[From the U.S. Government Printing Office, www.gpo.gov]

                             United States General Accounting Office

 GAO                               Testimony

                              Before the Subcommittee on Oceanography, Great Lakes, and
                              Outer Continental Shelf, Committee on Merchant Marine and
                              Fisheries
                              House of Representatives

For Release
on Delivery
        Epectdt                   WATER POLLUTION
2:00 p.m. EST
Wednesday
October 30, 1991                   Ocean Dumping Fee Program Is

                              Meeting Statutory Requirements

GcI

                              Statement of
/0   J ul 1 jill                   Richard L. Hembra, Director
                              Environmental Protection Issues
                              Resources, Community, and Economic Development Division


                                          r
                                            Property of CSC Library



                                    \,D ~~U. S. DEPARTMENT OF COMMERCE NOAA
                                              COASTAL SERVICES CENTER
                                             2234 SOUTH HOBSON AVENUE
                                             CHARLESTON, SC 29405-2413







 GC
 1127.5
  .W38
 1991


 GAO/T-RCED-92-5
                                                                        GAO Form 160 (12/87)






Dear Mr. Chairman and Members of the Committee:

    We appreciate the opportunity to provide the results of our
review in response to your request for information on the
collection and disposition of fees authorized by the Ocean Dumping
Ban Act of 1988. Ocean dumping fee requirements were established
to encourage and assist sewage authorities that dump sludge to
develop and implement alternative measures for disposing of their
sludge. Specifically, you asked us to determine (1) how much
sludge had been dumped in the ocean in calendar years 1989 and
1990, (2) whether the correct fees were collected and deposited in
the proper accounts, and (3) what specific activities were funded
with the fees collected. In addition, we examined some of the
problems facing these sewage authorities in developing long-term
alternatives for sludge disposal.

    In summary, Mr. Chairman, we found that:

    -- Between August 15, 1989 (when ocean dumping fee requirements
       became effective) and December 31, 1989, 132,424 tons of
       sewage sludge were dumped at the 106-Mile Site. In calendar
       year 1990, 354,700 tons were dumped at the site.

     --Ocean dumping fees paid by the sewage authorities in 1989
       and 1990 totalled about $77 million, generally equaled or
       exceeded the amounts required by the dumping ban act, and
       were deposited in the proper accounts.

     --The fees collected were used for purposes consistent with
       the requirements of the act, including developing and
       implementing land-based sludge disposal alternatives,.and
       research, monitoring, and surveillance of ocean dumping
       activities.

    While sewage authorities have generally been successful in
developing short-term alternatives to ocean dumping that could be
implemented by the December 31, 1991 statutory deadline, they also
need to develop and implement long-term alternatives that will
provide a more permanent solution. The long-range alternatives to
the ocean dumping of sewage sludge may face some potentially
difficult challenges. Opposition by local residents, for example,
has thwarted plans to construct incinerators to burn the sludge.
In addition, those who plan to market sludge as a soil conditioner,
or fertilizer, or for other beneficial purposes will- have to meet
stringent pollution requirements and establish a steady market for
their sludge products.

    Before I discuss these issues in more depth, let me briefly
provide some information on ocean dumping of sewage sludge.







BACKGROUND

   When the Ocean Dumping Ban Act was enacted in November 1988,
one ocean dumping site was authorized by the Environmental
Protection Agency (EPA) for the dumping of sewage sludge, and nine
sewage authorities were authorized to use this site. That site was
the 106-Mile Deepwater Municipal Sludge Site, located off the coast
of New Jersey. Designated in 1984, disposal operations began in
1986, and by late 1987, nine sewage authorities (three in New York
and six in New Jersey) were using it.

    Although the specific characteristics of sludge vary, the
material dumped at the 106-Mile Site is primarily biological in
nature. Biological sludge may contain small amounts of debris,
such as grit, paper, and fibers; trace levels of organic
contaminants such as aldrin, dieldrin, chlordane, DDT and its
degradation products, and polychlorinated biphenyls or PCBs; and
metals, such as cadmium, copper, chromium, and mercury. Because
these contaminants can adversely affect marine life and human
health, and because the sludge can travel great distances in ocean
currents before settling to the ocean floor, ocean dumping
activities at the 106-Mile Site require continuous management and
monitoring by EPA, the National Oceanic and Atmospheric
Administration (NOAA), and the Coast Guard.

