       Environmental Protection Agency Electronic Manifest System Survey

Introduction

The Environmental Protection Agency (hereafter referred to as "the Agency"), with the support of the states, NGOs, industry, and other stakeholders, is preparing to build an IT system to electronically collect the RCRA hazardous waste manifest.  In February 2014, EPA published the first of two rulemakings which will implement e-Manifest.  The Agency has been authorized to collect user fees to offset the costs of building and maintaining the electronic manifest system (hereafter referred to as "e-Manifest").  EPA is currently working on the second rulemaking, which will establish the user fees for the new system. For more information on the e-Manifest project, visit: http://www.epa.gov/osw/hazard/transportation/manifest/e-man.htm

To help inform the development of the Agency's second e-Manifest rulemaking and the new fee system, the Agency asks that you answer the questions in the attached questionnaire.  Aggregated survey results are likely to appear in the public docket for this rule.  These aggregated results will not reveal individual sources of data.  However, if you have concerns about your responses to any of the questions on this survey becoming publicly available, EPA has prepared an option for you to submit your responses as Confidential Business Information (CBI).  Any claim of CBI would be treated in accordance with the Agency's Confidentiality of Business regulations at 40 C.F.R. Part 2, subpart B. If no CBI claim is made when the information is received by EPA, the information may be made available to the public without further notice.

If you have questions concerning this survey please contact:

Christopher McMinimy	or	Alan Barnosky
EPA					EPA
703-308-0105				703-347-8959
mcminimy.chris@epa.gov		barnosky.alan@epa.gov

Submitting the Survey 

For your convenience, EPA has prepared both an electronic (our preference) and paper version of the survey (the only way to submit your responses as CBI).  If you choose to submit any of your responses as CBI, after you complete the paper survey please clearly bracket all information that you wish to claim CBI and indicate "CBI" or "confidential business information" next to the bracket.  Please enclose the survey in two envelopes.  The inner envelope must have "CBI" written on it.  All paper responses should be mailed by FedEx or UPS to:

LaShan Haynes
EPA/ORCR/PMCAO
2733 South Crystal Drive 6[TH] FL
Arlington, VA 22202
703-605-0516
Manifests in Circulation

User fees for the e-Manifest system will partly depend on the number of hazardous waste manifests the Agency will be processing.

 The Agency asks that you estimate the total number of hazardous waste manifests, Federal and State, your company received:

 In calendar year 2013
   ____________________ manifests
   
 In calendar year 2012
   ____________________ manifests
         
 In calendar year 2011
   ____________________ manifests

 What is the approximate number of manifests your company receives on a typical operating day?
      ____________________ manifests / day
      
 How many unique shippers did you receive manifests from in calendar year 2013?
____________________ shippers

 How many of the manifests that you processed in calendar year 2013 came from shippers who were not the original generators?
___________________ manifests

Conditionally Exempt Small Quantity Generator (CESQG) wastes are not subject to RCRA hazardous waste manifest requirements, but many states require manifests for CESQGs.  Since state governments will be users of e-Manifest, the system will carry CESQG manifests.  The Agency would like to know how many CESQG manifests it can expect the system to carry.

 Please estimate the total number of hazardous waste manifests your company received in calendar years 2011, 2012, and 2013, that involved shipments of CESQG wastes:

 In calendar year 2013
   ____________________ manifests
   
 In calendar year 2012
   ____________________ manifests
      
 In calendar year 2011
   ____________________ manifests
Electronic Manifest Adoption

E-Manifest will be an optional alternative to the current paper manifest.  However, as both paper and electronic manifests will be collected and processed by the Agency, the Agency will levy fees on both types of manifests to recover the respective processing costs of each.  In this context, the term "electronic" refers to systems where all data are entered electronically (not scanned, PDF'd, or emailed).  To help estimate the costs and benefits of the e-Manifest system, the Agency would like to know the factors that will affect the use of the system and how many manifests will pass through the system in its first years of operation.

 Does your company plan to switch from paper to electronic manifests?  Please indicate your answer by circling one of the following:

Yes		No

               Please explain the reason for your selection:
                  
                  
                  
                  

If you circled yes for question 6, please answer questions 7.  If you circled no, please skip down to question 8.

 Please circle the year of system operation in which you plan to switch.

