Cost Comparison of

Electronic Signature Options for

EPA’s RCRA Hazardous Waste Electronic Manifest IT System

(eManifest)

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

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

Option 3:	PKI identity verification

Prepared by:

Mark Eads, Economist

Economics, Methods & Risk Analysis Division

Office of Solid Waste

US Environmental Protection Agency

1200 Pennsylvania Avenue NW, Mailstop 5307P

Washington, DC 20460

703-308-8615;   HYPERLINK<EMAIL_ADDRESS><EMAIL_ADDRESS>
17 April 2007

Table of Contents

I.  Cost Comparison Summary Table						3

II.  Cost Estimation Methodology							4

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

II.B  Assumptions & Baseline							5

III. Cost Calculations									15

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

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

Option 3: PKI Identity Verification						28

Appendices											32

Appendix B: Estimated Counts of Manifests, Trucks, Industrial Facilities
& Industrial Employees Which May Become

eManifest Users									33

Appendix A: PIN/Password Reset Helpdesk Cost (for Sub-Options 1A, 1B,
1C, 2B)										35

I.  Cost Comparison Summary Table

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

75% Participation Rate Scenario*

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

eSignature

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

(IYC)/5+ARC

($millions/year)

	Software & IT Services

($millions)	Hardware

($millions)	Software & IT Services

($millions/year)	Hardware

($millions/year)

	Option 1: PIN/password

1A: Mail initial ink signature agreement to OEI (one-time 1-factor
proofing)	EPA: $1.976 to $5.229

Users: $1.009 to $4.217

Total: $2.985 to $9.446	EPA: $0

Users: $0

Total: $0	EPA: $0.535 to $5.327

Users: $0.161 to $0.675

Total: $0.696 to $6.002	EPA: $0

Users: $0

Total: $0	EPA: $0.930 to 6.373

Users: $0.363 to $1.518

Total: $1.293 to $7.891

1B: Initial DL#  or CC# check

(one-time 2-factor proofing)	EPA: $0

Users: $0.239 to $0.521

Total: $0.239 to $0.521	EPA: $0

Users: $0

Total: $0	EPA: $0.298 to $4.490

Users: $0.038 to $0.083

Total: $0.336 to $4.573	EPA: $0

Users: $0

Total: $0	EPA: $0.298 to $4.490

Users: $0.086 to $0.187

Total: $0.384 to $4.677

1C-1: TPV 2nd factor identity verification after PIN/password (everytime
2-factor verification)	EPA: $0.001

Users: $0

Total: $0.001	EPA: $0

Users: $0

Total: $0	EPA: $8.278 to $12.470

Users: $0.729

Total: $9.007 to $13.199	EPA: $0

Users: $0

Total: $0	EPA: $8.278 to $12.470

Users: $0729

Total: $9.007 to $13.199

1C-2: OTP 2nd factor identity verification after PIN/password

(everytime 2-factor verification)	EPA: $0

Users: $3.443

Total: $3.443	EPA: $0

Users: $0.596 to $22.559

Total: $0.596 to $22.559	EPA: $0.298 to $4.490

Users: $1.208 to $9.059

Total: $1.506 to $13.549	EPA: $0

Users: $0.045 to $0.833

Total: $0.045 to $0.833	EPA: $0.298 to $4.490

Users: $2.061 to $15.092

Total: $2.359 to $19.582

1C-3: IRS 2nd factor identity verification after PIN/password (everytime
2-factor verification)	EPA: $0.001 to $0.047

Users: $0

Total: $0.001 to $0.047	EPA: $0

Users: $0

Total: $0	EPA: $0.298 to $4.798

Users: $3.682 to $45.759

Total: $3.980 to $50.557	EPA: $0

Users: $0

Total: $0	EPA: $0.298 to $4.807

Users: $3.682 to $45.759

Total: $3.980 to $50.566

Option 2: Handwritten digitized signature

2A: Digitizer pad signatures w/out identity verification	EPA: $0.002

Users: $0

Total: $0.002	EPA: $0

Users: $1.658 to $4.975

Total: $1.658 to $4.975	EPA: $0.001

Users: $0

Total: $0.001	EPA: $0

Users: $0.166 to $0.498

Total: $0.166 to $0.498	EPA: $0.001

Users: $0.498 to $1.493

Total: $0.499 to $1.494

2B: Digitizer pad signatures with PIN/ password

(everytime 1-factor verification)	EPA: $0.002

Users: $1.658

Total: $1.660	EPA: $0

Users: $1.658 to $4.975

Total: $1.658 to $4.975	EPA: $0.299 to $4.491

Users: $1.061

Total: $1.360 to $5.552	EPA: $0

Users: $0.166 to $0.498

Total: $0.166 to $0.498	EPA: $0.299 to $4.491

Users: $1.890 to $2.886

Total: $2.189 to $7.377

2C: Digitizer pad signatures with biometric thumbprint

(everytime 1-factor verification)	EPA: $0.002

Users: $1.658

Total: $1.660	EPA: $0

Users: $5.306

Total: $5.306	EPA: $0.001

Users: $1.061

Total: $1.062	EPA: $0

Users: $0.531

Total: $0.531	EPA: $0.001

Users: $2.985

Total: $2.986

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

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

Users: $2.207 to $26.030

Total: $2.555 to $26.030	EPA: $0

Users: $0.260 to $0

Total: $0.260 to $0	EPA: $0

Users: $1.744 to $12.703

Total: $1.744 to $12.703	EPA: $0

Users: $0.172 to $0

Total: $0.172 to $0	EPA: $0.070 to $0

Users: $2.409 to $17.909

Total: $2.479 to $17.909

Explanatory Notes:

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

II.  Cost Estimation Methodology

Disclaimer

OSW’s reference to specific companies in the cost calculations below
does not constitute endorsement of those companies by OSW or EPA, nor
does it indicate OSW or EPA preference for specific IT hardware products
or IT software products or IT services or IT companies.  The companies
referenced in this cost comparison provided OSW with the information
cited below solely for use by OSW to formulate rough order-of-magnitude
cost estimates for eSignature options for OSW’s planned eManifest IT
system.  The cost information provided by these companies for this
purpose does not represent binding “price quotes” to OSW or to EPA
or to eManifest users, nor does their provision of this cost information
disqualify them as potential candidate IT vendors for supplying
eManifest hardware, software, or IT services.

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

Key definitions related to “electronic signature” as established 13
Oct 2005 by EPA’s CROMERR final rule at 40 CFR 3.3 (  HYPERLINK
"http://www.epa.gov/cdx/cromerrr"  http://www.epa.gov/cdx/cromerrr ):

Electronic signature:	Means any information in digital form that is
included in or logically associated with an electronic document for the
purpose of expressing the same meaning and intention as would a
handwritten signature if affixed to an equivalent paper document with
the same reference to the same content. The electronic document bears or
has on it an electronic signature where it includes or has logically
associated with it such information.

Electronic signature agreement:	Means an agreement signed by an
individual with respect to an electronic signature device that the
individual will use to create his or her electronic signatures requiring
such individual to protect the electronic signature device from
compromise; to promptly report to the agency or agencies relying on the
electronic signatures created any evidence discovered that the device
has been compromised; and to be held as legally bound, obligated, or
responsible by the electronic signatures created as by a handwritten
signature.

Electronic signature device:	Means a code or other mechanism that is
used to create electronic signatures. Where the device is used to create
an individual's electronic signature, then the code or mechanism must be
unique to that individual at the time the signature is created and he or
she must be uniquely entitled to use it. The device is compromised if
the code or mechanism is available for use by any other person.

II.B  Assumptions & Baseline

Cost Estimation Accuracy:

The expected accuracy of the cost estimates in this document, according
to the relatively low level-of-effort, the relatively small amount of
data, and lack of refined IT system design specifications on which they
are formulated --- represent “Budget Estimates”.  Consequently, the
expected accuracy range for such cost estimates (i.e., the actual cost)
is typically -30% to +50% of the numerical values shown.  This-expected
accuracy range is meant to represent variation in “Budget Estimates”
as prescribed by the ANSI Standard Z94.0 summarized in Figure 1.1: Cost
Estimate Classification Matrix for Process Industries on pages 1-3 and
1-4 of “Skills & Knowledge of Cost Engineering”, 4th edition,
Association for the Advancement of Cost Engineering, 1999
(http://www.aacei.org):

“Budget estimates are prepared with the help of flow sheets, layouts,
and equipment details.  In other words, enough preliminary engineering
has taken place to further define the project scope…  Budget estimates
are also called “study feasibility”, “design development”,
“semi-detailed”, “appropriation”, or “control” estimates.”

5-Year IT Lifecycle Cost Period:

OSW calculated the average annual cost (AAC) in the “Cost Summary
Table” above by (a) dividing initial year costs (IYC) by 5 years, and
(b) adding the 5-year averaged IYC to annual recurring cost (ARC).  This
simple annualization method does not apply a price inflation factor or
an economic discount factor.  This cost annualization method also
assumes that IYC will not repeat sooner than 5-year lifecycle intervals
(e.g., for hardware, software, and IT service upgrades), which may
understate AAC if upgrades are needed sooner such as every 3-years (one
Federal agency (NIH) advices use of a 3-year IT lifecycle cost period in
its “Cost-Benefit Analysis Guide For NIH IT Projects”:

“For example, you may assume that the PC hardware and software for a
system will need to be upgraded every three years.  This could be
justified on the basis of the rapid increases in capacity and speed and
decreases in cost for PCs over the past 15 years”; source: section
3.4.6 at   HYPERLINK "http://irm.cit.nih.gov/itmra/cbaguide.html"
http://irm.cit.nih.gov/itmra/cbaguide.html ).

Compliance with CROMERR:

OSW assumes in this cost comparison that the eSignature requirements of
EPA’s 13 Oct 2005 CROMERR final rule (  HYPERLINK
"http://www.epa.gov/cdx/cromerrr"  http://www.epa.gov/cdx/cromerrr ) are
applicable to OSW planned eManifest IT system to be hosted on EPA’s
CDX.  However, because of the fact that EPA has not historically since
the RCRA manifest system began operation in 1984, nor currently,
requires direct submission of completed manifests to EPA or to
RCRA-authorized state governments, another non-CROMERR scenario is for a
CDX-based eManifest system merely to provide a cradle-to-grave
electronic highway between waste shippers, waste transporters, and waste
receivers according to the current paper manifest system regulations.
Under such a business-to-business (B2B) alternative eManifest workflow
scenario, EPA’s CROMERR requirements might not attach to eManifest
because it would not be a business-to-government (B2G) workflow design.
This alternative B2B eManifest workflow scenario is consistent with
OSW’s current (baseline) RCRA paper manifest system which:

Does not require direct reporting of completed paper manifests to EPA
(but does require reporting of (a) waste discrepancies, (b) unmanifested
wastes, and (c) waste imports/exports received by TSDFs; 40 CFR
264.72(c), 40 CFR 264.76, and 40 CFR 264.71(d), respectively).

Does not require direct reporting of completed paper manifests to
RCRA-authorized state governments (but does require reporting of waste
discrepancies by TSDFs; 40 CFR 262 Appendix item 18).

Does not require identity proofing of ink signatures.

Allows for un-named and non-identified personnel to ink sign the
manifest “on behalf of” the waste generator “to indicate that the
individual signs as the employee or agent of the named principal”. (40
CFR 262 Appendix item 15).  Consistent with this, OSW proposed in the 22
May 2001 electronic manifest proposed rule that a “preparer” would
be able to electronically sign the waste generator’s certification on
behalf of the generator with the preparer’s electronic signature,
because:

“EPA is aware that it is a common practice for an entity or individual
other than the generator (e.g., employee or contractor) to perform the
steps necessary to prepare a waste shipment for transportation,
including the steps associated with preparing the manifest paperwork.
Often, the transporter or the TSDF prepare the manifest paperwork as a
part of the service it provides to its generator customers.  EPA has
already clarified, through an amendment to Item 16 of the manifest
instructions, that the handwritten signature on paper manifests may be
made by employees or other individuals on behalf of the generator. 51 FR
35190 at 35192 (October 1, 1986).  Because the electronic manifest may
also be prepared by entities or individuals other than the generator, it
is appropriate to provide similar flexibility for the preparation and
signing of the electronic manifest.  Please note, however, that EPA is
not reconsidering, reopening, or requesting comment on the existing rule
allowing employees or other individuals to sign the paper manifest on
behalf of a generator.  EPA believes that allowing preparers to sign an
electronic manifest on behalf of a generator would be particularly
important in ensuring that small generators may take advantage of the
electronic manifest option.  Hazardous waste transporters and TSDFs
frequently prepare manifests as a service to smaller generators.”
(Source: p.28291 at
http://www.epa.gov/fedrgstr/EPA-WASTE/2001/May/Day-22/f11909.htm).

