1 

## Cost **Compari s**  **on 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 id**  **entity verific ation** 

**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**

**1 7**  **April 2007** 2 

## Table of Contents **I. Cost Comparison Summary Table**  **3 II.**  **Cost Estimation Methodology**  **4 II.A**  **EPA’s Definition**  **of “ Electronic Signature**  **” 4**  **I I.B Assumptions & Baseline**  **5 III**  **. Cost Calculations 15**  **Option 1 : PIN/P**  **assword (5 sub**  **- options)**  **15 Option**  **2: Handwritten Digitized Signature (3 sub**  **- options)**  **25 Option 3**  **: PKI Identity Verification 28**  **Appendice s**  **32 Appendix B**  **: Estimated Counts of**  **Manifests, Truc**  **ks , Industrial**  **Facilities & Industrial Employees Which**  **May Become eManifest Users**  **3 3**  **Appendix A : PIN/Password Reset Helpdesk Cost (for Sub**  **- Options 1A,**  **1B, 1C, 2B) 35** 3 

## 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: C**  **ost ranges reflect OSW**  **uncertainty in eManifest user**  **counts and**  **/or p**  **rice s representing alternative IT vendors**  **or IT technologie s**  eSignature Option s & Sub - Options **Initial Year Cost (IYC)**  **Annual Recurring Cost (ARC) 5**  **- Year**  **Av erage Annual Cost**  **( IYC**  **) /5**  **+ARC** ($millions/year) Software & IT Services ($millions) Hardware ($millions) Software & IT Services ($millions/year) Hardware ($mil lions/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 $0.6 75 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.**  **2 93**  **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 2 nd 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: $0 729 **Total: $**  **9.007 to $13.199** 1C - 2 : OTP 2 nd facto r identity verification after PIN/password (every time 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 $1**  **9.582** 1C - 3: IRS 2 nd 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**  2 A : Digitizer pad signatures w/out identity verification EPA: $ 0.002 Users: $ 0 Total: $ 0.00 2 EPA: $ 0 Users: $ 1.658 to $4.975 Total: $ 1.658 to $ 4.975 EPA: $ 0.001 Users: $ 0 Total: $ 0.00 1 EPA: $ 0 Users: $ 0.166 to $0.498 Total: $ 0.16 6 to $0.498 EPA: $ 0.001 User s: $ 0.498 to $1.493 **Total: $ 0.499**  **to $ 1.494**  2B : Digitizer pad signatures with PIN/ password (every time 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: $ 1.0 61 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 (every time 1 - factor verification) EPA: $ 0.002 U sers: $ 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 ar**  **ray ed w.r.t two data sources so total AAC represents min**  **- max cost** **)** (every time 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. 1 72 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 c ounts of manifest s, truc ks, facilities, and em ploy ee s potentially using eManifest.4 

## I **I .**  **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 com

panies . 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 eMani fest users , nor does their provision of this cost information disqualify them as potential candidate IT vendors for supplying eManifest hardware, software, or IT services. 

### I **I .A**  **EPA’s Definitio**  **n of “ Electronic Signature**  **”** Key defin ition s related to “ elec tr onic signature” as established 13 Oct 2005 by EPA’s CROMERR final ru le at 40 CFR 3.3 ( http://www.epa.gov/cdx/cromerrr) :  Electronic signature: M eans 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 be ars or has on it an electronic signature where it includes or has logically associated with it such information.  Electronic signature agreement: M eans an agreement signed by an individual with respect to an electronic signature device that the individual w ill 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: M eans a code or other mechanism that is used to create electronic s ignatures. Wh ere 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 compromis ed if the code or mechanism is available for use by any other person.5



### I **I .**  **B Assumptions & Baseline** 

 **Cost Estimation Accuracy:**  The expected accuracy

of the cost estimates in this document, a ccording to the relativel y low level - of - effort , the relatively

sm all amount of data, and lack of refined IT s ys tem 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 t ypicall y **- 30% to +5**  **0%** of the numerical values shown. This - expected accuracy range is meant to represent variation in “Budget Estimates” as prescribed b y 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.or g):

“Budget estimates are prepared with the help of flow sheets, layouts, and equipment details. In other words, eno ugh 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 ye ars, 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 . 1 This cost annualization method also assumes that IYC will not repeat sooner than 5 - ye ar lifecycle intervals (e.g., for hardware, software, and IT service upgrades), which may understate AAC if upgrades are needed sooner such as every 3 - ye ars (one Federal agency (NIH) advices use of a 3 - ye ar IT lifecycle cost period in its “ Cos t - Benefit Analy sis 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 - benefi t 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 ).6

 **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/c romerrr) are applicable to OSW planned eManifest IT s ys tem to be hosted on EPA’s CDX . However, because of the fact that EPA has not historically since the RCRA manifest sy stem began operation in 1984, nor currently , requires direct submission of complete d manifests to EPA or to RCRA - authorized state governments, another non - CROMERR scenario is for a CDX - based eManifest s ystem merel y to provide a cradle - to - grave electronic highway between waste shippers, waste transporters, and waste receivers according to the current paper manifest sy stem regulations . Un der such a business - to - business (B2B) alternative eManifest workflow scenario, EPA’s CROMERR requirement s might not attach to eManifest because it would not be a business - to government (B2G) workflow design . This alternative B2B eManifest workflow scenario is consistent with OSW’s current (baseline ) RCRA paper manifest s ystem 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), respectivel y).  Does not require direct reporting of completed paper manifests to RCRA - authorized state governments (but does require reporting of waste discrepancies b y 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 electronicall y 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 cus tomers. 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, 1 986). 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. EPA7 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//currentfy s ervices/df/df.cfm ), which is a user friendl y, internet accessible, electronic forms processing application that allows users to prepare online, submit, route and approve forms that look just l ike 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 an yone for eas y approval, rapid processing, and remote archiving with users, including take - back and re - route functions. And the forms can b e printed b y users if necessary . 2

