This RIA relies on the methodology employed throughout EPA's Hazardous Waste Generator proposed rule Regulatory Impact Analysis (RIA) to estimate hazardous waste tonnage shipped by SQGs and CESQGs. However, this RIA only estimates waste tonnage shipped on a national basis, rather than a state-by-state basis. Correspondingly, this Appendix applies the methodology from the Hazardous Waste Generator proposed rule RIA to estimate state-by-state and total hazardous waste tonnage shipped by SQGs and CESQGs on an annual basis.

A.1 Small Quantity Generators

The Hazardous Waste Generator proposed rule RIA collected data on the number of SQGs and tons of hazardous waste produced by SQGs for Maine, Washington, and other states which had sufficient SQG data in the 2011 RCRA Biennial Report. Exhibit 2-9 from the Hazardous Waste Generator proposed rule RIA is reproduced below as Exhibit A-1.

                                 Exhibit A-1
                  SQG Hazardous Waste Generation Quantities
                                     Item
                                      A
                                      B
                                      C
                                      D

                                    State
                                     SQG
Facilities
Hazardous Waste Generated (Tons)
Tons per Facility
                                      1
2011 RCRA Biennial Report data (excluding ME and WA)[a]
                                                                         1,051
                                                                         3,270
                                                                           3.1
                                      2
Maine (data from Maine DEP)
                                                                           317
                                                                           461
                                                                           1.5
                                      3
Washington (data from Washington DOE)
                                                                           559
                                                                         1,183
                                                                           2.1
                                      4
                                                                         Total
                                                                         1,927
                                                                         4,914
                                                                           2.6
                                                                (Median = 1.5)
Source: 2015 Hazardous Waste Generator Standards proposed rule RIA, Exhibit 2-9. Available
at: http://www.regulations.gov/#!home. Exhibit excludes Column E regarding facility-level waste streams as it is not relevant to the present discussion.
[a] Data based on analysis of 2011 RCRA Biennial Report database (not National Summary Report). These data exclude facilities that are reported to be SQGs, but exceed the RCRA hazardous waste generation threshold for SQGs. Maine and Washington data were also excluded to avoid double-counting.

This RIA assumes that per-state hazardous waste generation from SQGs scales linearly with the number of SQGs in a state; the states with the most SQGs are therefore estimated to generate the most hazardous waste. This RIA further assumes that, consistent with Exhibit 2-7, 77 percent of all SQGs ship their hazardous waste off-site, and that ten percent of all SQGs (including those shipping off-site) are doing so for reclamation and recovery and are thus covered by bona-fide reclamation agreements (and are thus exempt from manifesting requirements). This RIA estimates the volume of hazardous waste shipped off-site by SQGs subject to manifest requirements as simply the number of manifesting SQGs per Exhibit 2-7 multiplied by 2.6, the average number of tons generated by an SQG per Exhibit A-1. The results are shown in Exhibit A-2 below.

                                     Exhibit A-2
                 Estimated Hazardous Waste Tonnage from Manifesting SQGs, by State

                                      Item
                                      A
                                      B
                                      C
                                      D

Item
                                      A
                                      B
                                      C
                                      D

                                    State
                                  Number of
Manifesting SQGs
                                (Exhibit 2-7)
                                     Tons
                             Generated (B x 2.6)
                                     % of
                                    Total

                                    State
                                  Number of
                               Manifesting SQGs
(Exhibit 2-7)
                                     Tons
                             Generated (B x 2.6)
                                     % of
                                    Total
                                      1
Alabama
                                                                           821
                                                                         2,136
                                                                          2.3%

                                      30
Nebraska
                                                                           167
                                                                           435
                                     0.3%
                                      2
Alaska
                                                                            80
                                                                           208
                                                                          0.1%

                                      31
Nevada
                                                                           159
                                                                           415
                                     0.3%
                                      3
Arizona
                                                                           429
                                                                         1,116
                                                                          0.6%

                                      32
New
Hampshire
                                                                           135
                                                                           350
                                     0.3%
                                      4
Arkansas
                                                                           192
                                                                           500
                                                                          0.3%

                                      33
New Jersey
                                                                           570
                                                                         1,481
                                     1.2%
                                      5
California
                                                                         3,963
                                                                        10,304
                                                                          5.7%

                                      34
New Mexico
                                                                           131
                                                                           341
                                     0.3%
                                      6
Colorado
                                                                           307
                                                                           798
                                                                          0.5%

                                      35
New York
                                                                         1,755
                                                                         4,562
                                     3.6%
                                      7
Connecticut
                                                                           619
                                                                         1,610
                                                                          1.0%

                                      36
North Carolina
                                                                           990
                                                                         2,574
                                     2.1%
                                      8
Delaware
                                                                           125
                                                                           325
                                                                          0.2%

                                      37
North Dakota
                                                                            47
                                                                           122
                                     0.1%
                                      9
District of Columbia
                                                                            37
                                                                            96
                                                                          0.1%

                                      38
Ohio
                                                                         1,769
                                                                         4,600
                                     3.9%
                                      10
Florida
                                                                         2,546
                                                                         6,620
                                                                          4.0%

                                      39
Oklahoma
                                                                           295
                                                                           767
                                     0.7%
                                      11
Georgia
                                                                           733
                                                                         1,906
                                                                          1.2%

                                      40
Oregon
                                                                           174
                                                                           453
                                     0.4%
                                      12
Guam
                                                                             4
                                                                            10
                                                                          0.0%

                                      41
Pennsylvania
                                                                         2,350
                                                                         6,109
                                     5.4%
                                      13
Hawaii
                                                                            96
                                                                           250
                                                                          0.2%

                                      42
Puerto Rico
                                                                            71
                                                                           184
                                     0.2%
                                      14
Idaho
                                                                            56
                                                                           146
                                                                          0.1%

                                      43
Rhode Island
                                                                           469
                                                                         1,219
                                     1.1%
                                      15
Illinois
                                                                         2,631
                                                                         6,842
                                                                          4.3%

                                      44
South Carolina
                                                                           404
                                                                         1,051
                                     1.0%
                                      16
Indiana
                                                                           652
                                                                         1,695
                                                                          1.1%

                                      45
South Dakota
                                                                           147
                                                                           381
                                     0.4%
                                      17
Iowa
                                                                           384
                                                                           998
                                                                          0.7%

                                      46
Tennessee
                                                                           386
                                                                         1,003
                                     1.0%
                                      18
Kansas
                                                                           389
                                                                         1,010
                                                                          0.7%

                                      47
Texas
                                                                         1,218
                                                                         3,166
                                     3.1%
                                      19
Kentucky
                                                                           276
                                                                           718
                                                                          0.5%

                                      48
Trust
Territories
                                                                             3
                                                                             7
< 0.1%
                                      20
Louisiana
                                                                           594
                                                                         1,544
                                                                          1.1%