For example, this alternative B2B eManifest workflow design might
include adaptation of the CDX “Web-based Electronic Forms Processing:
DF” service
(http://cfint.rtpnc.epa.gov/otop//currentfyservices/df/df.cfm), which is
a user friendly, internet accessible, electronic forms processing
application that allows users to prepare online, submit, route and
approve forms that look just like the paper-based version and can be
completed just as easily.  This design approach is workflow-enabled,
meaning that the CDX could route the form electronically to anyone for
easy approval, rapid processing, and remote archiving with users,
including take-back and re-route functions.  And the forms can be
printed by users if necessary.

eSignature Options OSW Proposed in 2001 and 2006:

A.	May 2001 Electronic Manifest Proposed Rule:

In OSW’s 22 May 2001 de-centralized electronic manifest proposed rule,
OSW proposed two electronic signature options (source: pp.28284 to 28291
at:   HYPERLINK
"http://www.epa.gov/fedrgstr/EPA-WASTE/2001/May/Day-22/f11909.htm"
http://www.epa.gov/fedrgstr/EPA-WASTE/2001/May/Day-22/f11909.htm ):

“Digital signature” option meeting the (a) Secure Hash Algorithm
(for creating message digests) described in FIPS PUB 180-1, (b) RSA
digital signature algorithm (see ANSI X9.31) in accordance with FIPS PUB
186-1 of December 1998, and (c) X.509 PKI digital certificate standard,
but would not require that digital signature systems employ a tokenized
digital signature.

“Secure digitized signature” option which would allow electronic
manifesting systems to incorporate software, digitizer pads, and
electronic pens that create a graphical representation of a signer's
handwritten signature. The electronic manifest copies would be signed
with the digitizer/pen device.  The signature software (a) would block
access to ``cut-and-paste'' editing functions; (b) only accept ``real
time'' signature data input from the digitizer/pen device; (c) record
the signature data as a ``signature object'' that contains: the
graphical image of the signature for display and print operations, in
industry-standard bitmap format (e.g., TIFF or BMP), signature capture
information (e.g., a user ID) and the date and time of signing, (d)
document binding data involving an encrypted checksum or hash function
of the data to which the signature relates, and (e) allow for
verification of signature objects to establish if data has been changed
since the signature was captured.

OSW did not propose in the May 2001 proposed rule a biometric electronic
signature method because OSW stated (p.28289) it believed that these
signature technologies are more practical and proven than other
authentication technologies that rely on biometrics (e.g., fingerprint
readers or retina scans), as the biometric methods identified to date
tend to have significant error rates which hamper their utility.
Biometric methods also are not typically implemented in ways that link
the biometric parameters being measured to the data being signed, so
they are not as helpful in assuring data integrity as the other two
proposed electronic signature methods.

Within the 43 questions (p.28290) that OSW asked for public comment
about electronic signature methods, OSW asked for public comment on a
third signature method but did not propose it as an option in the May
2001proposed rule:

3.	Personal Identification Number (PIN) option in which individuals
would enter a unique sequence of alpha-numeric characters which they
have adopted as their electronic signature.  OSW’s May 2001 proposed
rule explained that OSW did not propose a PIN option because: “[I]n
the context of developing electronic reporting standards for the
Discharge Monitoring Report (a Clean Water Act requirement), EPA
concluded that, in order to satisfy standards of proof for criminal
prosecutions, it was preferable to require more than simply a PIN for
authentication of a record. So, in the Discharge Monitoring Report
rulemaking, EPA proposed the use of a PIN signature backed up with a
follow-up certification that would be hand-signed and mailed to the
Agency. This approach seems impractical for the manifest, and therefore,
EPA has not included a PIN approach in today's proposal.”

B.	April 2006 Electronic Manifest NODA:

In contrast to OSW’s “decentralized” electronic manifest approach
described in the May 2001 proposed rule, OSW’s 18 April 2006 Federal
Register NODA announcing OSW’s intention to finalize a
“centralized” IT approach for eManifest based on EPA’s CDX and
EIEN, did not identify, propose, request public comment on, or otherwise
discuss, any electronic signature options because:

“EPA believes that as a result of this change in approach for the
e-manifest system, the final regulation authorizing the use of
electronic manifests would be much simpler than the regulation suggested
by the May 2001 proposed rule. The final rulemaking will be constrained
in its scope to authorizing the use of electronic manifests created and
transmitted in the national system, and to several other key policy
issues that must be resolved prior to implementation. EPA thus expects
to limit, as far as possible, the subject matter of the final rule on
electronic manifesting to the key policy issues associated with
authorizing the use of electronic manifests and with implementing the
electronic manifest as a means of tracking hazardous waste shipments and
recording and transmitting waste shipment information. EPA believes it
is far more sensible to address the more detailed technical system
design and performance requirements for the centralized e-manifest
system within the contracting process than to codify performance
requirements and other technical matters within the rulemaking
process.”  (Source: p.19847 at
http://www.epa.gov/epaoswer/hazwaste/gener/manifest/pdf/noda-06.pdf).

CROMERR Compliant eSignature Options:

The three primary options identified in this cost comparison are Nov
2006 updated versions (by Richard LaShier, OSW) of the three options OSW
described in the 22 May 2001 electronic manifest proposed rule.  OSW
assumes that all eSignature options/sub-options included in this cost
comparison are potentially compliant with EPA’s 2005 CROMERR final
rule, based on how the CROMERR final rule defines electronic signatures:

From page 59853 of the Federal Register:

“[I]n terms of electronic signature technology, the rule allows for a
range of approaches, including various implementations of PINs and
passwords, the use of private or personal information, digital
signatures based on PKI certificates, and other signature technologies
as they become viable for our applications. As EPA or authorized
programs implement electronic submission for specific reports, the rule
allows them to select one or more of the available submission and
signature approaches according to their circumstances and the
program-specific requirements.”

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

“Valid electronic signature means an electronic signature on an
electronic document that has been created with an electronic signature
device that the identified signatory is uniquely entitled to use for
signing that document, where this device has not been compromised, and
where the signatory is an individual who is authorized to sign the
document by virtue of his or her legal status and/or his or her
relationship to the entity on whose behalf the signature is executed.”

However, only eSignature options/sub-options 1A, 1B, and 3 evaluated in
this cost comparison conform to the CROMERR eSignature requirements for
EPA “Priority Reports”.  According to Appendix 1 to the CROMERR
final rule (Federal Register page 59885), three RCRA manifest-related
reports are classified under CROMERR as “Event Driven Notices” which
must meet additional CROMERR eSignature requirements:

“(vii) For each electronic signature device used to create an
electronic signature on the document, the identity of the individual
uniquely entitled to use the device and his or her relation to any
entity for which he or she will sign electronic documents has been
determined with legal certainty by the issuing state, tribe, or local
government.  In the case of priority reports identified in the table in
Appendix 1 of Part 3, this determination has been made before the
electronic document is received, by means of: (A) Identifiers or
attributes that are verified (and that may be re-verified at any time)
by attestation of disinterested individuals to be uniquely true of (or
attributable to) the individual in whose name the application is
submitted, based on information or objects of independent origin, at
least one item of which is not subject to change without governmental
action or authorization; or (B) A method of determining identity no less
stringent than would be permitted under paragraph (b)(5)(vii)(A) of this
section; or (C) Collection of either a subscriber agreement or a
certification from a local registration authority that such an agreement
has been received and securely stored.”

EPA Costs:

This cost category designates the costs that OSW anticipates OSW’s
eManifest IT vendor contractor will incur, for which OSW will need to
pay the IT vendor from eManifest user fees and/or Congressional budget
appropriation.  Important “EPA Cost” assumptions in this cost
comparison are:

Hosted application approach: Rather than attempting in this cost
comparison to estimate the potential hardware and software/services
costs to EPA’s eManifest IT vendor for designing, installing, testing,
implementing, operating and maintaining eSignature services within
eManifest’s CDX platform, this cost comparison estimates the cost for
the eSignature options/sub-options, based primarily on a “hosted
application” approach involving 3rd party IT vendor services:

“As access to the Internet becomes more widespread with faster, more
reliable and 'always on' connections becoming the norm the growth of
applications using the hosted application model continues to expand.
Although hosted applications will not suit every situation, or every
customer, they offer many individuals and organizations, as well as the
application manufacturers' themselves, considerable benefits over the
locally installed application.  A hosted application, also known as
Internet-based application, web-based application, online application
and Application Service Providers (ASPs) are software applications where
the software resides on servers that are accessed through the Internet
instead of the more traditional software that is installed on either a
local server or on individual PCs.  The thin client concept is nothing
new but advances in Internet connectivity have allowed the application
to move from a local server to a server on the Internet.” (source:
http://www.webpronews.com/expertarticles/2005/10/19/what-are-hosted-appl
ications).

eManifest user account costs: For all options/sub-options in this cost
comparison, OSW equally assumes, but does not add to the cost of each
option/sub-option, $2.250 million/year to $4.927 million/year in average
annual cost for EPA (CDX) to establish and maintain CDX user
registration accounts for eManifest users: [(119,300 to 260,300 employee
users) x ($18.93/year per user account)].  This estimate is based on EPA
OEI-OTOP’s FY2007 Working Capital Fund Rates for “Application
Hosting: Account/User Management: U3”.  Specific functions associated
with this service include (a) managing user accounts on EPA’s web
servers, and (b) maintaining user account data within EPA’s Time
Sharing Services Management System (TSSMS).  Source:   HYPERLINK
"http://cfint.rtpnc.epa.gov/otop/currentfyservices/u3/u3.cfm"
http://cfint.rtpnc.epa.gov/otop/currentfyservices/u3/u3.cfm .  Because
this cost is assumed equal to all options/sub-options, it does not
appear as a line-item under each in this cost comparison.  Furthermore,
CDX registration user accounts are assumed required for OSW to charge
and collect eManifest user fees under OSW’s proposed eManifest
lifecycle cost user fee funding scenario (rather than the alternative
Congressional appropriation funding scenario).  OSW’s user fee funding
approach is described in:

Business Case:	OSW’s 11 Sept 2006 submission to OMB of OSW’s FY2008
Circular A-11 Part 7 Section 300 Planning, Budgeting, Acquisition, &
Management of Capital Assets “Exhibit 300” business case for
eManifest (  HYPERLINK
"http://www.epa.gov/OEI/cpic/by2008/eManifest.pdf"
http://www.epa.gov/OEI/cpic/by2008/eManifest.pdf ); and

S.3871:	The “Hazardous Waste Electronic Manifest Establishment Act“
introduced 07 Sept 2006 in the US Senate by Senators Thune and Jeffords
as Senate Bill S.3871 which was read twice and referred to the US Senate
Committee on Environment and Public Works (  HYPERLINK
"http://thomas.loc.gov/cgi-bin/query/z?c109:s3871"
http://thomas.loc.gov/cgi-bin/query/z?c109:s3871 :).

EPA CDX helpdesk: This cost comparison does not include the $1.192
million/year to $4.490 million/year in CDX helpdesk cost for eManifest
users as estimated in Appendix A, because this cost comparison assigns a
20% to 50% fractional helpdesk cost for  PIN/password reset under the
four eSignature sub-options based on PIN/passwords (i.e., sub-options
1A, 1B, 1C, 2B).  OSW simply assumes that the $1.192 million/year to
$4.490 million/year cost for annual helpdesk services to resolve other
types of eManifest user problems are equal under each eSignature
option/sub-option, so this 80% to 50% other fraction of helpdesk cost,
respectively, is not assigned as either an EPA cost or a user cost in
this cost comparison for any sub-option.

User Costs:

Designate the costs that OSW anticipates industrial and waste management
facilities involved in hazardous waste transportation will incur to use
eManifest.  User costs will not be funded by OSW with either eManifest
user fees or Congressional budget appropriation.  Important “User
Cost” assumptions applied in this cost comparison are:

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

LQGs (population = 16,000 LQG shippers): Large quantity generators; many
of these are already CDX registered users for other EPA electronic
reporting purposes.

