1

Cost Comparison of

Electronic Signature Options for

EPA’s RCRA Hazardous Waste Electronic Manifest IT System

(eManifest)

Option 1: PIN/password (5 sub-options)

Option 2: Handwritten digitized signature (3 sub-options)

Option 3: PKI identity verification

Prepared by:

Mark Eads, Economist

Economics, Methods & Risk Analysis Division

Office of Solid Waste

US Environmental Protection Agency

1200 Pennsylvania Avenue NW, Mailstop 5307P

Washington, DC 20460

703-308-8615; eads.mark@epa.gov

17 April 2007
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Table of Contents

I. Cost Comparison Summary Table 3

II. Cost Estimation Methodology 4

II.A EPA’s Definition of “Electronic Signature” 4

II.B Assumptions & Baseline 5

III. Cost Calculations 15

Option 1: PIN/Password (5 sub-options) 15

Option 2: Handwritten Digitized Signature (3 sub-options) 25

Option 3: PKI Identity Verification 28

Appendices 32

Appendix B: Estimated Counts of Manifests, Trucks, Industrial 

Facilities & Industrial Employees Which May Become

eManifest Users 33

Appendix A: PIN/Password Reset Helpdesk Cost (for Sub-Options 1A, 

1B, 1C, 2B) 35
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I. Cost Comparison Summary Table

Summary of National Cost Estimates for Alternative Electronic Signature Options for OSW’s Planned RCRA eManifest IT System

75% Participation Rate Scenario*

Note: Cost ranges reflect OSW uncertainty in eManifest user counts and/or prices representing alternative IT vendors or IT technologies

eSignature

Options & Sub-Options

Initial Year Cost (IYC) Annual Recurring Cost (ARC) 5-Year Average Annual Cost

(IYC)/5+ARC

($millions/year)

Software & IT Services

($millions)

Hardware

($millions)

Software & IT Services

($millions/year)

Hardware

($millions/year)

Option 1: PIN/password

1A: Mail initial ink signature 

agreement to OEI (one-time 1-

factor proofing)

EPA: $1.976 to $5.229

Users: $1.009 to $4.217

Total: $2.985 to $9.446

EPA: $0

Users: $0

Total: $0

EPA: $0.535 to $5.327

Users: $0.161 to $0.675

Total: $0.696 to $6.002

EPA: $0

Users: $0

Total: $0

EPA: $0.930 to 6.373

Users: $0.363 to $1.518

Total: $1.293 to $7.891

1B: Initial DL# or CC# check

(one-time 2-factor proofing)

EPA: $0

Users: $0.239 to $0.521

Total: $0.239 to $0.521

EPA: $0

Users: $0

Total: $0

EPA: $0.298 to $4.490

Users: $0.038 to $0.083

Total: $0.336 to $4.573

EPA: $0

Users: $0

Total: $0

EPA: $0.298 to $4.490

Users: $0.086 to $0.187

Total: $0.384 to $4.677

1C-1: TPV 2nd factor identity 

verification after PIN/password 

(everytime 2-factor verification)

EPA: $0.001

Users: $0

Total: $0.001

EPA: $0

Users: $0

Total: $0

EPA: $8.278 to $12.470

Users: $0.729

Total: $9.007 to $13.199

EPA: $0

Users: $0

Total: $0

EPA: $8.278 to $12.470

Users: $0729

Total: $9.007 to $13.199

1C-2: OTP 2

nd factor identity 

verification after PIN/password

(everytime 2-factor verification)

EPA: $0

Users: $3.443

Total: $3.443

EPA: $0

Users: $0.596 to $22.559

Total: $0.596 to $22.559

EPA: $0.298 to $4.490

Users: $1.208 to $9.059

Total: $1.506 to $13.549

EPA: $0

Users: $0.045 to $0.833

Total: $0.045 to $0.833

EPA: $0.298 to $4.490

Users: $2.061 to $15.092

Total: $2.359 to $19.582

1C-3: IRS 2nd factor identity 

verification after PIN/password 

(everytime 2-factor verification)

EPA: $0.001 to $0.047

Users: $0

Total: $0.001 to $0.047

EPA: $0

Users: $0

Total: $0

EPA: $0.298 to $4.798

Users: $3.682 to $45.759

Total: $3.980 to $50.557

EPA: $0

Users: $0

Total: $0

EPA: $0.298 to $4.807

Users: $3.682 to $45.759

Total: $3.980 to $50.566

Option 2: Handwritten digitized signature

2A: Digitizer pad signatures 

w/out identity verification

EPA: $0.002

Users: $0

Total: $0.002

EPA: $0

Users: $1.658 to $4.975

Total: $1.658 to $4.975

EPA: $0.001

Users: $0

Total: $0.001

EPA: $0

Users: $0.166 to $0.498

Total: $0.166 to $0.498

EPA: $0.001

Users: $0.498 to $1.493

Total: $0.499 to $1.494

2B: Digitizer pad signatures with 

PIN/ password

(everytime 1-factor verification)

EPA: $0.002

Users: $1.658

Total: $1.660

EPA: $0

Users: $1.658 to $4.975

Total: $1.658 to $4.975

EPA: $0.299 to $4.491

Users: $1.061

Total: $1.360 to $5.552

EPA: $0

Users: $0.166 to $0.498

Total: $0.166 to $0.498

EPA: $0.299 to $4.491

Users: $1.890 to $2.886

Total: $2.189 to $7.377

2C: Digitizer pad signatures with 

biometric thumbprint

(everytime 1-factor verification)

EPA: $0.002

Users: $1.658

Total: $1.660

EPA: $0

Users: $5.306

Total: $5.306

EPA: $0.001

Users: $1.061

Total: $1.062

EPA: $0

Users: $0.531

Total: $0.531

EPA: $0.001

Users: $2.985

Total: $2.986

Option 3: PKI identity verification (Note: the ranges for this option are arrayed w.r.t two data sources so total AAC represents min-max cost)

(everytime 2-factor verification) EPA: $0.348 to $0

Users: $2.207 to $26.030

Total: $2.555 to $26.030

EPA: $0

Users: $0.260 to $0

Total: $0.260 to $0

EPA: $0

Users: $1.744 to $12.703

Total: $1.744 to $12.703

EPA: $0

Users: $0.172 to $0

Total: $0.172 to $0

EPA: $0.070 to $0

Users: $2.409 to $17.909

Total: $2.479 to $17.909

Explanatory Notes:

* For definition of the 75% participation rate scenario see the Appendix for the associated annual counts of manifests, trucks, facilities, and employees potentially using eManifest.
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II. Cost Estimation Methodology

Disclaimer

OSW’s reference to specific companies in the cost calculations below does not constitute endorsement of those companies by

OSW or EPA, nor does it indicate OSW or EPA preference for specific IT hardware products or IT software products or IT 

services or IT companies. The companies referenced in this cost comparison provided OSW with the information cited 

below solely for use by OSW to formulate rough order-of-magnitude cost estimates for eSignature options for OSW’s 

planned eManifest IT system. The cost information provided by these companies for this purpose does not represent binding 

“price quotes” to OSW or to EPA or to eManifest users, nor does their provision of this cost information disqualify them as 

potential candidate IT vendors for supplying eManifest hardware, software, or IT services.

II.A EPA’s Definition of “Electronic Signature”

Key definitions related to “electronic signature” as established 13 Oct 2005 by EPA’s CROMERR final rule at 40 CFR 3.3

(http://www.epa.gov/cdx/cromerrr):

 Electronic signature: Means any information in digital form that is included in or logically associated 

with an electronic document for the purpose of expressing the same meaning and 

intention as would a handwritten signature if affixed to an equivalent paper 

document with the same reference to the same content. The electronic document 

bears or has on it an electronic signature where it includes or has logically 

associated with it such information.

 Electronic signature agreement: Means an agreement signed by an individual with respect to an electronic 

signature device that the individual will use to create his or her electronic 

signatures requiring such individual to protect the electronic signature device

from compromise; to promptly report to the agency or agencies relying on the 

electronic signatures created any evidence discovered that the device has been 

compromised; and to be held as legally bound, obligated, or responsible by the 

electronic signatures created as by a handwritten signature.

 Electronic signature device: Means a code or other mechanism that is used to create electronic signatures. 

Where the device is used to create an individual's electronic signature, then the 

code or mechanism must be unique to that individual at the time the signature is 

created and he or she must be uniquely entitled to use it. The device is 

compromised if the code or mechanism is available for use by any other person.
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II.B Assumptions & Baseline

 Cost Estimation Accuracy:

The expected accuracy of the cost estimates in this document, according to the relatively low level-of-effort, the relatively small 

amount of data, and lack of refined IT system design specifications on which they are formulated --- represent “Budget Estimates”. 

Consequently, the expected accuracy range for such cost estimates (i.e., the actual cost) is typically -30% to +50% of the numerical 

values shown. This-expected accuracy range is meant to represent variation in “Budget Estimates” as prescribed by the ANSI 

Standard Z94.0 summarized in Figure 1.1: Cost Estimate Classification Matrix for Process Industries on pages 1-3 and 1-4 of “Skills 

& Knowledge of Cost Engineering”, 4th edition, Association for the Advancement of Cost Engineering, 1999 (http://www.aacei.org):

“Budget estimates are prepared with the help of flow sheets, layouts, and equipment details. In other words, enough 

preliminary engineering has taken place to further define the project scope... Budget estimates are also called “study 

feasibility”, “design development”, “semi-detailed”, “appropriation”, or “control” estimates.”

 5-Year IT Lifecycle Cost Period:

OSW calculated the average annual cost (AAC) in the “Cost Summary Table” above by (a) dividing initial year costs (IYC) by 5 

years, and (b) adding the 5-year averaged IYC to annual recurring cost (ARC). This simple annualization method does not apply a 

price inflation factor or an economic discount factor.

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 This cost annualization method also assumes that IYC will not repeat sooner 

than 5-year lifecycle intervals (e.g., for hardware, software, and IT service upgrades), which may understate AAC if upgrades are

needed sooner such as every 3-years (one Federal agency (NIH) advices use of a 3-year IT lifecycle cost period in its “Cost-Benefit 

Analysis Guide For NIH IT Projects”:

“For example, you may assume that the PC hardware and software for a system will need to be upgraded every three 

years. This could be justified on the basis of the rapid increases in capacity and speed and decreases in cost for PCs 

over the past 15 years”; source: section 3.4.6 at http://irm.cit.nih.gov/itmra/cbaguide.html).

 

1 OMB requires Federal agencies to apply discount rates for economic impact analysis, cost-effectiveness analysis, and cost-benefit analysis of Federal regulatory 

actions, capital investment planning, and for lease/purchase of services and equipment; two OMB guidances are:

 OMB’s Sept 2003 Circular A-4 “Regulatory Analysis” requires agencies such as the EPA to apply both alternative 3% and 7% discount rates to 

regulatory impact analyses (p.33 at: http://www.whitehouse.gov/omb/circulars/a004/a-4.pdf).

 OMB’s Jan 2007 updated Appendix C “Discount Rates For Cost-Effectiveness, Lease Purchase, And Related Analyses” to OMB’s Oct 1992 Circular 

A-94 “Guidelines and Discount Rates for Benefit-Cost Analysis of Federal Programs” requires agencies to apply real discount rates (adjusted to remove 

price inflation) ranging between 2.5% (for 3-year program periods) to 3.0% (for 30-year program periods) to constant dollar streams for lease/purchases 

(http://www.whitehouse.gov/omb/circulars/a094/a94_appx-c.html).
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 Compliance with CROMERR:

OSW assumes in this cost comparison that the eSignature requirements of EPA’s 13 Oct 2005 CROMERR final rule 

(http://www.epa.gov/cdx/cromerrr) are applicable to OSW planned eManifest IT system to be hosted on EPA’s CDX. However, 

because of the fact that EPA has not historically since the RCRA manifest system began operation in 1984, nor currently, requires 

direct submission of completed manifests to EPA or to RCRA-authorized state governments, another non-CROMERR scenario is for a 

CDX-based eManifest system merely to provide a cradle-to-grave electronic highway between waste shippers, waste transporters, and 

waste receivers according to the current paper manifest system regulations. Under such a business-to-business (B2B) alternative

eManifest workflow scenario, EPA’s CROMERR requirements might not attach to eManifest because it would not be a business-togovernment (B2G) workflow design. This alternative B2B eManifest workflow scenario is consistent with OSW’s current (baseline)

RCRA paper manifest system which:

 Does not require direct reporting of completed paper manifests to EPA (but does require reporting of (a) waste 

discrepancies, (b) unmanifested wastes, and (c) waste imports/exports received by TSDFs; 40 CFR 264.72(c), 40 CFR 

264.76, and 40 CFR 264.71(d), respectively).