                                      49
Utah
                                                                           127
                                                                           330
                                     0.3%
                                      21
Maine
                                                                           204
                                                                           530
                                                                          0.4%

                                      50
Vermont
                                                                           146
                                                                           379
                                     0.4%
                                      22
Maryland
                                                                           923
                                                                         2,399
                                                                          1.7%

                                      51
Virgin Islands
                                                                             4
                                                                            10
                                     0.0%
                                      23
Massachusetts
                                                                         1,798
                                                                         4,674
                                                                          3.3%

                                      52
Virginia
                                                                         1,107
                                                                         2,877
                                     2.9%
                                      24
Michigan
                                                                         1,233
                                                                         3,205
                                                                          2.3%

                                      53
Washington
                                                                           381
                                                                           989
                                     1.0%
                                      25
Minnesota
                                                                           915
                                                                         2,380
                                                                          1.8%

                                      54
West Virginia
                                                                           220
                                                                           571
                                     0.6%
                                      26
Mississippi
                                                                           166
                                                                           432
                                                                          0.3%

                                      55
Wisconsin
                                                                           822
                                                                         2,137
                                     2.3%
                                      27
Missouri
                                                                         1,007
                                                                         2,618
                                                                          2.0%

                                      56
Wyoming
                                                                            58
                                                                           152
                                     0.2%
                                      28
Montana
                                                                            44
                                                                           115
                                                                          0.1%

                                      57
                                                                         Total
                                                                        35,330
                                                                        91,859
100.0%
                                      29
Navajo Nation
                                                                             4
                                                                            10
                                                                     < 0.1%

Note that, as described in Chapter 3 of this RIA, estimates and assumptions about SQG hazardous waste tonnage generation and shipment are relevant only insofar as they inform the frequency with which pickups of hazardous waste must be made. The estimate of 2.6 tons of hazardous waste generated annually falls well short of this RIA's estimate of 30 tons of waste capable of being carried by one truck; correspondingly, this estimate is consistent with this RIA's methodology of assuming that pickups of hazardous waste from SQGs occur on a routine basis and do not require multiple trucks.

A.2 Conditionally-Exempt Small Quantity Generators

Similar to SQGs, there are few reporting requirements for CESQGs with respect to generation of hazardous waste. Because of this, the Hazardous Waste Generator proposed rule RIA extrapolated estimates of the average number of tons generated per CESQG from states where such data are available. For CESQG hazardous waste tonnage estimation, this RIA uses a similar methodology as for SQGs, as per Exhibit A-2 (which is Exhibit 2-10 in the Hazardous Waste Generator proposed rule RIA).

                                 Exhibit A-2
                 CESQG Hazardous Waste Generation Quantities
                                     Item
                                      A
                                      B
                                      C
                                      D

                                    State
CESQG
Facilities
Hazardous Waste Generated (Tons)
Tons per Facility
                                      1
2011 RCRA Biennial Report data (excluding ME and WA)[a]
                                                                           252
                                                                            67
                                                                          0.26
                                      2
Maine (data from Maine DEP)
                                                                           917
                                                                           161
                                                                          0.18
                                      3
New Jersey (data from New Jersey DEP)
                                                                         1,224
                                                                           501
                                                                          0.41
                                      4
Washington (data from Washington DOE)
                                                                           127
                                                                            42
                                                                          0.33
                                      5
                                                                         Total
                                                                         2,520
                                                                           771
                                                         0.31  (Median = 0.20)
Source: 2015 Hazardous Waste Generator Standards proposed rule RIA, Exhibit 2-9. Available
at: http://www.regulations.gov/#!home. Exhibit excludes Column E regarding facility-level waste streams as it is not relevant to the present discussion. [a] Data based on analysis of 2011 RCRA Biennial Report database (not National Summary Report). These data exclude facilities that are reported to be SQGs, but exceed the RCRA hazardous waste generation threshold for SQGs. Maine and Washington data were also excluded to avoid double-counting.

This RIA uses the mean (average) estimate of 0.31 tons of hazardous waste generation per
CESQG facility to estimate total hazardous waste tonnage generated by CESQGs. However,
CESQGs are exempt from manifest requirements unless a state requirement specifically requires CESQG to fill out and submit manifests for hazardous waste shipments (see Section <IP_ADDRESS>).
Therefore, only the one state that requires CESQGs to manifest shipments of hazardous waste, Arkansas, requires specific CESQG tonnage estimation relevant to this RIA. Given the other assumptions in Section <IP_ADDRESS>, this RIA estimates that 2,039 CESQGs in Arkansas are shipping hazardous waste off-site and must manifest. Using the 0.31 tons per facility multiplier, this RIA estimates that approximately 632 tons of hazardous waste are generated by CESQGs, shipped off-site, and accompanied by federal manifests.

Again, given that the estimation of annual generation by CESQGs is below the number of tons assumed to be carried by a single truck, this calculation is consistent with this RIA's broader estimation of the number of manifests used annually to accompany hazardous waste shipments.

A.3 Generators of State Hazardous Wastes

As described in Section <IP_ADDRESS>, 19 states have listed additional wastes as state hazardous wastes, beyond the requirements of the federal RCRA program. Consistent with Section <IP_ADDRESS>, this RIA assumes that the count of state hazardous waste generators is equal to the count of CESQGs in the state. Exhibit A-3 below summarizes the estimated number of state hazardous waste shippers based on this assumption, as well as their associated tonnage shipped off-site, based on the 0.31 tons per facility multiplier discussed above.

                                 Exhibit A-3
   Estimated State Hazardous Waste Tonnage from Shippers of State Hazardous
                               Waste, by State
                                     Item
                                      A
                                      B
                                      C
                                      D

                                    State
                       Count of Shippers (Exhibit 2-10)
                          Tons Generated  (B x 0.31)
                                     % of
                                    Total
                                      1
California
                                                                        16,170
                                                                         5,013
                                    11.1%
                                      2
Colorado
                                                                         2,297
                                                                           712
                                     1.6%
                                      3
Illinois
                                                                        19,370
                                                                         6,005
                                    13.3%
                                      4
Indiana
                                                                         7,702
                                                                         2,388
                                     5.3%
                                      5
Kentucky
                                                                         3,952
                                                                         1,225
                                     2.7%
                                      6
Louisiana
                                                                         5,527
                                                                         1,713
                                     3.8%
                                      7
Maine
                                                                           731
                                                                           227
                                     0.5%
                                      8
Maryland
                                                                         6,018
                                                                         1,866
                                     4.1%
                                      9
Michigan
                                                                         9,238
                                                                         2,864
                                     6.4%
                                      10
Missouri
                                                                         7,542
                                                                         2,338
                                     5.2%
                                      11
New Hampshire
                                                                         1,400
                                                                           434
                                     1.0%
                                      12
New York
                                                                        21,715
                                                                         6,732
                                    15.0%
                                      13
Oregon
                                                                         2,650
                                                                           822
                                     1.8%
                                      14
Rhode Island
                                                                         1,617
                                                                           501
                                     1.1%
                                      15
South Carolina
                                                                         4,137
                                                                         1,282
                                     2.8%
                                      16
Texas
                                                                        15,135
                                                                         4,692
                                    10.4%
                                      17
Utah
                                                                         1,699
                                                                           527
                                     1.2%
                                      18
Vermont
                                                                         1,079
                                                                           334
                                     0.7%
                                      19
Washington
                                                                        17,183
                                                                         5,327
                                    11.8%
                                                                         Total
                                                                       145,522
                                                                        45,000
 100%

Again, given that the estimation of annual generation by CESQGs is below the number of tons assumed to be carried by a single truck, this calculation is consistent with this RIA's broader estimation of the number of manifests used annually to accompany hazardous waste shipments.