                               1[st] year of system operation
                               2[nd] year of system operation
                               3[rd] year of system operation
                               4[th] year of system operation
                               5[th] year of system operation
                               6[th] year of system operation
                               7[th] year of system operation
                               8[th] year of system operation
                               9[th] year of system operation
                               10[th] year of system operation or later


Significant Discrepancies

The Agency believes that hazardous waste manifests with significant discrepancies will be more resource intensive for the e-Manifest system to process than hazardous waste manifests without significant discrepancies.  For the purpose of this survey, significant discrepancies include: 1) differences between the quantities or types of waste listed on the manifest and the quantities or types of waste a facility actually received, and 2) shipments of hazardous waste that a TSDF cannot accept (referred to hereafter as rejected wastes).

The Agency would like to estimate the additional costs associated with significant discrepancies.  The following questions ask about the number of manifests with these discrepancies.

 Please estimate the total number of hazardous waste manifests your company processed in calendar year 2013 that involved significant discrepancies to either waste types or waste quantities at the time of receipt.

      ____________________ manifests
 Briefly describe how these are noted on the paper manifest.
            
            
            
            
            
   
 Please estimate the total number of hazardous waste manifests your company processed in calendar year 2013 that involved significant discrepancies to either waste types or waste quantities after receipt.
            
      ____________________ manifests
      
 Please estimate the approximate number of these manifests that were corrected in the following timeframes.  These estimates should sum to the total number of manifests in the first part of question 9.
            
                   Within 1 to 15 days of receipt__________
                   Within 16 to 90 days of receipt_________
                   Beyond 90 days of receipt_____________
            
 Briefly describe how these are noted on the paper manifest
            
            
   
 Please estimate the total number of hazardous waste manifests your company processed in calendar years 2011, 2012, and 2013 that involved rejected wastes.
      
 In calendar year 2013
   ____________________ manifests
   
 In calendar year 2012
   ____________________ manifests
         
 In calendar year 2011
   ____________________ manifests
   
 Please estimate the total number of hazardous waste manifests your company processed in calendar years 2011, 2012, and 2013 that involved corrections other than the types listed in questions 8, 9, and 10:

In calendar year 2013
      ____________________ manifests
   
In calendar year 2012
      ____________________ manifests
      
In calendar year 2011
      ____________________ manifests
      
 Briefly describe the types of corrections and how they were noted on the paper manifest.
   
   
   
   
   
   


State Governments

      State governments that collect hazardous waste manifests will be users of the e-Manifest system.  The Agency would like to get a better understanding of which state governments collect hazardous waste manifests and how you currently handle fees to states.

      For questions 13, 14, 15, and 16 please mark your answer on the table below.

             Please indicate with a check mark in column B of the following table all state governments to which your company submitted copies of hazardous waste manifests during calendar years 2011 to 2013.
                                       
             Please indicate with a check mark in column C of the following table all state governments to which your company paid hazardous waste manifest fees during calendar years 2011 to 2013.

             Please indicate with a check mark in columns D through G of the following table how your company paid fees to each of the state governments you indicated in column C.

             .Please indicate with a checkmark in column H of the following table all state governments to which you make automated payments of state manifest fees.
            
                                       
                                       A
                                       B
                                       C
                                       D
                                       E
                                       F
                                       G
                                       H
                                       
                                   Question:
                                      13
                                      14
                                      15
                                      15
                                      15
                                      15
                                      16
                                       
                                     State
                            Submit Copies to State
                               Pay fees to State
                                  Credit Card
                             Central Debt Account
                                     Check
                            Other (please Specify)
                           Automated Payment Systems
                                       1
ALABAMA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       2
ALASKA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       3
ARIZONA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       4
ARKANSAS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       5
CALIFORNIA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       6
COLORADO
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       7
CONNECTICUT
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       8
DELAWARE
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       9
FLORIDA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      10
GEORGIA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      11
HAWAII
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      12
IDAHO
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      13
ILLINOIS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      14
INDIANA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      15
IOWA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      16
KANSAS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      17
KENTUCKY
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      18
LOUISIANA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      19
MAINE
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       A
                                       B
                                       C
                                       D
                                       E
                                       F
                                       G
                                       H
                                       
                                   Question:
                                      13
                                      14
                                      15
                                      15
                                      15
                                      15
                                      16
                                       