 Does not require direct reporting of completed paper manifests to RCRA-authorized state governments (but does 

require reporting of waste discrepancies by TSDFs; 40 CFR 262 Appendix item 18).

 Does not require identity proofing of ink signatures.

 Allows for un-named and non-identified personnel to ink sign the manifest “on behalf of” the waste generator “to 

indicate that the individual signs as the employee or agent of the named principal”. (40 CFR 262 Appendix item 15). 

Consistent with this, OSW proposed in the 22 May 2001 electronic manifest proposed rule that a “preparer” would be 

able to electronically sign the waste generator’s certification on behalf of the generator with the preparer’s electronic 

signature, because: 

“EPA is aware that it is a common practice for an entity or individual other than the generator (e.g., employee 

or contractor) to perform the steps necessary to prepare a waste shipment for transportation, including the 

steps associated with preparing the manifest paperwork. Often, the transporter or the TSDF prepare the 

manifest paperwork as a part of the service it provides to its generator customers. EPA has already clarified, 

through an amendment to Item 16 of the manifest instructions, that the handwritten signature on paper 

manifests may be made by employees or other individuals on behalf of the generator. 51 FR 35190 at 35192 

(October 1, 1986). Because the electronic manifest may also be prepared by entities or individuals other than 

the generator, it is appropriate to provide similar flexibility for the preparation and signing of the electronic 

manifest. Please note, however, that EPA is not reconsidering, reopening, or requesting comment on the 

existing rule allowing employees or other individuals to sign the paper manifest on behalf of a generator. EPA 
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believes that allowing preparers to sign an electronic manifest on behalf of a generator would be particularly 

important in ensuring that small generators may take advantage of the electronic manifest option. Hazardous 

waste transporters and TSDFs frequently prepare manifests as a service to smaller generators.” (Source: 

p.28291 at http://www.epa.gov/fedrgstr/EPA-WASTE/2001/May/Day-22/f11909.htm).

For example, this alternative B2B eManifest workflow design might include adaptation of the CDX “Web-based Electronic Forms 

Processing: DF” service (http://cfint.rtpnc.epa.gov/otop//currentfyservices/df/df.cfm), which is a user friendly, internet accessible, 

electronic forms processing application that allows users to prepare online, submit, route and approve forms that look just like the 

paper-based version and can be completed just as easily. This design approach is workflow-enabled, meaning that the CDX could 

route the form electronically to anyone for easy approval, rapid processing, and remote archiving with users, including take-back and 

re-route functions. And the forms can be printed by users if necessary.

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 eSignature Options OSW Proposed in 2001 and 2006:

A. May 2001 Electronic Manifest Proposed Rule:

In OSW’s 22 May 2001 de-centralized electronic manifest proposed rule, OSW proposed two electronic signature options (source: 

pp.28284 to 28291 at: http://www.epa.gov/fedrgstr/EPA-WASTE/2001/May/Day-22/f11909.htm):

1. “Digital signature” option meeting the (a) Secure Hash Algorithm (for creating message digests) described in FIPS PUB 180-

1, (b) RSA digital signature algorithm (see ANSI X9.31) in accordance with FIPS PUB 186-1 of December 1998, and (c) 

X.509 PKI digital certificate standard, but would not require that digital signature systems employ a tokenized digital 

signature.

2. “Secure digitized signature” option which would allow electronic manifesting systems to incorporate software, digitizer pads, 

and electronic pens that create a graphical representation of a signer's handwritten signature. The electronic manifest copies 

would be signed with the digitizer/pen device. The signature software (a) would block access to ``cut-and-paste'' editing 

functions; (b) only accept ``real time'' signature data input from the digitizer/pen device; (c) record the signature data as a 

``signature object'' that contains: the graphical image of the signature for display and print operations, in industry-standard 

bitmap format (e.g., TIFF or BMP), signature capture information (e.g., a user ID) and the date and time of signing, (d) 

document binding data involving an encrypted checksum or hash function of the data to which the signature relates, and (e) 

allow for verification of signature objects to establish if data has been changed since the signature was captured.

 

2 The potential base cost for a B2B eManifest design approach --- rather than a business-to-government (B2G) design approach --- based on EPA’s Working 

Capital Fund CDX services FY2007 price rates (http://cfint.rtpnc.epa.gov/otop//currentfyservices/index.cfm?fuseaction=services.showfyrates&fy=2007), is 

$0.457 million/year to $0.997 million/year:[ ($3.83 per user per year for “Webforms DF” service ) x (119,300 to 260,300 eManifest users at 75% implementation 

rate)].
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OSW did not propose in the May 2001 proposed rule a biometric electronic signature method because OSW stated (p.28289) it 

believed that these signature technologies are more practical and proven than other authentication technologies that rely on biometrics 

(e.g., fingerprint readers or retina scans), as the biometric methods identified to date tend to have significant error rates which hamper 

their utility. Biometric methods also are not typically implemented in ways that link the biometric parameters being measured to the 

data being signed, so they are not as helpful in assuring data integrity as the other two proposed electronic signature methods.

Within the 43 questions (p.28290) that OSW asked for public comment about electronic signature methods, OSW asked for public 

comment on a third signature method but did not propose it as an option in the May 2001proposed rule:

3. Personal Identification Number (PIN) option in which individuals would enter a unique sequence of alpha-numeric characters 

which they have adopted as their electronic signature. OSW’s May 2001 proposed rule explained that OSW did not propose a 

PIN option because: “[I]n the context of developing electronic reporting standards for the Discharge Monitoring Report (a 

Clean Water Act requirement), EPA concluded that, in order to satisfy standards of proof for criminal prosecutions, it was 

preferable to require more than simply a PIN for authentication of a record. So, in the Discharge Monitoring Report 

rulemaking, EPA proposed the use of a PIN signature backed up with a follow-up certification that would be hand-signed and 

mailed to the Agency. This approach seems impractical for the manifest, and therefore, EPA has not included a PIN approach 

in today's proposal.”

B. April 2006 Electronic Manifest NODA:

In contrast to OSW’s “decentralized” electronic manifest approach described in the May 2001 proposed rule, OSW’s 18 April 2006 

Federal Register NODA announcing OSW’s intention to finalize a “centralized” IT approach for eManifest based on EPA’s CDX and 

EIEN, did not identify, propose, request public comment on, or otherwise discuss, any electronic signature options because:

“EPA believes that as a result of this change in approach for the e-manifest system, the final regulation authorizing the 

use of electronic manifests would be much simpler than the regulation suggested by the May 2001 proposed rule. The 

final rulemaking will be constrained in its scope to authorizing the use of electronic manifests created and transmitted 

in the national system, and to several other key policy issues that must be resolved prior to implementation. EPA thus 

expects to limit, as far as possible, the subject matter of the final rule on electronic manifesting to the key policy issues

associated with authorizing the use of electronic manifests and with implementing the electronic manifest as a means of 

tracking hazardous waste shipments and recording and transmitting waste shipment information. EPA believes it is far 

more sensible to address the more detailed technical system design and performance requirements for the centralized 

e-manifest system within the contracting process than to codify performance requirements and other technical matters 

within the rulemaking process.” (Source: p.19847 at http://www.epa.gov/epaoswer/hazwaste/gener/manifest/pdf/noda06.pdf).
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 CROMERR Compliant eSignature Options:

The three primary options identified in this cost comparison are Nov 2006 updated versions (by Richard LaShier, OSW) of the three 

options OSW described in the 22 May 2001 electronic manifest proposed rule. OSW assumes that all eSignature options/sub-options 

included in this cost comparison are potentially compliant with EPA’s 2005 CROMERR final rule, based on how the CROMERR 

final rule defines electronic signatures:

o From page 59853 of the Federal Register:

“[I]n terms of electronic signature technology, the rule allows for a range of approaches, including various implementations of 

PINs and passwords, the use of private or personal information, digital signatures based on PKI certificates, and other 

signature technologies as they become viable for our applications. As EPA or authorized programs implement electronic 

submission for specific reports, the rule allows them to select one or more of the available submission and signature 

approaches according to their circumstances and the program-specific requirements.”

o Furthermore, Section 3.3 of EPA’s 13 Oct 2005 CROMERR final rule (Federal Register p.59881) defines “valid electronic 

signature”:

“Valid electronic signature means an electronic signature on an electronic document that has been created with an 

electronic signature device that the identified signatory is uniquely entitled to use for signing that document, where this 

device has not been compromised, and where the signatory is an individual who is authorized to sign the document by 

virtue of his or her legal status and/or his or her relationship to the entity on whose behalf the signature is executed.”

However, only eSignature options/sub-options 1A, 1B, and 3 evaluated in this cost comparison conform to the CROMERR eSignature 

requirements for EPA “Priority Reports”. According to Appendix 1 to the CROMERR final rule (Federal Register page 59885), three 

RCRA manifest-related reports are classified under CROMERR as “Event Driven Notices” which must meet additional CROMERR 

eSignature requirements:

“(vii) For each electronic signature device used to create an electronic signature on the document, the identity of the 

individual uniquely entitled to use the device and his or her relation to any entity for which he or she will sign 

electronic documents has been determined with legal certainty by the issuing state, tribe, or local government. In the 

case of priority reports identified in the table in Appendix 1 of Part 3, this determination has been made before the 

electronic document is received, by means of: (A) Identifiers or attributes that are verified (and that may be re-verified 

at any time) by attestation of disinterested individuals to be uniquely true of (or attributable to) the individual in whose 

name the application is submitted, based on information or objects of independent origin, at least one item of which is 

not subject to change without governmental action or authorization; or (B) A method of determining identity no less 

stringent than would be permitted under paragraph (b)(5)(vii)(A) of this section; or (C) Collection of either a 
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subscriber agreement or a certification from a local registration authority that such an agreement has been received 

and securely stored.”

 EPA Costs:

This cost category designates the costs that OSW anticipates OSW’s eManifest IT vendor contractor will incur, for which OSW will 

need to pay the IT vendor from eManifest user fees and/or Congressional budget appropriation. Important “EPA Cost” assumptions in 

this cost comparison are:

1. Hosted application approach: Rather than attempting in this cost comparison to estimate the potential hardware and 

software/services costs to EPA’s eManifest IT vendor for designing, installing, testing, implementing, operating and 

maintaining eSignature services within eManifest’s CDX platform, this cost comparison estimates the cost for the eSignature 

options/sub-options, based primarily on a “hosted application” approach involving 3rd party IT vendor services:

“As access to the Internet becomes more widespread with faster, more reliable and 'always on' connections becoming 

the norm the growth of applications using the hosted application model continues to expand. Although hosted 

applications will not suit every situation, or every customer, they offer many individuals and organizations, as well as 

the application manufacturers' themselves, considerable benefits over the locally installed application. A hosted 

application, also known as Internet-based application, web-based application, online application and Application 

Service Providers (ASPs) are software applications where the software resides on servers that are accessed through 

the Internet instead of the more traditional software that is installed on either a local server or on individual PCs. The 

thin client concept is nothing new but advances in Internet connectivity have allowed the application to move from a 

local server to a server on the Internet.” (source: http://www.webpronews.com/expertarticles/2005/10/19/what-arehosted-applications).

2. eManifest user account costs: For all options/sub-options in this cost comparison, OSW equally assumes, but does not add to 

the cost of each option/sub-option, $2.250 million/year to $4.927 million/year in average annual cost for EPA (CDX) to 

establish and maintain CDX user registration accounts

3

for eManifest users: [(119,300 to 260,300 employee users) x 

($18.93/year per user account)]. This estimate is based on EPA OEI-OTOP’s FY2007 Working Capital Fund Rates for 

“Application Hosting: Account/User Management: U3”. Specific functions associated with this service include (a) managing 

user accounts on EPA’s web servers, and (b) maintaining user account data within EPA’s Time Sharing Services Management 

 

3 EPA’s CDX user basic registration requirements are: (a) supply information to identify themselves, their company, and the EPA documents they wish to submit 

electronically, (b) verify and/or correct registration information, and (c) access their CDX web accounts through a secure website, and agree to the terms and 

conditions of using the site, which include safeguarding their self-generated password, before using web forms or uploading files to submit electronic documents 

or data to EPA. “These are the minimum steps for gaining access to CDX at this time” (source: EPA’s 13 Oct 2005 CROMERR final rule, p. 59862).
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System (TSSMS). Source: http://cfint.rtpnc.epa.gov/otop/currentfyservices/u3/u3.cfm. Because this cost is assumed equal to 

all options/sub-options, it does not appear as a line-item under each in this cost comparison. Furthermore, CDX registration 

user accounts are assumed required for OSW to charge and collect eManifest user fees under OSW’s proposed eManifest 

lifecycle cost user fee funding scenario (rather than the alternative Congressional appropriation funding scenario). OSW’s user 

fee funding approach is described in:

 Business Case: OSW’s 11 Sept 2006 submission to OMB of OSW’s FY2008 Circular A-11 Part 7 Section 300 

Planning, Budgeting, Acquisition, & Management of Capital Assets “Exhibit 300” business case for 

eManifest (http://www.epa.gov/OEI/cpic/by2008/eManifest.pdf); and

 S.3871: The “Hazardous Waste Electronic Manifest Establishment Act“ introduced 07 Sept 2006 in the US 

Senate by Senators Thune and Jeffords as Senate Bill S.3871 which was read twice and referred to the 

US Senate Committee on Environment and Public Works (http://thomas.loc.gov/cgibin/query/z?c109:s3871:).