                                   Appendix B
                         State Hazardous Waste Programs

As described in Section 2.2, some state governments have elected to adopt modifications to RCRA that make their programs more stringent than federal RCRA regulations. To examine in detail the ways in which the proposed rule may result in impacts to state hazardous waste programs, this RIA gathered data on state RCRA program requirements from the Environmental Compliance Assistance Program (ENVCAP), a repository of environmental regulations maintained by the National Center for Manufacturing Sciences and supported by EPA's Office of Enforcement Compliance Assurance. The state government RCRA program requirements can be accessed on ENVCAP's website at http://www.envcap.org/statetools/hzrl/.

Section 2.2 summarizes the key ways in which various state hazardous waste programs differ from the federal RCRA program, and Exhibits 2-12 and 2-13 indicate the specific state differences with potential implications for the proposed rule and this RIA. This Appendix provides greater detail on specific state requirements used to generate the data presented in Exhibits 2-12 and 2-13.

B.1 Additional State Hazardous Wastes

This RIA identified 19 states with additional state hazardous wastes. This section summarizes the available data on the ways in which state hazardous waste programs differ from the federal RCRA program with regard to which wastes are additionally considered hazardous.

       California  -  Used oil is considered a hazardous waste. Additionally, there are multiple additional eligible waste streams for the consolidated manifest, including: o used oil;
              the contents of an oil/water separator under certain conditions; o solids contaminated with used oil; o brake fluid;
              antifreeze or antifreeze sludge;
              parts cleaning solvent, including aqueous cleaning solvents;
              hydroxide sludge contaminated solely with metals from a wastewater treatment process' paint-related wastes, including paints, thinners, filters, and sludges;
              spent photographic solutions; o dry-cleaning solvents;
              filters, lint, and sludges contaminated with dry-cleaning solvent; o asbestos and asbestos-containing materials; o inks from the printing industry;
              chemicals and laboratory packs collected from K-12 schools; o absorbents contaminated with other eligible wastes; o filters from dispensing pumps for diesel and gasoline fuels; and o disabled vehicle wastes.

       Colorado  -  Colorado does not require use of state-specific waste codes on manifests. However, there are state-specific codes within the state relating to chemical weapons and associated treatment residues and contaminated materials that came in contact with chemical weapons.

       Illinois -- Illinois requires non-hazardous special waste to be manifested on the Uniform Hazardous Waste Manifest. Illinois generators and out-of-state generators sending nonhazardous waste to an Illinois receiving facility must use a manifest for all shipments of nonhazardous special waste.  All nonhazardous special waste should be identified as either Class A or Class B. Copies of these manifests are not to be submitted to the State of Illinois; instead Illinois receiving facilities and Illinois generators who send their waste out-of-state are required to submit summary information in the form of the Nonhazardous Special Waste Annual Report.

       Indiana  -  Chemical munitions are an additional hazardous waste.

       Kentucky  -  Various additional hazardous wastes, including:
              N001 GB (iso (isopropyl methyl phosphonofluoridate) (H);
              N002 VX (o-ethyl-S-(2-diisopropyl-aminoethyl)-methyl phosphonothiolate) (H); and
              N003 H (bis(2-chloroethyl) sulfide) and related compounds (H).

       Louisiana  -  Used oil is considered a hazardous waste.

       Maine -- The waste codes as designated in Maine Rules follow the federal coding conventions (D, F, U and P coding, consistent with federal codes) and as such, the corresponding federal code must be entered on the new federal manifest in Item 13 pursuant to the manifest instructions. However, Maine has state-specific waste codes for "state-listed" hazardous wastes (i.e. "state-regulated only") that are not found in the federal hazardous waste rules (i.e. "not redundant" with federal waste codes). As such, these "state-regulated only/ not redundant" waste codes must be entered on the manifest in Item 13 for shipments of such wastes.

      In addition, the State of Maine does not incorporate many of the federal exemptions and exclusions to the definition of solid waste and hazardous waste. Hazardous waste sent off-site for recycling or reclamation is not exempt from Maine regulations. Hazardous waste being sent for recycling or reclamation must use a uniform hazardous waste manifest to document the shipping. For wastes which are regulated as hazardous waste in Maine, but federally-exempt, the waste codes as designated in Maine Rules must be entered on the manifest in Item 13. Again, Maine Rules identify characteristic hazardous wastes by the same waste codes used under the federal rules (e.g. D001, D002, D003, D004, etc.), and identify listed hazardous waste using the F, P, and U-waste codes similar to the federal coding convention. As noted above, Maine Rules include state-specific wastes, including listings for PCBs (M002) and several P- and U- coded wastes which are not listed federally. For shipment of these wastes in Maine, the waste code as identified in Maine Rules must be entered on the manifest in Item 13. Generators may choose to specify in Item 14 of the manifest that such waste is "state-regulated only", but this is not required.

      The State of Maine regulates batteries, cathode ray tubes, mercury or lead containing lamps, mercury devices, mercury thermostats and motor vehicle mercury switches as universal waste. Generators of universal wastes must ship and track their waste using a hazardous waste manifest, a Uniform Bill of Lading, or an alternative form approved by the Department. If a generator chooses to use a hazardous waste manifest for a universal waste shipment, then item counts of the waste must be supplied in Item 14.