TSDFs (population = 1,200 TSDF receivers): Treatment, storage, disposal
facilities; many of these are already CDX registered users for other EPA
electronic reporting purposes.

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

SQGs (population = 114,000 SQG shippers): Small quantity generators are
largely excluded from this analysis because OSW assumes that TSDFs will
provide eManifest access to SQGs under commercial TSDF service customer
arrangements, which is consistent with OSW’s assumption in the 22 May
2001 electronic manifest proposed rule:

 “Hazardous waste transporters and TSDFs frequently prepare manifests
as a service to smaller generators.  While the small or infrequent
generator would not be expected to obtain computer equipment or software
to conduct automated manifesting, the transporters and TSDFs that deal
in larger volumes of manifests would likely find automated manifesting
more advantageous.  Thus, allowing the preparer to sign the electronic
manifest provides a way for small or infrequent generators to
participate in the automated system.  EPA estimates that small generator
manifests may account for about 66% of the manifests circulated
annually.  So, providing a means to include these manifests would extend
the burden reduction effects of manifest automation to these manifests
as well, particularly, as they are received and processed by
transporters, TSDFs, and State agencies.” (source: p.28291 at
http://www.epa.gov/fedrgstr/EPA-WASTE/2001/May/Day-22/f11909.htm).

State governments: With the exception of state government agencies which
generate, transport, or receive hazardous wastes, state government
RCRA-authorized environmental agencies are excluded from this cost
comparison because OSW assumes they will not execute or need to provide
for eManifest eSignatures.

Equal user group eSignature risk: For each option/sub-option, OSW
assumes in this cost comparison that each of the four user groups (i.e.,
SQGs, LQGs, transporters, and TSDFs) will use the same eSignature method
within each option/sub-option evaluated, rather than mixing and matching
different eSignature methods according to different perceived risks
associated with each of the four user groups.

User participation rate: 75% participation rate phase-in assumption
applied to cost calculations: see Appendix B to this document for the
associated eManifest user truck, facility, and employee counts.

Office desktop PCs: This cost comparison assumes that all LQGs and TSDFs
currently have at least one office destktop PC, with existing internet
ISP connection, which can be used for initiating and for receiving
eManifests at no additional initial year or annual year business cost,
as well as complying with the two fundamental CROMERR e-reporting
requirements:

View in “human readable format” (i.e., view an electronic computer
image) the content of the eManifest form that the employee is
“certifying to, attesting to or agreeing to by signing”, as required
by EPA’s CROMERR final rule (40 CFR 3.2000(b)(5)(iii)), and

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

This cost comparison assumes that SQGs do not have an office desktop PC
with internet ISP connection; consequently, this analysis assumes that
commercial hazardous waste trucks will provide eManifest capability for
SQGs.  The cost estimates assume that all facilities (i.e., LQGs,
trucks, and TSDFs) have at least one office desktop computer, or truck
PDA or tablet PC, on which hazardous waste generator shipping offeror,
waste transporter, and waste receiving facility employees may log-on to
the eManifest CDX-hosted website homepage.

Truck computer equipment: OSW is aware that at least one commercial
hazardous waste trucking company (Safety-Kleen) already has equipped
some or all of its hazardous waste trucks with onboard mobile PDAs
and/or tablet PCs.  However, because OSW does not have complete
information about the exact number of trucks and the specs required for
this truck computer equipment, this cost comparison simplistically
assumes that all 10,100 hazardous waste trucks in the US fleet do not
currently have onboard mobile computer hardware or existing wireless ISP
service for trucks.  Consequently, this assumption may overstate
wireless ISP service costs to waste transport trucks for the four
sub-options requiring mobile wireless connectivity for instantaneous
identity verification of eManifest eSignatures (i.e., sub-options 1C,
2B, 2C, 3) by at least 4%.

Alternatively, 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
eSignatures saved each day on the truck PDAs (or truck tablet PCs)
without requiring instantaneous identity verification at each signature
event, the wireless ISP cost assigned for trucks in this cost comparison
could be dropped from these four sub-options.

Mobile printer costs: This cost comparison does not include potential
costs to truckers for purchasing mobile printers for their trucks, or
for upgrading truck PDAs or truck tablet PCs with printer drivers and
printer connection ports/cables, so that a paper copy of the manifest
can be carried on the truck in lieu of the USDOT 49 CFR required
shipping paper.  Based on a cost of $320 for portable printers for PDAs,
such requirement could add at least $3.374 million additional initial
year user cost, which divided over a 5-year cost period is equivalent to
$1.103 million additional average annualized user cost.

Other Federal electronic programs: As of 2006, at least two other
Federal agencies are implementing electronic programs related to
transportation.  OSW anticipates that a relatively small 1.5% to 2.3%
fraction  of the 10,100 RCRA hazardous waste trucks (i.e., 150 to 230
trucks) may become future participants in these two other programs.
However, for purpose of this cost comparison, any potential future
electronic capabilities acquired for compliance with these two other
Federal electronic programs are not credited as potential hardware or
software cost savings to eManifest users in this cost comparison.

TWIC IDs:	The Transportation Worker Identification Credential (TWIC)
program is a Transportation Security Administration (TS) and US Coast
Guard initiative.  The TWIC program provides a tamper-resistant
biometric credential to maritime workers requiring unescorted access to
secure areas of port facilities.  An estimated 750,000 individuals will
require TWICs.  Enrollment and issuance will take place over an 18 month
period.  To obtain a TWIC, an individual must provide biographic and
biometric information such as fingerprints, sit for a digital photograph
and successfully pass a security threat assessment conducted by TSA.
While TWIC may be implemented across other transportation modes in the
future, the TWIC Final Rule, published in the Federal Register January
25, 2007, sets forth regulatory requirements to implement this program
in the maritime mode first (source:   HYPERLINK
"http://www.tsa.gov/what_we_do/layers/twic/index.shtm"
http://www.tsa.gov/what_we_do/layers/twic/index.shtm ).

ACE eManifest:	On 27 October 2006, the US Customs & Border Protection
(CBP) published the first of a series of Federal Register Notices (FRN)
announcing that electronic manifests (eManifests) will be required to be
submitted to CBP prior to a trucks arrival at specific land border
crossings. The requirement to submit eManifests at the initial ports
will be implemented 90 days from the date of publication of the
mandatory eManifest notice.  An aggressive roll-out schedule is planned
to make e-Manifests mandatory at all land border crossings by the end of
2007.  Carriers will be able to file an eManifest through the ACE Secure
Data Portal or by a CBP tested solution provider. (source:   HYPERLINK
"http://www.cbp.gov/xp/cgov/toolbox/about/modernization/ace"
http://www.cbp.gov/xp/cgov/toolbox/about/modernization/ace ).

III.  Cost Calculations

Option 1:  PIN/password

OSW estimated costs for the three sub-options (1A, 1B, 1C) based largely
on the FY2007 price list for IT services provided by EPA’s OEI-OTOP
at:   HYPERLINK "http://cfint.rtpnc.epa.gov/otop/currentfyservices"
http://cfint.rtpnc.epa.gov/otop/currentfyservices .

Sub-Option 1A:	PIN/password plus initially one-time mail to OEI (CDX),
employee “signature holder agreements” (SHAs) or facility-wide LRA
SHA certification (1-factor identity proofing)

This option assumes that PIN/password management is provided as a local
self-service at each user facility according to the CDX remote
certification agreements of this option, rather than managed via
eManifest CDX infrastructure.  Accordingly, the incremental cost for
PIN/password management software is assigned in this cost comparison as
a “User Cost” rather than as an “EPA Cost”.  However, because
the price example applied in this cost estimate is based on a
per-business license basis, the PIN/password software business license
cost estimate might also serve as a preliminary rough estimate of the
incremental cost to eManifest infrastructure for purchasing PIN/password
management licenses for  managing user PIN/passwords via the CDX
eManifest infrastructure.

Initial Year Costs

Software & IT Services:

EPA:	$1.976 million to $5.229 million:

Low-end: If OEI receives facility-wide certifications in mail that
employee ink “signature holder agreements” (SHAs) are maintained
onsite by the company notarized onsite custodian “LRA”:

$1.976 million, calculated as follows: [(98,360 facilities) x ($20.09
per incoming LRA SHA certification)].  This estimate is based on
OEI-OTOP’s FY2007 Working Capital Fund Rates for “Correspondence
Management System: EK” which is a service that “scans, logs, tracks,
and stores incoming and outgoing correspondence in all program and
regional offices… creating a virtual record for each control”; the
cost includes space rental for incoming documents.  OEI-OTOP’s unit
cost data from   HYPERLINK
"http://cfint.rtpnc.epa.gov/otop/currentfyservices/ek/ek.cfm"
http://cfint.rtpnc.epa.gov/otop/currentfyservices/ek/ek.cfm .

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

$2.397 million to $5.229 million, calculated as follows: [(119,300 to
260,300 employee users) x ($20.09 per incoming SHAs)].  This estimate is
based on OEI-OTOP’s FY2007 Working Capital Fund Rates for
“Correspondence Management System: EK” (see above for description).

Users:	$1.009 million to $4.217 million:

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

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

Low-end: $1.009 million to $2.202 million if OEI receives ink signature
agreements from all employees in mail without onsite LRA:

Labor burden to employees: $0.962 million to $2.100 million paperwork
burden for executing handwritten signatures by all employees: [(119,300
to 260,300 employee users) x (15 minutes per employee to retrieve, read,
sign, address, seal and mail agreement) x ($32.27/hour mean wage)].
Note: 15 minutes per employee assumption from EPA’s 13 Oct 2005
CROMERR final rule (FR p.59876).

File cabinets: $0.

Postage: $0.047 million to $0.102 million mail postage: [($0.39/stamp) x
(119,300 to 260,300 employee users)].

High-end: $3.079 million to $4.217 million if OEI receives facility-wide
certifications in mail certifying that ink signature agreements for all
employees are maintained onsite by the company notarized onsite
custodian “LRA”:

Labor burden to employees: $0.962 million to $2.100 million paperwork
burden for executing handwritten signatures by all employees: [(119,300
to 260,300 employee users) x (15 minutes per employee to read and sign
agreement) x ($32.27/hour mean wage)].  Note: 15 minutes per employee
assumption from EPA’s 13 Oct 2005 CROMERR final rule (FR p.59876).

Labor burden to LRA: $1.587 million paperwork burden for “preparing
and submitting the certification of receipt and secure storage to
EPA”; [(98,360 facility LRAs) x (30 minutes per LRA) x ($32.27/hour
mean wage)].  Note: 30 minutes per LRA assumption from EPA’s 13 Oct
2005 CROMERR final rule (FR p.59876).

File cabinets: $0.492 million for onsite file cabinet purchase cost:
[(10% ($5) average portion of $50 file cabinet per facility) x (98,300
facilities)].

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

Hardware:	$0; assume no incremental hardware costs to SQGs, LQGs,
transporters, and TSDFs because waste offeror and waste receiver
facility employees are assumed to view the eManifest form electronic
image and keypunch their PIN/password electronic signatures into
eManifest via existing office desktop PC keyboards and existing truck
PDAs/tablet PCs at time of waste pickup and delivery.

EPA:		$0

Users:	$0

Annually Recurring Costs

Software & IT Services:

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

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

Low-end: $0.237 million/year; calculated as 12% of initial year cost to
account for 12% future annual new establishment start-ups.

High-end: $0.837 million/year, calculated as 16% of initial year cost to
account for 16% employee annual turnover rate.

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

Users:	Certifications: $0.161 million/year to $0.675 million/year,
calculated as 16% of initial year cost to account for 16% employee
annual turnover rate.

Hardware:

EPA:	$0

Users:	$0

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

Assumes that DL# or CC# identity proofing only occurs for each eManifest
user upon initial registration with eManifest (i.e., as an initial year
cost according to the count of eManifest users), rather than at each
eManifest signing event (i.e., as an annually-recurring cost according
to the annual count of signatures on eManifests).  One example of an
existing IT approach to implementing this as a user feature within
eManifest is to use the “Designer” features provided by Adobe
Systems Inc. (http://www.adobe.com/government) in which the Adobe
designed electronic form is connected to a web service that validates
credit card numbers, by creating a new data connection to an WSDL to
bind one or more such web services providers (source:   HYPERLINK
"http://www.adobeforums.com/cgi-bin/webx/.3bb918ad"
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 successfully launched the world’s first “real
time” online driver’s license validation service, which reportedly
“can provide the basic ‘yes’ or ‘no’ validation answer in just
seconds” (source: http://news.thomasnet.com/fullstory/473992).