3. EPA CDX helpdesk: This cost comparison does not include the $1.192 million/year to $4.490 million/year in CDX helpdesk 

cost for eManifest users as estimated in Appendix A, because this cost comparison assigns a 20% to 50% fractional helpdesk 

cost for PIN/password reset under the four eSignature sub-options based on PIN/passwords (i.e., sub-options 1A, 1B, 1C, 2B). 

OSW simply assumes that the $1.192 million/year to $4.490 million/year cost for annual helpdesk services to resolve other 

types of eManifest user problems are equal under each eSignature option/sub-option, so this 80% to 50% other fraction of 

helpdesk cost, respectively, is not assigned as either an EPA cost or a user cost in this cost comparison for any sub-option.

 User Costs:

Designate the costs that OSW anticipates industrial and waste management facilities involved in hazardous waste transportation will 

incur to use eManifest. User costs will not be funded by OSW with either eManifest user fees or Congressional budget appropriation. 

Important “User Cost” assumptions applied in this cost comparison are:

1. Types of user groups included in this cost comparisons: See Appendix B for source of counts for each user group.

 LQGs (population = 16,000 LQG shippers): Large quantity generators; many of these are already CDX registered users for 

other EPA electronic reporting purposes.

 TSDFs (population = 1,200 TSDF receivers): Treatment, storage, disposal facilities; many of these are already CDX 

registered users for other EPA electronic reporting purposes.

 Transporters: (population = 10,100 trucks): This cost comparison only includes trucks, not rail or barges.
12

 SQGs (population = 114,000 SQG shippers): Small quantity generators are largely excluded from this analysis because 

OSW assumes that TSDFs will provide eManifest access to SQGs under commercial TSDF service customer 

arrangements, which is consistent with OSW’s assumption in the 22 May 2001 electronic manifest proposed rule:

“Hazardous waste transporters and TSDFs frequently prepare manifests as a service to smaller generators. While the 

small or infrequent generator would not be expected to obtain computer equipment or software to conduct automated 

manifesting, the transporters and TSDFs that deal in larger volumes of manifests would likely find automated 

manifesting more advantageous. Thus, allowing the preparer to sign the electronic manifest provides a way for small 

or infrequent generators to participate in the automated system. EPA estimates that small generator manifests may 

account for about 66% of the manifests circulated annually. So, providing a means to include these manifests would 

extend the burden reduction effects of manifest automation to these manifests as well, particularly, as they are received 

and processed by transporters, TSDFs, and State agencies.” (source: p.28291 at http://www.epa.gov/fedrgstr/EPAWASTE/2001/May/Day-22/f11909.htm).

 State governments: With the exception of state government agencies which generate, transport, or receive hazardous 

wastes, state government RCRA-authorized environmental agencies are excluded from this cost comparison because OSW 

assumes they will not execute or need to provide for eManifest eSignatures.

2. Equal user group eSignature risk: For each option/sub-option, OSW assumes in this cost comparison that each of the four user 

groups (i.e., SQGs, LQGs, transporters, and TSDFs) will use the same eSignature method within each option/sub-option 

evaluated, rather than mixing and matching different eSignature methods according to different perceived risks associated with 

each of the four user groups.

3. User participation rate: 75% participation rate phase-in assumption applied to cost calculations: see Appendix B to this 

document for the associated eManifest user truck, facility, and employee counts.

4. Office desktop PCs: This cost comparison assumes that all LQGs and TSDFs currently have at least one office destktop PC, 

with existing internet ISP connection, which can be used for initiating and for receiving eManifests at no additional initial year

or annual year business cost, as well as complying with the two fundamental CROMERR e-reporting requirements:

 View in “human readable format” (i.e., view an electronic computer image) the content of the eManifest form that the 

employee is “certifying to, attesting to or agreeing to by signing”, as required by EPA’s CROMERR final rule (40 CFR 

3.2000(b)(5)(iii)), and

 Keypunch their required PIN (personal identification number) or personal password to represent an electronic 

signature.

This cost comparison assumes that SQGs do not have an office desktop PC with internet ISP connection; consequently, this 

analysis assumes that commercial hazardous waste trucks will provide eManifest capability for SQGs. The cost estimates 

assume that all facilities (i.e., LQGs, trucks, and TSDFs) have at least one office desktop computer, or truck PDA or tablet PC, 
13

on which hazardous waste generator shipping offeror, waste transporter, and waste receiving facility employees may log-on to 

the eManifest CDX-hosted website homepage.

5. Truck computer equipment: OSW is aware that at least one commercial hazardous waste trucking company (Safety-Kleen) 

already has equipped some or all of its hazardous waste trucks with onboard mobile PDAs and/or tablet PCs. However, 

because OSW does not have complete information about the exact number of trucks and the specs required for this truck 

computer equipment, this cost comparison simplistically assumes that all 10,100 hazardous waste trucks in the US fleet do not

currently have onboard mobile computer hardware or existing wireless ISP service for trucks. Consequently, this assumption 

may overstate wireless ISP service costs to waste transport trucks for the four sub-options requiring mobile wireless 

connectivity for instantaneous identity verification of eManifest eSignatures (i.e., sub-options 1C, 2B, 2C, 3) by at least 4%.4

Alternatively, if the instantaneous identity verification assumption applied in this cost comparison for those four suboptions is dropped and substituted with an “end-of-business-day” uploading of eSignatures saved each day on the truck PDAs 

(or truck tablet PCs) without requiring instantaneous identity verification at each signature event, the wireless ISP cost 

assigned for trucks in this cost comparison could be dropped from these four sub-options.

6. Mobile printer costs: This cost comparison does not include potential costs to truckers for purchasing mobile printers for their 

trucks, or for upgrading truck PDAs or truck tablet PCs with printer drivers and printer connection ports/cables, so that a paper 

copy of the manifest can be carried on the truck in lieu of the USDOT 49 CFR required shipping paper. Based on a cost of

$320 for portable printers for PDAs, such requirement could add at least $3.374 million additional initial year user cost, which 

divided over a 5-year cost period is equivalent to $1.103 million additional average annualized user cost.

5

 

4 This 4% estimate is based on two information sources: (a) According to the Waste News magazine “2005 Hauling & Disposal Ranking” (17 July 2006 issue; 

pages 15 to 20; http://www.wastenews.com/rankings/haulers.html), based on 2005 business revenues from hauling, disposal and transfer of all types of 

residential, commercial and industrial waste (excluding revenue from incineration and sale of recyclables), Safety-Kleen Systems of Plano, TX is ranked 4th with 

2,227 trucks involved in solid waste, liquid waste, and hazardous waste. This ranking does not provide a breakout of the 2,227 trucks by waste class. However, 

from peer review comment made on OSW’s Nov 2006 1st draft of this cost comparison, Veolia Environmental Services Corp commented it operated 350 

hazardous waste trucks, which is about 12% of the 3,000 total hauling trucks reported for Veolia’s 5th place ranking in the Waste News 2005 Hauling Ranking. 

Applying this 12% to the 2,227 Safety-Kleen total truck count produces an estimate of 260 hazardous waste trucks. At the 75% eManifest implementation 

scenario involving 7,600 total hazardous waste trucks, the estimated 260 Safety-Kleen trucks represents 3.4%. (b) This estimate comports with the Safety-Kleen 

“fleet of more than 2,000 trucks” of which 300 are hazardous waste tanker trucks as reported for in the Bulk Transporter magazine report “Safety-Kleen 

Customers Receive Guaranteed Waste Handling Service”, 01 April 1998 at: http://bulktransporter.com/mag/transportation_safetykleen_customers_receive (i.e., 

300/7,600 = 3.9%).

5

$320 cost for mobile printer based on price for Infinite Peripherals PP-55 portable printer at: 

http://www.yourmobiledesk.com/products/proddetail.cfm?prodID=5052&catID=na&subcatID=na&sscatID=na&mfrID=na. [($320 per mobile printer) x (7,600 

trucks) x (120% truck backup & multiple employee per truck purchase multiplier) + ((7,600 trucks) x (($15 per paper roll) x (4 rolls/year))) = $3.374 million 

initial year cost], which is equivalent to $0.675 million/year divided over a 5-year period. Added to $0.337 million (i.e., $3.374 million x 10%) in annual cost for 

10% annual replacement rate for lost/ stolen/ broken PDA portable printers provides a 5-year average annualized cost of $1.012 million/year not included in this 

cost comparison for any eSignature option/sub-option.
14

7. Other Federal electronic programs: As of 2006, at least two other Federal agencies are implementing electronic programs 

related to transportation. OSW anticipates that a relatively small 1.5% to 2.3% fraction of the 10,100 RCRA hazardous waste 

trucks (i.e., 150 to 230 trucks) may become future participants in these two other programs. However, for purpose of this cost 

comparison, any potential future electronic capabilities acquired for compliance with these two other Federal electronic 

programs are not credited as potential hardware or software cost savings to eManifest users in this cost comparison.

 TWIC IDs: The Transportation Worker Identification Credential (TWIC) program is a Transportation Security 

Administration (TS) and US Coast Guard initiative. The TWIC program provides a tamper-resistant 

biometric credential to maritime workers requiring unescorted access to secure areas of port facilities. 

An estimated 750,000 individuals will require TWICs. Enrollment and issuance will take place over an 

18 month period. To obtain a TWIC, an individual must provide biographic and biometric information 

such as fingerprints, sit for a digital photograph and successfully pass a security threat assessment 

conducted by TSA. While TWIC may be implemented across other transportation modes in the future, 

the TWIC Final Rule, published in the Federal Register January 25, 2007, sets forth regulatory

requirements to implement this program in the maritime mode first (source:

http://www.tsa.gov/what_we_do/layers/twic/index.shtm).

 ACE eManifest: On 27 October 2006, the US Customs & Border Protection (CBP) published the first of a series of 

Federal Register Notices (FRN) announcing that electronic manifests (eManifests) will be required to be 

submitted to CBP prior to a trucks arrival at specific land border crossings. The requirement to submit 

eManifests at the initial ports will be implemented 90 days from the date of publication of the mandatory

eManifest notice. An aggressive roll-out schedule is planned to make e-Manifests mandatory at all land 

border crossings by the end of 2007. Carriers will be able to file an eManifest through the ACE Secure 

Data Portal or by a CBP tested solution provider. (source: 

http://www.cbp.gov/xp/cgov/toolbox/about/modernization/ace).
15

III. Cost Calculations

Option 1: PIN/password

OSW estimated costs for the three sub-options (1A, 1B, 1C) based largely on the FY2007 price list for IT services provided by EPA’s 

OEI-OTOP at: http://cfint.rtpnc.epa.gov/otop/currentfyservices.

Sub-Option 1A: PIN/password plus initially one-time mail to OEI (CDX), employee “signature holder agreements6”

(SHAs) or facility-wide LRA SHA certification (1-factor identity proofing)

This option assumes that PIN/password management is provided as a local self-service at each user facility according to the CDX 

remote certification agreements of this option, rather than managed via eManifest CDX infrastructure. Accordingly, the incremental 

cost for PIN/password management software is assigned in this cost comparison as a “User Cost” rather than as an “EPA Cost”. 

However, because the price example applied in this cost estimate is based on a per-business license basis, the PIN/password software 

business license cost estimate might also serve as a preliminary rough estimate of the incremental cost to eManifest infrastructure for 

purchasing PIN/password management licenses for managing user PIN/passwords via the CDX eManifest infrastructure.