 **eSignature Options**  **OSW Proposed in 2001**  **and 2006 :**  **A. May 2001 Electronic Manifest Proposed Rule:**  In OSW’s 22 May

2001 de - centralized e lectronic m anifest 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. “D igital signature” option meeting the (a) Secure Hash Algorithm (for creating message diges ts) 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 PKIdigital certificate standard, but would not require that digital signature s ys tems employ a tokenize d digital signature . 2. “Secure digitized signature” option which would allow electronic manifesting s ys tems to incorporate software, digitizer pads, and electronic pens that create a graphical representation of a signer's handwritten signature. The electron ic 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 ``s ignature object'' that contains: the graphical image of the signature for display and print operations, in industry - standard bitmap format (e.g., TIFF or BMP), s ignature capture information (e.g., a user ID) and the date and time of signin g, (d) d ocum ent binding data involving an encry pted 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.show fy rates&fy=2007 ), is $0.457 million/year to $0.997 million/year:[ ($ 3.83 pe r user per year for “Webforms DF” service ) x (119,300 to 260,300 eManifest users at 75% implementation rate)].8

OSW did n ot propose in the May 2001 proposed rule a biometric electronic signature method because OSW stated (p.28289) it believe d that these signature technologies are more practical and proven than other authentication technologies that rel y on biometric s (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 e lectronic signature methods , OSW ask ed 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 i n which individuals would enter a unique sequence of alpha - numeric characters which they

have ado pted as their electronic signature. OSW’s May 2001 proposed rule explained that OSW did not propose a PI N option because: “ [I

]n the context of developing electronic reporting standards for the Discharge Monitoring Report (a Clean W ater Act requirement), E

PA 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 N**  **ODA:** 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 an d 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/noda 06.pdf ).9

 **CROMERR Compliant eSignature**  **Options:** The three primary

options identified in this cost comparison are Nov 2006 updated versions (b y Richard LaShier, OSW) of the three options OSW described in the 22 May 2001 el ectronic 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 pa ge 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 PK I 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 sign ature 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 elec tronic 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 signato ry 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 i n 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 D riven 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 he r 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 de termination 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 a10

subscriber agreement or a certification from a local registration authority that such an agreement has been received and securely store d . ”

 **EPA Costs :**  This cost category

d esignate s the costs that OSW anticipates OSW’s eManifest I T 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, impl ementing, 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 3 rd part y IT vendor servic es:

“ 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 appli cation, 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/expertarticl es/2005/10/19/what - are hosted - applications ). 2. eManifest user account costs : For all options/s ub - 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 aver age annual cost for EPA (CDX) to establish and maintain CDX u ser registration account s 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 Man agement 3 EPA’s CDX user basic registration requirements are: (a) supply inf ormation 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 we bsite, and agree to the terms and conditi ons 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 1 3 Oct 2005 CROMERR final rule, p. 59862).11

Sy stem (T SSMS). Source: http://cfint.rtpnc.epa.gov/otop/currentfy services/u3/u3.cfm . Because this cost is assumed equal to all options/sub - options, it does not appear as a line - item unde r each in this cost comparison . Furthermore, CDX registration user accounts are ass umed 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 Congres sional appropriation funding scenario) . OSW’s user fee funding app roach 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: T he “ Hazardous Waste Electr onic Manifest Establishment Act“ i ntroduced 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/cgi b in/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% fractio nal helpdesk cost for PI

N/password reset under the four eSignature sub - options based on PI N/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 ty pes of eManifest user problems are equal under each eSignature option/sub - op tion, 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.

 **U ser Costs**  **:** Designate the costs that OSW anticipates industrial and waste management facilities involved in hazardous waste transportatio n will incur to use eManifest. User costs will not be funded by OSW with either eManifest user fees or Congressional b udget appropriation. Important “User Cost” assumptions applied in this cost comparison are: 1. Ty pes of user groups included in this cost comparisons: S ee **Appendix B**  for sourc e of counts for each user group.  LQGs (population = 16,000 L QG shippers) : Large qu antity 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): T his cost comparison only includes trucks, not rail or barges.12

 SQGs (population = 114,000 SQG shippers) : Small quantity generators are largel y excl uded from this analy sis because OS W assumes that TSDFs will provide eManifest access to SQGs under commercial TSD F service customer arrangements, which is consistent with OSW’s assumption in the 22 May 2001 electronic manifest proposed rule: “ Hazardous waste transporters and TSDFs frequen tly prepare manifests as a service to smaller generators. W hile 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 ma nifests 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 ma nifests 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/EPA WASTE/2001/May

/Day - 22/f11909.htm ).  State governments : With the exception of state government agencies which generate, transport, or receive hazardous w astes, 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 accordi ng 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, facili ty , and employee counts. 4. Office desktop PCs : This cost comparison assumes that all L QGs and TSDFs currentl y have at least one office destktop PC, with existing internet ISP connection, which can be used for initiating and for receiving eManifests at no ad ditional initial year or annual ye ar 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 employe e 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  Key punch their required PI

