1 **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:** Rich ard 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 st atements (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 t his cost savings estimate, whic h 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 esti mates administrative costs of approximately $300 million o Estimates reduction in administrative costs of 25% 1 o Estimate s annual cost savings of approximately $75 millio n
 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 b urden from complying with federal RCRA manifesting requirements  2,137,000 federal manifests generated annually2  Industry cost per manifest: $51 3  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 a nnually4 o Industry cost per manifest: $51 5

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 Coun cil 5 Requirements for Generators, Transporters, and Hazardous Waste Management Facilities Under the RCRA Hazardous Waste Manifest System," OMB Control No. 2050 -0039, EPA ICR number 801.162 o Total cost: $150,297,000

 State government burden from administering RCRA manifest collection programs o 2,947,000 state manifest generated annually 6 o Average per manifest cost: $5 7 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: $22,988,000 8 o Estimates reductions in admin istrative costs as 25% 9 of 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 Envi ronmental 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 I nformation C ollection R equest N umber 0976.1 4 “2013 H azardous W aste R eport, N otification Of R egulated W aste Activity, and P art A H azardous W aste P ermit A pplication and M odification ” OMB control #2050 -0024 9 “ e - Manifest Alternatives Analysis Document,” prepared by Project Performance Corporation (PPC) for the USEPA Office of Resource Conservat ion and Recovery, Final Version 4.0, November 11 , 2009.