 Initial Year Costs

o Software & IT Services:

EPA: $1.976 million to $5.229 million:

Low-end: If OEI receives facility-wide certifications in mail that employee ink “signature holder 

agreements” (SHAs) are maintained onsite by the company notarized onsite custodian “LRA”:

 

6

Signature holder agreements (SHAs): EPA’s 13 Oct 2005 CROMERR final rule (page 59863) requires that all persons reporting electronically to CDX (a) 

register with CDX and (b) print out a SHA from the CDX registration website, sign the SHA, and mail it to EPA’s CDX. Furthermore, the CROMERR final rule 

(page 59863) indicates that “CDX will continue this [SHA] approach for reports where electronic signatures are required, although EPA is exploring the use of 

an entirely paperless signature agreement process for at least some of these cases.” For purpose of this eSignature cost comparison, OSW assumes that 

eManifest users will only be required to register with CDX online via the eManifest website, without having to print, sign, and mail a SHA to EPA (CDX) under 

the other eSignature options/sub-options. Furthermore, OSW assumes for purpose of this cost comparison that EPA’s cost for establishing and maintaining 

eManifest user CDX registration accounts established via online registration is equal across all eSignature options/sub-options (the introduction to this cost 

comparison provides an estimate of this eManifest user account maintenance cost to EPA). The CDX user basic registration requirements are: (a) supply 

information to identify themselves, their company, and the EPA documents they wish to submit electronically, (b) verify and/or correct registration information, 

and (c) access their CDX web accounts through a secure website, and agree to the terms and conditions of using the site, which include safeguarding their selfgenerated password, before using web forms or uploading files to submit electronic documents or data to EPA. “These are the minimum steps for gaining access 

to CDX at this time” (source: EPA’s 13 Oct 2005 CROMERR final rule, p. 59862).
16

$1.976 million, calculated as follows: [(98,360 facilities) x ($20.09 per incoming LRA SHA 

certification)]. This estimate is based on OEI-OTOP’s FY2007 Working Capital Fund Rates for 

“Correspondence Management System: EK” which is a service that “scans, logs, tracks, and 

stores incoming and outgoing correspondence in all program and regional offices... creating a 

virtual record for each control”; the cost includes space rental for incoming documents. OEIOTOP’s unit cost data from http://cfint.rtpnc.epa.gov/otop/currentfyservices/ek/ek.cfm.

High-end: If OEI receives ink “signature holder agreements” (SHAs) from all employees in mail without 

onsite facility-wide LRA:

$2.397 million to $5.229 million, calculated as follows: [(119,300 to 260,300 employee users) x 

($20.09 per incoming SHAs)]. This estimate is based on OEI-OTOP’s FY2007 Working Capital 

Fund Rates for “Correspondence Management System: EK” (see above for description).

Users: $1.009 million to $4.217 million:

Software cost: $0; assumes that all facilities currently provide existing single password log-on access to 

internet-enabled desktop PCs and truck PDAs via internet service provider (ISP) log-on protocol).

Labor cost: $1.009 million to $4.217 million calculated as follows:

o Low-end: $1.009 million to $2.202 million if OEI receives ink signature agreements from all 

employees in mail without onsite LRA:

 Labor burden to employees: $0.962 million to $2.100 million paperwork burden for 

executing handwritten signatures by all employees: [(119,300 to 260,300 employee users) 

x (15 minutes per employee to retrieve, read, sign, address, seal and mail agreement) x 

($32.27/hour mean wage)]. Note: 15 minutes per employee assumption from EPA’s 13 

Oct 2005 CROMERR final rule (FR p.59876).

 File cabinets: $0.

 Postage: $0.047 million to $0.102 million mail postage: [($0.39/stamp) x (119,300 to 

260,300 employee users)].

o High-end: $3.079 million to $4.217 million if OEI receives facility-wide certifications in mail 

certifying that ink signature agreements for all employees are maintained onsite by the company

notarized onsite custodian “LRA”:

 Labor burden to employees: $0.962 million to $2.100 million paperwork burden for 

executing handwritten signatures by all employees: [(119,300 to 260,300 employee users) 

x (15 minutes per employee to read and sign agreement) x ($32.27/hour mean wage7)]. 

 

7 Mean industrial employee loaded wage rate of $32.27 per hour applied in this cost analysis, represents an average of the 2005 mean wage rates for all 

occupational categories in two NAICS industrial groupings: (a) NAICS 31, 32, 33 manufacturing industry sector ($18.87/hour;

http://www.bls.gov/oes/current/naics2_31-33.htm) which is the single largest shipper of RCRA hazardous wastes, and (b) NAICS 562 waste management 
17

Note: 15 minutes per employee assumption from EPA’s 13 Oct 2005 CROMERR final 

rule (FR p.59876).

 Labor burden to LRA: $1.587 million paperwork burden for “preparing and submitting 

the certification of receipt and secure storage to EPA”; [(98,360 facility LRAs) x (30 

minutes per LRA) x ($32.27/hour mean wage)]. Note: 30 minutes per LRA assumption 

from EPA’s 13 Oct 2005 CROMERR final rule (FR p.59876).

 File cabinets: $0.492 million for onsite file cabinet purchase cost: [(10% ($5) average 

portion of $50 file cabinet per facility) x (98,300 facilities)].

 Postage: $0.038 million mail postage: [($0.39/stamp) x (98,360 facilities)].

o Hardware: $0; assume no incremental hardware costs to SQGs, LQGs, transporters, and TSDFs because waste 

offeror and waste receiver facility employees are assumed to view the eManifest form electronic image 

and keypunch their PIN/password electronic signatures into eManifest via existing office desktop PC 

keyboards and existing truck PDAs/tablet PCs at time of waste pickup and delivery.

EPA: $0

Users: $0

 Annually Recurring Costs

o Software & IT Services:

EPA: $0.535 million/year to $5.327 million/year:

 $0.237 million/year to $0.837 million/year:

o Low-end: $0.237 million/year; calculated as 12% of initial year cost to account for 12% 

future annual new establishment start-ups.

8

o High-end: $0.837 million/year, calculated as 16% of initial year cost to account for 16% 

employee annual turnover rate.

 $0.298 million/year to $4.490 million year for PIN/password helpdesk resets (see Appendix A).

Users: Certifications: $0.161 million/year to $0.675 million/year, calculated as 16% of initial year cost to 

account for 16% employee annual turnover rate.

 

industry group ($18.56/hour; http://www.bls.gov/oes/current/naics3_562000.htm) which represents the single largest receiver of RCRA hazardous wastes; both 

wage rates were loaded with (a) 30% US national average private industry employer cost for employee benefits (http://www.bls.gov/news.release/pdf/ecec.pdf), 

and (b) 12% business labor overhead cost factor as prescribed by Figure C1 “Table of Standard A-76 Costing Factors” on page C-4 of OMB Circular A-76. 

OSW calculated the average wage rate for these two industry groups, with these two cost factors applied, as follows: [(($18.87/hour + $18.56/hour)/2) / (100% -

(30%+12%)) = $32.27/hour.]

8

12% annual new establishment start-up rate is based on a December 1996 US Census Bureau study of 6.08 million operating business establishments in 1992, 

in eight US economic sectors (i.e., 1. mining, 2. construction, 3. manufacturing, 4. transportation & public utilities, 5. wholesale, 6. retail, 7. finance, insurance & 

real estate, and 8. services); the study found a 12% rate of new establishment start-ups, and an 11% rate of existing establishment closures for the study year 1992 

(see page 9 at: http://www.ces.census.gov/index.php/ces/1.00/cespapers?down_key=100249).
18

o Hardware:

EPA: $0

Users: $0

Sub-Option 1B: PIN/password plus initial one-time driver’s license# or credit card# remote cross-check (initial 2-factor 

identity proofing)

Assumes that DL# or CC# identity proofing only occurs for each eManifest user upon initial registration with eManifest (i.e., as an 

initial year cost according to the count of eManifest users), rather than at each eManifest signing event (i.e., as an annually-recurring 

cost according to the annual count of signatures on eManifests). One example of an existing IT approach to implementing this as a 

user feature within eManifest is to use the “Designer” features provided by Adobe Systems Inc. (http://www.adobe.com/government) 

in which the Adobe designed electronic form is connected to a web service that validates credit card numbers, by creating a new data 

connection to an WSDL9to bind one or more such web services providers (source: http://www.adobeforums.com/cgibin/webx/.3bb918ad). This identity proofing services cost is based on price data from World DLA, an IT services vendor which 

successfully launched the world’s first “real time” online driver’s license validation service, which reportedly “can provide the basic 

‘yes’ or ‘no’ validation answer in just seconds” (source: http://news.thomasnet.com/fullstory/473992).

 Initial Year Costs

o Software & IT Services:

EPA: $0

Users: $0.239 million to $0.521 million:

o Initial DL# or CC# identity proofing: $0.239 million to $0.521 million, calculated as follows: 

[(119,300 to 260,300 employee users) x ($2 per remote DL# or CC# identity proofing service)].

o Software cost: $0; assumes all facilities currently provide single password log-on access to 

internet-enabled desktop PCs and truck PDAs via internet service provider (ISP) log-on protocol).

o Hardware:

EPA: $0

Users: $0

 Annually Recurring Costs

o Software & IT Services:

EPA: $0.298 million/year to $4.490 million year for PIN/password helpdesk resets (see Appendix A).

 

9 WSDL: Short for “Web Services Description Language”, an XML-formatted language used to describe a web service's capabilities as collections of 

communication endpoints capable of exchanging messages. WSDL is an integral part of UDDI, an XML-based worldwide business registry. WSDL is the 

language that UDDI uses. WSDL was developed jointly by Microsoft and IBM (source: http://www.webopedia.com/TERM/W/WSDL.html.
19

Users: Annual DL# or CC# identity proofing: $0.038 million/year to $0.083 million/year, calculated as 16% of 

initial year cost to account for 16% employee annual turnover rate.

o Hardware:

EPA: $0

Users: $0

Sub-Option 1C: PIN/password plus 2

nd factor identity verification

To differentiate in this cost comparison, the cost of a single PIN/password solution (Option 1A) compared to a 2nd factor identity

verification in addition to a PIN/password, as well as to reflect multiple possible IT solutions for 2nd factor identity verification, the 

cost estimate for this sub-option is based on three sub-options:

1C-1: TPV: Third party verification online service

1C-2: OTP: One-time password token online service

1C-3: IRS: Internal Revenue Service efiling “Self-Select PIN”

In addition, this sub-option includes the cost for wireless ISP access by trucks for realtime and everytime identity verification in the 

field for each manifest signature event (as well as for sub-options 2B, 2C and 3); in contrast, a wireless ISP cost is not assigned to suboptions 1A or 1B (or 2A) in this cost comparison because those two PIN/password sub-options represent one-time identity verification 

methods for initial user registration with the eManifest system, not for each eManifest signature event (and sub-option 2A does not 

require identity verification).

 Sub-Option 1C-1: TPV:

Online third-party identity verification (TPV) service exampled based on the IDology Inc’s “ExpectID IQ” service, in which a “https 

post” XML connection to the TPV is embedded within the eManifest homepage architecture. eManifest users would log-on to 

eManifest with user name, PIN/password, and then the TPV service returns to the eManifest homepage screen, a series of multiple 

choice questions to which the user would type-in answers. The questions would be derived by the TPV from instantaneous queries of 

public records databases (now available in all US states and territories). The user responses would determine if the user is actually

who he/she claims to be. The entire verification process can be completed within less than one minute, depending upon the number of 

2

nd identity proofing questions asked by the TPV. Under this arrangement, OSW’s eManifest system would be the single TPV 

customer to which monthly invoices would be sent, not the eManifest users. OSW could then pass-thru this annual O&M expense to 

eManifest users via user fees.

 Initial Year Costs
20

o Software & IT Services:

EPA: $0.001 eManifest architecture integration cost (source: OSW estimate of relatively small start-up fee 

based on “less than $1,000” estimate verbally provided over the phone 12 April 2007 to Mark Eads, 

OSW. by Doug Finlayson, Customer Service Manager, IDology, Inc., 770-984-4697. The initial 

integration of this TPV service into the eManifest architecture is a 1-day task according to IDology Inc.

Users: $0

o Hardware:

EPA: $0

Users: $0

 Annually Recurring Costs

o Software & IT Services:

EPA: $8.278 million/year to $12.470 million/year:

o $7.980 million/year calculated as follows: [(3.8 million eManifests per year) x (average of 3 

eSignature 2nd factor verifications needed per eManifest) x ($0.97 for TPV service cost per 

transaction) x (0.70 for 30% large volume pricing discount)]; price source: 12 April 2007 phone 

verbal price quote (non-discounted volume) provided to Mark Eads, OSW by Doug Finlayson, 

Customer Service Manager and Jim Mitchell, VP Marketing, IDology, Inc., 770-984-4697 and 

770-984-4699. Otherwise, there are no monthly or annual subscription or license fees required 

for this TPV service.

o $0.298 million/year to $4.490 million year for PIN/password helpdesk resets (see Appendix A).