N (personal identification number) or personal password to represent an electronic signature. T his cost comparison assumes that SQGs do not have an office desktop PC with internet I SP connection; consequently , this anal ys is assumes that commercial hazardous waste trucks will provide eManifest capability for SQGs. The cost estimates assume that all facilities (i.e., LQ Gs, 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 employ ees 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 (Safet y - Kleen ) already has equipped some or all of its hazardous waste trucks with onboard mobile PDAs and/or tablet PCs. Howeve r, 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 currentl y have onboard mobile computer hardware or existing wireless I SP 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 Alternativel y, if the instantaneous identity verification assumption applied in this cost comparison for those four sub options is dropped and substituted with an “end - of - business - day” uploading of eSignature s saved each day on the truck PDAs (or truck tablet PCs ) wi thout requiring instantaneous identity verification at each signature event , the wireless ISP cost assigned for trucks in this cost compari son 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 PDA s 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 $32 0 for portable printers for PDAs , such requirement could add at least $3.374 million additional initial year user cost, which divided over a 5 - ye ar 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 Ranki ng” (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 4 th wi th 2,227 trucks involved in solid waste, liquid waste, and hazardous waste. This ranking does not provide a breakout of the 2,2 27 trucks by waste class. However, from peer review comment made on OSW’s Nov 2006 1 st 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 5 th 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 repre sents 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 b ased 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 emplo yee 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 1 0%) in annual cost for 10% annual replacement rate for lost/ stolen/ broken PDA portable printers provides a 5 - ye ar 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 implementin g 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 p urpose of this cost comparison, an y 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 .  TWI C IDs: The Transportation Worker Identification Credential (TWI C) program is a Transportation Securit y

Administration (TS) and US Coast Guard initiative. The TWI C 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 TWI Cs. Enrollment and issuance will take place over an 18 month period. To obtain a TWI C, an individual must provide biographic and biometric informatio n such as fingerprints, sit for a digital photograph and successfull y pass a security threat assessment conducted b y TSA. While TWI C may be implemented across other transportation modes in the future, the TWI C Final Rule, published in the Federal Register January 25, 2007, sets forth regulatory requirements to implement this pro gram in the maritime mode first (source: http://www.tsa.gov/what_we_do/lay ers/twic/index.shtm ). 

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

Federal Regis ter Notices (FRN) announci ng that electronic manifests (e Manifests) will be required to be submitted to CBP prior to a trucks arrival at specific land border crossin gs. The requirement to submit e Manifests at the initial ports will be implemented 90 day s from the date of publication of the mandatory e Manifest notice. An aggressive roll - out schedule is planned to make e - Manifests mandatory at all land border crossings b y the end of 2007. Car riers will be able to file an e Manifest through the AC E Secure Data Portal or b y a CBP tested solution provider. ( source: http://www.cbp. gov/xp/cgov/toolbox/about/modernization/ace ).15 

## III. C **ost Calculations Option 1:**  **PIN/password** OSW estimated costs for the three sub - options (1A, 1B, 1C) based largel y on the FY2007 price list for IT services provided by EPA’s OEI - OTOP at: http://cfint.rtpnc.epa.gov/otop/currentfy services . **Sub -**  **Option 1A: PIN/password plus**  **initially one -**  **time m**  **ail to OEI**  **(CDX) ,**  **employee “**  **signature holder**  **agreements 6**  **”**

**(SHAs) or facility -**  **wide LRA SHA cert ification**  **(1 -**  **factor identity**  **proofing)** This option assumes that PI N/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 in frastructure. Accordingl y, 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 - bus iness license basis, the PI N/password software business license cost estimate might also serve as a preliminary rough estimate of the incremental cost to eManifest infrastr ucture for purchasing PIN/password management license s for managing user PIN/passwo rds 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 agreement s ” (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 CD X (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. Furthe rmore, 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 eSign ature 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/su b - 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 d ocuments 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, whic h include safeguarding their selfgenerated password, before using web forms or uploading files to submit electronic documents or data to EPA. “These are the mi nimum 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 facilitie s) x ($20.09 per incoming LRA SHA certification )]. This estimate is based on OEI - OTOP’s FY2007 Working Capital Fund Rates for “ Correspondence Management Sy stem: 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 . O EI OTOP’s unit cost data from http://cfint.rtpnc.epa.gov/otop/currentfy services/ek/ek.cfm . High - end : If OE I 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 employ ee users) x ($20.09 per incoming SHAs )]. This estimate is based on OEI - OTOP’s FY2007 Working Capital Fund Rates for “ Correspondence Management S ystem: 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 intern et service provider (I SP) 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 i f OEIreceives ink signature agreements from all employees in mail without onsite LRA:  Labor burden t o employees: $0.962 million to $2.100 million paperwork burden for executing handwritten signatures b y all emplo ye es: [(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 : $3.07 9 million to $4.217 million i f OEIreceives 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 p aperwork burd en for executing handwritten signatures b y all emplo ye es : [(119,300 to 260,30 0 employee users) x ( 1 5 minutes per employee to read and sign agreement) x ( $32.27 /hour mean wage 7 )].

7 Mean industrial e mployee 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 w aste management17 Note: 15 minutes per employee assumption from E PA’s 13 Oct 2005 CROMERR final rule (FR p.59876).  Lab or 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 minute s 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; a ssume no incremental hardware costs to SQGs, L QGs, transporters, and TSDFs because waste

offeror and waste re ceiver facilit y emplo yees are assumed to view the eMani fest form electronic image and key punch their PIN/password electronic signatures into eManifest via existing office desktop PC key boards and existing truck PDAs /tablet PCs at time of waste pickup and delivery . EPA: $ 0 Users: $ 0  Annually

