35/User/Month for Cloud hosting 
On-Premises or Cloud Based 
http://www.novosolutions.com/it-helpdesk-software/ 
Appendix C  -  Helpdesk Ticket Volumes 
 
Metric 
RCRA 
Hotline 
Manifest 
Questions 
HMIC 
Shipping 
Papers 
Calls & 
Emails 
Toxics 
Release 
Inventory 
Calls 
Federal 
Docket 
Management 
System 
(FDMS) 
Calls 
RCRAInfo 
User 
Support 
Calls & 
Emails 
EPA Info 
Center 
Calls 
eRule Helpdesk 
Calls 
RCRA 
Hotline 
Calls 
ENERGY 
STAR 
Calls 
DOT 
HMIC 
Calls & 
Emails 
CDX 
Help 
Desk 
National 
Lead Info 
Center 
CDX 
Lead Fee 
Tickets 
Year 
2004 
2013 
2013 
2013 
2004 
2013 
2013 
2004 
2013 
2013 
2013 
2013-14 
2012-13 
Approx. 
Stakeholders 
160,000 
250,000 
21,025 
9,596 
2,100 
1,168,500 
 
160,000 
 
250,000 
253,638 
 
 
January 
51 
207 
69 
203 
76 
372 
737 
1,033 
1,178 
2,301 
2,898 
1,477 
3 
February 
60 
175 
77 
157 
95 
606 
628 
1,371 
1,039 
2,008 
2,825 
1,320 
3 
March 
61 
154 
96 
154 
113 
403 
643 
1,178 
1,172 
2,046 
3,387 
1,612 
7 
April 
57 
131 
133 
162 
85 
499 
665 
998 
1,363 
2,207 
3,551 
1,650 
4 
May 
43 
191 
324 
168 
68 
652 
622 
786 
2,727 
2,575 
5,717 
1,638 
3 
June 
46 
161 
1,243 
181 
127 
1,560 
633 
928 
1,658 
2,424 
16,299 
1,878 
8 
July 
67 
141 
224 
165 
85 
479 
549 
913 
1,846 
2,189 
5,552 
1,824 
 
August 
79 
137 
54 
177 
95 
346 
568 
961 
1,705 
2,094 
2,440 
1,871 
 
September 
64 
104 
41 
154 
91 
297 
503 
835 
1,595 
1,963 
2,135 
1,611 
5 
October 
67 
65 
24 
103 
96 
179 
472 
734 
1,001 
1,158 
2,175 
889 
14 
November 
42 
90 
52 
171 
46 
267 
763 
693 
1,530 
1,635 
2,477 
1,359 
2 
December 
42 
68 
33 
147 
54 
294 
549 
646 
1,364 
1,359 
2,915 
1,096 
5 
Total 
679 
1,624 
2,370 
1,942 
1,031 
5,954 
7,332 
11,076 
18,178 
23,959 
52,371 
18,225 
54 

Appendix D  -  Cost Estimate 
Table D-1: Cost Based on 10% Adoption 
 
                                    Staff 
                                    Salary 
                              Hourly Loaded Rate 
                         [(Salary/2060)* Multiplier] 
                                 Target Rate 
                            (Loaded Rate plus 15%) 
Annual Hours 
                                  Total Cost 
Tier 1 CSR #1 (7am2pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #2 (7am2pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #3 (2pm9pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #4 (2pm9pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #5 (9pm2am, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1188.00 
                                                                    $80,910.87 
Tier 1 CSR #6 (2am7am, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1188.00 
                                                                    $80,910.87 
Tier 1 CSR #7 (7am3pm, Sa-Su) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                        777.60 
                                                                    $52,959.84 
Tier 1 CSR #8 (3pm11pm, Sa-Su) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                        777.60 
                                                                    $52,959.84 
Tier 1 CSR #9 (11pm7am, Sa-Su) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                        777.60 
                                                                    $52,959.84 
Tier 2 CSR #1 (7am2pm, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        369.60 
                                                                    $32,723.95 
Tier 2 CSR #2 (2pm9pm, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        369.60 
                                                                    $32,723.95 
Tier 2 CSR #3 (9pm2am, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        132.00 
                                                                    $11,687.13 
Tier 2 CSR #4 (2am7am, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        132.00 
                                                                    $11,687.13 
Tier 2 CSR #5 (7am3pm, Sa-Su) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                         86.40 
                                                                     $7,649.76 
Tier 2 CSR #6 (3pm11pm, Sa-Su) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                         86.40 
                                                                     $7,649.76 
Tier 2 CSR #7 (11pm7am, Sa-Su) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                         86.40 
                                                                     $7,649.76 
Project Manager 
                                                                         85000 
                                                                        100.68 
                                                                        115.78 
                                                                        180.00 
                                                                    $20,840.68 
Program Manager 
                                                                        135000 
                                                                        159.90 
                                                                        183.89 
                                                                         20.00 
                                                                     $3,677.77 
Sys Admin 
                                                                        115000 
                                                                        136.21 
                                                                        156.65 
                                                                        500.00 
                                                                    $78,322.82 
Totals 
 
 
 
                                                                         13324 
                                                                   $988,414.86 
  	 