    The Ocean Dumping Ban Act set December 31, 1991, as the date
for all sewage authorities in the United States to cease dumping
sludge into the ocean. The act required the authorities to sign an
agreement with EPA and their respective states to phase out ocean
dumping and to obtain a new ocean dumping permit from EPA (or
terminate ocean dumping) within 270 days of act's passage. All
nine sewage authorities signed agreements to phase out ocean
dumping and obtained dumping permits by the August 15, 1989,
deadline.

    Sewage authorities agreed to develop interim land-based
alternatives to ocean dumping that could be implemented as soon as
possible and long-term alternatives that would provide a more
permanent solution. The interim alternatives generally consist of
dewatering the sludge to reduce its volume and trucking it to
landfills. Among the long-term alternatives selected by the
authorities are incineration and various forms of beneficial uses,
such as direct application on land and use as a fertilizer additive
or soil conditioner.

    The act requires the authorities to pay fees for each dry ton
of sludge they dump in the ocean between August 15, 1989, and
December 31, 1991. Since the moisture content of sludge can vary
considerably, using dry tonnage as the unit of measure means that
authorities are only assessed fees for the actual solids content of
their sludge. Ocean dumping fees increased from $100 per dry ton
in 1989 to $150 per dry ton in 1990, and to $200 per dry ton in

                                 2







1991. For any ocean dumping continuing after December 31, 19910,
sewage authorities will face significantly increased charges. The
act imposes penalties on the sewage authorities, beginning with
$600 per dry ton in 1992 and increasing in subsequent years.'

    The fees collected under the act are placed in separate
accounts to be used in specific ways. Eighty-five percent of the
fees are to be deposited in trust accounts set up by the sewage
authorities to pay for the development and implementation of
alternative measures for waste disposal, such as landfill,
incineration, or conversion of waste to beneficial uses. Of the
remaining 15 percent, $15 per dry ton is paid to EPA and evenly
split between EPA, NOAA, and the Coast Guard to pay for the
following responsibilities. EPA is responsible for negotiating
agreements for terminating ocean dumping, granting ocean dumping
permits, and monitoring sewage authority compliance with the
agreements and permits. NOAA's task is to monitor the impact of
ocean dumping activities on the environment. The Coast Guard is
responsible for surveillance of ocean dumping activities. To
coordinate these separate efforts, the three agencies jointly
developed a monitoring and surveillance plan and signed a
memorandum of understanding specifying each agency's
responsibilities for the management and oversight of ocean dumping
activities.

    After the fees are paid to the trust accounts and the federal
agencies, any balance is divided evenly between state Clean Oceans
Funds and water pollution control revolving funds of the states
where the sludge originates (i.e., New York or New Jersey).
Deposits in Clean Oceans Funds are returned annually to the sewage
authorities, with interest, to pay for the development and
implementation of ocean dumping alternatives. Deposits in state
revolving funds are used by the states to fund loans to
municipalities for water pollution qontrol projects.' A chart
depicting the collection and disposition of ocean dumping fees is
included in attachment I,

    We conducted our review at EPA headquarters and Region II in
New York City, NOAA headquarters., Coast Guard headquarters, state
agencies in New York and New Jersey responsible for ocean dumping
activities, and two of the nine sewage authorities disposing of
sewage sludge in the ocean. We also discussed with federal, state,
and sewage authority officials the feasibility of proposed long-
term alternatives to ocean dumping.

SEWAGE SLUDGE VOLUME

    Between August 15, 1989, when ocean dumping fees became
effective, and December 31, 1990, the nine sewage authorities
reported dumping 487,124 dry tons of sewage sludge into the ocean.
(The tonnage for each authority is shown in attachment II.) The
six New Jersey authorities ceased ocean dumping in March 1991, and

                                 3






two of the three New York authorities plan to cease ocean dumping
by December 31, 1991. The third.New York authority--New York City-
-plans to cease ocean dumping of 20 percent of its sludge by
December 31, 1991, and the balance by June 30, 1992. In accordance
with the act, ocean dumping continuing after December 31, 1991, is
subject to penalties of $600 per dry ton.

