251 



Incorporating these changes, we have lowered our estimated 

 annual cost to go to the 106 mile site from $26.72 million to 

 $23.22 million. 



It should be noted that in presenting our annual operating cost 

 for sludge disposal at the 12 mile site for 1982, we show a 

 figure of $6,224,285. We believe this figure does not 

 accurately reflect our average annual operating costs because 

 it contains a cost of $2,396,000 for repairs, maintenance and 

 supplies. Of this amount, $2,123,600 was spent for shipyard 

 repairs. This figure is approximately double the average 

 annual expenditure for this item. 



In addition, because the vessel Owls Head was laid up the 

 entire year, the amount required for private barging was 

 increased. 



It would appear, that based on the recent work done by New York 

 City and its consultants, Ecological Analysts, Inc. and 

 SEAMOcean, Inc., in the preparation of a Special Permit 

 application as well as the Site Designation comment documents. 

 New York City's sludge will meet existing criteria for ocean 

 disposal . 



It appears, that because of the decreased usage of PCB ' s and the 

 possible over estimate of PCB ' s once thought to be contributed 