Initial Year Costs

Software & IT Services:

EPA:	$0

Users:	$0.239 million to $0.521 million:

Initial DL# or CC# identity proofing: $0.239 million to $0.521 million,
calculated as follows: [(119,300 to 260,300 employee users) x ($2 per
remote DL# or CC# identity proofing service)].

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

Hardware:

EPA:	$0

Users:	$0

Annually Recurring Costs

Software & IT Services:

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

Users:	Annual DL# or CC# identity proofing: $0.038 million/year to
$0.083 million/year, calculated as 16% of initial year cost to account
for 16% employee annual turnover rate.

Hardware:

EPA:	$0

Users:	$0

Sub-Option 1C:	PIN/password plus 2nd factor identity verification

To differentiate in this cost comparison, the cost of a single
PIN/password solution (Option 1A) compared to a 2nd factor identity
verification in addition to a PIN/password, as well as to reflect
multiple possible IT solutions for 2nd factor identity verification, the
cost estimate for this sub-option is based on three sub-options:

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

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

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

In addition, this sub-option includes the cost for wireless ISP access
by trucks for realtime and everytime identity verification in the field
for each manifest signature event (as well as for sub-options 2B, 2C and
3); in contrast, a wireless ISP cost is not assigned to sub-options 1A
or 1B (or 2A) in this cost comparison because those two PIN/password
sub-options represent one-time identity verification methods for initial
user registration with the eManifest system, not for each eManifest
signature event (and sub-option 2A does not require identity
verification).

Sub-Option 1C-1:	TPV:

Online third-party identity verification (TPV) service exampled based on
the IDology Inc’s “ExpectID IQ” service, in which a “https
post” XML connection to the TPV is embedded within the eManifest
homepage architecture.  eManifest users would log-on to eManifest with
user name, PIN/password, and then the TPV service returns to the
eManifest homepage screen, a series of multiple choice questions to
which the user would type-in answers.  The questions would be derived by
the TPV from instantaneous queries of public records databases (now
available in all US states and territories).  The user responses would
determine if the user is actually who he/she claims to be.  The entire
verification process can be completed within less than one minute,
depending upon the number of 2nd identity proofing questions asked by
the TPV.  Under this arrangement, OSW’s eManifest system would be the
single TPV customer to which monthly invoices would be sent, not the
eManifest users.  OSW could then pass-thru this annual O&M expense to
eManifest users via user fees.

Initial Year Costs

Software & IT Services:

EPA:	$0.001 eManifest architecture integration cost (source: OSW
estimate of relatively small start-up fee based on “less than
$1,000” estimate verbally provided over the phone 12 April 2007 to
Mark Eads, OSW. by Doug Finlayson, Customer Service Manager, IDology,
Inc.,<PHONE_NUMBER>.  The initial integration of this TPV service into
the eManifest architecture is a 1-day task according to IDology Inc.

Users:	$0

Hardware:

EPA:	$0

Users:	$0

Annually Recurring Costs

Software & IT Services:

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

$7.980 million/year calculated as follows: [(3.8 million eManifests per
year) x (average of 3 eSignature 2nd factor verifications needed per
eManifest) x ($0.97 for TPV service cost per transaction) x (0.70 for
30% large volume pricing discount)]; price source: 12 April 2007 phone
verbal price quote (non-discounted volume) provided to Mark Eads, OSW by
Doug Finlayson, Customer Service Manager and Jim Mitchell, VP Marketing,
IDology, Inc.,<PHONE_NUMBER> and<PHONE_NUMBER>.  Otherwise, there are no
monthly or annual subscription or license fees required for this TPV
service.

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

Users:	Wireless ISP for trucks: $0.729 million/year for wireless ISP
(internet service provider) service calculated as follow: [($39.99/month
per 5-truck user ISP account) x (12 months/year) x (7,600 trucks) / (5
trucks/ISP account)] to provide the necessary wireless connectivity of
truck PDAs to connect realtime for eSignature identity verification each
time an eManifest is electronically signed (source: $39.99 monthly
wireless ISP fee price example from Palm.Net's Executive Unlimited
monthly usage plan
http://www.smartcomputing.com/editorial/article.asp?article=articles/arc
hive/l0805/09l05/09l05.asp&guid=).

Hardware:

EPA:	$0

Users:	$0

Sub-Option 1C-2:	OTP:

One-time password (OTP) token technology which generates and displays a
pseudo-random number consisting of six or more alphanumeric characters;
when the pseudo-random number is combined with a PIN or password, the
resulting passcode is considered two factors of authentication (source:
 HYPERLINK "http://en.wikipedia.org/wiki/One-time_password"
http://en.wikipedia.org/wiki/One-time_password ).

Initial Year Costs

Software & IT Services:

EPA:	$0

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

Hardware:

EPA:	$0

Users:	2nd factor tokens: $0.596 million to $22.559 million: [($5 per
Entrust mini token) to ($52 per RSASecurID token x (5 years cost
period)/(3 year license) x (119,300 to 260,300 employee users)].

Annually Recurring Costs

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:

2nd factor license: $0.477 million/year to $8.330 million/year:
[(119,300 to 260,300 employee users) x ($4 to $32 per user per year)].
Although one source reports that the incremental annual cost to users of
adding this 2nd computer access factor typically ranges from $50 to $100
per user per year (source:
http://en.wikipedia.org/wiki/Strong_authentication), a lower-cost
Entrust IdentityGuard OTP token service introduced in 2007 is priced at
an average annualized cost of $4 per user per year (source:   HYPERLINK
"http://www.entrust.com/strong-authentication/identityguard/calculator.c
fm"
http://www.entrust.com/strong-authentication/identityguard/calculator.cf
m ).  The Entrust website also provides an upper-bound cost example
based on the RSA SecurID token 3-year license technology
(http://en.wikipedia.org/wiki/SecurID) with an average annualized user
cost of $32.   These two cost points provide a range of $4 to $32 per
user per year applied in this sub-option rather than the broader $50 to
$100 price range.

Wireless ISP for trucks: $0.729 million/year for wireless ISP (internet
service provider) service calculated as follow: [($39.99/month per
5-truck user ISP account) x (12 months/year) x (7,600 trucks) / (5
trucks/ISP account)] to provide the necessary wireless connectivity of
truck PDAs to connect realtime for eSignature identity verification each
time an eManifest is electronically signed (source: $39.99 monthly
wireless ISP fee price example from Palm.Net's Executive Unlimited
monthly usage plan
http://www.smartcomputing.com/editorial/article.asp?article=articles/arc
hive/l0805/09l05/09l05.asp&guid=).

Hardware:

EPA:	$0

Users:	$0.045 million/year to $0.833 million/year for token replacement:
10% of initial hardware cost for annual replacement of lost and broken
hardware tokens (source: 10% replacement rate assumption is from
VeriSign’s 2005 white paper “Two-Factor Authentication: A Total Cost
of Ownership Viewpoint”, p.7:   HYPERLINK
"http://www.verisign.com/Resources/Unified_Authentication_White_Papers/i
ndex.html"
http://www.verisign.com/Resources/Unified_Authentication_White_Papers/in
dex.html ).

Sub-Option 1C-3:	IRS.

The IRS efile “self-select PIN” method involves internet IT services
provided to taxpayers by 3rd party IT vendor “partners” to the IRS,
to provide both (a) tax form preparation software, and (b) e-filing
services involving the taxpayer creating a self-select PIN via the IT
vendor online service.  When the PIN e-signature method is used, no
signature documents are required to be filed by the taxpayer with the
IRS.  The PIN may be any five digits the taxpayer chooses (except all
zeros) to use as his/her electronic signature.  Taxpayers create their
own PIN (but do not register the PIN with IRS before filing or need to
contact IRS to get it) using one of the commercially available tax
software packages that support the Self-Select PIN.  IRS’s self-select
PIN method requires use of the PIN plus original Adjusted Gross Income
(AGI) or PIN (if e-filed and signed electronically) from the prior year
tax return and Date of Birth (DOB) for verification purposes by the IT
vendor.  The same PIN may be used in future years, or it may be changed
by the taxpayer in any year.  This method is for taxpayers who file
electronically using tax preparation software.

The IRS also offers a “Practitioner PIN Method” whereby the taxpayer
e-files through a tax professional who is an Authorized e-file provider
.  This alternative method does not required the taxpayer to provide
his/her original Adjusted Gross Income (AGI) or PIN (if e-filed and
signed electronically) from prior year return or DOB.  The IRS itself
does not provide and maintain taxpayer PIN numbers, the necessary
software, or provide a public website for direct e-filing; the parter IT
vendors e-file to the IRS on behalf of taxpayers via the vendor’s own
secure internet servers with SSL encryption.

As of March 2007, IRS had entered into partnership agreements with 26 IT
vendor companies to provide self-select PIN e-filing services for
taxpayers, but the IRS does not endorse or warrant its partner companies
for their products or services (source:   HYPERLINK
"http://www.irs.gov/efile/lists/0,,id=101223,00.html"
http://www.irs.gov/efile/lists/0,,id=101223,00.html  and   HYPERLINK
"http://www.irs.gov/efile/article/0,,id=101246,00.html"
http://www.irs.gov/efile/article/0,,id=101246,00.html ).

OSW’s cost estimates below for this two-factor identity proofing
sub-option are based on the 21 April 2006 Chevo Consulting cost estimate
for the IRS efile “Self-Select PIN” method in “eSignature Cost
Benefit Analysis” (provided 10 April 2007 to OSW by Kevin Hatton, IRS
ETA Technology Programs Branch,<PHONE_NUMBER>), and the IRS “efile
Partners for Taxpayers” price list (source:
http://www.irs.gov/efile/lists/0,,id=101223,00.html), scaled in cost by
OSW according to the eManifest user volume scenario shown in Appendix B
to this cost comparison.

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

Low-End:	OSW also computed a “Low-End” cost estimate substitute to
the IRS PIN approach, based on price data supplied 12 April 2007 to Mark
Eads, OSW, by Doug Finlayson, Customer Service Manageer of IDology Inc.,
for their “ExpectID” identity verification service (  HYPERLINK
"http://www.idology.com/identity.html"
http://www.idology.com/identity.html ) which requires users to supply
their SSN4 or year-of-birth (YOB) as a 2nd factor PIN-type verification.

Initial Year Costs

Software & IT Services:

EPA:	$0.001 million to $0.047 million

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

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

Hardware:

EPA:	$0

Users:	$0

Annually Recurring Costs

Software & IT Services:

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

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

Low-end (SSN4 or YOB): $0

High-end (IRS): $0.070 million/year to $0.308 million/year, calculated
as follows: [((500 to 2,200 EPA IT contractor helpdesk support labor
hours for rejected PIN/passwords) + (10 to 40 EPA IT contractor
maintenance hours/year)) x (($135/hour EPA IT contractor labor rate) x
(1.02 price inflation factor)].

$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:

Service fee for 2nd factor verification:

Low-end (SSN4 or YOB): $2.953 million/year, calculated as follows: [(3.8
million eManifests per year) x (average of 3 eSignature 2nd factor
verifications needed per eManifest) x ($0.37/transaction) x (0.70 for
30% large volume pricing discount)].  Note the 30% pricing discount for
ExpectID is a rough estimate provided 12 April 2007 to Mark Eads, OSW,
by IDology Inc. (Jim Mitchell,<PHONE_NUMBER>).

High-end (IRS): $45.030 million/year, calculated as follows: [(3.8
million eManifests per year) x (average of 3 eSignature 2nd factor
verifications needed per eManifest) x ($3.95 PIN creation and efiling
fee charged by IRS-approved efile IT vendors)].  This e-filing fee
represents the lowest non-zero price point of the broader $0 to $14.95
range across the 26 IRS partner IT vendors (as of 10 April 2007), which
appears to represent only the incremental cost of the PIN-based e-filing
service, excluding the additional cost of the tax form preparation
software.