      Universal wastes use the prefix MR followed by the federal or state waste code. For example, mercury containing lamps would use the code MRD009. For additional examples, see Appendix J of the Universal Waste Handbook. Waste oil being transported into Maine from out of state must be accompanied by a hazardous waste manifest. The results from analysis required by the Waste Oil Management Rules, Chapter 860.15(C) may be recorded in Item 14. Special Handling Instructions and Additional Information. If the results are not included on the manifest in Item 14, then a copy of the results must be attached to each copy of the manifest at the time of each copy's distribution. If a shipment of waste oil from a storage facility does not meet the specification described in Chapter 860.4(B), then it must be accompanied by a hazardous waste manifest pursuant to Waste Oil Management Rules, Chapter 860.13(B)(2)(b). The results of the analysis may be recorded in Item 14. Special Handling Instructions and Additional Information. If the results are not included on the manifest in Item 14, then a copy of the results must be attached to each copy of the manifest at the time of each copy's distribution.Additional Wastes:

       Maryland  -- Various additional hazardous wastes, including:
         o Hazardous Waste From Specific Sources (COMAR <IP_ADDRESS>):
                    Primary Copper, K064;
                    Primary Lead, K065;
                    Primary Zinc, K066;
                    Primary Zinc, K067;
                    Primary Zinc, K068;
                    Ferroalloys, K090 & K091; and
                    Military K991, K992, K993, K994, K995, K996, K997, K998 and K999.
              Hazardous Waste from Specific Sources (State) (COMAR <IP_ADDRESS>):   Organic Chemical, MD01; and  Military, MD02 and MD03.
              Discarded Commercial Chemical Products, Off-Specification Species, Containers, and Spill Residues of These (COMAR <IP_ADDRESS>):
                    MX 01: "Any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill, into or on any land or water, of any commercial chemical product or manufacturing chemical product or manufacturing chemical intermediate having the generic name listed in §E or G or mixtures containing polychlorinated biphenyls (PCBs) at concentrations greater than 50 ppm.";
                    M001: Polychlorinated biphenyls (PCB)(above 500 ppm); and   MT01: Polychlorinated biphenyls (50 to 500 ppm).

       Michigan  -  Additional hazardous wastes assigned to numerous waste with Michigan Hazardous Waste numbers, including specific hazardous wastes from specific sources and specific substances. Shipments of liquid industrial waste must be manifested. Some specific types of additional hazardous wastes include:
           mixed solvents; o pharmaceutical wastes; o crankcase oil;
           coolants and water soluble oil; o other oil; o brine; o PCBs;
           other wastes; o antifreeze; o storm sewer cleanouts; o sanitary sewer cleanouts; o x-ray/photo cleaning solutions; o water-based cleaning solutions; o car wash sludges; and o grease trap wastes.

       Missouri  -  State waste codes must be used if federal waste codes do not apply. State waste codes include: o PCB wastes; o dioxin waste; and o disposal of used oil.

       New Hampshire  -  Additional wastes include:
           federally-exempt due to recycling wastes; o federally-exempt household hazardous waste; o remediation waste; o federally-exempt sludge;
           federally-exempt municipal solid waste ash; and o federally-exempt shooting range waste.

       New York  -  Generators must complete Block 13 Waste Codes. They may designate up to, but not more than, six Waste Codes. If applicable, NYS DEC's "B" type Waste Codes for PCB wastes must be used. Generators must provide the "old Handling Code" for their wastes in Block 13 in certain cases, or else the waste will be assumed to be landfilled.

       Oregon  -  Oregon has state-specific wastes codes for acute and toxic hazardous wastes. Other additional wastes includes:

              waste pesticide residue, except for those that are managed as universal wastes or whose constituents are listed in the federal regulations, but are below the prescribed regulatory levels;
              wastes received from out of state that are not regulated in Oregon but are regulated as hazardous waste in state of origin.
              residues from demilitarization, treatment and testing of blister agents (such as mustard agents), which have been added to and made a part of the list found in the federal regulations;
              residues from demilitarization, treatment and testing of nerve agents, such as GB (Sarin) and VX; which have been added to and made a part of the list found in the federal regulations; and
              blister agents, such as mustard agents, which have been added to the list of commercial chemical products found in the federal regulations. 9. P999 Nerve agents, such as GB (Sarin) and VX, which have been added to the list of commercial chemical products found in the federal regulations.

       Rhode Island  -  State codes R001-R010 are to be used if Federal codes do not apply. The state codes will work on the new Uniform Hazardous Waste Manifest in exactly the same way as they functioned on the previous manifest. State codes R011-R016 are to be used for Fee Exempt waste and should be used in addition to federal waste codes. In the event that the waste carries more than six waste codes, the generator should select the most appropriate codes for use.

       South Carolina  -  Additional wastes include:
              organotins; o tributyltin;
              any solid waste that the state determines constitutes a hazard and requires greater control; and
              non-hazardous waste received by a hazardous waste facility.

       Texas  -  Texas has its own 8-digit waste code that identifies each waste stream. The Texas waste code will still go on the manifest - regardless of if the waste is hazardous or not. Use two of the 6 waste code blocks in Item 13 for the Texas Waste Code. For hazardous waste, up to 4 applicable EPA codes (e.g., D001, F001, etc) will go in the remaining waste code boxes. The formula for the Texas waste code is: The 4-digit sequence number + the 3-digit form code + the 1-digit classification code.

       Utah  -  Additional wastes includes two wastes associated with the management of chemical nerve agents.

       Vermont  -  Vermont has seven additional state waste codes.

       Washington  -  Multiple additional state waste codes. Furthermore, shipments of lab packs have special manifesting instructions.

           Removal of Exemptions

This RIA identified six states that remove certain federal exemptions present under federal RCRA regulations. Specifically, these six states remove the exemption for SQGs that have bonafide contractual reclamation agreements (with TSDFs)  -  under federal requirements these SQGs do not have to provide manifests accompanying shipments of their hazardous waste, but in these six states, SQGs must provide accompanying manifests even for these shipments.

These six states are Connecticut, Delaware, Kentucky, Maryland, Minnesota, and New Hampshire.

Texas' state hazardous waste program also removes some exemptions relative to the federal
RCRA program; however, these do not have direct bearing on the proposed rule or this RIA.

           Distribution Requirements

This RIA identified 32 states that require industry entities to send copies of the manifest from shipments originating and/or terminating within their boundaries to state regulatory agencies.

Note that this set of states does not overlap perfectly with either the set of states with additional state hazardous wastes, nor the 23 states identified in Chapter 4 as collecting and processing manifests in the baseline.

           Additional Reporting Requirements

This RIA identified 17 states have reporting requirements more stringent than the federal RCRA program as pertaining to certain hazardous waste activities. These additional requirements may include additional instances requiring reports, more frequent or shorter reporting timetables, or additional facility classes subject to these requirements.

           Additional Recordkeeping Requirements

This RIA identified five states with additional recordkeeping requirements beyond the federal RCRA requirement to maintain records of all manifest shipments for three years.

           Other Additional Requirements

This RIA identified 22 states with additional requirements beyond the federal RCRA program distinct from the five categories described above. One of these states, Arkansas, requires CESQGs to provide accompanying manifests for hazardous waste shipments.

  APPENDIX C 2014 EPA Survey of Hazardous Waste Treatment, Storage, and Disposal Companies

To gather information on the number of manifests nationwide and the manner in which they are handled, EPA asked nine of the largest TSDF companies to respond to a voluntary questionnaire in August 2014. This RIA uses information from the questionnaire to confirm estimates of the number of manifests from other sources, and incorporates manifest handling information into the estimation of baseline costs and post-rule cost and cost savings. In total, six of the nine firms responded to this questionnaire.