Recurring Costs o So ftware & 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 annu al new establishment start - up s . 8 o High - end : $0.837 m illion /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. 1 61 million/year to $0. 6 7 5 million/year , calculated as 16 % of initial year cost to

account for 1 6% emplo yee 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 wa ge rates were loaded with (a) 30% US national average private industry employer cost for employee benefits ( http://www.bls.gov/news.release/pdf/ece c.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 U S 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 onl y 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 b y Adobe Sy stems Inc. ( http://www.adobe.com/government) in which the Adobe designed electronic form is connected to a web service that validate s credit card number s, by creating a new data connection to an WSDL 9 to bind one or more such web service s provider s (source: http://www.adobeforums.com/cgi bin/webx/.3bb918ad). This identity proofing services cost is based on price data from World DLA, an IT services vendor which successfull y launched the world’s fir st “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: E PA: $0 Use rs: $ 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 employ ee users) x ($2 per remote DL# or CC# identity proofing service)] . o Software cost: $0; assumes al l facili ties currentl y provide single password log - on access to internet - enabled desktop PCs and truck PDAs via internet service provider (I SP) log - on protocol). o Hardware: EPA: $0 Users: $0  Annually

Recurring Costs o Software & IT Services: EPA: $0.298 milli on/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 develope d 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% emplo yee annual turnover rat e. o Hardware: EPA: $0 Users: $0 **Sub -**  **Option 1C: PIN/password plus**  **2 nd**  **factor identity verification** T o differentiate in this cost comparison, the cost of a single PIN/password solution (Option 1A) compared to a 2 nd factor identity verification in addition to a PIN/password, as well as to reflect multiple possible I T solutions for 2 nd factor identit y verification , the cost estimate for this sub - opt ion is based on three sub - options : 1C - 1: TPV : T hird part y verification online service 1C - 2: OTP : O ne - time passw ord 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 b y trucks for realtime and every time identit y verific ation in the field for each manifest signature event (as well as for sub - options 2B, 2C and 3) ; in contrast, a wireless I SP cost is no t assigned to sub options 1A or 1B (or 2A) in this co st comparison because those two PI N/password sub - options represent one - time identity verification methods for ini tial user registration with the eManifest sy stem, not for each eManifest signature event (and sub - option 2A does not require identit y verification) .

 **Sub -**  **O ption 1C**  **- 1**  : TP V: Online third - part y identity verification (TP V) service exampled based on the ID olog y Inc’s “ExpectID IQ” service, in which a “https post” XML connection to the TP V is embedded within the eManifest homepage architecture. eManifest user s would log - on to eManifest with user name , PIN/password, and then the TP V service returns to the eManif est homepage screen, a series of multiple choice questions to which the user would t ype - in answers. The questions would be derived b y the TPV from instantaneous queries of public records databases (now available in all US states and territori es). The use r responses would determine i f the user is actually who he/she claim s 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 arran geme nt, OSW’s eManifest sy stem 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 Costs20 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, O SW. by Doug Finlay son, Customer Service Manager, ID ol ogy , Inc., 770 - 984 - 4697 . The initial integration of this TP V service into the eManifest architecture is a 1 - d ay task according to IDology I nc. 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 2 nd factor verifications needed per eManifest) x ($0.97 for T P V service cost per transaction ) x (0.70 for 30% large volume pri cing discount)]; price source: 12 April 2007 phone verbal price quote (non - discounted volume) provided to Mark Eads, OSW by Doug Finlay son, Customer Service Manager and Jim Mitchell , VP Marketing, IDology , Inc. , 770 - 984 - 4697 and 770 - 984 - 4699 . Otherwise, there are no monthl y 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 I SP 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/I SP account)] to provide the necessary wireless connectivity

of truck PDAs to connect realtime for eSignatur e identit y 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/archi ve/l0805/09l05/09l05.asp&gu id=). o Hardware: EPA: $ 0 Users: $021

 **Sub -**  **O ption 1C**  **- 2**  : OTP: O ne - time password (OTP) token technology which generates and display s a pseudo - random number consisting of six or more alphanumeric characters; when the pseudo - random numbe r is combined with a PI N 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 currentl y provide existing single password log - on access to internet enabled desktop PCs and truck PDAs via internet service provider (I SP) log - on protocol . o Hardware: EPA: $0 Users: 2 nd factor to kens: $ 0.596 million to $ 22.559 million: [($5 per Entrust mini token) to ($52 per

RSASecurID token x (5 years cost period)/( 3 ye ar 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 t o $8.330 million/year : [ (119,300 to 260,300 employee users) x ($4 to $32 per user per ye ar)] . Although one source reports that the incremental annual cost to users of adding this 2 nd 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 Id enti tyGuard OTP token service introduced in 2007 is priced at an average annualized cost of $4 per user per ye ar (source: http://www.entrust.com/strong authentication/ide ntityguard/calculator.cfm ). The Entrust website also provides an upper - bound cost example based on the RSA SecurID token 3 - ye ar 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 exa mple 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 pur chase 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 o n $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 I SP for trucks: $0.729 million/year for wireless ISP (internet service provider) service calculated as follow: [($39.99/mo nth 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 electronicall y s igned (source: $39.99 monthly wireless IS P 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 m illion/year to $0.833 million/year for token replacement: 10% of initial hardware cost for

annual replacement of lost and broken hardware token s (source: 10% replacement rate assumption is from VeriSign ’s 2005 white paper “Two - Factor Authentication: A Tota l Cost of Ownership Viewpoint”, p.7: http://www.verisign.com/Resources/Unified_Authentication_White_Papers/index.html ).