                                     State
                            Submit Copies to State
                               Pay fees to State
                                  Credit Card
                             Central Debt Account
                                     Check
                            Other (please Specify)
                           Automated Payment Systems
                                      20
MARYLAND
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      21
MASSACHUSETTS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      22
MICHIGAN
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      23
MINNESOTA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      24
MISSISSIPPI
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      25
MISSOURI
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      26
MONTANA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      27
NEBRASKA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      28
NEVADA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      29
NEW HAMPSHIRE
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      30
NEW JERSEY
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      31
NEW MEXICO
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      32
NEW YORK
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      33
NORTH CAROLINA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      34
NORTH DAKOTA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      35
OHIO
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      36
OKLAHOMA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      37
OREGON
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      38
PENNSYLVANIA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      39
RHODE ISLAND
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      40
SOUTH CAROLINA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      41
SOUTH DAKOTA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      42
TENNESSEE
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      43
TEXAS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      44
UTAH
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      45
VERMONT
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      46
VIRGINIA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      47
WASHINGTON
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      48
WEST VIRGINIA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      49
WISCONSIN
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                      50
WYOMING
                                       
                                       
                                       
                                       
                                       
                                       
                                       


 Please estimate how many of the total number of hazardous waste manifests your company processed in calendar years 2011, 2012, and 2013 that only carried state hazardous waste codes.

 In calendar year 2013
   ____________________ manifests
   
 In calendar year 2012
   ____________________ manifests
      
 In calendar year 2011
   ____________________ manifests

Transportation

The Agency expects that manifests associated with rail shipments, and manifests associated with international shipments, will require e-Manifest system resources above and beyond a standard truck-borne, domestic manifest.  The Agency would like to be able to better estimate these additional costs.

 Please estimate the total number of hazardous waste manifests your company processed in calendar year 2013 that were carried at least partially by rail.
      ____________________ manifests
      
 Please estimate the total number of hazardous waste manifests your company processed in calendar year 2013 that involved international shipments.
      ____________________ manifests

Industry Systems

 Does your company currently use your own electronic systems to comply with federal or state RCRA reporting requirements? Please indicate your answer by circling one of the following options.  (Note: in this context, the term "electronic" refers to systems where all data are entered electronically (not scanned, PDF'd, or emailed).

Yes		No
      
If you circled yes, please answer the following questions.  If you circled no, please skip to questions 22.

             Please briefly describe the electronic system(s) that you use.
            
            
            
             What technology is your current manifest system built on? (Ex. .NET Framework, Java 2 Platform Enterprise Edition (J2EE), Commercial Off The Shelf Products (COTS), Government Off The Shelf Products (GOTS)).
            
            
            
            
            
             Is your company's system open or closed?  If it is open what protocol does it use? (Ex. XML stream).
            
            
            
            
            
             On average, how often do you need to enroll or remove users from your current system?  Please circle the most correct answer.
               
               Daily	Weekly	Monthly	Quarterly	Annually

       Do you currently require your customers to use electronic tracking/electronic recordkeeping systems? Please indicate your answer by circling one of the following:

Yes		No

 If yes, please briefly describe these systems.
            
            
            
            
            
            
            
            
            
       Would you require your customers to use electronic manifests/electronic record keeping systems if you were using e-Manifest? Please indicate your answer by circling one of the following:

Yes		No
If you answered yes to the previous question, please answer Question 23. If you answered no, please continue to Question 24.

    Based on the requirements set forth in the 1-year e-Manifest rule, how would you encourage your customers to use electronic manifests/electronic record systems? (Examples might include:  provide them with software, increase the charge for paper manifests, etc.)
       
       
       
       
       

The Agency needs to estimate the number of user accounts which will be registered in the electronic manifest system and how the system will be used.  To get an upper-bound estimate, the Agency is assuming for purposes of the current survey that every employee who signs, modifies, or handles a manifest will need to register a user account.  

    Under this scenario, how many user accounts do you estimate your company would require?
   ____________________ accounts

    What is the smallest number of users that your company might have?

   ____________________ users

    How would you prefer to enter data into e-Manifest?  Please rank the following options in order from most to least desirable, with 1 being most desirable and 7 being least desirable.

 Smartphone
 Tablet
 Desktop computer
 Laptop computer
 Website
 Electronic transfer from existing industry system 
 Other  -  please specify:

Thank you for completing this survey.  As this is part of an ongoing effort, please provide the name, email address, and phone number of someone the Agency may contact incase further questions arise.
Name: ____________________
E-Mail:____________________
Phone: ____________________