Manifests

As shown in Exhibit C-1, these six firms reported receiving approximately 800,000 manifests in total each year, with the total annual number varying by less than 5,000 manifests from year to year. In 2013, these companies received shipments from approximately 140,000 entities (e.g,, generators or transporters).

                                 Exhibit C-1
  Reported Manifest Usage by Six TSDF Companies for the Years 2011 through 2013
                                     Item
                                      A
                                      B
                                      C
                                      D

                                   Company
                                  Count 2013
                                  Count 2012
                                  Count 2011
                                      1
Veolia
                                                                       100,000
                                                                       100,000
                                                                       100,000
                                      2
Tradebe
                                                                        45,000
                                                                        46,000
                                                                        45,000
                                      3
Clean Harbors Environmental Services
                                                                       561,761
                                                                       569,507
                                                                       572,290
                                      4
Ross Environmental Services, Inc.
                                                                        14,448
                                                                        13,592
                                                                        12,782
                                      5
Heritage Environmental Services
                                                                        50,200
                                                                        42,700
                                                                        49,700
                                      6
Systech Environmental Corporation
                                                                        21,470
                                                                        22,982
                                                                        19,629
                                      7
Total
                                                                       792,879
                                                                       794,781
                                                                       799,401

These firms reported submitting copies of manifests to 47 states, and reported paying manifest fees to six states (California, Massachusetts, Michigan, Missouri, New Jersey, and
Pennsylvania). Overall, approximately 18 percent of manifests in each year carried only state hazardous waste codes (Exhibit C-2).

                                     C-1

                                    Exhibit C-2
              Manifests Carrying Only State Waste Codes For Six TSDF Companies

                                     Item
                                      A
                                      B
                                      C
                                      D

                                   Company
                                  Count 2013
                                  Count 2012
                                  Count 2011
                                      1
Veolia
                                                                        10,000
                                                                        10,000
                                                                        10,000
                                      2
Tradebe
                                                                         1,000
                                                                         1,250
                                                                         1,000
                                      3
Clean Harbors Environmental Services
                                                                      120,589
                                                                       134,011
                                                                       123,862
                                      4
Ross Environmental Services, Inc.
                                                                             1
                                                                             1
                                                                             1
                                      5
Heritage Environmental Services
                                                                         9,000
                                                                         5,800
                                                                         8,000
                                      6
Systech Environmental Corporation
                                                                           500
                                                                           500
                                                                           500
                                      7
Total
                                                                       141,090
                                                                       151,562
                                                                       143,363

Existing electronic systems

Five companies reported using their own electronic systems to comply with federal or state RCRA reporting requirements, and invoicing support systems. These included proprietary waste tracking database systems that recorded waste shipments and container movements, as well as customized versions of commercial software (e.g., .NET, SAP, Oracle). For four companies, these electronic systems were closed (i.e., did not presently have the ability to communicate with external systems), while the electronic system used by one company utilized XML web services in order to transfer or receive data from other systems.

None of these five companies reported requiring their customers to use electronic systems. At least one company uploaded scanned paper manifest images and extracted data from these images for incorporation into its electronic system.

Adoption of e-Manifest

All six major TSDF companies indicated their intention to transition from paper to electronic manifests. At least three companies indicated that because of customer demand, the transition to electronic manifests would be gradual, and paper manifests would continue to be supported. Only two companies indicated that they would impose any type of requirement on customers to use electronic manifest systems after the TSDF's transition to the e-Manifest system. One company specifically identified differential pricing for customers using paper or electronic manifests as a potential strategy for encouraging the use of e-Manifest, while one company indicated that differential pricing did not align with its business strategy.

                                     C-2

                                   Appendix D
                          Manifest-Related Activities

This Appendix consists of two sections. Section D.1 provides the set of manifest activities used to estimate baseline and post-rule costs and cost savings within this RIA, based on the activities, hourly labor burdens, and other costs as reported within the 2015 Hazardous Waste Manifest System (HWMS) ICR. Section D.2 then provides two visual summaries of the manifest process which help to illustrate both how industrial entities interact with one another and the manifest in the baseline, and how they may do so under the e-Manifest system via electronic manifests.

D.1 Manifest-Related Activities from the Hazardous Waste Manifest System ICR

As described in Chapter 4, this RIA uses the 2015 Hazardous Waste Manifest System (HWMS) ICR as the main underlying data source for unit costs and frequencies associated with the activities required to complete a federal manifest. These specific assumptions and parameters are summarized in this Appendix. Note that this RIA uses the labor rates from the 2015 HWMS ICR to calculate industry costs associated with manifest-related activities, so the labor rates shown below are consistent with the HWMS ICR.

Exhibit D-1 below replicates the relevant activities and their associated hourly labor burdens and operations and maintenance (O&M) costs as reported within the 2015 HWMS ICR. The columns of Exhibit D-1 provide the following information:

       Column A  -  Describes the manifest-related activity in question. Note that activities are grouped by category and subcategory where appropriate.
       Columns B through E  -  Provide the number of labor hours necessary to complete the activity for legal, managerial, technical, and clerical labor, respectively.
       Column F  -  Based on the hourly labor rates provided in the 2015 HWMS ICR and the column headings of Columns B through E, the total labor cost associated with the labor burden shown in Columns B through E.
       Column G  -  The O&M costs associated with the activity.
       Column H  -  The proportion of manifests to which the activity applies. Note that a value here does not mean this activity applies to all Federal manifests; rather, this proportion applies only to the subset of manifests as defined in Column I.
       Column I  -  The subset of manifests to which the activity applies. Some activities apply only to manifests originated by a specific entity (e.g., LQG-originated manifests, SQGoriginated manifests). The majority of activities, however, apply to all manifests; these are designated as "All Federal Manifests" in this column.
       Column J  -  Per this RIA's methodology to estimate burden reductions as detailed in
Chapter 5, whether the activity corresponds to a major burden reduction (i.e., 80 percent reduction in overall cost) or a minimal burden reduction (i.e., five percent reduction in overall cost) when electronic manifests are used in lieu of paper manifests.

As described in Chapter 4, the HWMS ICR pertained only to federal manifests. Chapter 4 of this RIA details how the assumptions and parameters from the HWMS ICR, reproduced below, were additionally extrapolated to state manifests.

This RIA made only one alteration to the assumptions and parameters in the HWMS ICR in order to align to calculations used elsewhere in the RIA; this alteration pertained to estimates of the number of hazardous waste discharges. Specifically, the HWMS ICR used approximate figures rather than actual reported numbers for the volume of such discharges in a given year, whereas this RIA uses the actual numbers of highway and marine discharges in lieu of the approximations. Exhibit D-1 reflects this alteration. Because the HWMS ICR and this RIA differ in the total number of annual federal manifests considered, the proportion of manifests associated with a discharge or incident requiring a specific burden activity differs across the HWMS and this RIA, but the underlying figures and calculations have been adjusted so that the overall count of incidents is similar.