 **Sub -**  **O ption 1C**  **- 3**  : IRS. The IRS efile “self

- select P IN ” method involves internet IT services provide d to taxpayers b y 3 rd party I T vendor “partners” to the IRS, to provide both (a) tax form preparation software, and (b) e - fil ing services involving the taxpay er creating a self - select PI N via th e 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 an y five digits the taxpayer choose s (e xcept all zeros) to use as his/her electronic signature. Taxpayers create their own PI N (but do not register the PIN with IRS before filing or need to contact IRS to get it) us ing one of the commerciall y available tax software packages that support the Self - Select PI N . IRS’s self

- select PIN method requires use of the PI N plus original Adjusted Gross Income (AGI) or PIN (if e - filed and signed electronicall y) from the prior year tax return and Date of Birth (DOB) for verific ation purposes by the IT vendor . The same PIN may be used in future years, or it may be changed by the taxpayer in an y ye ar. This method is for taxpayers who file electronicall y 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 - fil e provider . This alternative method does not required the taxpayer to provide his/her original Adjusted Gross Income (AGI) or PI N (if e - filed and s igned electronically) from prior y ear return or DOB. The IRS itself does not provide and maintain taxpayer PI N 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 server s with SSLencry ption . As of March 2007, IR S had entered into p artnership agreements with 26 IT vendor companies to provide self - select PIN e filing 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 i dentity 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 Anal ys is” (provided 10 April 2007 to OSW by Kevin Hatton, IRS ETA Technology Programs Branch, 2 02 - 283 - 7877) , and the IRS “efile Partners for Taxpay ers” 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 I T vendor fees for PIN e filing 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 PI N approach , based on price data supplied 12 April 2007 to Mark Eads, OSW, by Doug Finlay son, Customer Service Manageer of IDology In c., for their “ExpectID” identity verification service ( http://www.idology.com/identity .html ) which requires users to supply

their SSN4 or year - of

- birth ( Y OB) as a 2 nd factor PIN - ty pe 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 sub option 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 I T contractor helpdesk support labor hours for rejected PIN/passwords) + ( 10 to 40 EPA I T contractor maintenance hours/ ye ar)) 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 2 nd 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 2 nd 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

I Dology 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 2 nd factor verifications needed p er eManifest) x ($3.95 PI N creation and efiling fee charged b y IR S - 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 inc remental cost of the PIN - based e - filing service, excluding the additional cost of the tax form preparation software . o Wireless I SP 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 conn ect realtime for eSignature identity verification each time an eManifest is electronicall y signed (source: $39.99 monthly wireless IS P 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: $025



### Option 2: **Handwritten Digitized**  **Signature** OSW’s cost calculations for this option are largely based on price quotes supplied 01 March 2007 b y Interl ink Electronics Inc . to Rich LaS hier Interlink Electron ics is an e Signature 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 quant ity discounted price quotes for both hardware and software user costs. Price quotes include one - year product warrant y. An important assumption for this option is that the costs of purchasing and maintaining business o ffice desktop PCs (for L QGs & 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 fo r purchasing and maintaining digitized signature hardware and software peripherals 11

. The cost estimates for this option assume purchase of alternative ty pes of digitizer signature pads for LQG & TSDF office desktop PCs as well as for trucks. Although OSW anticipates that hazardous waste transporters will purchase heav y - dut y mobile “tablet PCs” for trucks 12 , the entire cost of a tablet PC is not completely allocatable to the eSignature feature ; consequentl y, the digitizer pad costs applied in this cost comp arison are OSW’s approximation of the allocatable portion of a tablet PC cost. **Sub -**  **Option 2A: eSignature Pads w**  **ithout i**  **dentity 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 emp loyee per truck in some cases 13 ) x ($75 per standard USB signature pad to $225 for L CD visual display signature pad)] . 11 Peripherals: A p eripheral is a piece of computer hardware that is adde d 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 prin ciple. The term also tends to be app lied to devices that are hooked up externally, typically through some form of computer bus like USB. Ty pical examples include joysticks, printers and scanners. Devices such as monitors and disk drives are not considered peripherals when they are not truly optional (so ur ce: 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 hardw are 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 stol en/ lost/ broken digitized signature pads . **Sub -**  **Option 2B: eSignature pads**  **w ith PIN/pas**  **sword 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 job s 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 em ploy ee .27

**Sub -**  **Option 2C: eSignature p**  **ad s**  **with t**  **humbprint b**  **iometric identity verification**   Initial Year Costs o Software & IT Services: E PA: 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 emp loyee 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 T SDFs + (7,600 trucks x 120% to account for truck backup

devices and for more than one emp loyee 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 L QGs + 890 TSDFs + ((7,600 trucks) x (120% to account for truck backup devices and for more than one emplo ye e per truck in some cases) ) x ( $15 extra cost for “pro” software license annual maintenance needed for each biometric sign ature pad) ] . o Wireless I SP 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 n ecessary wireless connectivity

of truck PDAs to connect realtime for eSignature identity verification each time an eManifest is electronicall y signed (source: $39.99 monthly wireless IS P fee price example from Palm.Net's Executive Unlimited monthly

usage p lan 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 1 0% replacement rate of initial ye ar cost for replacement of

st olen/ lost/ broken biometric signature pads .28



### Option 3: **PKI Identity Verification** Short for “public key

infrastructure ”, PKI identity verification is a sy stem based on digital certificates, Certificate Authorities (CAs) , and other registration authorities that verify and authenticate the validity of each part y involved in an Internet transaction. PKI s are currentl y evolving and as of 2006 there is no single PKI nor even a single agreed - upon standard for setting up a PKI. A PKI i s also called a “trust hierarch y” (source: http://www.webopedia.com/TERM/P/PKI.html ). CAs are trusted third - party organization s or companies that issue digital certificates used to create digital signatures and electronic public - private key p airs. 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 cre dit card compan y, 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 reall y who they claim to be (source: http://www.webopedia.com/TERM/c/certification_authority .html ). A d igital 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 u ser sending a message is who he or she claims to be, and to provide the receiver with the means to encode a repl y. An individual wishing to send an encrypted message applies for a digital certificat e from a CA. The CA issues an encry pted digital certific ate 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 encry pted message u ses 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 encry pted r eply . The most widely