Wireless ISP for trucks: $0.729 million/year for wireless ISP (internet
service provider) service calculated as follow: [($39.99/month per
5-truck user ISP account) x (12 months/year) x (7,600 trucks) / (5
trucks/ISP account)] to provide the necessary wireless connectivity of
truck PDAs to connect realtime for eSignature identity verification each
time an eManifest is electronically signed (source: $39.99 monthly
wireless ISP fee price example from Palm.Net's Executive Unlimited
monthly usage plan
http://www.smartcomputing.com/editorial/article.asp?article=articles/arc
hive/l0805/09l05/09l05.asp&guid=).

Hardware:

EPA:	$0

Users:	$0

Option 2:	Handwritten Digitized Signature

OSW’s cost calculations for this option are largely based on price
quotes supplied 01 March 2007 by Interlink Electronics Inc. to Rich
LaShier Interlink Electronics is an eSignature products vendor (
HYPERLINK "http://www.interlinkelectronics.com/index.php?id=Mzg4"
http://www.interlinkelectronics.com/index.php?id=Mzg4 ).  The cost
calculations for each sub-option (2A, 2B, 2C) are based on Interlink’s
large quantity discounted price quotes for both hardware and software
user costs.  Price quotes include one-year product warranty.  An
important assumption for this option is that the costs of purchasing and
maintaining business office desktop PCs (for LQGs & TSDFs) and of PDAs
or tablet PCs for trucks, are considered required for basic
participation in eManifest, and thus are not assigned as incremental
costs to eSignature options.  Consequently, this option only includes
costs for purchasing and maintaining digitized signature hardware and
software peripherals.  The cost estimates for this option assume
purchase of alternative types of digitizer signature pads for LQG & TSDF
office desktop PCs as well as for trucks.  Although OSW anticipates that
hazardous waste transporters will purchase heavy-duty mobile “tablet
PCs” for trucks, the entire cost of a tablet PC is not completely
allocatable to the eSignature feature; consequently, the digitizer pad
costs applied in this cost comparison are OSW’s approximation of the
allocatable portion of a tablet PC cost.

Sub-Option 2A:	eSignature Pads without identity verification

Initial Year Costs

Software & IT Services:

EPA:	$0.0015 million server license cost

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

Hardware:

EPA:	$0

Users:	$1.658 million to $4.975 million: [(12,100 LQGs + 890 TSDFs +
(7,600 trucks x 120% to account for truck backup devices and for more
than one employee per truck in some cases) x ($75 per standard USB
signature pad to $225 for LCD visual display signature pad)].

Annually Recurring Costs

Software & IT Services:

EPA:	$0.0004 million/year server license cost

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

Hardware:

EPA:	$0

Users:	$0.166 million/year to $0.498 million/year; assumes average
annual 10% replacement rate of initial year cost for replacement of
stolen/ lost/ broken digitized signature pads.

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

Initial Year Costs

Software & IT Services:

EPA:	Same as 2A,

Users:	Same as 2C

Hardware:

EPA:	$0

Users:	Same as 2A

Annually Recurring Costs

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

Hardware:

EPA:	$0

Users:	Same as 2A

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

Initial Year Costs

Software & IT Services:

EPA:	Same as 2A

Users:	$1.658 million: [(12,100 LQGs + 890 TSDFs + (7,600 trucks x 120%
to account for truck backup devices and for more than one employee per
truck in some cases)) x ($75 extra cost for “pro” software license
needed for each biometric signature pad)].

Hardware:

EPA:	$0

Users:	$5.306 million: [(12,100 LQGs + 890 TSDFs + (7,600 trucks x 120%
to account for truck backup devices and for more than one employee per
truck in some cases)) x ($240 per biometric signature pad)].

Annually Recurring Costs

Software & IT Services:

EPA:	Same as 2A

Users:	$1.061 million/year:

$0.332 million/year [(12,100 LQGs + 890 TSDFs + ((7,600 trucks) x (120%
to account for truck backup devices and for more than one employee per
truck in some cases)) x ($15 extra cost for “pro” software license
annual maintenance needed for each biometric signature pad)].

Wireless ISP for trucks: $0.729 million/year for wireless ISP (internet
service provider) service calculated as follow: [($39.99/month per
5-truck user ISP account) x (12 months/year) x (7,600 trucks) / (5
trucks/ISP account)] to provide the necessary wireless connectivity of
truck PDAs to connect realtime for eSignature identity verification each
time an eManifest is electronically signed (source: $39.99 monthly
wireless ISP fee price example from Palm.Net's Executive Unlimited
monthly usage plan
http://www.smartcomputing.com/editorial/article.asp?article=articles/arc
hive/l0805/09l05/09l05.asp&guid=).

Hardware:

EPA:	$0

Users:	$0.531 million: assumes average annual 10% replacement rate of
initial year cost for replacement of stolen/ lost/ broken biometric
signature pads.

Option 3:	PKI Identity Verification

Short for “public key infrastructure”, PKI identity verification is
a system based on digital certificates, Certificate Authorities (CAs),
and other registration authorities that verify and authenticate the
validity of each party involved in an Internet transaction.  PKIs are
currently evolving and as of 2006 there is no single PKI nor even a
single agreed-upon standard for setting up a PKI.  A PKI is also called
a “trust hierarchy” (source:   HYPERLINK
"http://www.webopedia.com/TERM/P/PKI.html"
http://www.webopedia.com/TERM/P/PKI.html ).

CAs are trusted third-party organizations or companies that issue
digital certificates used to create digital signatures and electronic
public-private key pairs.  The role of the CA in the PKI process is to
guarantee that the individual granted the unique digital certificate is,
in fact, who he or she claims to be.  Usually, this means that the CA
has an arrangement with a financial institution, such as a credit card
company, which provides the CA with information to confirm an
individual's claimed identity.  CAs are a critical component in data
security and electronic commerce because they guarantee that the two
parties exchanging information are really who they claim to be (source:
http://www.webopedia.com/TERM/c/certification_authority.html).

A digital certificate (“cert”) is an attachment to an electronic
message used for security purposes.  The most common use of a digital
certificate is to verify that a user sending a message is who he or she
claims to be, and to provide the receiver with the means to encode a
reply.  An individual wishing to send an encrypted message applies for a
digital certificate from a CA.  The CA issues an encrypted digital
certificate containing the applicant's public key and a variety of other
identification information.  The CA makes its own public key readily
available through print publicity or perhaps on the Internet.  The
recipient of an encrypted message uses the CA's public key to decode the
digital certificate attached to the message, verifies it as issued by
the CA and then obtains the sender's public key and identification
information held within the certificate. With this information, the
recipient can send an encrypted reply.  The most widely used standard
for digital certificates is X.509 (source:
http://www.webopedia.com/TERM/D/digital_certificate.html).

EPA’s 13 Oct 2005 CROMERR final rule (page 59862) indicated that EPA
does not expect PKI digital signature options such as this one to
dominate CDX applications:

“Thus, for electronic reports currently submitted to CDX, only in one
case is PKI used for electronic signature. The other cases involve
PIN-based electronic signatures or other non-PKI electronic signature
approaches.  As an example of the latter, this year we anticipate
implementing electronic signatures for an EPA reporting requirement by
having signatories use a password that is self-generated during CDX
registration in combination with certain items of information that are
unlikely to be available to anyone except the signatory.  This is a
``knowledge-based'' approach, which is being used extensively by
commercial software vendors supporting the United States Internal
Revenue Service (IRS) for electronic tax filings or ``e-filings', and is
being adopted by other agencies.  EPA expects that these non-PKI-based
approaches to signature will continue to dominate CDX implementations of
electronic reporting.  We currently intend to use PKI where such needs
as security or assuring very robust non- repudiation of signature make
this the most appropriate approach.” (Source:   HYPERLINK
"http://www.epa.gov/fedrgstr/EPA-GENERAL/2005/October/Day-13/g19601.htm"
 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-year PKI
licensing and digital certificate solutions:

Source A:	Entrust Inc.: “Rough order of magnitude” (ROM) cost
estimates provided 14 March 2007 to OSW by the Entrust Inc., a digital
identities and information security company which released the first
commercially available PKI in 1994 (http://www.entrust.com/pki).  The
Entrust data are based on scaling of actual case examples of
implementation of this eSignature technology at other government
agencies, heavily discounted in price relative to the potential large
size of eManifest users.  The sever price discounting apparently makes
this cost source the low-end of the two alternative sources (e.g., the
Entrust user license price quotes provided to OSW declined from $51/user
for 100 user quantity, to $30/user for 10,000 user quantity, to
$18.50/user for 250,000 user quantity per 2-year license period).  The
Entrust PKI approach to eSignature workflow routing and processing
between eManifest users and the CDX eManifest is based on internet Java
applets technology.

Source B:	EPA-OEI-OTOP: OSW (Richard LaShier, Bryan Groce, Mark Eads)
met with OEI-OTOP (David Schwartz, Charles Freeman, Cory Wagner) on 27
March 2007 to discuss the prior draft of this cost comparison, during
which OEI-OTOP provided a cost range of $70 to $100 per user “cert”
per 2-year license period for CDX PKI services.

Note:  The IYC and ARC cost ranges for Option 3 below are ordered
respective to the order of these two cost data sources (i.e., bottom-end
is Source A, and top-end is Source B), rather than representing
numerical “low-ends” and “high-ends”.  Furthermore, for Source A
OSW used the “heavy-discounted” cost estimate for the summary range
of each cost sub-item.

Initial Year Costs

Software & IT Services:

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

Source A: Represents installing the Entrust PKI infrastructure as a
component of the CDX-based eManifest system; the cost involve (a)
infrastructure implementation (i.e., architecture consulting & design,
implementation integration of PKI software, testing, post-implementation
consulting), and (b) eManifest integration (i.e., requirements
gathering, integration design of eManifest form, integration
development, testing, onsite implementation, post-implementation
consulting, project management).

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

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

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

If heavy-discounted price: [($18.50 per seat) x (119,300 to 260,300 user
employees) = $2.207 million to $4.816 million].  The per-seat cost
consists of three cost components (a) manage services for identity
credentials, (b) software enterprise license, and (c) 2-factor
authentication service.

If light-discounted price: [($251 per certificate per user) x (119,300
to 260,300 eManifest users) = $29.944 million to $65.335 million for
certificate cost].

Source B: $8.351 million to $26.030 million based on the OEI-OTOP price
quote [($70 to $100 per PKI “cert”) x (119,300 to 260,300 user
employees)].

Hardware:

EPA:	$0

Users:	$0.260 million to $0 million

Source A: PKI grid cards: $0.303 million to $0.260 million for plastic
wallet-sized grid cards, calculated as follows: [($2.54 per grid card) x
(119,300 to 260,300 user employees)].

Source B: $0 assumes grid cards not required.

Annually Recurring Costs

Software & IT Services:

EPA:	$0

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

$1.015 million/year to $11.974 million/year for subsequent annual
licenses for new employees, calculated as 16% of initial year cost to
account for 16% employee annual turnover rate, plus annual 30% of
initial year cost for average annual license renewal for PKI certificate
licenses assumed valid for 2-years (i.e., 46% of initial year cost):

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

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

Wireless ISP for trucks: $0.729 million/year for wireless ISP (internet
service provider) service calculated as follow: [($39.99/month per
5-truck user ISP account) x (12 months/year) x (7,600 trucks) / (5
trucks/ISP account)] to provide the necessary wireless connectivity of
truck PDAs to connect realtime for eSignature identity verification each
time an eManifest is electronically signed (source: $39.99 monthly
wireless ISP fee price example from Palm.Net's Executive Unlimited
monthly usage plan
http://www.smartcomputing.com/editorial/article.asp?article=articles/arc
hive/l0805/09l05/09l05.asp&guid=).

Hardware:

EPA:	$0

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

Source A: PKI grid card replacement: $0.079 million/year to $0.172
million/year for replacement of plastic grid cards, calculated as 26% of
the initial year cost to reflect 16% annual employee turnover rate plus
10% annual lost grid card and broken grid card average annual
replacement rate.

Source B: $0 assumes grid cards not required.

