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COMMENT AND QUESTIONS FROM MR. D' AMOURS 



I question whether the total cost for dumping the City's sludge 

 at the 106-mile site will total $26.71 million as you claim in 

 chapter 17 of "Technical Information to Support the Designation of 

 the 106-mile Site for the Ocean Disposal of Municipal Sludge." 



First of all, you overstate the amount of sludge that the 

 City dumps. According to the cost analysis, the total cost per 

 year is based on 1982 costs and sludge production of 117 million 

 cubic feet (mcf) per year. Assuming that the conversion factor 

 on page 17-1 should read "mcf multiplied by 0.03148 yields million 

 wet tons" instead of "wet tons", 117 mcf is the equivalent of 

 3,683,000 wet tons. Testimony from EPA on May 25, 1983 indicates 

 that the City actually dumped 3,206,000 wet tons (101.8 mcf) in 

 1982, 477,000 wet tons less than the basis for your figures. 



Second, simple analysis of the City's economic projection for 

 dumping at the 106-mile site indicates that a reduction of . 7 hours 

 (42 minutes) per round trip would save the City in excess of 

 S13 million since this reduction would allow City vessels to make 

 an extra 156 trips per year. The 42 minutes should be easy to 

 achieve. For example, by petitioning to move the dumpsite to 101 

 miles, City vessels would save 50 minutes per round trip. In rhis 

 era of tight money, I find it hard to believe that the City would 

 not pursue all available means to reduce the round trip time in 

 order to utilize the more cost effective City vessels. 



Third, I question the accuracy of your cost esti.T.ates for 

 private barging. .According to information received by the CommiLtee 

 (attached) your cost estimates are two to three times as high as 

 the amount that the .A&S Transportation Company of South Kearney, N.J. 

 has quoted to a current dumper who inquired about transportation 

 costs for dumping at the 106-mile site. The Company quoted a price 

 of $3.50 - S5.00 per wet ton ($0.11 - $0.16 per cubic foot). Using 

 the City's estimates for sludge production, the cost to the City 

 for transporting all of its sludge by private barge to the 106-mile 

 site would range from $12.9 million to $18.4 million. Thus if the City 

 simply used a private contractor to haul its sludge the City could 

 reduce its 106-mile dumping costs by $8.3 million to $13.8 million. 

 Further, these figures do not take into account the salvage or 

 resale value of the City's fleet. 



Fourth, I question the need to build a storage facility to 

 hold one week's production of sludge. .According to the .A & S 

 Transportation Company, excess sludge could simply be loaded onto 

 extra barges and be held for future transport. 



Therefore, according to the information available to myself, 

 the total cost to the City for dumping sludge at the 106-mile 

 site would range from $9.47 million to $10.61 million, considerably 

 less than the $26.71 million quoted by the City. 



I request that the City review and comment on the attached 

 information and submit answers to the attached questions. 