used standard for digital certificates is X.509 14 (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 PKIdigital signature options s uch 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 ap proaches. 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 inf ormation 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 ta

x filings or ``e -

filings', and is being adopted by other agencies. EPA expects that these non -PKI - 14 The X.509 digital certificate (Ve rsion 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 us age. (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 secu rity or assuring very robust non - repudiation of signature make this the most appropriate approach . ” (Source: http://www.epa.gov/fedrgstr/EPA - GENERAL/2005/October/Day 13 /g19601.htm ) OSW formulated cost estimates for this eSignature option based on two alternative sources , both of which are assumed to represent 2 - ye ar PKI licensing and digital certificate solution s : Source A: Entrust Inc.: “Rough order of magnitude” (RO M) cost estimates provided 14 March 2007 to OSW by the Entrust In c., a digital identities and information security company which released the first commercial ly available PKIin 1994 (http://www.entrust.com/pki). The Entrust data are based on scaling of a ctual case examples of implementation of this eSignature technology at other government agencies , heavil y discounted in price relative to the potential large size of eManifest users . The sever price discounting apparentl y makes this cost source the low - en d 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 quantit y, to $18.50/user for 250,000 user quantity per 2 - ye ar license period). The Entr ust PKI approach to eSignature workflow routing and processing between eManifest u sers and the CDX eManifest is based on internet Java applets 15 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 pe r user “cert” per 2 - ye ar license period for CDX PKI services. Note : The IYC and ARC cost range s 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 - end s ” and “high - end s ”. Further

more, for Source A OSW used the “he av y - discounted” cost estimate for the summary range of each cost sub - item.

 Initial Year Costs o Software & IT Services: EPA: PKIinfrastructure: $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 wit h the human user. (Source: http://en.wikipedia.org/wiki/Applet).30 o Source A : R epresents installing the Entrust PKI infrastructure as a component of the CDX - based eManifest s ys tem; 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 hy pothetical utilization of the existing CDX PKIservice infrastructur e. Users: PKIservice 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 heav y - discounted price: [ ($18.50 per seat 16 ) x ( 119,300 to 260,300 user employ ees) = $2.207 million to $4.8 16 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 260,3 00 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 pric e quote [($70 to $100 per PKI “cert” ) x (119,300 to 260,300 user employees)]. o Hardware: EPA: $0 U sers: $0.260 million to $0 million

o Source A: PKI grid cards : $0.303 million to $ 0.260 millio n 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 req uired.  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 s ubsequent annual license s for new employees, calculated as 16% of initial year cost to acco unt for 16% employee annual turnover rate , plus

16 Seat: A technical word use d 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 w here 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 th e first five log off, the next person can log on (s ource: http://www.techweb.com/encyclopedia/defineterm.jhtml?term=perseatlicense).31 annual 3 0% of init ial year cost for average annual license renewal for PKI certificate licenses assumed valid for 2 - ye ars (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 I SP 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 electronicall y signed (source: $39.99 monthly wireless IS P fee price example from Pal m.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: $0.07 9 million/year to $0.172 million/year for replacement of plas tic grid cards, calculated as 2 6% of the initial year cost to reflect 16% annual employee turnover rate plus 1 0% annual lost grid card and broken grid card average annual replacement rate. o Source B: $0 assumes grid cards not required.32 

## Appendices33 

## Appendix A **OSW Estimate of Average Annual**  **Cost for EPA CDX Helpdesk Services for eManifest Users $0.298 million/year to $4.490 million/year**  for eManifest user helpdesk PIN/password rese t services, assigned in this cost comparison as EPA costs to the four PIN/password sub - options 1A, 1B, 1C, and 2B . This cost range is based on two alternative helpdesk approaches and four alternative cost estimate calculations and cost data sources : Furth ermore, this cost range represents 20% to 50%, respectively , of the **$ 1.49**  **0 million/year to $**  **8.98 0**  **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 prob lems concerning the eManifest s ys tem , calculated as follows: [($0.298 million/year)/(20%) to ($4.490 million/year)/(50%)]. For the other three sub - options not based on PI N/passwords (i.e., sub - options 2A, 2C, and 3), the helpdesk cost is estimated at **$1.19 2 million/year to $4.490 million/year**  , which is the difference between the full helpdesk cost for the four PIN/password sub options, and the 20% to 50% fraction of that cost for PI N/password reset: [($1.490 million/year - $0.298 million/year) to ($8.980 mi llion/year - $4.490 million/year)]. Inother 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 fractio n (80% to 50%, respectivel y) 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 R**  **eset** $1.188 million/year to $2.593 millio n/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 - Sy nch” password management service costing $9.96 per user per year provided b y M - Te ch Id entity Management Solutions Inc. ( http://www.p - sy nch.com/savings/example.html ), calculated as follows: [(119,300 to 260,300 employee eManifest users) x ($9.96 per user per year)] ) . The P - Sy nch a utomated password reset service allows locked out users to reset their own passwords, effectively addressing the problem of forgotten passwords. P - Sy nch creates a secure and efficient process for users to reset their passwords, thus minimizing help desk c all volume s for resetting passwords. Once authenticated, users can reset their own pas swords without calling the help desk. 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 promp t of the user's own workstation, or (c) a telephone fro m which the user dials the IVR (interactive voice response) s ys tem that pr ovides password reset .34



