301 
Aptil 29, 1982 
The Honorable Norman E. D'Amours j 
Committee Chairman on Subcommittee on Oceanography 
U. S. House of Representatives 
Washington, D.C. 20515 
Dear Chairman D'Amours: 
Regarding your inquiry about the costs of pretreatment 
programs made to me at the March 23, 1982 hearing of 
the Subcommittees (page 177, line 4338), I am enclosing 
(1) a copy of a portion of the pretreatment regulation 
regulatory assessment report (pages 4-16 to 4-24) which 
NEIL B. GOLDSTEIN is addressed to overall costs. I have been told that 
National Conservation the appendix to this report may contain detailed case 
Representative study costs; (2) copies of a portion of the Pretreat- 
ment Resource Reader by the Association of Metropolitan 
Sewerage Agencies, pages 96 to 110, on capitol and 
administrative costs whichcontains specific cost 
estimates and user charge options, even though it 
concludesby assuming that the municipalities will have 
to assume all administrative costs; and (3) part of 
the East Bay Municipal Utility District analysis 
relating to setting equitable pretreatment charges. 
Our suggestions for dump site specific and ocean 
territory area costs which should be covered by 
assessed dumping fees are as follows (see page 174, line 
4253 of the transcript): 
--analytic procedures by the Army-Corps and the EPA 
including bioassay and bioaccumulation testing 
--ocean research and monitoring 
--EPA research into new processes for reducing 
toxic contamination, including development of 
new, less polluting processes 
--research into methods of municipal pretreatment 
and tertiary treatment 
--clean up projects such as PCB dredging 
--assistance to industry for pretreatment and 
source reduction 
--planning funds for establishing land application 
programs , 
--land application siting, including money for 
land through purchase or condemnation and 
amenities packages of mitigation measures 
--regional and dumpsite management programs. 
Sincerely, 
NEW YORK OFFICE 
228 East 45th St. 
New York, N.Y. 10017 
(212) 687-2950 
Michael Garabedian 
NATIONAL HEADQUARTERS 
San Francisco, California 
