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MEMORANDUM

SUBJECT: Derivation of E-Manifest Cost Savings Estimate of $75 Million/Year

From the 2009 e-Manifest Alternatives Analysis Document

Date: November 13, 2013

From: Richard LaShier, Workgroup Chair

To: e-Manifest Regulatory Docket

EPA has not prepared a detailed regulatory impact assessment for this regulation, as we have deferred the 

detailed evaluation of costs, burdens, savings, and other benefits until the later promulgation of the Fee Rule. 

However, the final rule does include statements (consistent with EPA’s 2012 testimony on e-Manifest 

legislation) indicating that when e-Manifest is implemented, we expect cost savings exceeding $75 million per 

year. To support this statement, we are including in the docket this derivation of this cost savings estimate, 

which was prepared by EPA economist Chris McMinimy in the Office of Resource Conservation and Recovery.

 EPA expects e-Manifest will reduce RCRA hazardous waste manifest compliance burden

o 2009 eManifest Alternatives Analysis estimates administrative costs of approximately $300 

million

o Estimates reduction in administrative costs of 25%1

o Estimates annual cost savings of approximately $75 million

 EPA estimates reductions in administrative costs in 2009 eManifest Alternatives Analysis Document

o Estimates three types of administrative costs

1. Federal Manifest administrative costs

 Industry burden from complying with federal RCRA manifesting requirements

 2,137,000 federal manifests generated annually2

 Industry cost per manifest: $513

 Total cost: $108,987,000

2. State Manifest administrative costs

 Industry burden from complying with state RCRA manifesting requirements

o More stringent than federal RCRA, only applicable to some states

o 2,947,000 state manifests generated annually4

o Industry cost per manifest: $515

 

1

“e-Manifest Alternatives Analysis Document,” prepared by Project Performance Corporation (PPC) for the USEPA Office of 

Resource Conservation and Recovery, Final Version 4.0, November 11, 2009.

2

Requirements for Generators, Transporters, and Hazardous Waste Management Facilities Under the RCRA Hazardous Waste 

Manifest System," OMB Control No. 2050-0039, EPA ICR number 801.16

3

ibid

4

Submitted to EPA by hazardous waste industry trade group The Environmental Technology Council

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Requirements for Generators, Transporters, and Hazardous Waste Management Facilities Under the RCRA Hazardous Waste 

Manifest System," OMB Control No. 2050-0039, EPA ICR number 801.16
2

o Total cost: $150,297,000

 State government burden from administering RCRA manifest collection 

programs

o 2,947,000 state manifest generated annually6

o Average per manifest cost: $57

o Total cost: $14,735,000

3. RCRA Biennial Reporting Administrative Costs

 Burden from complying with RCRA hazardous waste biennial reporting 

requirements

 Costs included because e-Manifest will eventually incorporate biennial reporting

 Total cost: $22,988,0008

o Estimates reductions in administrative costs as 25%9of all administrative costs

 Sum of federal manifest, state manifest, and RCRA biennial reporting 

administrative cost: $297,007,000

 25% = $74,251,750

 

6

Submitted to EPA by hazardous waste industry trade group The Environmental Technology Council

7

Source of state government per manifest administrative costs are NY and MI state governments, members of the e-Manifest 

workgroup.

8

EPA Information Collection Request Number 0976.14 “2013 Hazardous Waste Report, Notification Of Regulated Waste Activity, 

and Part A Hazardous Waste Permit Application and Modification” OMB control #2050-0024

9

“e-Manifest Alternatives Analysis Document,” prepared by Project Performance Corporation (PPC) for the USEPA Office of 

Resource Conservation and Recovery, Final Version 4.0, November 11, 2009.