###  **Approach #2: EPA Contractor**  **- Staffed CDX Helpdesk R**  **eset** $0.298 million/year to $4.490 million/ye ar for the 20% to 50% fraction , respectivel y, 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 $2.46 4 million/year, calculated as follows: [(119,300 to 260,300 employ ee users) x ($18.93/y ear

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 S ys tem (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.rt pnc.epa.gov/otop/currentfy services/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 20 07 with OEICall 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 as sumptions from M - Tech Identity Management Solutions at http://www.p - sy nch.com/savings/example.html: [ (119,300 to 260,300 employ ee users) x (3 password reset helpdesk calls per ye ar per user) x ($5.75 helpdesk cost per call) ] .35 

## Appendix **B OSW**  **Estimated Co unts of Truck** **s, Industrial Facilities & Industrial Employees Which May Become Users of OSW’s RC**  **RA Hazardous Waste eManifest System**  Prepared b y: 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 draft s of this A ppendix 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 wa ste management com

panies, 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/epao swer/hazwaste/gener/manifest/present/proceed.pdf ) . ETC suppli ed 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 m anifesting 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 2 nd draft of this A ppendix to Andrew Lehfeldt of Entrust Inc of McLean VA, so that this IT vendor could formulate a properly scaled cost estimate. 

### I. **RCRA Man ifesting Truck** **s IA. Count**  **of T**  **rucks Potentially Involved in e**  **Manifesting** • 7,500 trucks (private + commercial) registered or licensed as of 1997 in the US, reportedl y transport EPA - manifested hazardous wastes as "primary products carried" (PPC) , which rep resents 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 - ye ar 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 . N ote that the newer36

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 - manifest ing trucks . • If p roject (extrapolate) the 1992 - 1997 growth trend of 2 0 additional trucks every year (i.e., 7,400 trucks in 1992 compared to 7,500 in 1997) we can estimate 7,80 0 EPA - manifestin g hazardous waste trucks for 2010 (i.e., (2010 - 1997) x 2 0/year) + 7,500 = 7,80 0 (rounded to nearest 100) . • This estimated 2010 total of 7,76 0 hazardous waste manifesting trucks represents an ave rage 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” (s ource: 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**  **T rucks**  **Involved with Other Wastes** • 2,200 trucks (1997) transport non - EPA manifest hazardous wastes as "primary product carried" (PPC ) ; upd ated using the same 1997 to 2010 extrapolation factor of 1.035 (i.e., 7760/7500) from above yi elds 2,300 non - EPA hazardous waste trucks (2010 ). • 6,200 trucks (1997) transport industrial wastewaters as PPC ; upd ated using the same 1997 to 2010 extrapolat ion factor of 1.035 from above yi elds 6,400 in dustrial wastewater trucks (2010 ). • 49,300 trucks (1997) transpo rt recyclable materials as PPC ; upd ated using the same 1997 to 2010 extrapolation factor of 1.035 from above yi elds 51,000 r ecyclable materials tru cks (2010 ). • 166,800 trucks (1997) transport sc rap, refuse, or garbage as PPC ; updated using the s ame 1997 to 2010 extrapolation factor of 1.035 from above yi elds 172,6 00 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 . N ote that the newer 2002 VIUS report dropped th e 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 governme nt regulated hazardous wastes using EPA’s eManifest s ys tem, results in an estimated 2007 total **10,10 0**  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 Ma nifesting Facilities & Employees**  **IIA. Count**  **of Potential**  **Transporter and TSDF e**  **Manifesting Facilities &**  **Employees:** • 488 NAI CS 562112 hazardous waste collection & removal service establishments with 10,196 employ ees (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.p df ) • 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 56 2", Table 1 page 1 and Table 3 page 3 at: http://www.census.gov/prod/ec02/ec0256i09.pdf ). T hese establishments consist of the following primary product lines codes (PL Cs) within NAI CS code 56 2 : • NAI CS PL C 38471 : 225 hazardous waste transfer service establishments • NAI CS PL C 38430 : 358 hazardous waste transport service establishments (not counting collection & disposal) • NAI CS PL C 38440 + PLC 38450: 324 hazardous waste disposal service establishme nts (253 by confinement + 71 non - confinement methods , respectivel y) • NAI CS PL C 38480: 664 hazardous waste treatment service establishments • NAI CS PL C 38550: 20 hazardous waste - to - energy generation service establishments • E stimated total count of TSDFs involve d in hazardous waste manifesting: • As of 2002, **1,184 total TSDF**  s ( i.e., 488+696 from above ) with 31,762 total employ ees (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 analy sis uses the larger 1,184 TSDF for the purpose of including state hazardous waste receivers, a s well as RCRA hazardous waste receivers. • Estimated total count of TSDF emplo yees involved in hazardous waste manifesting (based on upper - and lower - bound TSDF counts above, respectively) : • A ssume average of 6 employees per - TSDF involved in hazardous waste manifesting as part of their job duties , provides an estimate of 7,104 TSDF emplo yees (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 prov ided OSW (Mark Eads) in its peer review comments on OSW’s Nov 2006 initial draft of this estimate d counts of facilities and employees potentially