Users: Wireless ISP for trucks: $0.729 million/year for wireless ISP (internet service provider) service 

calculated as follow: [($39.99/month per 5-truck user ISP account) x (12 months/year) x (7,600 trucks) / 

(5 trucks/ISP account)] to provide the necessary wireless connectivity of truck PDAs to connect realtime 

for eSignature identity verification each time an eManifest is electronically signed (source: $39.99 

monthly wireless ISP fee price example from Palm.Net's Executive Unlimited monthly usage plan 

http://www.smartcomputing.com/editorial/article.asp?article=articles/archive/l0805/09l05/09l05.asp&gu

id=).

o Hardware:

EPA: $0

Users: $0
21

 Sub-Option 1C-2: OTP:

One-time password (OTP) token technology which generates and displays a pseudo-random number consisting of six or more 

alphanumeric characters; when the pseudo-random number is combined with a PIN or password, the resulting passcode is considered 

two factors of authentication (source: http://en.wikipedia.org/wiki/One-time_password).

 Initial Year Costs

o Software & IT Services:

EPA: $0

Users: $0; assumes that all facilities currently provide existing single password log-on access to internetenabled desktop PCs and truck PDAs via internet service provider (ISP) log-on protocol.

o Hardware:

EPA: $0

Users: 2

nd factor tokens: $0.596 million to $22.559 million: [($5 per Entrust mini token) to ($52 per 

RSASecurID token x (5 years cost period)/(3 year license) x (119,300 to 260,300 employee users)].

 Annually Recurring Costs

o Software & IT Services:

EPA: $0.298 million/year to $4.490 million year for PIN/password helpdesk resets (see Appendix A).

Users: $1.206 million/year to $9.059 million/year:

o 2

nd factor license: $0.477 million/year to $8.330 million/year: [(119,300 to 260,300 employee 

users) x ($4 to $32 per user per year)]. Although one source reports that the incremental annual 

cost to users of adding this 2nd computer access factor typically ranges from $50 to $100 per user 

per year (source: http://en.wikipedia.org/wiki/Strong_authentication), a lower-cost Entrust 

IdentityGuard OTP token service introduced in 2007 is priced at an average annualized cost of 

$4 per user per year (source: http://www.entrust.com/strongauthentication/identityguard/calculator.cfm). The Entrust website also provides an upper-bound 

cost example based on the RSA SecurID token 3-year license technology

(http://en.wikipedia.org/wiki/SecurID) with an average annualized user cost of $32. These two 

cost points provide a range of $4 to $32 per user per year applied in this sub-option rather than 

the broader $50 to $100 price range.10

 

10 Another two-factor OTP authentication technology involves USB tokens. This cost comparison does not estimate the cost for this third example technology 

for Suboption 1C (in addition to the Entrust IdentityGuard mini token and the RSASecurID token products) because the $13 average annualized user cost falls 

within the $4 to $32 average annual user cost of the other two products. Source: $30 average purchase cost for UBS token purchase based on $25 to $43 price 

range for a sample of eight products (Aladdin, G&D, Gem E-Seal, Oberthur companies) priced March 2007 at http://www.usasmartcard.com, and $35 average 

purchase cost for USB token software based on $30 to $39 price range for a sample of four products (Dekart Logon, Mipko Software Double Password 1.21, 

Proteg 3.1) priced March 2007 at http://www.surfpack.com/software/usbtoken1.
22

o Wireless ISP for trucks: $0.729 million/year for wireless ISP (internet service provider) service 

calculated as follow: [($39.99/month per 5-truck user ISP account) x (12 months/year) x (7,600 

trucks) / (5 trucks/ISP account)] to provide the necessary wireless connectivity of truck PDAs to 

connect realtime for eSignature identity verification each time an eManifest is electronically 

signed (source: $39.99 monthly wireless ISP fee price example from Palm.Net's Executive 

Unlimited monthly usage plan 

http://www.smartcomputing.com/editorial/article.asp?article=articles/archive/l0805/09l05/09l05.

asp&guid=).

o Hardware:

EPA: $0

Users: $0.045 million/year to $0.833 million/year for token replacement: 10% of initial hardware cost for 

annual replacement of lost and broken hardware tokens (source: 10% replacement rate assumption is 

from VeriSign’s 2005 white paper “Two-Factor Authentication: A Total Cost of Ownership Viewpoint”, 

p.7: http://www.verisign.com/Resources/Unified_Authentication_White_Papers/index.html).

 Sub-Option 1C-3: IRS.

The IRS efile “self-select PIN” method involves internet IT services provided to taxpayers by 3

rd party IT vendor “partners” to the 

IRS, to provide both (a) tax form preparation software, and (b) e-filing services involving the taxpayer creating a self-select PIN via 

the IT vendor online service. When the PIN e-signature method is used, no signature documents are required to be filed by the 

taxpayer with the IRS. The PIN may be any five digits the taxpayer chooses (except all zeros) to use as his/her electronic signature. 

Taxpayers create their own PIN (but do not register the PIN with IRS before filing or need to contact IRS to get it) using one of the 

commercially available tax software packages that support the Self-Select PIN. IRS’s self-select PIN method requires use of the PIN 

plus original Adjusted Gross Income (AGI) or PIN (if e-filed and signed electronically) from the prior year tax return and Date of 

Birth (DOB) for verification purposes by the IT vendor. The same PIN may be used in future years, or it may be changed by the 

taxpayer in any year. This method is for taxpayers who file electronically using tax preparation software.

The IRS also offers a “Practitioner PIN Method” whereby the taxpayer e-files through a tax professional who is an Authorized 

e-file provider . This alternative method does not required the taxpayer to provide his/her original Adjusted Gross Income (AGI) or 

PIN (if e-filed and signed electronically) from prior year return or DOB. The IRS itself does not provide and maintain taxpayer PIN 

numbers, the necessary software, or provide a public website for direct e-filing; the parter IT vendors e-file to the IRS on behalf of 

taxpayers via the vendor’s own secure internet servers with SSL encryption.

As of March 2007, IRS had entered into partnership agreements with 26 IT vendor companies to provide self-select PIN efiling services for taxpayers, but the IRS does not endorse or warrant its partner companies for their products or services (source: 

http://www.irs.gov/efile/lists/0,,id=101223,00.html and http://www.irs.gov/efile/article/0,,id=101246,00.html).
23

OSW’s cost estimates below for this two-factor identity proofing sub-option are based on the 21 April 2006 Chevo Consulting 

cost estimate for the IRS efile “Self-Select PIN” method in “eSignature Cost Benefit Analysis” (provided 10 April 2007 to OSW by

Kevin Hatton, IRS ETA Technology Programs Branch, 202-283-7877), and the IRS “efile Partners for Taxpayers” price list (source: 

http://www.irs.gov/efile/lists/0,,id=101223,00.html), scaled in cost by OSW according to the eManifest user volume scenario shown in 

Appendix B to this cost comparison.

o High-End: However, given the relatively large annual user cost estimate based on the IRS IT vendor fees for PIN efiling services, the IRS-based cost estimate constituents a “High-End” for this sub-option.

o Low-End: OSW also computed a “Low-End” cost estimate substitute to the IRS PIN approach, based on price data 

supplied 12 April 2007 to Mark Eads, OSW, by Doug Finlayson, Customer Service Manageer of IDology

Inc., for their “ExpectID” identity verification service (http://www.idology.com/identity.html) which 

requires users to supply their SSN4 or year-of-birth (YOB) as a 2nd factor PIN-type verification.

 Initial Year Costs

o Software & IT Services:

EPA: $0.001 million to $0.047 million

o Low-end (SSN4 or YOB): $0.001 eManifest architecture integration cost (source: same as suboption 1C-1).

o High-end (IRS): $0.006 million to $0.047 million, calculated as follows: [(30 to 240 EPA IT

contractor labor hours) x (($135/hour EPA IT contractor labor wage rate) + ($57/hour EPA FTE 

oversight cost)) x (1.02 price inflation factor)] for eManifest architecture development.

Users: $0

o Hardware:

EPA: $0

Users: $0

 Annually Recurring Costs

o Software & IT Services:

EPA: $0.298 million/year to $4.798 million/year:

o $0 million/year to $0.308 million/year:

o Low-end (SSN4 or YOB): $0

o High-end (IRS): $0.070 million/year to $0.308 million/year, calculated as follows: [((500 to 

2,200 EPA IT contractor helpdesk support labor hours for rejected PIN/passwords) + (10 to 

40 EPA IT contractor maintenance hours/year)) x (($135/hour EPA IT contractor labor rate)

x (1.02 price inflation factor)].

o $0.298 million/year to $4.490 million year for PIN/password helpdesk resets (see Appendix A).

Users: $3.682 million/year to $45.759 million/year:

o Service fee for 2nd factor verification:
24

 Low-end (SSN4 or YOB): $2.953 million/year, calculated as follows: [(3.8 million 

eManifests per year) x (average of 3 eSignature 2nd factor verifications needed per 

eManifest) x ($0.37/transaction) x (0.70 for 30% large volume pricing discount)]. Note 

the 30% pricing discount for ExpectID is a rough estimate provided 12 April 2007 to 

Mark Eads, OSW, by IDology Inc. (Jim Mitchell, 770-984-4699).

 High-end (IRS): $45.030 million/year, calculated as follows: [(3.8 million eManifests per 

year) x (average of 3 eSignature 2nd factor verifications needed per eManifest) x ($3.95 

PIN creation and efiling fee charged by IRS-approved efile IT vendors)]. This e-filing

fee represents the lowest non-zero price point of the broader $0 to $14.95 range across 

the 26 IRS partner IT vendors (as of 10 April 2007), which appears to represent only the 

incremental cost of the PIN-based e-filing service, excluding the additional cost of the tax 

form preparation software.

o Wireless ISP for trucks: $0.729 million/year for wireless ISP (internet service provider) service 

calculated as follow: [($39.99/month per 5-truck user ISP account) x (12 months/year) x (7,600 

trucks) / (5 trucks/ISP account)] to provide the necessary wireless connectivity of truck PDAs to 

connect realtime for eSignature identity verification each time an eManifest is electronically 

signed (source: $39.99 monthly wireless ISP fee price example from Palm.Net's Executive 

Unlimited monthly usage plan 

http://www.smartcomputing.com/editorial/article.asp?article=articles/archive/l0805/09l05/09l05.

asp&guid=).

o Hardware:

EPA: $0

Users: $0
25

Option 2: Handwritten Digitized Signature

OSW’s cost calculations for this option are largely based on price quotes supplied 01 March 2007 by Interlink Electronics Inc. to Rich 

LaShier Interlink Electronics is an eSignature products vendor (http://www.interlinkelectronics.com/index.php?id=Mzg4). The cost 

calculations for each sub-option (2A, 2B, 2C) are based on Interlink’s large quantity discounted price quotes for both hardware and 

software user costs. Price quotes include one-year product warranty. An important assumption for this option is that the costs of 

purchasing and maintaining business office desktop PCs (for LQGs & TSDFs) and of PDAs or tablet PCs for trucks, are considered 

required for basic participation in eManifest, and thus are not assigned as incremental costs to eSignature options. Consequently, this 

option only includes costs for purchasing and maintaining digitized signature hardware and software peripherals11. The cost estimates 

for this option assume purchase of alternative types of digitizer signature pads for LQG & TSDF office desktop PCs as well as for 

trucks. Although OSW anticipates that hazardous waste transporters will purchase heavy-duty mobile “tablet PCs” for trucks12, the 

entire cost of a tablet PC is not completely allocatable to the eSignature feature; consequently, the digitizer pad costs applied in this 

cost comparison are OSW’s approximation of the allocatable portion of a tablet PC cost.

Sub-Option 2A: eSignature Pads without identity verification

 Initial Year Costs

o Software & IT Services:

EPA: $0.0015 million server license cost

Users: $0 (basic software cost included in hardware cost)

o Hardware:

EPA: $0

Users: $1.658 million to $4.975 million: [(12,100 LQGs + 890 TSDFs + (7,600 trucks x 120% to account for 

truck backup devices and for more than one employee per truck in some cases13) x ($75 per standard 

USB signature pad to $225 for LCD visual display signature pad)].

 

11 Peripherals: A peripheral is a piece of computer hardware that is added to a host computer in order to expand its abilities. More specifically, the term is used to 

describe those devices that are optional in nature, as opposed to hardware that is either demanded or always required in principle. The term also tends to be 

applied to devices that are hooked up externally, typically through some form of computer bus like USB. Typical examples include joysticks, printers and 

scanners. Devices such as monitors and disk drives are not considered peripherals when they are not truly optional (source: 

http://en.wikipedia.org/wiki/Peripheral).

12 Examples of mobile “tablet PCs” for trucking are http://www.xploretech.com/public/iX104C2_July2006.pdf and 

http://www.dataltd.com/vehiclemountprod.html and http://www.myruggedtabletpc.com.