                                     D-2

                                     Exhibit D-1
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR

                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion

Without TSDF assistance

LQG - Complete manifest
                                      0
                                      0
                                     0.4
                                     0.1
$18.42
$0.42
                                    58.0%
                                 LQG Shipper-
                                  Originated
                                  Manifests
                                    Major
LQG - Complete continuation sheet
                                      0
                                      0
                                     0.19
                                     0.04
                                                                        $8.58
$0.42
                                     2.9%
                                 LQG Shipper-
                                  Originated
                                  Manifests
                                    Major
LQG - Subtotal
                                    Major
With TSDF assistance

LQG - Complete manifest
                                      0
                                      0
                                     0.02
                                     0.01
                                                                        $1.03
                                      0
                                    42.0%
                                 LQG Shipper-
                                  Originated
                                  Manifests
                                   Minimal
TSDF - Complete manifest
                                      0
                                      0
                                     0.43
                                     0.1
$19.63
$0.42
                                    42.0%
                                 LQG Shipper-
                                  Originated
                                  Manifests
                                   Minimal
TSDF - Complete continuation sheet
                                      0
                                      0
                                     0.18
                                     0.04
                                                                        $8.18
$0.42
                                     2.1%
                                 LQG Shipper-
                                  Originated
                                  Manifests
                                   Minimal
LQG - Subtotal

                                   Minimal
TSDF Receiver - Subtotal

                                   Minimal
TSDF Shippers - Manifest Completion

Complete manfiest
                                      0
                                      0
                                     0.43
                                     0.1
$19.63
$0.42
                                    100.0%
                                 TSDF Shipper-
                                  Originated
                                  Manifests
                                   Minimal
Complete continuation sheet
                                      0
                                      0
                                     0.18
                                     0.04
                                                                        $8.18
$0.42
                                    5.00%
                                 TSDF Shipper-
                                  Originated
                                  Manifests
                                   Minimal
TSDF Shipper - Subtotal

                                   Minimal
SQG Shippers - Manifest Completion

                                     Exhibit D-1
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR

                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion

Without TSDF assistance

SQG - Complete manifest
                                      0
                                      0
                                     0.4
                                     0.08
$17.97
$0.42
                                    20.0%
                                 SQG Shipper-
                                  Originated
                                  Manifests
                                    Major
SQG - Complete continuation sheet
                                      0
                                      0
                                     0.18
                                     0.03
                                                                        $7.95
$0.42
                                     1.0%
                                 SQG Shipper-
                                  Originated
                                  Manifests
                                    Major
SQG - Subtotal

                                    Major
With TSDF assistance

SQG - Complete manifest
                                      0
                                      0
                                     0.02
                                     0.01
                                                                        $1.03
                                      0
                                    80.0%
                                 SQG Shipper-
                                  Originated
                                  Manifests
                                   Minimal
TSDF - Complete manifest
                                      0
                                      0
                                     0.43
                                     0.1
$19.63
$0.42
                                    80.0%
                                 SQG Shipper-
                                  Originated
                                  Manifests
                                   Minimal
TSDF - Complete continuation sheet
                                      0
                                      0
                                     0.18
                                     0.04
                                                                        $8.18
$0.42
                                     4.0%
                                 SQG Shipper-
                                  Originated
                                  Manifests
                                   Minimal
SQG - Subtotal

                                   Minimal
TSDF Receiver - Subtotal

                                   Minimal
LQG Shippers - Exception report completion, submission, and recordkeeping

LQG Shippers

 Prepare and submit a signed cover letter to EPA explaining the generator's efforts to locate the hazardous waste and the results of those efforts, along with a legible copy of the manifest.
                                      0
                                     0.5
                                     0.5
                                     0.1
$63.33
$0.62
                                    1.91%
                                 LQG Shipper-
                                  Originated
                                  Manifests
                                   Minimal

                                     Exhibit D-1
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR

                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion

Keep a copy of each exception report
                                      0
                                      0
                                      0
                                     0.1
                                                                        $2.24
$0.10
                                    1.91%
                                 LQG Shipper-
                                  Originated
                                  Manifests
                                   Minimal
LQG - Subtotal

                                   Minimal
TSDF Shippers

Prepare and submit a signed cover letter to EPA explaining the generator's efforts to locate the hazardous waste and the results of those efforts, along with a legible copy of the manifest
                                      0
                                     0.5
                                     0.5
                                     0.1
$63.33
$0.62
                                    0.51%
                                 TSDF Shipper-
                                  Originated
                                  Manifests
                                   Minimal
Keep a copy of each exception report
                                      0
                                      0
                                      0
                                     0.1
                                                                        $2.24
$0.10
                                    0.51%
                                 TSDF Shipper-
                                  Originated
                                  Manifests
                                   Minimal
TSDF Shippers - Subtotal

                                   Minimal
SQG Shippers

Submit a legible copy of the manifest...
                                      0
                                     0.25
                                     0.25
                                      0
$30.54
$0.62
                                    0.50%
                                 SQG Shipper-
                                  Originated
                                  Manifests
                                   Minimal
SQG - Subtotal

                                   Minimal
Manifest transmittal and recordkeeping

All Federal Manifests Together

Sign the manifest certification and obtain the signature of the initial transporter and date of acceptance on the manifest
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                    100.0%
                            All Federal Manifests
                                    Major
Keep a copy of the manifest and give the remaining copies to the initial transporter
                                      0
                                      0
                                      0
                                     0.1
                                                                        $2.24
$0.00
                                    100.0%
                            All Federal Manifests
                                    Major

                                     Exhibit D-1
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR

                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion

Keep a copy of the manifest returned from the designated facility
                                      0
                                      0
                                      0
                                     0.1
                                                                        $2.24
$0.00
                                    100.0%
                            All Federal Manifests
                                    Major
For shipments solely by water, send three copies of the manifest, dated and signed, to the designated facility or the last water transporter to handle the waste in the U.S.
                                      0
                                      0
                                      0
                                     0.16
                                                                        $3.58
$0.52
                                     3.0%
                            All Federal Manifests
                                    Major
For shipments by rail originating at the site of generation, send at least three copies of the manifest to the next non-rail transporter, the designated facility, or the last rail transporter to handle the waste in the U.S.
                                      0
                                      0
                                      0
                                     0.16
                                                                        $3.58
$0.52
                                     6.0%
                            All Federal Manifests
                                    Major
Exports - Provide the transporter with an EPA Acknowledgment of Consent and an additional copy of the manifest or shipping papers for delivery to the U.S. Customs official at the point the hazardous waste exits the U.S.
                                      0
                                      0
                                      0
                                     0.25
                                                                        $5.60
$0.10
                                     1.5%
                            All Federal Manifests
                                    Major
Subtotal - LQGs

                                    Major
Subtotal - TSDF Shippers

                                    Major
Subtotal - SQGs

                                    Major
Undeliverable Shipments

All Federal Manifests Together

Designate another facility or instruct the transporter to return the waste
                                      0
                                      0
                                     0.08
                                      0
                                                                        $3.24
$0.00
                                     0.1%
                            All Federal Manifests
                                   Minimal
Subtotal - LQGs