    EPA's processzfor determining dry tonnage for the purpose of
assessing fees appears reasonable. EPA-approved inspectors take
readings to determine the gallons of sludge placed on board a barge
at each sewage treatment plant, and EPA-approved shipriders take
similar readings when the barge is loaded and ready to leave for
the ocean dumping site. Each of these individuals files certified
reports with EPA on the volume of sludge they recorded. Samples
are taken of the sludge loaded at each facility and tested by EPA-
approved laboratories to determine the percentage of solids in the
sludge. The gallons of wet sludgd reported by the inspectors and
shipriders are mathematically converted to wet tons, and the
percentage of solids is then used to compute the dry tons of sludge
dumped in the ocean.

    According to EPA officials, another indicator of the accuracy
of sludge reported dumped in the ocean is historical data. The
nine sewage authorities haverbeen dumping sludge in the ocean for
many years. While it is normal to see fluctuations in sludge
generated as new areas are hooked up to sewers and as industries
change processes that affect the volume of discharges to the
sewers, EPA officials noted nonsignificant variations in sludge
volume reports when the ocean dumping fees went into effect.

FEE PAYMENTS

    Ocean dumping fees are due by the end of the month following
the quarter in which the dumping occurred. Thus, fees paid in
calendar year 1989 were based on sludge dumped between August 15,
1989, when the fee requirements became effective, and September 30,
1989. Similarly, fees paid in calendar year 1990 were based on
sludge dumped between October 1, 1989, and September 30, 1990.

    In 1989 and 1990, the nine sewage authorities paid a total of
$76.7 million into the ocean-dumping fee accounts. Of this amount,
$68.7 million was deposited in individual sewage authority trust
accounts, $2 million was deposited in the states' Clean Oceans
Funds and revolving funds, and $6 million was paid to EPA for use
by EPA, NOAA, and the Coast Guard. The breakdown of fees paid by
each of the sewage authorities into these accounts is shown in
attachments III through VI.






                                 4







USES OF OCEAN DUMPING FEES

    The Ocean Dumping Ban Act specifies permitted uses of fees
deposited in the separate accounts.. We found that the fees were
used for purposes consistent with the requirements of the act.

Uses of Trust Account Fees

    To ensure that ocean dumping fees deposited into trust accounts
are used to develop and implement ocean dumping alternatives, EPA
requires sewage authorities to submit plans covering a 6-month
period, detailing the work to be performed and including a payout
schedule for trust account withdrawals. These plans'are geared to
accomplishing specific segments of work in accordance with time-
phased schedules in each authority's agreement. Upon EPA's
approval of the plans, the authorities are free to withdraw trust
account moneys in accordance with the payout schedule.

    EPA does not verify that sewage authorities actually use moneys
withdrawn from trust accounts in accordance with their approved
work plan. Rather, EPA monitors authorities' progress in
developing and implementing ocean dumping alternatives in
accordance with time-phased schedules in each authority's
agreement. According to EPA officials, as long as the sewage
authorities remain on schedule, they believe there is little
likelihood that trust account moneys are not-being used in
accordance with the dumping ban act requirements.

    To check the validity of EPA's assertion, we reviewed the
actual uses of trust account funds by two of the largest sewage
authorities--Nassau County in New York and Passaic Valley in New
Jersey. We found that both had properly used trust account moneys
for EPA-approved expenditures, consistent with the Ocean Dumping
Ban Act. During 1989 and 1990, Nassau County deposited $2.27
million in its trust account and withdrew $479,610. In accordance
with its EPA-approved scope of work and payout schedule, the county
used this money to evaluate proposals from private vendors for
land-based management of sludge; assess the environmental impacts
of the recommended plan; implement a public participation program
to involve the public in the decision-making process for this plan;
and complete a feasibility study for sludge disposal from one of
the county's three sewage treatment plants.

    Passaic Valley had deposited $16.7 million in and withdrawn the
same amount from its trust account as of December 31, 1990. These
moneys were used for'designing and constructing sewage sludge
dewatering facilities for an interim land-based sludge disposal
alternative, and developing plans for a sludge incinerator for the
authority's long-term sludge disposal alternative.




                                 5






Uses of Clean Oceans Funds

    There were no withdrawals from the New York and New Jersey
Clean Oceans Funds in calendar years 1989 or 1990. Under the act's
fee structure, sewage authorities did not begin depositing fees in
these accounts until 1990. Since these fees are retained in Clean
Oceans Funds for up to 1 year before being returned to the sewage
authorities, the first use of these fees did not occur until 1991.