13 120% multiplier applied to truck-hardware costs in this cost comparison is an OSW estimate for additional hardware needed to reflect the reality that some 

companies have more field personnel than trucks: One peer reviewer of OSW’s 15 Nov 2006 first draft of the Appendix to this cost comparison – affiliated with 

a commercial hazardous waste transport company operating a fleet of 350 hazardous waste trucks -- commented “It appears that EPA is assuming that there’s a 

direct 1 to 1 correlation of the number of trucks to the number of e-signature devices needed. From a field perspective, we’d likely need more than one unit [i.e., 
26

 Annually Recurring Costs

o Software & IT Services:

EPA: $0.0004 million/year server license cost

Users: $0 (basic software cost included in hardware cost)

o Hardware:

EPA: $0

Users: $0.166 million/year to $0.498 million/year; assumes average annual 10% replacement rate of initial year 

cost for replacement of stolen/ lost/ broken digitized signature pads.

Sub-Option 2B: eSignature pads with PIN/password 1-factor identity verification

 Initial Year Costs

o Software & IT Services:

EPA: Same as 2A,

Users: Same as 2C

o Hardware:

EPA: $0

Users: Same as 2A

 Annually Recurring Costs

o Software & IT Services:

EPA: Same as 2A plus $0.298 million/year to $4.490 million year for PIN/password helpdesk resets (see 

Appendix A).

Users: Same as 2C

o Hardware:

EPA: $0

Users: Same as 2A

 

electronic signature device] per commercial vehicle as we have more field service personnel than commercial trucks and some jobs may require more than 1 

device be available.” (source: Tom Baker, Director, Environment & Transportation, Veolia ES Technical Solutions LLC, Flanders NJ). Rather than apply a 

multiplier of 2 (i.e., 200%) to this cost item, OSW applied a smaller 1.2 multiplier (i.e., 120%) to reflect the fact that some trucks only have one assigned 

employee.
27

Sub-Option 2C: eSignature pads with thumbprint biometric identity verification

 Initial Year Costs

o Software & IT Services:

EPA: Same as 2A

Users: $1.658 million: [(12,100 LQGs + 890 TSDFs + (7,600 trucks x 120% to account for truck backup 

devices and for more than one employee per truck in some cases)) x ($75 extra cost for “pro” software 

license needed for each biometric signature pad)].

o Hardware:

EPA: $0

Users: $5.306 million: [(12,100 LQGs + 890 TSDFs + (7,600 trucks x 120% to account for truck backup 

devices and for more than one employee per truck in some cases)) x ($240 per biometric signature pad)].

 Annually Recurring Costs

o Software & IT Services:

EPA: Same as 2A

Users: $1.061 million/year:

o $0.332 million/year [(12,100 LQGs + 890 TSDFs + ((7,600 trucks) x (120% to account for truck 

backup devices and for more than one employee per truck in some cases)) x ($15 extra cost for 

“pro” software license annual maintenance needed for each biometric signature pad)].

o Wireless ISP for trucks: $0.729 million/year for wireless ISP (internet service provider) service 

calculated as follow: [($39.99/month per 5-truck user ISP account) x (12 months/year) x (7,600 

trucks) / (5 trucks/ISP account)] to provide the necessary wireless connectivity of truck PDAs to 

connect realtime for eSignature identity verification each time an eManifest is electronically 

signed (source: $39.99 monthly wireless ISP fee price example from Palm.Net's Executive 

Unlimited monthly usage plan 

http://www.smartcomputing.com/editorial/article.asp?article=articles/archive/l0805/09l05/09l05.

asp&guid=).

o Hardware:

EPA: $0

Users: $0.531 million: assumes average annual 10% replacement rate of initial year cost for replacement of 

stolen/ lost/ broken biometric signature pads.
28

Option 3: PKI Identity Verification

Short for “public key infrastructure”, PKI identity verification is a system based on digital certificates, Certificate Authorities (CAs), 

and other registration authorities that verify and authenticate the validity of each party involved in an Internet transaction. PKIs are 

currently evolving and as of 2006 there is no single PKI nor even a single agreed-upon standard for setting up a PKI. A PKI is also 

called a “trust hierarchy” (source: http://www.webopedia.com/TERM/P/PKI.html).

CAs are trusted third-party organizations or companies that issue digital certificates used to create digital signatures and 

electronic public-private key pairs. The role of the CA in the PKI process is to guarantee that the individual granted the unique digital 

certificate is, in fact, who he or she claims to be. Usually, this means that the CA has an arrangement with a financial institution, such 

as a credit card company, which provides the CA with information to confirm an individual's claimed identity. CAs are a critical 

component in data security and electronic commerce because they guarantee that the two parties exchanging information are really 

who they claim to be (source: http://www.webopedia.com/TERM/c/certification_authority.html).

A digital certificate (“cert”) is an attachment to an electronic message used for security purposes. The most common use of a 

digital certificate is to verify that a user sending a message is who he or she claims to be, and to provide the receiver with the means to 

encode a reply. An individual wishing to send an encrypted message applies for a digital certificate from a CA. The CA issues an 

encrypted digital certificate containing the applicant's public key and a variety of other identification information. The CA makes its 

own public key readily available through print publicity or perhaps on the Internet. The recipient of an encrypted message uses the 

CA's public key to decode the digital certificate attached to the message, verifies it as issued by the CA and then obtains the sender's 

public key and identification information held within the certificate. With this information, the recipient can send an encrypted reply. 

The most widely used standard for digital certificates is X.50914 (source: 

http://www.webopedia.com/TERM/D/digital_certificate.html).

EPA’s 13 Oct 2005 CROMERR final rule (page 59862) indicated that EPA does not expect PKI digital signature options such 

as this one to dominate CDX applications:

“Thus, for electronic reports currently submitted to CDX, only in one case is PKI used for electronic signature. The 

other cases involve PIN-based electronic signatures or other non-PKI electronic signature approaches. As an example 

of the latter, this year we anticipate implementing electronic signatures for an EPA reporting requirement by having 

signatories use a password that is self-generated during CDX registration in combination with certain items of 

information that are unlikely to be available to anyone except the signatory. This is a ``knowledge-based'' approach, 

which is being used extensively by commercial software vendors supporting the United States Internal Revenue Service 

(IRS) for electronic tax filings or ``e-filings', and is being adopted by other agencies. EPA expects that these non-PKI-

 

14 The X.509 digital certificate (Version 1) was first issued in 1988 as a part of the ITU X.500 Directory Services standard. When X.509 was revised in 1993, 

two more fields were added resulting in the Version 2 format. These two additional fields support directory access control. X.509 Version 3 defines the format 

for certificate extensions used to store additional information regarding the certificate holder and to define certificate usage. (source: 

http://www.webopedia.com/TERM/X/X_509.html)
29

based approaches to signature will continue to dominate CDX implementations of electronic reporting. We currently 

intend to use PKI where such needs as security or assuring very robust non- repudiation of signature make this the 

most appropriate approach.” (Source: http://www.epa.gov/fedrgstr/EPA-GENERAL/2005/October/Day13/g19601.htm)

OSW formulated cost estimates for this eSignature option based on two alternative sources, both of which are assumed to 

represent 2-year PKI licensing and digital certificate solutions:

Source A: Entrust Inc.: “Rough order of magnitude” (ROM) cost estimates provided 14 March 2007 to OSW by the Entrust 

Inc., a digital identities and information security company which released the first commercially available PKI in 

1994 (http://www.entrust.com/pki). The Entrust data are based on scaling of actual case examples of 

implementation of this eSignature technology at other government agencies, heavily discounted in price relative 

to the potential large size of eManifest users. The sever price discounting apparently makes this cost source the 

low-end of the two alternative sources (e.g., the Entrust user license price quotes provided to OSW declined 

from $51/user for 100 user quantity, to $30/user for 10,000 user quantity, to $18.50/user for 250,000 user 

quantity per 2-year license period). The Entrust PKI approach to eSignature workflow routing and processing 

between eManifest users and the CDX eManifest is based on internet Java applets15 technology.

Source B: EPA-OEI-OTOP: OSW (Richard LaShier, Bryan Groce, Mark Eads) met with OEI-OTOP (David Schwartz, 

Charles Freeman, Cory Wagner) on 27 March 2007 to discuss the prior draft of this cost comparison, during 

which OEI-OTOP provided a cost range of $70 to $100 per user “cert” per 2-year license period for CDX PKI

services.

Note: The IYC and ARC cost ranges for Option 3 below are ordered respective to the order of these two cost data 

sources (i.e., bottom-end is Source A, and top-end is Source B), rather than representing numerical “low-ends” and 

“high-ends”. Furthermore, for Source A OSW used the “heavy-discounted” cost estimate for the summary range of 

each cost sub-item.

 Initial Year Costs

o Software & IT Services:

EPA: PKI infrastructure: $0.348 million to $0 million:

 

15 Applets: Technical word originating in 1993, an “applet” is a software component that runs in the context of another program, for example a web browser. An 

applet usually performs a very narrow function that has no independent use. An applet is written in a language that is different from the scripting or HTML 

language which invokes it. Unlike a program, an applet cannot run independently; an applet usually features display and graphics and often interacts with the 

human user. (Source: http://en.wikipedia.org/wiki/Applet).
30

o Source A: Represents installing the Entrust PKI infrastructure as a component of the CDX-based 

eManifest system; the cost involve (a) infrastructure implementation (i.e., architecture consulting 

& design, implementation integration of PKI software, testing, post-implementation consulting), 

and (b) eManifest integration (i.e., requirements gathering, integration design of eManifest form, 

integration development, testing, onsite implementation, post-implementation consulting, project 

management).

o Source B: $0 represents hypothetical utilization of the existing CDX PKI service infrastructure.

Users: PKI service license: $2.207 million to $26.030 million:

o Source A: $2.207 million to $65.335 million based on the Entrust price estimate:

o If heavy-discounted price: [($18.50 per seat16) x (119,300 to 260,300 user employees) = 

$2.207 million to $4.816 million]. The per-seat cost consists of three cost components 

(a) manage services for identity credentials, (b) software enterprise license, and (c) 2-

factor authentication service.

o If light-discounted price: [($251 per certificate per user) x (119,300 to 260,300 eManifest 

users) = $29.944 million to $65.335 million for certificate cost].

o Source B: $8.351 million to $26.030 million based on the OEI-OTOP price quote [($70 to $100 

per PKI “cert”) x (119,300 to 260,300 user employees)].

o Hardware:

EPA: $0

Users: $0.260 million to $0 million

o Source A: PKI grid cards: $0.303 million to $0.260 million for plastic wallet-sized grid cards,

calculated as follows: [($2.54 per grid card) x (119,300 to 260,300 user employees)].

o Source B: $0 assumes grid cards not required.

 Annually Recurring Costs

o Software & IT Services:

EPA: $0

Users: $1.744 million/year to $12.703 million/year:

o $1.015 million/year to $11.974 million/year for subsequent annual licenses for new employees,

calculated as 16% of initial year cost to account for 16% employee annual turnover rate, plus 

 

16 Seat: A technical word used in the IT field usually as “per seat license”, which is a software license based on the number of users who have access to the 

software. For example, a 100-user license based on users means that up to 100 specifically named users (i.e., 100 “seats”) have access to the program. Per seat 

licensing is administered by providing user-level security to the directory containing the program. In contrast, “concurrent use license” is a software license that 

is based on the number of simultaneous users accessing the program. It typically deals with software running in the server where users connect via the network. 

For example, in a five-user concurrent use license, after five users are logged on to the program, the sixth user is prohibited. When any one of the first five log 

off, the next person can log on (source: http://www.techweb.com/encyclopedia/defineterm.jhtml?term=perseatlicense).
31

annual 30% of initial year cost for average annual license renewal for PKI certificate licenses 

assumed valid for 2-years (i.e., 46% of initial year cost):

 Source A: $1.015 million/year to $30.054 million/year

 Source B: $3.841 million/year to $11.974 million/year

o Wireless ISP for trucks: $0.729 million/year for wireless ISP (internet service provider) service 

calculated as follow: [($39.99/month per 5-truck user ISP account) x (12 months/year) x (7,600 

trucks) / (5 trucks/ISP account)] to provide the necessary wireless connectivity of truck PDAs to 

connect realtime for eSignature identity verification each time an eManifest is electronically 

signed (source: $39.99 monthly wireless ISP fee price example from Palm.Net's Executive 

Unlimited monthly usage plan 

http://www.smartcomputing.com/editorial/article.asp?article=articles/archive/l0805/09l05/09l05.

asp&guid=).

o Hardware:

EPA: $0

Users: $0.172 million to $0 million/year:

o Source A: PKI grid card replacement: $0.079 million/year to $0.172 million/year for replacement 

of plastic grid cards, calculated as 26% of the initial year cost to reflect 16% annual employee 

turnover rate plus 10% annual lost grid card and broken grid card average annual replacement 

rate.

o Source B: $0 assumes grid cards not required.
32

Appendices
33

Appendix A

OSW Estimate of Average Annual Cost for EPA CDX Helpdesk Services for eManifest Users

$0.298 million/year to $4.490 million/year for eManifest user helpdesk PIN/password reset services, assigned in this cost 

comparison as EPA costs to the four PIN/password sub-options 1A, 1B, 1C, and 2B. This cost range is based on two alternative 

helpdesk approaches and four alternative cost estimate calculations and cost data sources:

Furthermore, this cost range represents 20% to 50%, respectively, of the $1.490 million/year to $8.980 million/year in full annual 

cost for those four sub-options to provide eManifest helpdesk services to resolve PIN/password reset problems plus other user 

problems concerning the eManifest system, calculated as follows: [($0.298 million/year)/(20%) to ($4.490 million/year)/(50%)].