                                   Minimal

                                     Exhibit D-1
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR

                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion

Subtotal - TSDF Shippers

                                   Minimal
Subtotal - SQGs

                                   Minimal
Rejected waste and container residues

All Federal Manifests Together

Sign Item 18c of the manifest, if the transporter returned the shipment using the original manifest
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                    0.015%
                            All Federal Manifests
                                   Minimal
Sign Item 20 of the manifest, if the transporter returned the shipment using a new manifest
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                    0.015%
                            All Federal Manifests
                                   Minimal
Provide the transporter a copy of the manifest
                                      0
                                      0
                                     0.17
                                      0
                                                                        $6.87
$0.00
                                    0.03%
                            All Federal Manifests
                                   Minimal
Within 30 days of delivery, send a copy to the designated...
                                      0
                                      0
                                      0
                                     0.15
                                                                        $3.36
$0.52
                                    0.03%
                            All Federal Manifests
                                   Minimal
Retain a copy
                                      0
                                      0
                                      0
                                     0.17
                                                                        $3.81
$0.00
                                    0.03%
                            All Federal Manifests
                                   Minimal
Subtotal - LQGs

                                   Minimal
Subtotal - TSDF Shippers

                                   Minimal
Subtotal - SQGs

                                   Minimal
Transporters

Highway Transporters

Sign and date the manifest
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     91%
                            All Federal Manifests
                                    Major
Return a signed copy of the manifest to the generator
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     91%
                            All Federal Manifests
                                    Major

                                     Exhibit D-1
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR

                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion

Ensure that the manifest (or other shipping paper) accompanies the waste to its destination
                                      0
                                      0
                                     0.13
                                      0
                                                                        $5.26
$0.00
                                     91%
                            All Federal Manifests
                                    Major
Obtain the date of delivery and signature of that transporter or the owner/operator of the facility or alternate facility designated on the manifest
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     91%
                            All Federal Manifests
                                    Major
Retain a copy of the manifest
                                      0
                                      0
                                      0
                                     0.17
                                                                        $3.81
$0.00
                                     91%
                            All Federal Manifests
                                    Major
Give remaining copies of the manifest to the accepting transporter or facility
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     91%
                            All Federal Manifests
                                    Major
Subtotal - Transporters

                                    Major
Delivery to initial water transporters

Obtain the date of delivery and signature of the initial water transporter on the manifest
                                      0
                                      0
                                      0
                                     0.01
                                                                        $0.22
$0.00
                                      3%
                            All Federal Manifests
                                    Major
Forward the manifest to the designated facility
                                      0
                                      0
                                      0
                                     0.16
                                                                        $3.58
$0.52
                                      3%
                            All Federal Manifests
                                    Major
Subtotal - Transporters

                                    Major
Manifest requirements for water (bulk shipment) transporters

Ensure that the shipping paper (and Acknowledgment of Consent, for exports) accompanies the waste to its destination
                                      0
                                      0
                                     0.13
                                      0
                                                                        $5.26
$0.00
                                      3%
                            All Federal Manifests
                                    Major

                                     Exhibit D-1
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR

                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion

If the delivering (water) transporter, obtain the date of delivery and signature of the owner/operator of the designated facility on either the manifest or shipping paper
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                      3%
                            All Federal Manifests
                                    Major
If the initial water transporter, sign and date the manifest and return it to the delivering transporter so that the manifest can be forwarded to the designated facility owner/operator
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                      3%
                            All Federal Manifests
                                    Major
Retain a copy of the manifest or shipping paper
                                      0
                                      0
                                      0
                                     0.17
                                                                        $3.81
$0.00
                                      3%
                            All Federal Manifests
                                    Major
Subtotal - Transporters

                                    Major
Rail Transporters

When accepting waste from a nonrail transporter, sign and date the manifest and return or transmit a signed copy of the manifest to the non-rail transporter
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                      6%
                            All Federal Manifests
                                    Major
Forward at least three copies of the manifest to either the next non-rail transporter, the designated facility, or the last rail transporter designated to handle the waste in the U.S.
                                      0
                                      0
                                      0
                                     0.16
                                                                        $3.58
$0.52
                                      6%
                            All Federal Manifests
                                    Major

                                 Exhibit D-1
Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR
                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion
Ensure a shipping paper containing all the information required on the manifest excluding the U.S. EPA ID number, generator certification, and signatures (and for exports an Acknowledgment of Consent) accompanies the waste
                                      0
                                      0
                                     0.13
                                      0
                                                                        $5.26
$0.00
                                      6%
                            All Federal Manifests
                                    Major
When delivering hazardous waste to the designated facility or to the next non-rail transporter, obtain the signature and date of delivery of the facility or non-rail transporter on the manifest
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                      6%
                            All Federal Manifests
                                    Major
Retain a copy of the manifest and/or rail shipping paper
                                      0
                                      0
                                      0
                                     0.17
                                                                        $3.81
$0.00
                                      6%
                            All Federal Manifests
                                    Major
Before accepting hazardous waste from a rail transporter, sign and date the manifest and provide a copy to the rail transporter
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                      6%
                            All Federal Manifests
                                    Major
Subtotal - Transporters

                                    Major
Transporters importing/exporting waste

For imports and exports, sign and date the manifest in the International Shipments block to indicate the date that the shipment left the U.S., as required by section 263.20(g)(1)
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     2.5%
                            All Federal Manifests
                                    Major
For imports and exports, retain a copy of the manifest, as required by section 263.20(g)(2)
                                      0
                                      0
                                      0
                                     0.17
                                                                        $3.81
$0.00
                                     2.5%
                            All Federal Manifests
                                    Major

                                     Exhibit D-1
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR

                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion

For imports give copy of import manifest to TSDF receiving facility
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     1.0%
                            All Federal Manifests
                                    Major
For exports, return a signed copy of the manifest to the generator, as required by section 263.20(g)(3)
                                      0
                                      0
                                      0
                                     0.01
                                                                        $0.22
$0.00
                                     1.5%
                            All Federal Manifests
                                    Major
For exports, give a copy of the manifest to a U.S. Customs official at the point of departure from the
U.S., as required by section
263.20(g)(4)
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.10
                                     1.5%
                            All Federal Manifests
                                    Major
For exports, ensure that copies of the manifest and EPA Acknowledgment of Consent accompanies the waste, as required by section 263.20(a)
                                      0
                                      0
                                     0.13
                                      0
                                                                        $5.26
$0.00
                                     1.5%
                            All Federal Manifests
                                    Major
Subtotal - Transporters

                                    Major
Undeliverable Shipments

Contact the generator for further directions and revise the manifest according to the generator's instructions
                                      0
                                      0
                                     0.08
                                      0
                                                                        $3.24
$2.00
                                     0.1%
                            All Federal Manifests
                                   Minimal
Subtotal - Transporters