Appendices

Appendix A

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

$0.298 million/year to $4.490 million/year for eManifest user helpdesk
PIN/password reset services, assigned in this cost comparison as EPA
costs to the four PIN/password sub-options 1A, 1B, 1C, and 2B.  This
cost range is based on two alternative helpdesk approaches and four
alternative cost estimate calculations and cost data sources:

Furthermore, this cost range represents 20% to 50%, respectively, of the
$1.490 million/year to $8.980 million/year in full annual cost for those
four sub-options to provide eManifest helpdesk services to resolve
PIN/password reset problems plus other user problems concerning the
eManifest system, calculated as follows: [($0.298 million/year)/(20%) to
($4.490 million/year)/(50%)].

For the other three sub-options not based on PIN/passwords (i.e.,
sub-options 2A, 2C, and 3), the helpdesk cost is estimated at $1.192
million/year to $4.490 million/year, which is the difference between the
full helpdesk cost for the four PIN/password sub-options, and the 20% to
50% fraction of that cost for PIN/password reset: [($1.490 million/year
- $0.298 million/year) to ($8.980 million/year - $4.490 million/year)].
In other words, the incremental helpdesk cost (i..e., 20% to 50% cost
fraction) for PIN/password reset service is added to the four
appropriate sub-options of this cost comparison, but the baseline
helpdesk cost fraction (80% to 50%, respectively) for other helpdesk
services is not added to any sub-option of this cost comparison because
OSW simply assumes it is equal to each sub-option.

Approach #1:	User Self-Service Helpdesk Reset

$1.188 million/year to $2.593 million/year annual cost to EPA for
PIN/password reset if conducted within the eManifest architecture using
user self-service reset software.  This estimate is based on the
“P-Synch” password management service costing $9.96 per user per
year provided by M-Tech Identity Management Solutions Inc. (  HYPERLINK
"http://www.p-synch.com/savings/example.html"
http://www.p-synch.com/savings/example.html ), calculated as follows:
[(119,300 to 260,300 employee eManifest users) x ($9.96 per user per
year)]).

The P-Synch automated password reset service allows locked out users to
reset their own passwords, effectively addressing the problem of
forgotten passwords.  P-Synch creates a secure and efficient process for
users to reset their passwords, thus minimizing helpdesk call volumes
for resetting passwords.  Once authenticated, users can reset their own
passwords without calling the helpdesk.  Self-service password reset is
available from (a) a web browser using the user's own computer or that
of a neighbor, (b) the login prompt of the user's own workstation, or
(c) a telephone from which the user dials the IVR (interactive voice
response) system that provides password reset.

Approach #2:	EPA Contractor-Staffed CDX Helpdesk Reset

$0.298 million/year to $4.490 million/year for the 20% to 50% fraction,
respectively, of helpdesk annual cost which reportedly involve user
requests to IT helpdesks for user PIN/password resets (source: Gartner
Group study results cited at   HYPERLINK
"http://mandylionlabs.com/PRCCalc/PRCCalc.htm"
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:

Source A:	$0.452 million/year to $2.464 million/year, calculated as
follows: [(119,300 to 260,300 employee users) x ($18.93/year per user
account management) x (20% to 50% helpdesk calls for password reset
assistance)].  This estimate is based on OEI-OTOP’s FY2007 Working
Capital Fund Rate of “$18.93/year per use for “Application Hosting:
Account/User Management: U3”.  Specific functions associated with this
service include (a) managing user accounts on EPA’s web servers, and
(b) maintaining user account data within EPA’s Time Sharing Services
Management System (TSSMS).  The costs associated with this service
include overhead for EPA management, utilities, and space rental.
OEI-OTOP’s unit cost data from:   HYPERLINK
"http://cfint.rtpnc.epa.gov/otop/currentfyservices/u3/u3.cfm"
http://cfint.rtpnc.epa.gov/otop/currentfyservices/u3/u3.cfm .

Source B:	$0.298 million/year to $1.627 million/year, based on
extrapolating EPA’s total CDX helpdesk budget for FY2007 of about $0.5
million/year servicing about 40,000 CDX users, to the projected 119,300
to 260,300 eManifest users at 75% implementation level and at 20% to 50%
for reset quest calls, calculated as follows: [($0.5 million/year) x
(119,300 to 260,300 eManifest users) / (40,000 FY2007 CDX users) x (20%
to 50% helpdesk calls are reset requests)].  OEI’s $0.5 million/year
FY2007 budget for CDX helpdesk services consists of a $3,000/year to
$300,000/year range in CDX helpdesk call center services support for 15
EPA CDX electronic reporting programs (source: Mark Eads phone
conversation on 16 March 2007 with OEI Call Center contact person Jose
Gonzalez , and 27 March 2007 meeting with Charles Freeman of OEI-OTOP.
Information about OEI’s CDX call center services is available at:
HYPERLINK "http://cfint.rtpnc.epa.gov/otop/resources/callcenter.cfm"
http://cfint.rtpnc.epa.gov/otop/resources/callcenter.cfm ).

Source C:	$2.058 million/year to $4.490 million/year, calculated using
the (a) $5.75 unit cost per user helpdesk call and (b) an average of
three password reset helpdesk calls per year per user assumptions from
M-Tech Identity Management Solutions at
http://www.p-synch.com/savings/example.html: [(119,300 to 260,300
employee users) x (3 password reset helpdesk calls per year per user) x
($5.75 helpdesk cost per call)].

Appendix B

OSW Estimated Counts of Trucks, Industrial Facilities & Industrial
Employees

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

Prepared by:

Mark Eads, Economist<PHONE_NUMBER>)

EPA Office of Solid Waste (OSW)

14 March 2007

Disclosure of EPA External Peer Review of this Appendix

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

On 15 Nov 2006, Mark Eads (OSW) shared via email the 15 Nov 2006 first
draft of this Appendix with the Environmental Technology Council (
HYPERLINK "http://www.etc.org"  http://www.etc.org ), requesting an
informal review by Scott Slesinger, ETC Vice President for Governmental
Affairs, of the data and calculations in the first draft.  ETC is an
industry membership association of hazardous waste management companies,
and has been a major stakeholder in OSW’s eManifest rulemaking project
since OSW’s 2001 eManifest proposed rule (see Section 1.3 at:
HYPERLINK
"http://www.epa.gov/epaoswer/hazwaste/gener/manifest/present/proceed.pdf
"
http://www.epa.gov/epaoswer/hazwaste/gener/manifest/present/proceed.pdf
).  ETC supplied OSW by phone call 17 Nov 2006 and by email 22 Nov 2006,
comments about data assumptions from three of its member companies
(Clean Harbors, Safety-Kleen, Veolia) concerning average count of
manifesting employees per TSDF and count of eSignature devices needed
per manifesting truck, which have been incorporated into the numerical
uncertainty ranges in this document.

On 28 Feb 2007, for purpose of requesting a rough cost estimate for
deploying a PKI electronic signature application for eManifest, Richard
Lashier (OSW) shared via email the 2nd draft of this Appendix to Andrew
Lehfeldt of Entrust Inc of McLean VA, so that this IT vendor could
formulate a properly scaled cost estimate.

I.	RCRA Manifesting Trucks

IA.  Count of Trucks Potentially Involved in eManifesting

7,500 trucks  (private + commercial) registered or licensed as of 1997
in the US, reportedly transport EPA-manifested hazardous wastes as
"primary products carried" (PPC), which represents 1.9% of the 403,300
total 1997 US trucks which transport DOT-placarded hazardous materials.
These 7,500 EPA-manifested hazardous waste trucks traveled a total 465.8
million miles in 1997, which is an average of 62,200 miles per-year
per-truck (source: US Census Bureau "1997 Vehicle Inventory & Use
Survey", Table 2a, pages 11 and 23 at   HYPERLINK
"http://www.census.gov/prod/ec97/97tv-us.pdf_"
http://www.census.gov/prod/ec97/97tv-us.pdf .  Note that the newer 2002
VIUS report dropped the PPC data details (  HYPERLINK
"http://www.census.gov/prod/ec02/ec02tv-us.pdf_"
http://www.census.gov/prod/ec02/ec02tv-us.pdf ), thus the 1997 VIUS
report is the most recent data on RCRA-manifesting trucks.

If project (extrapolate) the 1992-1997 growth trend of 20 additional
trucks every year (i.e., 7,400 trucks in 1992 compared to 7,500 in 1997)
we can estimate 7,800 EPA-manifesting hazardous waste trucks for 2010
(i.e., (2010-1997) x 20/year) + 7,500 = 7,800 (rounded to nearest 100).

This estimated 2010 total of 7,760 hazardous waste manifesting trucks
represents an average of 22 RCRA-manifesting trucks per transporter
TSDF, if averaged over 358 establishments classified in the 2002 Census
Bureau NAICS 562211 “hazardous waste transportation service”
establishments under NAICS 38430 product line code “hazardous waste
transportation services, excluding collection and disposal” (source:
US Census Bureau "2002 Waste Management & Remediation Services: NAICS
562", Table 3 page 3, at:   HYPERLINK
"http://www.census.gov/prod/ec02/ec0256i09.pdf_"
http://www.census.gov/prod/ec02/ec0256i09.pdf ).

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

2,200 trucks (1997) transport non-EPA manifest hazardous wastes as
"primary product carried" (PPC); updated using the same 1997 to 2010
extrapolation factor of 1.035 (i.e., 7760/7500) from above yields 2,300
non-EPA hazardous waste trucks (2010).

6,200 trucks (1997) transport industrial wastewaters as PPC; updated
using the same 1997 to 2010 extrapolation factor of 1.035 from above
yields 6,400 industrial wastewater trucks (2010).

49,300 trucks (1997) transport recyclable materials as PPC; updated
using the same 1997 to 2010 extrapolation factor of 1.035 from above
yields 51,000 recyclable materials trucks (2010).

166,800 trucks (1997) transport scrap, refuse, or garbage as PPC;
updated using the same 1997 to 2010 extrapolation factor of 1.035 from
above yields 172,600 scrap/garbage trucks (2010).

Source: US Census Bureau "1997 Vehicle Inventory & Use Survey", Table
2a, pages 11 and 23 at   HYPERLINK
"http://www.census.gov/prod/ec97/97tv-us.pdf"
http://www.census.gov/prod/ec97/97tv-us.pdf .  Note that the newer 2002
VIUS report dropped the PPC data details
(http://www.census.gov/prod/ec02/ec02tv-us.pdf), thus the 1997 VIUS
report is the most recent data on these four other classes of
waste-related trucks.

IC.  Total Count of Potential eManifesting Trucks

Assume that the RCRA-regulated community will desire to process both
Federal RCRA and state government regulated hazardous wastes using
EPA’s eManifest system, results in an estimated 2007 total 10,100
manifesting trucks (i.e., 7,800 RCRA manifesting trucks + 2,300 non-EPA
manifesting trucks), assuming 100% of hazardous waste is eManifested.

II.	RCRA Manifesting Facilities & Employees

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

488 NAICS 562112 hazardous waste collection & removal service
establishments with 10,196 employees (2002), which is an average of 21
employees per TSDF establishment (source: US Census Bureau "2002 Waste
Management & Remediation Services: NAICS 562", Table 1 page 1 and Table
3 page 3 at:   HYPERLINK
"http://www.census.gov/prod/ec02/ec0256i09.pdf_"
http://www.census.gov/prod/ec02/ec0256i09.pdf )

696 non-duplicative count for NAICS 562211 hazardous waste treatment &
establishments with 21,566 employees (2002), which is an average of 31
employees per establishment (source: US Census Bureau "2002 Waste
Management & Remediation Services: NAICS 562", Table 1 page 1 and Table
3 page 3 at:   HYPERLINK
"http://www.census.gov/prod/ec02/ec0256i09.pdf_"
http://www.census.gov/prod/ec02/ec0256i09.pdf ).  These establishments
consist of the following primary product lines codes (PLCs) within NAICS
code 562:

NAICS PLC 38471:	225 hazardous waste transfer service establishments

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

NAICS PLC 38440 + PLC 38450:	324 hazardous waste disposal service
establishments (253 by confinement + 71 non-confinement methods,
respectively)

NAICS PLC 38480:	664 hazardous waste treatment service establishments

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

Estimated total count of TSDFs involved in hazardous waste manifesting:

As of 2002, 1,184 total TSDFs (i.e., 488+696 from above) with 31,762
total employees (i.e., 10,196+21,566 from above).  In comparison, 557
hazardous waste “receiver” TSDFs reported in the 2005 RCRA Biennial
Report (Exhibit 3.5 at:   HYPERLINK
"http://www.epa.gov/epaoswer/hazwaste/data/br05/national05.pdf"
http://www.epa.gov/epaoswer/hazwaste/data/br05/national05.pdf ); this
analysis uses the larger 1,184 TSDF for the purpose of including state
hazardous waste receivers, as well as RCRA hazardous waste receivers.