Table D-2: Cost Based on 25% Adoption 
 
                                    Staff 
                                    Salary 
                              Hourly Loaded Rate 
                         [(Salary/2060)* Multiplier] 
                                 Target Rate 
                            (Loaded Rate plus 15%) 
Annual Hours 
                                  Total Cost 
Tier 1 CSR #1 (7am2pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #2 (7am2pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #3 (7am2pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #4 (2pm9pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #5 (2pm9pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #6 (2pm9pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #7 (9pm2am, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1188.00 
                                                                    $80,910.87 
Tier 1 CSR #8 (2am7am, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1188.00 
                                                                    $80,910.87 
Tier 1 CSR #9 (7am3pm, Sa-Su) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                        777.60 
                                                                    $52,959.84 
Tier 1 CSR #10 (3pm11pm, Sa-Su) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                        777.60 
                                                                    $52,959.84 
Tier 1 CSR #11 (11pm7am, Sa-Su) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                        777.60 
                                                                    $52,959.84 
Tier 2 CSR #1 (7am2pm, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        554.40 
                                                                    $49,085.93 
Tier 2 CSR #2 (2pm9pm, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        554.40 
                                                                    $49,085.93 
Tier 2 CSR #3 (9pm2am, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        132.00 
                                                                    $11,687.13 
Tier 2 CSR #4 (2am7am, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        132.00 
                                                                    $11,687.13 
Tier 2 CSR #5 (7am3pm, Sa-Su) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                         86.40 
                                                                     $7,649.76 
Tier 2 CSR #6 (3pm11pm, Sa-Su) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                         86.40 
                                                                     $7,649.76 
Tier 2 CSR #7 (11pm7am, Sa-Su) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                         86.40 
                                                                     $7,649.76 
Project Manager 
                                                                         85000 
                                                                        100.68 
                                                                        115.78 
                                                                        180.00 
                                                                    $20,840.68 
Program Manager 
                                                                        135000 
                                                                        159.90 
                                                                        183.89 
                                                                         20.00 
                                                                     $3,677.77 
Sys Admin 
                                                                        115000 
                                                                        136.21 
                                                                        156.65 
                                                                        500.00 
                                                                    $78,322.82 
Totals 
 
 
 
                                                                         17020 
                                                                 $1,247,689.26 
  	 
Table D-3: Cost Based on 40% Adoption 
 
                                    Staff 
 Salary 
                              Hourly Loaded Rate 
                         [(Salary/2060)* Multiplier] 
                                 Target Rate 
                            (Loaded Rate plus 15%) 
Annual Hours 
                                  Total Cost 
Tier 1 CSR #1 (7am-2pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #2 (7am-2pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #3 (7am-2pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #4 (7am-2pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #5 (2pm-9pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #6 (2pm-9pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #7 (2pm-9pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #8 (2pm-9pm, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1663.20 
                                                                   $113,275.22 
Tier 1 CSR #9 (9pm-2am, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1188.00 
                                                                    $80,910.87 
Tier 1 CSR #10 (2am-7am, M-F) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                       1188.00 
                                                                    $80,910.87 
Tier 1 CSR #11 (7am-3pm, Sa-Su) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                        777.60 
                                                                    $52,959.84 
Tier 1 CSR #12 (3pm-11pm, Sa-Su) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                        777.60 
                                                                    $52,959.84 
Tier 1 CSR #13 (11pm-7am, Sa-Su) 
                                                                         50000 
                                                                         59.22 
                                                                         68.11 
                                                                        777.60 
                                                                    $52,959.84 
Tier 2 CSR #1 (7am-2pm, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        184.80 
                                                                    $16,361.98 
Tier 2 CSR #2 (7am-2pm, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        184.80 
                                                                    $16,361.98 
Tier 2 CSR #3 (7am-2pm, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        184.80 
                                                                    $16,361.98 
Tier 2 CSR #4 (7am-2pm, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        184.80 
                                                                    $16,361.98 
Tier 2 CSR #5 (2pm-9pm, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        184.80 
                                                                    $16,361.98 
Tier 2 CSR #6 (2pm-9pm, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        184.80 
                                                                    $16,361.98 
Tier 2 CSR #7 (2pm-9pm, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        184.80 
                                                                    $16,361.98 
Tier 2 CSR #8 (2pm-9pm, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        184.80 
                                                                    $16,361.98 
Tier 2 CSR #9 (9pm-2am, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        132.00 
                                                                    $11,687.13 
Tier 2 CSR #10 (2am-7am, M-F) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                        132.00 
                                                                    $11,687.13 
Tier 2 CSR #11 (7am-3pm, Sa-Su) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                         86.40 
                                                                     $7,649.76 
Tier 2 CSR #12 (3pm-11pm, Sa-Su) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                         86.40 
                                                                     $7,649.76 
Tier 2 CSR #13 (11pm-7am, Sa-Su) 
                                                                         65000 
                                                                         76.99 
                                                                         88.54 
                                                                         86.40 
                                                                     $7,649.76 
Project Manager 
                                                                         85000 
                                                                        100.68 
                                                                        115.78 
                                                                        180.00 
                                                                    $20,840.68 
Program Manager 
                                                                        135000 
                                                                        159.90 
                                                                        183.89 
                                                                         20.00 
                                                                     $3,677.77 
Sys Admin 
                                                                        115000 
                                                                        136.21 
                                                                        156.65 
                                                                        500.00 
                                                                    $78,322.82 
Totals 
 
 
 
                                                                         20716 
                                                                 $1,506,963.66 
 

  APPENDIX G Industries Potentially Affected by the Proposed Rule and SBA Size 
                                        
                              Standards, by NAICS Code 
                                        
                                            
Appendix G.1 Industries Potentially Affected by the Proposed Rule and SBA Size Standards, by NAICS 
Code............................................................................................................................................G-2 
Appendix G.2 Screening-Level Assessment of Potentially Small Entities Affected by the Proposed 
Rule...............................................................................................................G-5 
                                        
                                                                             	 