For the other three sub-options not based on PIN/passwords (i.e., sub-options 2A, 2C, and 3), the helpdesk cost is estimated at 

$1.192 million/year to $4.490 million/year, which is the difference between the full helpdesk cost for the four PIN/password suboptions, and the 20% to 50% fraction of that cost for PIN/password reset: [($1.490 million/year - $0.298 million/year) to ($8.980 

million/year - $4.490 million/year)]. In other words, the incremental helpdesk cost (i..e., 20% to 50% cost fraction) for PIN/password 

reset service is added to the four appropriate sub-options of this cost comparison, but the baseline helpdesk cost fraction (80% to 50%, 

respectively) for other helpdesk services is not added to any sub-option of this cost comparison because OSW simply assumes it is 

equal to each sub-option.

 Approach #1: User Self-Service Helpdesk Reset

$1.188 million/year to $2.593 million/year annual cost to EPA for PIN/password reset if conducted within the eManifest architecture 

using user self-service reset software. This estimate is based on the “P-Synch” password management service costing $9.96 per user 

per year provided by M-Tech Identity Management Solutions Inc. (http://www.p-synch.com/savings/example.html), calculated as 

follows: [(119,300 to 260,300 employee eManifest users) x ($9.96 per user per year)]).

The P-Synch automated password reset service allows locked out users to reset their own passwords, effectively addressing the 

problem of forgotten passwords. P-Synch creates a secure and efficient process for users to reset their passwords, thus minimizing 

helpdesk call volumes for resetting passwords. Once authenticated, users can reset their own passwords without calling the helpdesk. 

Self-service password reset is available from (a) a web browser using the user's own computer or that of a neighbor, (b) the login 

prompt of the user's own workstation, or (c) a telephone from which the user dials the IVR (interactive voice response) system that 

provides password reset.
34

 Approach #2: EPA Contractor-Staffed CDX Helpdesk Reset

$0.298 million/year to $4.490 million/year for the 20% to 50% fraction, respectively, of helpdesk annual cost which reportedly

involve user requests to IT helpdesks for user PIN/password resets (source: Gartner Group study results cited at 

http://mandylionlabs.com/PRCCalc/PRCCalc.htm). This estimated range in cost to EPA for supplying CDX helpdesk services to 

eManifest users for PIN/password resets is based on three independent cost data sources:

o Source A: $0.452 million/year to $2.464 million/year, calculated as follows: [(119,300 to 260,300 employee users) x ($18.93/year 

per user account management) x (20% to 50% helpdesk calls for password reset assistance)]. This estimate is based on 

OEI-OTOP’s FY2007 Working Capital Fund Rate of “$18.93/year per use for “Application Hosting: Account/User 

Management: U3”. Specific functions associated with this service include (a) managing user accounts on EPA’s web 

servers, and (b) maintaining user account data within EPA’s Time Sharing Services Management System (TSSMS). 

The costs associated with this service include overhead for EPA management, utilities, and space rental. OEI-OTOP’s 

unit cost data from: http://cfint.rtpnc.epa.gov/otop/currentfyservices/u3/u3.cfm.

o Source B: $0.298 million/year to $1.627 million/year, based on extrapolating EPA’s total CDX helpdesk budget for FY2007 of 

about $0.5 million/year servicing about 40,000 CDX users, to the projected 119,300 to 260,300 eManifest users at 75% 

implementation level and at 20% to 50% for reset quest calls, calculated as follows: [($0.5 million/year) x (119,300 to 

260,300 eManifest users) / (40,000 FY2007 CDX users) x (20% to 50% helpdesk calls are reset requests)]. OEI’s $0.5 

million/year FY2007 budget for CDX helpdesk services consists of a $3,000/year to $300,000/year range in CDX

helpdesk call center services support for 15 EPA CDX electronic reporting programs (source: Mark Eads phone 

conversation on 16 March 2007 with OEI Call Center contact person Jose Gonzalez , and 27 March 2007 meeting with 

Charles Freeman of OEI-OTOP. Information about OEI’s CDX call center services is available at: 

http://cfint.rtpnc.epa.gov/otop/resources/callcenter.cfm).

o Source C: $2.058 million/year to $4.490 million/year, calculated using the (a) $5.75 unit cost per user helpdesk call and (b) an 

average of three password reset helpdesk calls per year per user assumptions from M-Tech Identity Management 

Solutions at http://www.p-synch.com/savings/example.html: [(119,300 to 260,300 employee users) x (3 password reset 

helpdesk calls per year per user) x ($5.75 helpdesk cost per call)].
35

Appendix B

OSW Estimated Counts of Trucks, Industrial Facilities & Industrial Employees

Which May Become Users of OSW’s RCRA Hazardous Waste eManifest System

Prepared by:

Mark Eads, Economist (703-308-8615)

EPA Office of Solid Waste (OSW)

14 March 2007

Disclosure of EPA External Peer Review of this Appendix

OSW distributed prior drafts of this Appendix to two external entities:

1. On 15 Nov 2006, Mark Eads (OSW) shared via email the 15 Nov 2006 first draft of this Appendix with the Environmental 

Technology Council (http://www.etc.org), requesting an informal review by Scott Slesinger, ETC Vice President for 

Governmental Affairs, of the data and calculations in the first draft. ETC is an industry membership association of hazardous 

waste management companies, and has been a major stakeholder in OSW’s eManifest rulemaking project since OSW’s 2001

eManifest proposed rule (see Section 1.3 at: http://www.epa.gov/epaoswer/hazwaste/gener/manifest/present/proceed.pdf). 

ETC supplied OSW by phone call 17 Nov 2006 and by email 22 Nov 2006, comments about data assumptions from three of 

its member companies (Clean Harbors, Safety-Kleen, Veolia) concerning average count of manifesting employees per TSDF 

and count of eSignature devices needed per manifesting truck, which have been incorporated into the numerical uncertainty 

ranges in this document.

2. On 28 Feb 2007, for purpose of requesting a rough cost estimate for deploying a PKI electronic signature application for 

eManifest, Richard Lashier (OSW) shared via email the 2nd draft of this Appendix to Andrew Lehfeldt of Entrust Inc of 

McLean VA, so that this IT vendor could formulate a properly scaled cost estimate.

I. RCRA Manifesting Trucks

IA. Count of Trucks Potentially Involved in eManifesting

• 7,500 trucks (private + commercial) registered or licensed as of 1997 in the US, reportedly transport EPA-manifested 

hazardous wastes as "primary products carried" (PPC), which represents 1.9% of the 403,300 total 1997 US trucks which 

transport DOT-placarded hazardous materials. These 7,500 EPA-manifested hazardous waste trucks traveled a total 465.8 

million miles in 1997, which is an average of 62,200 miles per-year per-truck (source: US Census Bureau "1997 Vehicle 

Inventory & Use Survey", Table 2a, pages 11 and 23 at http://www.census.gov/prod/ec97/97tv-us.pdf. Note that the newer 
36

2002 VIUS report dropped the PPC data details (http://www.census.gov/prod/ec02/ec02tv-us.pdf), thus the 1997 VIUS report 

is the most recent data on RCRA-manifesting trucks.

• If project (extrapolate) the 1992-1997 growth trend of 20 additional trucks every year (i.e., 7,400 trucks in 1992 compared to 

7,500 in 1997) we can estimate 7,800 EPA-manifesting hazardous waste trucks for 2010 (i.e., (2010-1997) x 20/year) + 7,500 

= 7,800 (rounded to nearest 100).

• This estimated 2010 total of 7,760 hazardous waste manifesting trucks represents an average of 22 RCRA-manifesting trucks 

per transporter TSDF, if averaged over 358 establishments classified in the 2002 Census Bureau NAICS 562211 “hazardous 

waste transportation service” establishments under NAICS 38430 product line code “hazardous waste transportation services, 

excluding collection and disposal” (source: US Census Bureau "2002 Waste Management & Remediation Services: NAICS 

562", Table 3 page 3, at: http://www.census.gov/prod/ec02/ec0256i09.pdf).

IB. Additional Count of Potential eManifesting Trucks Involved with Other Wastes

• 2,200 trucks (1997) transport non-EPA manifest hazardous wastes as "primary product carried" (PPC); updated using the 

same 1997 to 2010 extrapolation factor of 1.035 (i.e., 7760/7500) from above yields 2,300 non-EPA hazardous waste trucks 

(2010).

• 6,200 trucks (1997) transport industrial wastewaters as PPC; updated using the same 1997 to 2010 extrapolation factor of 

1.035 from above yields 6,400 industrial wastewater trucks (2010).

• 49,300 trucks (1997) transport recyclable materials as PPC; updated using the same 1997 to 2010 extrapolation factor of 1.035

from above yields 51,000 recyclable materials trucks (2010).

• 166,800 trucks (1997) transport scrap, refuse, or garbage as PPC; updated using the same 1997 to 2010 extrapolation factor of 

1.035 from above yields 172,600 scrap/garbage trucks (2010).

• Source: US Census Bureau "1997 Vehicle Inventory & Use Survey", Table 2a, pages 11 and 23 at 

http://www.census.gov/prod/ec97/97tv-us.pdf. Note that the newer 2002 VIUS report dropped the PPC data details 

(http://www.census.gov/prod/ec02/ec02tv-us.pdf), thus the 1997 VIUS report is the most recent data on these four other 

classes of waste-related trucks.

IC. Total Count of Potential eManifesting Trucks

• Assume that the RCRA-regulated community will desire to process both Federal RCRA and state government regulated 

hazardous wastes using EPA’s eManifest system, results in an estimated 2007 total 10,100 manifesting trucks (i.e., 7,800 

RCRA manifesting trucks + 2,300 non-EPA manifesting trucks), assuming 100% of hazardous waste is eManifested.
37

II. RCRA Manifesting Facilities & Employees

IIA. Count of Potential Transporter and TSDF eManifesting Facilities & Employees:

• 488 NAICS 562112 hazardous waste collection & removal service establishments with 10,196 employees (2002), which is an 

average of 21 employees per TSDF establishment (source: US Census Bureau "2002 Waste Management & Remediation 

Services: NAICS 562", Table 1 page 1 and Table 3 page 3 at: http://www.census.gov/prod/ec02/ec0256i09.pdf)

• 696 non-duplicative count for NAICS 562211 hazardous waste treatment & establishments with 21,566 employees (2002), 

which is an average of 31 employees per establishment (source: US Census Bureau "2002 Waste Management & Remediation 

Services: NAICS 562", Table 1 page 1 and Table 3 page 3 at: http://www.census.gov/prod/ec02/ec0256i09.pdf). These 

establishments consist of the following primary product lines codes (PLCs) within NAICS code 562:

• NAICS PLC 38471: 225 hazardous waste transfer service establishments

• NAICS PLC 38430: 358 hazardous waste transport service establishments (not counting collection & disposal)

• NAICS PLC 38440 + PLC 38450: 324 hazardous waste disposal service establishments (253 by confinement + 71 

non-confinement methods, respectively)

• NAICS PLC 38480: 664 hazardous waste treatment service establishments

• NAICS PLC 38550: 20 hazardous waste-to-energy generation service establishments

• Estimated total count of TSDFs involved in hazardous waste manifesting:

• As of 2002, 1,184 total TSDFs (i.e., 488+696 from above) with 31,762 total employees (i.e., 10,196+21,566 from 

above). In comparison, 557 hazardous waste “receiver” TSDFs reported in the 2005 RCRA Biennial Report (Exhibit

3.5 at: http://www.epa.gov/epaoswer/hazwaste/data/br05/national05.pdf); this analysis uses the larger 1,184 TSDF for 

the purpose of including state hazardous waste receivers, as well as RCRA hazardous waste receivers.