Estimated total count of TSDF employees involved in hazardous waste
manifesting (based on upper- and lower-bound TSDF counts above,
respectively):

Assume average of 6 employees per-TSDF involved in hazardous waste
manifesting as part of their job duties, provides an estimate of 7,104
TSDF employees (i.e., 6 x 1,184 total TSDFs), which represents 22% of
all TSDF employees (i.e., 7,104/31,762).  Average of 6 employees is the
midpoint of the 4 to 8 range which ETC provided OSW (Mark Eads) in its
peer review comments on OSW’s Nov 2006 initial draft of this estimated
counts of facilities and employees potentially using eManifest.

Turnover estimate:	Assume 16% employee annual turn-over rate, which when
multiplied by the estimation range is 1,137 new-hire TSDF employees per
year (i.e., 16% x 7,104).

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

IIB.  Count of Potential eManifesting LQG Facilities & Employees

16,082 LQG shippers as of 2005 (source: Exhibit 3.1 at:
http://www.epa.gov/epaoswer/hazwaste/data/br05/national05.pdf); based on
the NAICS 325 chemical mfg industry group which is the largest RCRA
hazardous waste LQG industry (i.e., 63% of 2005 national generation
tonnage), there are an average 63 employees per LQG, which provides an
estimate of 1,013,166 LQG employees (source: 852,297 employees in 13,476
establishments for year 2002 NAICS 325:   HYPERLINK
"http://www.census.gov/econ/census02/data/us/US000_31.HTM_"
http://www.census.gov/econ/census02/data/us/US000_31.HTM ).

Estimate of LQG shipper employees involved in hazardous waste
manifesting:

Upper-bound estimate:	Assume 4 of 63 employees per-LQG require eManifest
access as part of their job duties which is 64,328 LQG employees (i.e.,
4 x 16,082 LQGs).

Lower-bound estimate:	Assume 1 of 63 employees per-LQG require eManifest
access as part of their job duties which is 16,082 LQG employees (i.e.,
1 x 16,082 LQGs).

Turnover estimate:	Assume 16% employee annual turn-over rate, which
applied to the estimation range is 2,573 to 10,292 new-hire LQG
employees per year (i.e., 16% x 16,082 to 16% x 64,328).

Including 16% turnover, total LQG employees counts are:

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

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

IIC.  Count of Potential eManifesting SQG Facilities & Employees

The most recent count of SQGs is for 1999 based on an EPA contractor
analysis of EPA's RCRIS hazardous waste generator registry data (now
called RCRAInfo), which enumerated 113,879 operating SQGs; based on the
NAICS 811 repair & maintenance services industry group, which is one of
the largest SQG industries, there are an average 6 employees per SQG,
which provides an estimate of 683,274 total SQG employees (source:
1,285,371 employees in 231,043 establishments for year 2002 NAICS 811:
HYPERLINK "http://www.census.gov/econ/census02/data/us/US000_81.HTM_"
http://www.census.gov/econ/census02/data/us/US000_81.HTM ).

Estimate of SQG employees involved in hazardous waste manifesting:

Upper-bound estimate:	Assume 2 of 6 employees per-SQG require eManifest
access as part of their job duties which is 227,758 SQG employees (i.e.,
2 x 113,879 SQGs).

Lower-bound estimate:	Assume only 1 of 6 employees per-SQG require
eManifest access as part of their job duties which is 113,879 SQG
employees (i.e., 1 x 113,879 SQGs).

Turnover estimate:	Assume 16% employee annual turn-over rate, which
applied to the estimation range is 18,221 to 36,441 new-hire SQG
employees per-year (i.e., 16% x 113,879 to 16% x 227,758).

Including 16% turnover, total SQG employees counts are:

Upper-bound:	264,000 SQG employees (i.e., 227,758 + 36,441)

Lower-bound:	132,000 SQG employees (i.e., 113,879 + 18,221)

IID.  Total Count of Potential eManifesting Industrial Facilities &
Employees (Transporters/TSDFs + LQGs + SQGs):

Total industrial facilities potentially involved in using eManifest:
131,000 facilities

Total industrial employees pontentially involved in using eManifest
(including 16% employee annual turnover):

Upper-bound estimate:						347,000 employees

Lower-bound estimate:						159,000 employees

III.	E-Manifest User Phase-In Scenario

Because OSW’s eManifest system may be voluntary, not mandatory (i.e.,
industries may elect to continue using the current RCRA paper manifest
form 8700-22), OSW expects less than 100% of future annual paper
manifests will be eliminated by paperless electronic processing using
eManifest, particularly during the first few years after which the
eManifest IT system begins operation.  For purpose of scenario
illustration, the table below presents a 5-year phase-in scenario of the
number of RCRA paper manifests, trucks, industrial facilities, and
industrial employees which may become involved in using eManifest for
both Federal- and state-regulated hazardous wastes (i.e., relative to
the current baseline of 5.1 million Federal + state government hazardous
waste paper manifests per year).  The scenario uses the baseline counts
developed in the prior sections of this Appendix.

“Scenarios are not predictions.  They are stories of how the future
might unfold — plausible stories that reflect information about trends
and potential future developments.  [Scenarios may be] designed to span
a range of potential future conditions.  The actual future is not likely
to match any one of [alternative] depictions, but it will probably fall
somewhere within the range of possibilities that the scenarios
explore.”  Source: http://www.epa.gov/cfo/futures/env_scen.htm.

The phase-in scenario truncates after five years at a 75% user phase-in
as an expected upper-bound assumption.  Although OSW’s economic
analysis contractor in 2000 (ICF Inc) for the May 2001 eManifest
proposed rule initially formulated a cautiously low 25% to 50% adoption
rate range assumption (see page 14 at:
http://www.epa.gov/epaoswer/hazwaste/gener/manifest/pdf/ebd.pdf),
OSW’s 2002 benefit-cost analysis contractor (LMI, Inc) formulated a
75% adoption assumption after questioning a small sample of LQGs and
TSDFs about likely participation in eManifest.

The 5-year phase-in scenario further assumes a direct numerical
correlation (i.e., association) between the phase-in percentages based
on an annual manifest counts, and the counts of trucks, facilities, and
employees likely to become users of eManifest.  This simple direct
correlation assumption probably results in an over-estimate of the
number of facilities which may become eManifest users at each phase-in
year for the associated percentage of manifests assumed processed by
eManifest, because similar to the 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 majority of RCRA
hazardous waste tonnages and associated paper manifests annually.  For
example, based on OSW’s 2005 RCRA hazardous waste “Biennial
Report”, the top-10 of the 16,082 LQG waste shippers accounted for 18%
of the total 7.7 million tons of shipper quantity, and the top-10 of the
557  TSDF waste receivers accounted for 36% of the total 8.5 million
tons of receiver quantity.

OSW Estimates of Number of RCRA Manifests, Trucks, Industrial Facilities
& Industrial Employees

Which May Become eManifest Users

5-Year User Phase-In Scenario 2010-2014

A	B	C	D	E	F	G	H	I (F+G+H)	J	K	L	M (J+K+L)

Year	eManifest User

Phase-In Scenario*	Count of  RCRA Electronic

Manifests (millions)	Count of Truck Vehicles	Count of Industrial
Facilities	Count of Industrial Employees

LQG shippers	SQG shippers	TSDF receivers	Total Facilities

LQG+SQG+TSDF	LQG

employees	SQG

employees	TSDF

employees	Total Employees

LQG+SQG+TSDF

1	2010	10%	0.5	1,000	1,600	11,400	120	13,100	1,860 to 7,460	13,210 to
26,420	800	15,900 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 Phase-in Assumptions (Column C):

Year 1: Represents eManifest system start-up testing mode based on a
small number (e.g., 3 to 10) facilities participating in the testing.

Year 2: Represents additional 15% participation expectation over 1st
year 10%, based on approximate average between actual environmental
electronic reporting results of 10% for EPA’s eTRI program rate after
its 1st year (2002), and 34% after about 2-years for State of
Michigan’s Clean Water Act Discharge Monitoring Reports (DMRs); [i.e.,
(10% + 34%)/2 = 22% (say 25%)].

Year 3: Represents approximate hazardous waste annual tonnage
transportation US marketshare of the top-3 of the 10 to 15 commercial
TSDF members of the Environmental Technology Council (  HYPERLINK
"http://www.etc.org"  http://www.etc.org ); assumption is that the top-3
TSDFs will use eManifest by the 3rd year.

Year 4: Represents approximate hazardous waste annual tonnage
transportation US marketshare of the top-10 commercial TSDF members of
the ETC.

Year 5: In 2002 OSW’s eManifest benefit-cost analysis (BCA) contractor
Logistics Management Institute (LMI) formulated this as a reasonable
upper-bound expectation in the Oct 2002 BCA, based on LMI interviews
with a small (less than 10) sample of LQGs and TSDFs.

** 5.1 million RCRA Federal + state government hazardous waste paper
manifests per year baseline (Column D), based on a survey data report
provided 06 Nov 2002 to OSW by the Environmental Technology Council
HYPERLINK "http://www.etc.org"  http://www.etc.org  (see document ID nr.
EPA-HQ-RCRA-2001-0032-0095 at   HYPERLINK "http://www.regulations.gov"
http://www.regulations.gov )..

 OMB requires Federal agencies to apply discount rates for economic
impact analysis, cost-effectiveness analysis, and cost-benefit analysis
of Federal regulatory actions, capital investment planning, and for
lease/purchase of services and equipment; two OMB guidances are:

OMB’s Sept 2003 Circular A-4 “Regulatory Analysis” requires
agencies such as the EPA to apply both alternative 3% and 7% discount
rates to regulatory impact analyses (p.33 at:
http://www.whitehouse.gov/omb/circulars/a004/a-4.pdf).

OMB’s Jan 2007 updated Appendix C “Discount Rates For
Cost-Effectiveness, Lease Purchase, And Related Analyses” to OMB’s
Oct 1992 Circular A-94 “Guidelines and Discount Rates for Benefit-Cost
Analysis of Federal Programs” requires agencies to apply real discount
rates (adjusted to remove price inflation) ranging between 2.5% (for
3-year program periods) to 3.0% (for 30-year program periods) to
constant dollar streams for lease/purchases
(http://www.whitehouse.gov/omb/circulars/a094/a94_appx-c.html).

 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 (  HYPERLINK
"http://cfint.rtpnc.epa.gov/otop//currentfyservices/index.cfm?fuseaction
=services.showfyrates&fy=2007"
http://cfint.rtpnc.epa.gov/otop//currentfyservices/index.cfm?fuseaction=
services.showfyrates&fy=2007 ), is $0.457 million/year to $0.997
million/year:[ ($3.83 per user per year for “Webforms DF” service )
x (119,300 to 260,300 eManifest users at 75% implementation rate)].

 EPA’s CDX user basic registration requirements are: (a) supply
information to identify themselves, their company, and the EPA documents
they wish to submit electronically, (b) verify and/or correct
registration information, and (c) access their CDX web accounts through
a secure website, and agree to the terms and conditions of using the
site, which include safeguarding their self-generated password, before
using web forms or uploading files to submit electronic documents or
data to EPA.  “These are the minimum steps for gaining access to CDX
at this time” (source: EPA’s 13 Oct 2005 CROMERR final rule, p.
59862).