                                  Appendix G 
Industries Potentially Affected by the Proposed Rule and SBA Size Standards, by NAICS Code 
NAICS Code 
                              NAICS Description 
                         Small Business Size Standard 


                                   Revenue  
                                 ($ Millions) 
                                  Employees 
                                    212231 
Lead Ore and Zinc Ore Mining 
                                        
                                     750 
                                    213112 
Support Activities for Oil and Gas Operations 
                                     38.5 
                                        
                                    221118 
Other Electric Power Generation 
                                        
                                     250 
                                    221121 
Electric Bulk Power Transmission and Control 
                                        
                                     500 
                                    221210 
Natural Gas Distribution 
                                        
                                    1,000 
                                    237990 
Other Heavy and Civil Engineering Construction 
                                     36.5 
                                        
                                    238990 
All Other Specialty Trade Contractors 
                                      15 
                                        
                                    324191 
Petroleum Lubricating Oil and Grease Manufacturing 
                                        
                                     750 
                                    325110 
Petrochemical Manufacturing 
                                        
                                    1,000 
                                    325180 
Other Basic Inorganic Chemical Manufacturing 
                                        
                                    1,000 
                                    325199 
All Other Basic Organic Chemical Manufacturing   
                                        
                                    1,250 
                                    325211 
Plastics Material and Resin Manufacturing 
                                        
                                    1,250 
                                    325212 
Synthetic Rubber Manufacturing 
                                        
                                    1,000 
                                    325320 
Pesticide and Other Agricultural Chemical Manufacturing 
                                        
                                    1,000 
                                    325412 
Pharmaceutical Preparation Manufacturing 
                                        
                                    1,250 
                                    325510 
Paint and Coating Manufacturing 
                                        
                                    1,000 
                                    325612 
Polish and Other Sanitation Good Manufacturing   
                                        
                                     750 
                                    325920 
Explosives Manufacturing 
                                        
                                     750 
                                    325992 
Photographic Film, Paper, Plate and Chemical Manufacturing 
                                        
                                    1,500 
                                    325998 
All Other Miscellaneous Chemical Product and Preparation Manufacturing 
                                        
                                     500 
                                    326113 
Unlaminated Plastics Film and Sheet (except Packaging) Manufacturing 
                                        
                                     750 
                                    326199 
All Other Plastics Product Manufacturing 
                                        
                                     750 
                                    327310 
Cement Manufacturing 
                                        
                                    1,000 
                                    327320 
Ready-Mix Concrete Manufacturing 
                                        
                                     500 
                                    327992 
Ground or Treated Mineral and Earth Manufacturing 
                                        
                                     500 
                                    331410 
Nonferrous Metal (except Aluminum) Smelting and Refining 
                                        
                                     1000 
                                    331491 
Nonferrous Metal (except Copper and Aluminum) Rolling, Drawing and Extruding 
                                        
                                     750 
                                    331492 
Secondary Smelting, Refining, and Alloying of 
Nonferrous Metal (except Copper and Aluminum)   
                                        
                                     750 
                                    332618 
Other Fabricated Wire Product Manufacturing 
                                        
                                     500 
                                    332999 
All Other Miscellaneous Fabricated Metal Product Manufacturing 
                                        
                                     750 
                                    333132 
Oil and Gas Field Machinery and Equipment Manufacturing 
                                        
                                    1,250 
                                    333249 
Other Industrial Machinery Manufacturing 
                                        
                                     500 
                                    333318 
Other Commercial and Service Industry Machinery Manufacturing 
                                        
                                    1,000 

                                  Appendix G 
Industries Potentially Affected by the Proposed Rule and SBA Size Standards, by NAICS Code 
NAICS Code 
                              NAICS Description 
                         Small Business Size Standard 


                                   Revenue  
                                 ($ Millions) 
                                  Employees 
                                    333999 
All Other Miscellaneous General Purpose Machinery Manufacturing 
                                        
                                     500 
                                    334118 
Computer Terminal and Other Computer Peripheral Equipment Manufacturing 
                                        
                                    1,000 
                                    334210 
Telephone Apparatus Manufacturing 
                                        
                                    1,250 
                                    334220 
Radio and Television Broadcasting and Wireless Communications Equipment Manufacturing 
                                        
                                    1,250 
                                    334511 
Search, Detection, Navigation, Guidance, Aeronautical, and Nautical System and Instrument Manufacturing 
                                        
                                    1,250 
                                    334512 
Automatic Environmental Control Manufacturing for Residential, Commercial and Appliance Use 
                                        
                                     500 
                                    335911 
Storage Battery Manufacturing 
                                        
                                    1,250 
                                    336320 
Motor Vehicle Electrical and Electronic Equipment Manufacturing 
                                        
                                    1,000 
                                    336412 
Aircraft Engine and Engine Parts Manufacturing 
                                        
                                    1,000 
                                    336415 
Guided Missile and Space Vehicle Propulsion Unit and Propulsion Unit Parts Manufacturing 
                                        
                                    1,250 
                                    423120 
Motor Vehicle Supplies and New Parts Merchant Wholesalers 
                                        
                                     200 
                                    423320 
Brick, Stone, and Related Construction Material Merchant Wholesalers 
                                        
                                     150 
                                    423930 
Recyclable Material Merchant Wholesalers 
                                        
                                     100 
                                    423940 
Jewelry, Watch, Precious Stone, and Precious Metal Merchant Wholesalers 
                                        
                                     100 
                                    424690 
Other Chemical and Allied Products Merchant Wholesalers 
                                        
                                     150 
                                    424720 
Petroleum and Petroleum Products Merchant Wholesalers (except Bulk Stations and Terminals) 
                                        