using eManifest . 17 • Turnover estimate: A ssume 16 % emplo yee annual turn - over rate 18 , which when multiplied by the estimation range is 1,137 new - hire TSDF employee s pe r ye ar (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 comp anies 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 De pt of Labor Bureau of Labor Statistics “ Job Openings and Labor Turnover Survey ” (JOLTS) w ebsite: http://www.bls.gov/jlt/ . 16% is based on numerical rounding the 15.9% manufacturing “total separation” rate for38 • In cluding 16% turnover, total TSDF employees count : **8,200 TSD**  **F employees** (i.e., 7,104 + 1,137 ) **IIB. Count of**  **Potential eManifesting LQG**  **Facilities & Employees**  • **16,082 LQG ship pers**  as of 2005 (source: Exhibit 3.1 at: http://www.epa.gov/epaoswer/hazwaste/data/br05/national05.pdf ); based on the NAI CS 325 chemical mfg industry group which is the largest RCRA hazardous waste LQG industry (i.e., 63 % of 2005 national generation tonnag e 19 ) , there are an average 63 employees per L QG, which provides an estimate of 1,013,166 LQG emplo yees (source: 852,297 employees in 13,476 establishments for year 2002 NAICS 325: htt p://www.census.gov/econ/census02/data/us/US000_31.HTM ). • Estimate of LQG shipper employ ees involved in hazardous waste manifesting: • Upper - bound estimate: A ssume 4 of 63 employees per - LQG require eManifest access as part of their job duties which is 64,328 LQ G employees (i.e., 4 x 16,082 LQGs ). • L ower - bound estimate: A ssume 1 of 63 employees per - LQG require eManifest ac cess as part of their job duties which is 16,082 LQ G employees (i.e., 1 x 16,082 LQGs ). • Turnover estimate: A ssume 16 % emplo yee annual turn - ove r rate, which app l ied to the estimation range i s 2,573 to 10,292 new - hire LQG employee s per year (i.e ., 16% x 16,082 to 16 % x 64,328 ) . • In cluding 16% turnover, total L QG employees counts are: • Upper - bound: **74,60 0**  **LQG employees** (i.e., 64,328 + 10,292) • Lower - b ound: **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 analy sis of EPA's RCRI S hazardous waste generator registry data (now ca lled RCRAInfo) , which enumerated **113,879 operating SQGs** ; based on the NAI CS 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 employ ees in 231,043 establishments for year 2002 NAI CS 811: http://www.census.gov/econ/census02/data/us/US000_81.HTM ). • Estimate of SQG employees involved in hazardous waste manifesting: • Upper - bound estimate: A ss ume 2 of 6 employees per - SQG require eManifest ac cess as part of their job duties which is 227,758 SQG employees (i.e., 2 x 113,879 SQGs ). • Lower - bound estimate: A ssume only 1 of 6 employee s pe r - SQG require eManifest ac cess as part of their job duties which is 113,879 SQG employ ees (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/ne ws.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 wa ste generated in 2005; source: Exhibit 1.9 at: http://www.epa.gov/epaoswer/hazwaste/data/br05/national05.pdf39 • Turnover estimate: A ssume 16 % emplo yee annual turn - over rate, which applied to the estimation range i s 18,221 to 36,441 new - hire SQG employe e s per - ye ar (i.e. , 16% x 113,879 to 16 % x 227,758 ) . • In cluding 16% turnover, total SQG employ ees counts are: • Upper - bound: **264,000 SQG employees**  (i.e., 227,758 + 36,441) • Lower - bound: **132,0 00**  **SQG employees** (i.e., 113,879 + 18,221) **IID. Total Count of**  **Potent ial**  **eManifesting Industrial**  **Facilities & Employees**  **( Transporters/**  **TSDFs +**  **LQGs +**  **SQGs)** : • Total i ndustrial f

acilit ies potentially

i nvolved in using e Manifest : **131,000 facilities**  • Total i ndustrial e mployees pontentially involved in using e Manifest (including 1 6% employee annual turnover) : • Upper - bound estimate: **347,000 employees**  • Lower - bound estimate: **159,000 employees**  

### III. **E -**  **Manifest User Phase -**  **In Scenario** Because O SW’s eManifest sy stem 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 , particularl y during the first few ye ars after which the eManif est IT sy stem begins operation. For purpose of scenario illustration, the table below presents a 5 - year phase - in scenario of the number of RCRA paper m anifests, trucks, industrial facilities , and industrial employees which may become inv olved in using eManifest for both Federal - and state regulated hazardous wastes (i.e., relative to the current baseline of 5.1 million Federal + state government hazardous waste paper manifests per ye ar) . The scenario uses the baseline counts developed in the prior section s 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. T he pha se - in scenario truncates after five years at a 75% user phase - in as an expected upper - bound assumpt ion . Although OSW’s economic analy sis 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 anal ys is contractor (LMI , Inc ) formulated a 75% adoption assumption af ter questioning a small sample of LQGs and TSDF s about likely

participation in eManifest.40

The 5 - ye ar phase - in scenari o further assumes a direct numerical correlation ( i.e., association) between the phase - in percentages based on an annual manifest counts , and the counts of tr ucks, facilities, and employees likely to become users of eManif est . 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 p rocesse d by eManifest, because similar to the large size facility

skewness of many

US industries, there are a relatively small number of LQG and TSD facilities which generate, ship, and receive the majorit y of RCRA hazardous waste tonnages and associated p aper 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 receiv ers accounted for 36% of the total 8.5 million tons of receiver quantit y . 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 sk ewness 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 Ske wness of Hazardous Waste Shippers : Large - Size Ske wness 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 mill ion 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 **Tot al Facilities** 

LQG+SQG+TSDF LQG

em ploy ees SQG

em ploy ees TSDF

em ploy ees **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 to 34,700 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 to 86,700 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 to 138,80000 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 to 225,500 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 to 347,000 **Explanatory Notes:** * Source of P h ase - in A ssum ptions (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 1 st year 10%, based on approximate average between actual environmenta l electronic reporting results of 1 0% for EPA’s eTRI program rate after its 1 st 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 3 rd 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 200 2 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 i nterviews 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 )..