 This 4% estimate is based on two information sources: (a) According to
the Waste News magazine “2005 Hauling & Disposal Ranking” (17 July
2006 issue; pages 15 to 20;   HYPERLINK
"http://www.wastenews.com/rankings/haulers.html"
http://www.wastenews.com/rankings/haulers.html ), based on 2005 business
revenues from hauling, disposal and transfer of all types of
residential, commercial and industrial waste (excluding revenue from
incineration and sale of recyclables), Safety-Kleen Systems of Plano, TX
is ranked 4th with 2,227 trucks involved in solid waste, liquid waste,
and hazardous waste.  This ranking does not provide a breakout of the
2,227 trucks by waste class.  However, from peer review comment made on
OSW’s Nov 2006 1st draft of this cost comparison, Veolia Environmental
Services Corp commented it operated 350 hazardous waste trucks, which is
about 12% of the 3,000 total hauling trucks reported for Veolia’s 5th
place ranking in the Waste News 2005 Hauling Ranking.  Applying this 12%
to the 2,227 Safety-Kleen total truck count produces an estimate of 260
hazardous waste trucks.  At the 75% eManifest implementation scenario
involving 7,600 total hazardous waste trucks, the estimated 260
Safety-Kleen trucks represents 3.4%.  (b) This estimate comports with
the Safety-Kleen “fleet of more than 2,000 trucks” of which 300 are
hazardous waste tanker trucks as reported for in the Bulk Transporter
magazine report “Safety-Kleen Customers Receive Guaranteed Waste
Handling Service”, 01 April 1998 at:   HYPERLINK
"http://bulktransporter.com/mag/transportation_safetykleen_customers_rec
eive"
http://bulktransporter.com/mag/transportation_safetykleen_customers_rece
ive  (i.e., 300/7,600 = 3.9%).

 $320 cost for mobile printer based on price for Infinite Peripherals
PP-55 portable printer at:
http://www.yourmobiledesk.com/products/proddetail.cfm?prodID=5052&catID=
na&subcatID=na&sscatID=na&mfrID=na.  [($320 per mobile printer) x (7,600
trucks) x (120% truck backup & multiple employee per truck purchase
multiplier) + ((7,600 trucks) x (($15 per paper roll) x (4 rolls/year)))
= $3.374 million initial year cost], which is equivalent to $0.675
million/year divided over a 5-year period.  Added to $0.337 million
(i.e., $3.374 million x 10%) in annual cost for 10% annual replacement
rate for lost/ stolen/ broken PDA portable printers provides a 5-year
average annualized cost of $1.012 million/year not included in this cost
comparison for any eSignature option/sub-option.

 Signature holder agreements (SHAs): EPA’s 13 Oct 2005 CROMERR final
rule (page 59863) requires that all persons reporting electronically to
CDX (a) register with CDX and (b) print out a SHA from the CDX
registration website, sign the SHA, and mail it to EPA’s CDX.
Furthermore, the CROMERR final rule (page 59863) indicates that “CDX
will continue this [SHA] approach for reports where electronic
signatures are required, although EPA is exploring the use of an
entirely paperless signature agreement process for at least some of
these cases.”  For purpose of this eSignature cost comparison, OSW
assumes that eManifest users will only be required to register with CDX
online via the eManifest website, without having to print, sign, and
mail a SHA to EPA (CDX) under the other eSignature options/sub-options.
Furthermore, OSW assumes for purpose of this cost comparison that
EPA’s cost for establishing and maintaining eManifest user CDX
registration accounts established via online registration is equal
across all eSignature options/sub-options (the introduction to this cost
comparison provides an estimate of this eManifest user account
maintenance cost to EPA).  The CDX user basic registration requirements
are: (a) supply information to identify themselves, their company, and
the EPA documents they wish to submit electronically, (b) verify and/or
correct registration information, and (c) access their CDX web accounts
through a secure website, and agree to the terms and conditions of using
the site, which include safeguarding their self-generated password,
before using web forms or uploading files to submit electronic documents
or data to EPA.  “These are the minimum steps for gaining access to
CDX at this time” (source: EPA’s 13 Oct 2005 CROMERR final rule, p.
59862).

 Mean industrial employee loaded wage rate of $32.27 per hour applied in
this cost analysis, represents an average of the 2005 mean wage rates
for all occupational categories in two NAICS industrial groupings: (a)
NAICS 31, 32, 33 manufacturing industry sector ($18.87/hour;
http://www.bls.gov/oes/current/naics2_31-33.htm) which is the single
largest shipper of RCRA hazardous wastes, and (b) NAICS 562 waste
management industry group ($18.56/hour;
http://www.bls.gov/oes/current/naics3_562000.htm) which represents the
single largest receiver of RCRA hazardous wastes; both wage rates were
loaded with (a) 30% US national average private industry employer cost
for employee benefits (  HYPERLINK
"http://www.bls.gov/news.release/pdf/ecec.pdf"
http://www.bls.gov/news.release/pdf/ecec.pdf ), and (b) 12% business
labor overhead cost factor as prescribed by Figure C1 “Table of
Standard A-76 Costing Factors” on page C-4 of OMB Circular A-76.  OSW
calculated the average wage rate for these two industry groups, with
these two cost factors applied, as follows: [(($18.87/hour +
$18.56/hour)/2) / (100% - (30%+12%)) = $32.27/hour.]

 12% annual new establishment start-up rate is based on a December 1996
US Census Bureau study of 6.08 million operating business establishments
in 1992, in eight US economic sectors (i.e., 1. mining, 2. construction,
3. manufacturing, 4. transportation & public utilities, 5. wholesale, 6.
retail, 7. finance, insurance & real estate, and 8. services); the study
found a 12% rate of new establishment start-ups, and an 11% rate of
existing establishment closures for the study year 1992 (see page 9 at:
http://www.ces.census.gov/index.php/ces/1.00/cespapers?down_key=100249).

 WSDL: Short for “Web Services Description Language”, an
XML-formatted language used to describe a web service's capabilities as
collections of communication endpoints capable of exchanging messages.
WSDL is an integral part of UDDI, an XML-based worldwide business
registry.  WSDL is the language that UDDI uses. WSDL was developed
jointly by Microsoft and IBM (source:
http://www.webopedia.com/TERM/W/WSDL.html.

 Another two-factor OTP authentication technology involves USB tokens.
This cost comparison does not estimate the cost for this third example
technology for Suboption 1C (in addition to the Entrust IdentityGuard
mini token and the RSASecurID token products) because the $13 average
annualized user cost falls within the $4 to $32 average annual user cost
of the other two products.  Source: $30 average purchase cost for UBS
token purchase based on $25 to $43 price range for a sample of eight
products (Aladdin, G&D, Gem E-Seal, Oberthur companies) priced March
2007 at   HYPERLINK "http://www.usasmartcard.com"
http://www.usasmartcard.com , and $35 average purchase cost for USB
token software based on $30 to $39 price range for a sample of four
products (Dekart Logon, Mipko Software Double Password 1.21, Proteg 3.1)
priced March 2007 at http://www.surfpack.com/software/usbtoken1.

 Peripherals: A peripheral is a piece of computer hardware that is added
to a host computer in order to expand its abilities. More specifically,
the term is used to describe those devices that are optional in nature,
as opposed to hardware that is either demanded or always required in
principle.  The term also tends to be applied to devices that are hooked
up externally, typically through some form of computer bus like USB.
Typical examples include joysticks, printers and scanners. Devices such
as monitors and disk drives are not considered peripherals when they are
not truly optional (source: http://en.wikipedia.org/wiki/Peripheral).

 Examples of mobile “tablet PCs” for trucking are   HYPERLINK
"http://www.xploretech.com/public/iX104C2_July2006.pdf"
http://www.xploretech.com/public/iX104C2_July2006.pdf  and   HYPERLINK
"http://www.dataltd.com/vehiclemountprod.html"
http://www.dataltd.com/vehiclemountprod.html  and
http://www.myruggedtabletpc.com.

 120%  multiplier applied to truck-hardware costs in this cost
comparison is an OSW estimate for additional hardware needed to reflect
the reality that some companies have more field personnel than trucks:
One peer reviewer of OSW’s 15 Nov 2006 first draft of the Appendix to
this cost comparison – affiliated with a commercial hazardous waste
transport company operating a fleet of 350 hazardous waste trucks --
commented “It appears that EPA is assuming that there’s a direct 1
to 1 correlation of the number of trucks to the number of e-signature
devices needed.  From a field perspective, we’d likely need more than
one unit [i.e., electronic signature device] per commercial vehicle as
we have more field service personnel than commercial trucks and some
jobs may require more than 1 device be available.” (source: Tom Baker,
Director, Environment & Transportation, Veolia ES Technical Solutions
LLC, Flanders NJ).  Rather than apply a multiplier of 2 (i.e., 200%) to
this cost item, OSW applied a smaller 1.2 multiplier (i.e., 120%) to
reflect the fact that some trucks only have one assigned employee.

 The X.509 digital certificate (Version 1) was first issued in 1988 as a
part of the ITU X.500 Directory Services standard.  When X.509 was
revised in 1993, two more fields were added resulting in the Version 2
format.  These two additional fields support directory access control.
X.509 Version 3 defines the format for certificate extensions used to
store additional information regarding the certificate holder and to
define certificate usage. (source:
http://www.webopedia.com/TERM/X/X_509.html)

 Applets: Technical word originating in 1993, an “applet” is a
software component that runs in the context of another program, for
example a web browser.  An applet usually performs a very narrow
function that has no independent use.  An applet is written in a
language that is different from the scripting or HTML language which
invokes it.  Unlike a program, an applet cannot run independently; an
applet usually features display and graphics and often interacts with
the human user.  (Source: http://en.wikipedia.org/wiki/Applet).

 Seat: A technical word used in the IT field usually as “per seat
license”, which is a software license based on the number of users who
have access to the software. For example, a 100-user license based on
users means that up to 100 specifically named users (i.e., 100
“seats”) have access to the program.  Per seat licensing is
administered by providing user-level security to the directory
containing the program.  In contrast, “concurrent use license” is a
software license that is based on the number of simultaneous users
accessing the program.  It typically deals with software running in the
server where users connect via the network.  For example, in a five-user
concurrent use license, after five users are logged on to the program,
the sixth user is prohibited.  When any one of the first five log off,
the next person can log on (source:
http://www.techweb.com/encyclopedia/defineterm.jhtml?term=perseatlicense
).

 Coincidentally, EPA’s 13 Oct 2005 CROMERR final rule (p.59874)
assumes an average of 6 employees per facility in large companies that
would become registered CDX users for environmental reporting to EPA:
http://www.epa.gov/fedrgstr/EPA-GENERAL/2005/October/Day-13/g19601.htm

 16% manufacturing industry employee annual turn-over rate (i.e., total
job separation rate) from US Dept of Labor Bureau of Labor Statistics
“Job Openings and Labor Turnover Survey” (JOLTS) website:
HYPERLINK "http://www.bls.gov/jlt/"  http://www.bls.gov/jlt/ .  16% is
based on numerical rounding the 15.9% manufacturing “total
separation” rate for Sept 2005 to Aug 2006 in “Table 3. Total
separations levels(1) and rates(2) by industry and region, seasonally
adjusted” at: http://www.bls.gov/news.release/jolts.t03.htm

 NAICS 325 chemical manufacturing industry group reportedly generated
about 23.9 million of the 37.9 million tons (i.e., 63%) national total
RCRA hazardous waste generated in 2005; source: Exhibit 1.9 at:
http://www.epa.gov/epaoswer/hazwaste/data/br05/national05.pdf

 For each of OSW’s RCRA hazardous waste national “Biennial Report”
data years (i.e., 1991, 1993, 1995, 1997; 1999, 2001, 2003, 2005;
HYPERLINK
"http://www.epa.gov/epaoswer/hazwaste/data/biennialreport/index.htm"
http://www.epa.gov/epaoswer/hazwaste/data/biennialreport/index.htm ),
the LQG and TSDF data show a large degree of skewness in the tonnages of
annual RCRA hazardous wastes reported as generated, shipped, received,
and managed by LQGs and TSDFs.  For example, in 2005 the most recent
national Biennial Report data year available, the top-5 and top-10
facility counts of LQG shippers and TSDF receivers are (source: EPA 2005
RCRA Hazardous Waste National Analysis Biennial Report, Exhibits 3.3,
3.4, 3.7, 3.8 at:
http://www.epa.gov/epaoswer/hazwaste/data/br05/national05.pdf):

Large-Size Skewness of Hazardous Waste Shippers:				Large-Size Skewness
of Hazardous Waste Receivers:

Top-5 LQG shippers:		11%  (0.869 million tons in 2005)		Top-5 TSDF
receivers:		26%  (2.244 million tons in 2005)

Top-10 LQG shippers:		18% (1.367 million tons in 2005)		Top-10 TSDF
receivers:		36% (3.097 million tons in 2005)

16,082 total LQG shippers:	100% (7.686 million tons in 2005)		557 total
TSDF receivers:		100% (8.546 million tons in 2005)

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