                                     200 
                                    454310 
Fuel Dealers 
                                        
                                     100 
                                    454390 
Other Direct Selling Establishments 
                                     7.5 
                                        
                                    484110 
General Freight Trucking, Local 
                                     27.5 
                                        
                                    484220 
Specialized Freight (except Used Goods) Trucking, Local 
                                     27.5 
                                        
                                    488320 
Marine Cargo Handling 
                                     38.5 
                                        
                                    488999 
All Other Support Activities for Transportation 
                                     7.5 
                                        
                                    493110 
General Warehousing and Storage 
                                     27.5 
                                        
                                    493190 
Other Warehousing and Storage 
                                     27.5 
                                        
                                    522390 
Other Activities Related to Credit Intermediation 
                                     20.5 
                                        
                                    523910 
Miscellaneous Intermediation 
                                     38.5 
                                        
                                    532299 
All Other Consumer Goods Rental 
                                     7.5 
                                        
                                    532490 
Other Commercial and Industrial Machinery and Equipment Rental and Leasing 
                                     32.5 
                                        
                                    541330 
Engineering Services 
                                      15 
                                        
                                    541380 
Testing Laboratories 
                                      15 
                                        
                                    541620 
Environmental Consulting Services 
                                      15 
                                        
                                  Appendix G 
Industries Potentially Affected by the Proposed Rule and SBA Size Standards, by NAICS Code 
NAICS Code 
                              NAICS Description 
                         Small Business Size Standard 


                                   Revenue  
                                 ($ Millions) 
                                  Employees 
                                    541690 
Other Scientific and Technical Consulting Services   
                                      15 
                                        
                                    541712 
Research and Development in the Physical, Engineering, and Life Sciences (except Biotechnology) 11 
                                        
                                    1,000 
                                    541820 
Public Relations Agencies 
                                      15 
                                        
                                    561210 
Facilities Support Services12 
                                     38.5 
                                        
                                    561499 
All Other Business Support Services 
                                      15 
                                        
                                    561790 
Other Services to Buildings and Dwellings   
                                     7.5 
                                        
                                    561990 
All Other Support Services 
                                      11 
                                        
                                    562111 
Solid Waste Collection 
                                     38.5 
                                        
                                    562112 
Hazardous Waste Collection 
                                     38.5 
                                        
                                    562119 
Other Waste Collection 
                                     38.5 
                                        
                                    562211 
Hazardous Waste Treatment and Disposal 
                                     38.5 
                                        
                                    562212 
Solid Waste Landfill 
                                     38.5 
                                        
                                    562213 
Solid Waste Combustors and Incinerators 
                                     38.5 
                                        
                                    562219 
Other Nonhazardous Waste Treatment and Disposal   
                                     38.5 
                                        
                                    562910 
Remediation Services 
                                     20.5 
                                        
                                    562920 
Materials Recovery Facilities 
                                     20.5 
                                        
                                    562991 
Septic Tank and Related Services 
                                     7.5 
                                        
                                    562998 
All Other Miscellaneous Waste Management Services 
                                     7.5 
                                        
                                    611310 
Colleges, Universities and Professional Schools 
                                     27.5 
                                        
                                    621610 
Home Health Care Services 
                                      15 
                                        
                                    622110 
General Medical and Surgical Hospitals 
                                     38.5 
                                        
                                        

The following table reflects 89 facilities identified across the 74 entities identified by EPA as potentially small TSDFs. As discussed in Section 7.2.2.3, EPA conducted a screening-level assessment of these 74 entities to determine whether they could incur costs potentially in excess of one percent of their revenues if they continued to process similar tonnages of waste using only paper manifests, instead of adopting e-Manifest options. For a detailed summary of the process through which EPA calculated the figures in the following table, refer to Section 7.2.2.3. 
 
Generally, small entities will not own more than one establishment. However, EPA's screeninglevel assessment indicates that 10 of the 74 entities identified by EPA as potentially small TSDFs may own more than one establishment. As a conservative assumption, the screening-level assessment estimates costs and revenues at the per-establishment, rather than the per-entity level, and considers an entity to have paper manifest costs in excess of one percent of estimated revenues if costs exceed one percent of estimated revenues at any of its potentially-owned establishments. Therefore, 25 of the rows in the table below are shaded gray, as they represent establishments potentially owned by one of these 10 entities that incur relatively lower proportions of costs relative to revenues.  
 
                                   Facility 
Number 
                                  NAICS Code 
                                Tons received  
                                     % of 
                                    Waste 
                               No. of Manifests 
                           Paper manifest fees ($k) 
                                   SBA Size 
                                   Standard 
(Revenues, 
                                     $M) 
Midpoint 
                                      of 
Revenue 
                                     Size 
Standard 
                                     ($M) 
                                   SBA Size 
                                   Standard 
(Employment) 
                                 Midpoint of 
Employment
                                   -Derived 
                                     Size 
                                   Standard 
                                     ($M) 
                                     Cost 
Impact (% 
                                      of 
                               MidpointDerived 
                                  Revenues) 
                                     [A] 
                                     [B] 
                                     [C] 
                                     [D] 
                                     [E] 
                                     [F] 
                                     [G] 
                                     [H] 
                                     [I] 
                                     [J] 
                                     [K] 
                                      13 
331492 
                                                                      12,770.4 
                                                                         0.22% 
                                                                         2,239 
                                                                        $55.35 
                                     N/A 
                                     N/A 
                                                                           750 
                                      ** 
                                  See below 
                                      18 
333249 
                                                                       3,765.7 
                                                                         0.06% 
                                                                           661 
                                                                        $16.34 
                                     N/A 
                                     N/A 
                                                                           500 
                                                                        $35.20 
                                    0.05% 
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                       
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                                                               
                                       