                                   Minimal
Rejected waste and container residues

For partially rejected loads made while the transporter is on site, obtain the amended manifest from the facility, keep a copy, and, if receiving the rejected waste, obtain
the new manifest
                                      0
                                      0
                                     0.1
                                      0
                                                                        $4.04
$0.00
                                    0.15%
                            All Federal Manifests
                                   Minimal

                                     Exhibit D-1
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR

                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion

For fully rejected loads made or container residues identified while the transporter is on site, obtain the original manifest, as amended, from the facility
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Subtotal - Transporters

                                   Minimal
Notification of discharge of hazardous waste

All Transporters

Notify local authorities
                                      0
                                     0.25
                                      1
                                      0
$60.87
$0.00
                                    0.05%
                            All Federal Manifests
                                     None
Subtotal - Transporters

                                     None
Water (bulk shipment) Transporters

Notify NRC, or a predesignated OSC, of the discharge
                                      0
                                     0.25
                                      1
                                      0
$60.87
$0.00
                                    0.01%
                            All Federal Manifests
                                     None
Subtotal - Transporters

                                     None
TSDFs - Manifest completion, transmittal and recordkeeping

Federal Requirements

Enter the name of the person accepting the waste and sign and date each copy of the manifest (or shipping paper, if applicable)
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                    99.90%
                            All Federal Manifests
                                    Major
Complete the management method code
                                      0
                                      0
                                     0.02
                                      0
                                                                        $0.81
$0.00
                                    99.90%
                            All Federal Manifests
                                    Major
Note any discrepancies on each copy of the manifest (or shipping paper, if applicable)
                                      0
                                      0
                                     0.08
                                      0
                                                                        $3.24
$0.00
                                    24.25%
                            All Federal Manifests
                                    Major

                                     Exhibit D-1
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR

                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion

Immediately give the transporter at least one copy of the manifest (or shipping paper)
                                      0
                                      0
                                     0.17
                                      0
                                                                        $6.87
$0.00
                                    99.90%
                            All Federal Manifests
                                    Major
Within 30 days of delivery, send a copy of the manifest (or shipping paper) to the generator (or to EPAOECA for import manifests)
                                      0
                                      0
                                      0
                                     0.15
                                                                        $3.36
$0.52
100.00%
                            All Federal Manifests
                                    Major
Retain a copy of the manifest (or shipping paper) for at least three years from the delivery date (includes import manifests)
                                      0
                                      0
                                      0
                                     0.17
                                                                        $3.81
$0.00
100.00%
                            All Federal Manifests
                                    Major
Subtotal - TSDF Receiver

                                    Major
Discrepancy report completion and submission

Attempt to reconcile any discrepancies
                                      0
                                      0
                                     0.08
                                      0
                                                                        $3.24
$2.00
                                    24.25%
                            All Federal Manifests
                                   Minimal
Prepare and submit a letter to EPA describing the discrepancy and attempts to reconcile it, along with a copy of the manifest or shipping paper at issue
                                      0
                                     0.1
                                     0.17
                                     0.1
$17.29
$0.62
                                    0.39%
                            All Federal Manifests
                                   Minimal
Subtotal - TSDF Receiver

                                   Minimal
Rejected waste and container residues

Rejection of Waste after the Transporter Leaves the Facility

Enter the name of the person accepting the waste and sign and date each copy of the manifest (or shipping paper, if applicable)
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Complete the management method code
                                      0
                                      0
                                     0.02
                                      0
                                                                        $0.81
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal

                                 Exhibit D-1
Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR
                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion
Immediately give the transporter at least one copy of the manifest (or shipping paper)
                                      0
                                      0
                                     0.17
                                      0
                                                                        $6.87
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Within 30 days of delivery, send a copy of the manifest (or shipping paper) to the generator
                                      0
                                      0
                                      0
                                     0.16
                                                                        $3.58
$0.52
                                     1.5%
                            All Federal Manifests
                                   Minimal
Contact the generator to obtain the generator's instructions for forwarding the waste to another facility that can manage the waste
                                      0
                                      0
                                     0.08
                                      0
                                                                        $3.24
$2.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Prepare a new manifest for rejected loads or container residues sent to the alternate designated facility or back to the generator
                                      0
                                      0
                                     0.43
                                     0.1
$19.63
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Amend the facility's copy of the manifest to indicate the rejected wastes or residues in the discrepancy space of the amended manifest
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Copy the manifest tracking number from Item 4 of the new manifest to the Discrepancy space of the amended manifest
                                      0
                                      0
                                     0.02
                                      0
                                                                        $0.81
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Re-sign and date the manifest
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Retain the amended manifest for at
least three years from the date of the amendment
                                      0
                                      0
                                      0
                                     0.17
                                                                        $3.81
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal

                                     Exhibit D-1
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR

                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98
                                   $81.73
                                   $40.44
                                                                       $22.40

LQG Shippers - Manifest Completion

Within 30 days, send a copy of the amended manifest to the delivering transporter and to the generator
                                      0
                                      0
                                      0
                                     0.16
                                                                        $3.58
$0.52
                                     1.5%
                            All Federal Manifests
                                   Minimal
Subtotal - TSDF Receiver

                                   Minimal
Rejection of Waste while the Transporter Remains Present at the Facility

Enter the name of the person accepting the waste and sign and date each copy of the manifest (or shipping paper, if applicable)
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Contact the generator to obtain the generator's instructions for forwarding the waste to another facility that can manage the waste
                                      0
                                      0
                                     0.08
                                      0
                                                                        $3.24
$2.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Complete Item 18a and 18b of the original manifest, as applicable
                                      0
                                      0
                                     0.08
                                      0
                                                                        $3.24
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Retain a copy of the manifest (or shipping paper) for at least three years from the date of delivery
                                      0
                                      0
                                      0
                                     0.17
                                                                        $3.81
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Give the remaining copies back to the transporter
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     1.5%
                            All Federal Manifests
                                   Minimal
Subtotal - TSDF Receiver

                                   Minimal
Manifest completion, transmittal, and recordkeeping by Alternate TSDFs

Enter the name of the person accepting the waste and sign and date each copy of the manifest (or shipping paper, if applicable)
                                      0
                                      0
                                     0.01
                                      0
                                                                        $0.40
$0.00
                                     3.0%
                            All Federal Manifests
                                   Minimal
Complete the management method code
                                      0
                                      0
                                     0.02
                                      0
                                                                        $0.81
$0.00
                                     3.0%
                            All Federal Manifests
                                   Minimal

                                     Exhibit D-1
                    Assumptions and Parameters for Manifest-Related Activities from the 2015 HWMS ICR

                             Activity Description
                                    Hours
                                 Total Labor
O&M
 Cost
                                 Fraction of
Manifests
                          Applicable Manifest Subset
                                   RIA's
Estimated
Reduction

Legal
Managerial
Technical
Clerical

$96.98