• Estimated total count of TSDF employees involved in hazardous waste manifesting (based on upper- and lower-bound TSDF 

counts above, respectively):

• Assume average of 6 employees per-TSDF involved in hazardous waste manifesting as part of their job duties, 

provides an estimate of 7,104 TSDF employees (i.e., 6 x 1,184 total TSDFs), which represents 22% of all TSDF 

employees (i.e., 7,104/31,762). Average of 6 employees is the midpoint of the 4 to 8 range which ETC provided OSW 

(Mark Eads) in its peer review comments on OSW’s Nov 2006 initial draft of this estimated counts of facilities and 

employees potentially using eManifest.

17

• Turnover estimate: Assume 16% employee annual turn-over rate18, which when multiplied by the estimation range is 

1,137 new-hire TSDF employees per year (i.e., 16% x 7,104).

 

17 Coincidentally, EPA’s 13 Oct 2005 CROMERR final rule (p.59874) assumes an average of 6 employees per facility in large companies that would become 

registered CDX users for environmental reporting to EPA: http://www.epa.gov/fedrgstr/EPA-GENERAL/2005/October/Day-13/g19601.htm

18 16% manufacturing industry employee annual turn-over rate (i.e., total job separation rate) from US Dept of Labor Bureau of Labor Statistics “Job Openings 

and Labor Turnover Survey” (JOLTS) website: http://www.bls.gov/jlt/. 16% is based on numerical rounding the 15.9% manufacturing “total separation” rate for 
38

• Including 16% turnover, total TSDF employees count: 8,200 TSDF employees (i.e., 7,104 + 1,137)

IIB. Count of Potential eManifesting LQG Facilities & Employees

• 16,082 LQG shippers as of 2005 (source: Exhibit 3.1 at: http://www.epa.gov/epaoswer/hazwaste/data/br05/national05.pdf); 

based on the NAICS 325 chemical mfg industry group which is the largest RCRA hazardous waste LQG industry (i.e., 63% of 

2005 national generation tonnage

19), there are an average 63 employees per LQG, which provides an estimate of 1,013,166

LQG employees (source: 852,297 employees in 13,476 establishments for year 2002 NAICS 325: 

http://www.census.gov/econ/census02/data/us/US000_31.HTM).

• Estimate of LQG shipper employees involved in hazardous waste manifesting:

• Upper-bound estimate: Assume 4 of 63 employees per-LQG require eManifest access as part of their job duties 

which is 64,328 LQG employees (i.e., 4 x 16,082 LQGs).

• Lower-bound estimate: Assume 1 of 63 employees per-LQG require eManifest access as part of their job duties 

which is 16,082 LQG employees (i.e., 1 x 16,082 LQGs).

• Turnover estimate: Assume 16% employee annual turn-over rate, which applied to the estimation range is 2,573 to 

10,292 new-hire LQG employees per year (i.e., 16% x 16,082 to 16% x 64,328).

• Including 16% turnover, total LQG employees counts are:

• Upper-bound: 74,600 LQG employees (i.e., 64,328 + 10,292)

• Lower-bound: 18,700 LQG employees (i.e., 16,082 + 2,572)

IIC. Count of Potential eManifesting SQG Facilities & Employees

• The most recent count of SQGs is for 1999 based on an EPA contractor analysis of EPA's RCRIS hazardous waste generator 

registry data (now called RCRAInfo), which enumerated 113,879 operating SQGs; based on the NAICS 811 repair & 

maintenance services industry group, which is one of the largest SQG industries, there are an average 6 employees per SQG, 

which provides an estimate of 683,274 total SQG employees (source: 1,285,371 employees in 231,043 establishments for year 

2002 NAICS 811: http://www.census.gov/econ/census02/data/us/US000_81.HTM).

• Estimate of SQG employees involved in hazardous waste manifesting:

• Upper-bound estimate: Assume 2 of 6 employees per-SQG require eManifest access as part of their job duties 

which is 227,758 SQG employees (i.e., 2 x 113,879 SQGs).

• Lower-bound estimate: Assume only 1 of 6 employees per-SQG require eManifest access as part of their job 

duties which is 113,879 SQG employees (i.e., 1 x 113,879 SQGs).

 

Sept 2005 to Aug 2006 in “Table 3. Total separations levels(1) and rates(2) by industry and region, seasonally adjusted” at: 

http://www.bls.gov/news.release/jolts.t03.htm

19 NAICS 325 chemical manufacturing industry group reportedly generated about 23.9 million of the 37.9 million tons (i.e., 63%) national total RCRA hazardous 

waste generated in 2005; source: Exhibit 1.9 at: http://www.epa.gov/epaoswer/hazwaste/data/br05/national05.pdf
39

• Turnover estimate: Assume 16% employee annual turn-over rate, which applied to the estimation range is 18,221 to 

36,441 new-hire SQG employees per-year (i.e., 16% x 113,879 to 16% x 227,758).

• Including 16% turnover, total SQG employees counts are:

• Upper-bound: 264,000 SQG employees (i.e., 227,758 + 36,441)

• Lower-bound: 132,000 SQG employees (i.e., 113,879 + 18,221)

IID. Total Count of Potential eManifesting Industrial Facilities & Employees (Transporters/TSDFs + LQGs + SQGs):

• Total industrial facilities potentially involved in using eManifest: 131,000 facilities

• Total industrial employees pontentially involved in using eManifest (including 16% employee annual turnover):

• Upper-bound estimate: 347,000 employees

• Lower-bound estimate: 159,000 employees

III. E-Manifest User Phase-In Scenario

Because OSW’s eManifest system may be voluntary, not mandatory (i.e., industries may elect to continue using the current RCRA 

paper manifest form 8700-22), OSW expects less than 100% of future annual paper manifests will be eliminated by paperless 

electronic processing using eManifest, particularly during the first few years after which the eManifest IT system begins operation. 

For purpose of scenario illustration, the table below presents a 5-year phase-in scenario of the number of RCRA paper manifests, 

trucks, industrial facilities, and industrial employees which may become involved in using eManifest for both Federal- and stateregulated hazardous wastes (i.e., relative to the current baseline of 5.1 million Federal + state government hazardous waste paper 

manifests per year). The scenario uses the baseline counts developed in the prior sections of this Appendix.

“Scenarios are not predictions. They are stories of how the future might unfold — plausible stories that reflect 

information about trends and potential future developments. [Scenarios may be] designed to span a range of potential 

future conditions. The actual future is not likely to match any one of [alternative] depictions, but it will probably fall 

somewhere within the range of possibilities that the scenarios explore.” Source: 

http://www.epa.gov/cfo/futures/env_scen.htm.

The phase-in scenario truncates after five years at a 75% user phase-in as an expected upper-bound assumption. Although OSW’s 

economic analysis contractor in 2000 (ICF Inc) for the May 2001 eManifest proposed rule initially formulated a cautiously low 25% 

to 50% adoption rate range assumption (see page 14 at: http://www.epa.gov/epaoswer/hazwaste/gener/manifest/pdf/ebd.pdf), OSW’s 

2002 benefit-cost analysis contractor (LMI, Inc) formulated a 75% adoption assumption after questioning a small sample of LQGs and 

TSDFs about likely participation in eManifest.
40

The 5-year phase-in scenario further assumes a direct numerical correlation (i.e., association) between the phase-in percentages 

based on an annual manifest counts, and the counts of trucks, facilities, and employees likely to become users of eManifest. This 

simple direct correlation assumption probably results in an over-estimate of the number of facilities which may become eManifest 

users at each phase-in year for the associated percentage of manifests assumed processed by eManifest, because similar to the largesize facility skewness of many US industries, there are a relatively small number of LQG and TSD facilities which generate, ship, and 

receive the majority of RCRA hazardous waste tonnages and associated paper manifests annually. For example, based on OSW’s 

2005 RCRA hazardous waste “Biennial Report”, the top-10 of the 16,082 LQG waste shippers accounted for 18% of the total 7.7 

million tons of shipper quantity, and the top-10 of the 557 TSDF waste receivers accounted for 36% of the total 8.5 million tons of 

receiver quantity.

20

 

20 For each of OSW’s RCRA hazardous waste national “Biennial Report” data years (i.e., 1991, 1993, 1995, 1997; 1999, 2001, 2003, 2005; 

http://www.epa.gov/epaoswer/hazwaste/data/biennialreport/index.htm), the LQG and TSDF data show a large degree of skewness in the tonnages of annual 

RCRA hazardous wastes reported as generated, shipped, received, and managed by LQGs and TSDFs. For example, in 2005 the most recent national Biennial 

Report data year available, the top-5 and top-10 facility counts of LQG shippers and TSDF receivers are (source: EPA 2005 RCRA Hazardous Waste National 

Analysis Biennial Report, Exhibits 3.3, 3.4, 3.7, 3.8 at: http://www.epa.gov/epaoswer/hazwaste/data/br05/national05.pdf):

Large-Size Skewness of Hazardous Waste Shippers: Large-Size Skewness of Hazardous Waste Receivers:

Top-5 LQG shippers: 11% (0.869 million tons in 2005) Top-5 TSDF receivers: 26% (2.244 million tons in 2005)

Top-10 LQG shippers: 18% (1.367 million tons in 2005) Top-10 TSDF receivers: 36% (3.097 million tons in 2005)

16,082 total LQG shippers: 100% (7.686 million tons in 2005) 557 total TSDF receivers: 100% (8.546 million tons in 2005)
41

OSW Estimates of Number of RCRA Manifests, Trucks, Industrial Facilities & Industrial Employees

Which May Become eManifest Users

5-Year User Phase-In Scenario 2010-2014

A B C D E F G H I (F+G+H) J K L M (J+K+L)

Year

eManifest 

User

Phase-In 

Scenario*

Count of 

RCRA 

Electronic

Manifests

(millions)

Count of 

Truck 

Vehicles

Count of Industrial Facilities Count of Industrial Employees

LQG 

shippers

SQG 

shippers

TSDF 

receivers

Total Facilities

LQG+SQG+TSDF

LQG

employees

SQG

employees

TSDF

employees

Total Employees

LQG+SQG+TSDF

1 2010 10% 0.5 1,000 1,600 11,400 120 13,100 1,860 to 

7,460

13,210 to 

26,420 800 15,900 to34,700

2 2011 25% 1.3 2,500 4,000 28,500 300 32,800 4,660 to 

18,660

33,020 to 

66,050 2,000 39,700 to86,700

3 2012 40% 2.0 4,000 6,400 45,600 470 52,500 7,460 to 

29,850

52,840 to 

105,680 3,300 63,600 to138,80000

4 2013 65% 3.3 6,600 10,500 74,000 770 85,000 12,120 to 

48,500

85,860 to 

171,730 5,300 103,300 to225,500

5 2014 75% 3.8 7,600 12,100 85,400 890 98,400 13,990 to 

55,960

99,08 0 to 

198,150 6,200 119,300 to

260,300

Universe (if 100%) = 5.1** 10,100 16,000 114,000 1,200 131,000 18,700 to 

74,600

132,000 to 

264,000 8,200 159,000 to347,000

Explanatory Notes:

* Source of Phase-in Assumptions (Column C):

 Year 1: Represents eManifest system start-up testing mode based on a small number (e.g., 3 to 10) facilities participating in the testing.

 Year 2: Represents additional 15% participation expectation over 1st year 10%, based on approximate average between actual environmental electronic reporting results of 

10% for EPA’s eTRI program rate after its 1st year (2002), and 34% after about 2-years for State of Michigan’s Clean Water Act Discharge Monitoring Reports (DMRs); 

[i.e., (10% + 34%)/2 = 22% (say 25%)].

 Year 3: Represents approximate hazardous waste annual tonnage transportation US marketshare of the top-3 of the 10 to 15 commercial TSDF members of the 

Environmental Technology Council (http://www.etc.org); assumption is that the top-3 TSDFs will use eManifest by the 3rd year.

 Year 4: Represents approximate hazardous waste annual tonnage transportation US marketshare of the top-10 commercial TSDF members of the ETC.

 Year 5: In 2002 OSW’s eManifest benefit-cost analysis (BCA) contractor Logistics Management Institute (LMI) formulated this as a reasonable upper-bound expectation in 

the Oct 2002 BCA, based on LMI interviews with a small (less than 10) sample of LQGs and TSDFs.

** 5.1 million RCRA Federal + state government hazardous waste paper manifests per year baseline (Column D), based on a survey data report provided 06 Nov 2002 to OSW by 

the Environmental Technology Council http://www.etc.org (see document ID nr. EPA-HQ-RCRA-2001-0032-0095 at http://www.regulations.gov)..