                                       
                                      34 
331492 
                                                                      11,701.8 
                                                                         0.20% 
                                                                         2,052 
                                                                        $50.73 
                                     N/A 
                                     N/A 
                                                                           750 
                                      ** 
                                  See below 
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                       
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                                                          1,000
                                                                               
                                       
                                      55 
562920 
                                                                       4,360.4 
                                                                         0.07% 
                                                                           765 
                                                                        $18.91 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.18% 
                                      66 
562910 
                                                                         233.1 
< 0.01% 
                                                                            41 
                                                                         $1.01 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.01% 
                                      67 
562211 
                                                                       5,043.6 
                                                                         0.09% 
                                                                           885 
                                                                        $21.88 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.11% 
                                      70 
562211 
                                                                      13,556.3 
                                                                         0.23% 
                                                                         2,377 
                                                                        $58.76 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.31% 
                                      82 
423930 
                                                                       2,847.8 
                                                                         0.05% 
                                                                           500 
                                                                        $12.36 
                                     N/A 
                                     N/A 
                                                                           100 
                                                                        $18.77 
                                    0.07% 
                                      83 
424720 
                                                                       2,440.9 
                                                                         0.04% 
                                                                           428 
                                                                        $10.58 
                                     N/A 
                                     N/A 
                                                                           100 
                                                                       $125.86 
                                    0.01% 
                                      89 
484220 
                                                                       6,478.6 
                                                                         0.11% 
                                                                         1,136 
                                                                        $28.08 
                                                                        $27.50 
                                                                        $13.75 
                                     N/A 
                                     N/A 
                                    0.20% 
                                      90 
562112 
                                                                       3,754.5 
                                                                         0.06% 
                                                                           659 
                                                                        $16.29 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.08% 
                                      92 
423940 
                                                                           2.4 
< 0.01% 
                                                                             1 
                                                                         $0.02 
                                     N/A 
                                     N/A 
                                                                           100 
                                                                        $35.43 
                                    0.00% 
                                      96 
562112 
                                                                      12,000.0 
                                                                         0.20% 
                                                                         2,104 
                                                                        $52.01 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.27% 
                                      97 
331410 
                                                                         137.7 
< 0.01% 
                                                                            25 
                                                                         $0.62 
                                     N/A 
                                     N/A 
                                                                         1,000 
                                                                       $102.26 
                                    0.00% 
                                      98 
562920 
                                                                          11.8 
< 0.01% 
                                                                             3 
                                                                         $0.07 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.00% 
                                      99 
326113 
                                                                      13,033.4 
                                                                         0.22% 
                                                                         2,286 
                                                                        $56.51 
                                     N/A 
                                     N/A 
                                                                           500 
                                                                        $47.23 
                                    0.12% 
                                     101 
562211 
                                                                      24,379.0 
                                                                         0.42% 
                                                                         4,275 
                                                                       $105.68 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.55% 
                                     105 
331491 
                                                                         382.7 
                                                                         0.01% 
                                                                            68 
                                                                         $1.68 
                                     N/A 
                                     N/A 
                                                                           750 
                                                                        $26.25 
                                    0.01% 
                                     106 
331410 
                                                                           0.1 
< 0.01% 
                                                                             1 
                                                                         $0.02 
                                     N/A 
                                     N/A 
                                                                         1,000 
                                                                       $102.26 
                                    0.00% 
                                     107 
423930 
                                                                       9,689.6 
                                                                         0.17% 
                                                                         1,699 
                                                                        $42.00 
                                     N/A 
                                     N/A 
                                                                           100 
                                                                        $18.77 
                                    0.22% 
                                     108 
331492 
                                                                           8.1 
< 0.01% 
                                                                             2 
                                                                         $0.05 
                                     N/A 
                                     N/A 
                                                                           750 
                                      ** 
                                  See below 
                                     109 
423930 
                                                                       4,659.1 
                                                                         0.08% 
                                                                           817 
                                                                        $20.20 
                                     N/A 
                                     N/A 
                                                                           100 
                                                                        $18.77 
                                    0.11% 
                                     111 
522390 
                                                                      11,716.4 
                                                                         0.20% 
                                                                         2,055 
                                                                        $50.80 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.50% 
                                     112 
484110 
                                                                          44.6 
< 0.01% 
                                                                             8 
                                                                         $0.20 
                                                                        $27.50 
                                                                        $13.75 
                                     N/A 
                                     N/A 
                                    0.00% 
                                     113 
484220 
                                                                         413.8 
                                                                         0.01% 
                                                                            73 
                                                                         $1.80 
                                                                        $27.50 
                                                                        $13.75 
                                     N/A 
                                     N/A 
                                    0.01% 

                                   Facility 
Number 
                                  NAICS Code 
                                Tons received  
                                     % of 
                                    Waste 
                               No. of Manifests 
                           Paper manifest fees ($k) 
                                   SBA Size 
                                   Standard 
(Revenues, 
                                     $M) 
Midpoint 
                                      of 
Revenue 
                                     Size 
Standard 
                                     ($M) 
                                   SBA Size 
                                   Standard 
(Employment) 
                                 Midpoint of 
Employment
                                   -Derived 
                                     Size 
                                   Standard 
                                     ($M) 
                                     Cost 
Impact (% 
                                      of 
                               MidpointDerived 
                                  Revenues) 
                                     [A] 
                                     [B] 
                                     [C] 
                                     [D] 
                                     [E] 
                                     [F] 
                                     [G] 
                                     [H] 
                                     [I] 
                                     [J] 
                                     [K] 
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                                                               
                                                                               
                                       
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                       
                                       

                                                                               

                                                                               
                                                                               
                                                                               
                                                                               
                                     N/A 
                                     N/A 
                                       
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                     N/A 
                                     N/A 
                                       
                                     126 
541620 
                                                                      36,664.6 
                                                                         0.62% 
                                                                         6,429 
                                                                       $158.92 
                                                                        $15.00 
                                                                         $7.50 
                                     N/A 
                                     N/A 
                                    2.12% 
                                     127 
213112 
                                                                      11,150.2 
                                                                         0.19% 
                                                                         1,955 
                                                                        $48.33 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.25% 
                                     129 
562112 
                                                                      36,280.6 
                                                                         0.62% 
                                                                         6,361 
                                                                       $157.24 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.82% 
                                     130 
324191 
                                                                       3,905.9 
                                                                         0.07% 
                                                                           685 
                                                                        $16.93 
                                     N/A 
                                     N/A 
                                                                           500 
                                                                        $66.67 
                                    0.03% 
                                     138 
562211 
                                                                         475.7 
                                                                         0.01% 
                                                                            84 
                                                                         $2.08 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.01% 
                                     178 
334512 
                                                                          20.5 
< 0.01% 
                                                                             4 
                                                                         $0.10 
                                     N/A 
                                     N/A 
                                                                           500 
                                                                        $17.38 
                                    0.00% 
                                     188 
562920 
                                                                          59.8 
< 0.01% 
                                                                            11 
                                                                         $0.27 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.00% 
                                     195 
562211 
                                                                         173.5 
< 0.01% 
                                                                            31 
                                                                         $0.77 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.00% 
                                     222 
562211 
                                                                          80.4 
< 0.01% 
                                                                            15 
                                                                         $0.37 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.00% 
                                     235 
541330 
                                                                      43,651.9 
                                                                         0.74% 
                                                                         7,654 
                                                                       $189.21 
                                                                        $15.00 
                                                                         $7.50 
                                     N/A 
                                     N/A 
                                    2.52% 
                                     254 
562119 
                                                                       6,529.0 
                                                                         0.11% 
                                                                         1,145 
                                                                        $28.30 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.15% 
                                     276 
562920 
                                                                         883.5 
                                                                         0.02% 
                                                                           155 
                                                                         $3.83 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.04% 
                                     278 
331491 
                                                                       4,257.2 
                                                                         0.07% 
                                                                           747 
                                                                        $18.47 
                                     N/A 
                                     N/A 
                                                                           750 
                                                                        $26.25 
                                    0.07% 
                                     281 
561990 
                                                                       9,509.2 
                                                                         0.16% 
                                                                         1,668 
                                                                        $41.23 
                                                                        $11.00 
                                                                         $5.50 
                                     N/A 
                                     N/A 
                                    0.75% 
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                     N/A 
                                     N/A 
                                                                               
                                                                               
                                       
                                     289 
325612 
                                                                          47.7 
< 0.01% 
                                                                             9 
                                                                         $0.22 
                                     N/A 
                                     N/A 
                                                                           500 
                                                                        $31.18 
                                    0.00% 
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                     N/A 
                                       
                                                                               
                                       
                                       
                                       

                                                                               
0.01% 
                                                                               
                                                                               
                                     N/A 
                                     N/A 
                                                                               
                                                                               
                                       
                                     323 
541620 
                                                                      18,357.6 
                                                                         0.31% 
                                                                         3,219 
                                                                        $79.57 
                                                                        $15.00 
                                                                         $7.50 
                                     N/A 
                                     N/A 
                                    1.06% 
                                     325 
562211 
                                                                       2,893.4 
                                                                         0.05% 
                                                                           508 
                                                                        $12.56 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.07% 
                                     333 
325212 
307,297.0 
                                                                         5.23% 
                                                                        53,878 
$1,331.86 
                                     N/A 
                                     N/A 
                                                                         1,000 
                                                                        $81.23 
                                    1.64% 
                                     344 
325998 
                                                                       6,298.4 
                                                                         0.11% 
                                                                         1,105 
                                                                        $27.32 
                                     N/A 
                                     N/A 
                                                                           500 
                                                                        $50.28 
                                    0.05% 
                                     352 
562211 
                                                                         978.0 
                                                                         0.02% 
                                                                           172 
                                                                         $4.25 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.02% 
                                     371 
562219 
                                                                         135.5 
< 0.01% 
                                                                            24 
                                                                         $0.59 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.00% 
                                     397 
562211 
                                                                         208.7 
< 0.01% 
                                                                            37 
                                                                         $0.91 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.00% 
                                     399 
562998 
                                                                      15,648.5 
                                                                         0.27% 
                                                                         2,744 
                                                                        $67.83 
                                                                         $7.50 
                                                                         $3.75 
                                     N/A 
                                     N/A 
                                    1.81% 
                                     410 
331410 
139,306.1 
                                                                         2.37% 
                                                                        24,424 
                                                                       $603.76 
                                     N/A 
                                     N/A 
                                                                         1,000 
                                                                       $102.26 
                                    0.59% 
                                     437 
562211 
                                                                         162.3 
< 0.01% 
                                                                            29 
                                                                         $0.72 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.00% 
                                     500 
523910 
                                                                          99.7 
< 0.01% 
                                                                            18 
                                                                         $0.44 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.00% 
                                     501 
562219 
                                                                       3,119.9 
                                                                         0.05% 
                                                                           548 
                                                                        $13.55 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.07% 
                                     518 
562211 
                                                                         117.3 
< 0.01% 
                                                                            21 
                                                                         $0.52 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.00% 
                                     542 
493110 
                                                                       4,579.7 
                                                                         0.08% 
                                                                           803 
                                                                        $19.85 
                                                                        $27.50 
                                                                        $13.75 
                                     N/A 
                                     N/A 
                                    0.14% 
                                     567 
488999 
                                                                         384.0 
                                                                         0.01% 
                                                                            68 
                                                                         $1.68 
                                                                         $7.50 
                                                                         $3.75 
                                     N/A 
                                     N/A 
                                    0.04% 
                                     584 
326199 
                                                                       2,442.6 
                                                                         0.04% 
                                                                           429 
                                                                        $10.60 
                                     N/A 
                                     N/A 
                                                                           750 
                                                                        $24.32 
                                    0.04% 
                                     589 
424720 
                                                                         315.6 
                                                                         0.01% 
                                                                            56 
                                                                         $1.38 
                                     N/A 
                                     N/A 
                                                                           100 
                                                                       $125.86 
                                    0.00% 
                                     590 
331491 
                                                                          32.1 
< 0.01% 
                                                                             6 
                                                                         $0.15 
                                     N/A 
                                     N/A 
                                                                           750 
                                                                        $26.25 
                                    0.00% 
                                     595 
541620 
                                                                         311.9 
                                                                         0.01% 
                                                                            55 
                                                                         $1.36 
                                                                        $15.00 
                                                                         $7.50 
                                     N/A 
                                     N/A 
                                    0.02% 
                                     614 
561990 
                                                                      15,863.7 
                                                                         0.27% 
                                                                         2,782 
                                                                        $68.77 
                                                                        $11.00 
                                                                         $5.50 
                                     N/A 
                                     N/A 
                                    1.25% 
                                     618 
454390 
                                                                      14,431.3 
                                                                         0.25% 
                                                                         2,531 
                                                                        $62.57 
                                                                         $7.50 
                                                                         $3.75 
                                     N/A 
                                     N/A 
                                    1.67% 
                                     628 
562213 
                                                                      61,378.2 
                                                                         1.05% 
                                                                        10,762 
                                                                       $266.04 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    1.38% 
                                     629 
562920 
                                                                      12,713.8 
                                                                         0.22% 
                                                                         2,230 
                                                                        $55.13 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.54% 
                                     630 
335911 
                                                                      19,074.8 
                                                                         0.32% 
                                                                         3,345 
                                                                        $82.69 
                                     N/A 
                                     N/A 
                                                                           500 
                                                                        $39.72 
                                    0.21% 
                                     632 
541380 
                                                                       5,380.3 
                                                                         0.09% 
                                                                           944 
                                                                        $23.34 
                                                                        $15.00 
                                                                         $7.50 
                                     N/A 
                                     N/A 
                                    0.31% 
                                     637 
562920 
                                                                         269.1 
< 0.01% 
                                                                            48 
                                                                         $1.19 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.01% 
                                     638 
424690 
                                                                       5,882.5 
                                                                         0.10% 
                                                                         1,032 
                                                                        $25.51 
                                     N/A 
                                     N/A 
                                                                           100 
                                                                        $23.40 
                                    0.11% 
                                     641 
562920 
                                                                       1,000.9 
                                                                         0.02% 
                                                                           176 
                                                                         $4.35 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.04% 
                                   Facility 
Number 
                                  NAICS Code 
                                Tons received  
                                     % of 
                                    Waste 
                               No. of Manifests 
                           Paper manifest fees ($k) 
                                   SBA Size 
                                   Standard 
(Revenues, 
                                     $M) 
Midpoint 
                                      of 
Revenue 
                                     Size 
Standard 
                                     ($M) 
                                   SBA Size 
                                   Standard 
(Employment) 
                                 Midpoint of 
Employment
                                   -Derived 
                                     Size 
                                   Standard 
                                     ($M) 
                                     Cost 
Impact (% 
                                      of 
                               MidpointDerived 
                                  Revenues) 
                                     [A] 
                                     [B] 
                                     [C] 
                                     [D] 
                                     [E] 
                                     [F] 
                                     [G] 
                                     [H] 
                                     [I] 
                                     [J] 
                                     [K] 
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                     N/A 
                                       
                                       
                                       
562213 
                                                                      61,378.2 
                                                                         1.05% 
                                                                               
                                                                               
                                                                               
                                                                        $19.25 
                                       
                                       
                                       
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                        $10.25 
                                       
                                       
                                       
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                                                               
                                                                               
                                       
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                       
                                       

                                                                               

                                                                               
                                                                               
                                                                        $20.50 
                                                                        $10.25 
                                       
                                       
                                       
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                                                               
                                                                               
                                       
                                       

                                                                          1,000
                                                                               
                                                                               
                                                                               
                                                                        $20.50 
                                                                        $10.25 
                                       
                                       
                                    0.04% 
                                     642 
562920 
                                                                       1,093.9 
                                                                         0.02% 
                                                                           192 
                                                                         $4.75 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.05% 
                                     662 
325180 
                                                                         114.3 
< 0.01% 
                                                                            21 
                                                                         $0.52 
                                     N/A 
                                     N/A 
                                                                         1,000 
                                                                        $50.19 
                                    0.00% 
                                       

                                                                               

                                                                               
                                                                               
                                       
                                       
                                                                               
                                                                               
                                       
                                     674 
325180 
                                                                         262.3 
< 0.01% 
                                                                            46 
                                                                         $1.14 
                                     N/A 
                                     N/A 
                                                                         1,000 
                                                                        $50.19 
                                    0.00% 
                                     678 
562211 
                                                                      37,299.7 
                                                                         0.64% 
                                                                         6,540 
                                                                       $161.67 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.84% 
                                     684 
562211 
                                                                       4,603.0 
                                                                         0.08% 
                                                                           808 
                                                                        $19.97 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.10% 
                                     690 
332618 
                                                                       9,670.9 
                                                                         0.16% 
                                                                         1,696 
                                                                        $41.93 
                                     N/A 
                                     N/A 
                                                                           500 
                                                                        $19.78 
                                    0.21% 
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                                                          1,000
                                                                               
                                       
                                     696 
238990 
                                                                         505.0 
                                                                         0.01% 
                                                                            89 
                                                                         $2.20 
                                                                        $15.00 
                                                                         $7.50 
                                     N/A 
                                     N/A 
                                    0.03% 
                                     697 
562920 
                                                                         370.3 
                                                                         0.01% 
                                                                            65 
                                                                         $1.61 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.02% 
                                     700 
561210 
                                                                          72.9 
< 0.01% 
                                                                            13 
                                                                         $0.32 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.00% 
                                     743 
541380 
                                                                       1,820.8 
                                                                         0.03% 
                                                                           320 
                                                                         $7.91 
                                                                        $15.00 
                                                                         $7.50 
                                     N/A 
                                     N/A 
                                    0.11% 
                                       

                                                                               

                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                       
                                     749 
562211 
150,000.0 
                                                                         2.55% 
                                                                        26,299 
                                                                       $650.11 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    3.38% 
                                     762 
562212 
                                                                       1,766.5 
                                                                         0.03% 
                                                                           310 
                                                                         $7.66 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.04% 
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                       
                                     785 
523910 
                                                                         371.7 
                                                                         0.01% 
                                                                            66 
                                                                         $1.63 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.01% 
                                     787 
325199 
                                                                         115.9 
< 0.01% 
                                                                            21 
                                                                         $0.52 
                                     N/A 
                                     N/A 
                                                                         1,000 
                                                                        $96.96 
                                    0.00% 
                                     790 
423930 
                                                                          15.1 
< 0.01% 
                                                                             3 
                                                                         $0.07 
                                     N/A 
                                     N/A 
                                                                           100 
                                                                        $18.77 
                                    0.00% 
                                     791 
562212 
                                                                      14,548.6 
                                                                         0.25% 
                                                                         2,551 
                                                                        $63.06 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.33% 
                                       

                                                                               

                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                       
                                     793 
562920 
                                                                           3.4 
< 0.01% 
                                                                             1 
                                                                         $0.02 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.00% 
                                     794 
562219 
                                                                       1,057.5 
                                                                         0.02% 
                                                                           186 
                                                                         $4.60 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.02% 
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                       
                                     828 
562211 
                                                                       1,329.8 
                                                                         0.02% 
                                                                           234 
                                                                         $5.78 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.03% 
                                       

                                                                               
                                                                               
                                                                               
                                                                               
                                       
                                       
                                                                               
                                                                               
                                       
                                     860 
523910 
                                                                       4,877.1 
                                                                         0.08% 
                                                                           856 
                                                                        $21.16 
                                                                        $38.50 
                                                                        $19.25 
                                     N/A 
                                     N/A 
                                    0.11% 
                                     861 
562920 
                                                                      18,590.9 
                                                                         0.32% 
                                                                         3,260 
                                                                        $80.59 
                                                                        $20.50 
                                                                        $10.25 
                                     N/A 
                                     N/A 
                                    0.79% 
 
As indicated by Column [K], 10 entities could have paper manifest costs in excess of one percent of midpoint-derived revenues if they continued to process similar tonnages of waste using paper manifests. However, three establishments across three entities are within a NAICS code for which revenue data for midpoint-derived employment size classes are not readily available from the 2012 Economic Census. This NAICS code is 331492 (Secondary Smelting, Refining, and Alloying of Nonferrous Metal, except Copper and Aluminum, three entities, designated "**" above). For this NAICS code, the SBA threshold for small entities is 750 employees, with midpoint at 375 employees. However, the 2012 Economic Census does not provide revenue data for establishments with 100 to 499 employees for this NAICS code, due to the small number of firms and establishments in this employment category in these NAICS codes. Therefore, within this screening-level assessment using midpoint-derived revenues, these four entities may or may not have costs exceeding one percent of revenues under the high-cost assumptions of this screening assessment. 
 
Further analysis suggests that for NAICS 331492 ("**"), average revenues per entity of a smaller employment size class (20 to 99 employees) are sufficiently large to preclude costs exceeding one percent of revenues. Therefore, as indicated in Section 7.2.2.3, this screening-level assessment's best estimate of the number of entities whose costs would exceed one percent of midpoint-derived revenues is 10 entities.  
 
Lastly, as a sensitivity analysis, EPA also examined an alternative approach for midpoint-derived revenues for those entities in NAICS codes with employment-defined small business thresholds. This approach uses the midpoint of revenues associated with the largest employment size category, rather than average revenues for entities at the employment size midpoint for the small business threshold in a given NAICS code. Generally, this approach leads to an assumption of average revenues for $50 million per potentially small entity, and resulted in an estimate of 10 total potentially small entities with paper-manifest costs that could exceed one percent of midpoint-derived revenues, consistent with the screening-level assessment presented in Section 7.2.2.3 and in this appendix. 
 
   
 
 
 
 
 
 
 
 	 