    We also reviewed the use of Clean Oceans Funds returned by the
states in 1991. We found that for Nassau County and Passaic
Valley, Clean Oceans Funds were used to supplement trust account
moneys for expenditures approved by EPA.

Uses of State Revolvincf Funds

    As with Clean Oceans Funds, ocean dumping fee, deposits to state
revolving funds did not begin until 1990. As of December 31, 1990,
deposits to the New York fund totaled $438,744; no funds had yet
been used.  Of the $555,457 paid into the New Jersey fund, $31,74
was obligated for a loan to the Middlesex County Utilities
Authority to help pay for a new sewage sludge dewatering facility
needed for land-based disposal of sludge.

Uses of Ocean Dumpina Fees bv
EPA, NOAA, and the Coast Guard

    Ocean dumping fees were first paid to EPA in November 1989.
EPA distributed these fees to NOAA, the Coast Guard, and the EPA
office responsible for ocean dumping activities in February 1990,
after procedures were established to transfer the moneys to the
agencies. During calendar year 1990, each of the agencies received
a total of $1.99 million. We found that each agency used its
portion of the fees for activities consistent with the requirements
of the dumping ban act.

    During 1990, EPA obligated about $1.52 million of its ocean
dumping fees, leaving an unobligated balance of about $465,915 as
of December 31, 1990. The activities EPA supported with ocean
dumping fees included (1) administrative activities associated with
implementation of the dumping ban act, (2) technical assistance
projects to help sewage authorities develop and implement
alternative disposal mechanisms, (3) activities related to the
restoration of a previously used, closer to shore ocean dumping
site, (4) research and monitoring activities conducted jointly with
NOAA, and (5) enforcement of its agreements with the sewage
authorities and of their dumping permits.

    NOAA used its portion of ocean dumping fees for research and
monitoring of physical conditions and effects of sludge dumping at
the 106-Mile Site. Of the $1.99 million in ocean dumping fees


                                 6







received by NOAA in calendar year 1990, NOAA obligated about $1.39
million through December 31, 1990, to support these activities.

    NOAA's physical oceanography studies focus on the physical and
chemical fate of the sewage sludge. The major objectives of these
studies are as follows:

    -- Examining the general water circulation patterns in the area
       of the 106-Mile Site and seaward as they affect the long-
       term, far-field transport of sludge constituents.

    -- Examining the characteristics and relationships between
       ocean current, surface temperature, and other water
       conditions in and near the dumpsite.

    -- Developing a better understanding of the accuracy of present
       estimates of sludge settlement patterns, the relationship
       between these patterns and the results of
       biological/chemical surveys, and the relationship of both to
       modeling results.

    NOAA also initiated biological/chemical studies to determine
the effects of sludge dumped at the 106-Mile Site on marine life at
the site and elsewhere in the area, and what threat dumping poses
to human consumers of these resources or to other users of the
Bight's resources.

    During calendar year 1990, the Coast Guard obligated about
$1.97 million of its ocean dumping fees for the surveillance of
ocean dumping activities, leaving an unobligated balance of $22,096
as of December 31, 1990. The majority of these obligations
supported purchases and operations (aircraft, vessels, personnel,
and administration) for the Coast Guard's ongoing Ocean Dumping
Surveillance System program. Beginning in fiscal year 1991, the
Coast Guard's budget was reduced by the amount of anticipated ocean
dumping fees. For the first quarter of fiscal year 1991, about
$451,355 in ocean dumping fees was used to offset the budget
reduction.

LONG-RANGE ALTERNATIVES TO
OCEAN DUMPING ARE UNCERTAIN

    The Ocean Dumping Ban Act requires that the-ocean dumping of
sludge cease by December 31, 1991. Anticipating that the sewage
authorities would be unable to develop permanent, land-based
alternatives for sludge disposal by the deadline, agreements were
negotiated by EPA and the states with each of the authorities to
develop and implement both interim alternatives and long-term
alternatives that could provide a more permanent solution.

    Interim alternatives selected by the authorities generally
consist of drying the sludge and trucking it to landfills. Since

                                 7







landfill capacity is limited, EPA does not consider this
alternative viable over the long term.

   Among the long-term alternatives selected by authorities are
incineration and various forms of beneficial uses, such as direct
application on land and use as a fertilizer additive or soil
conditioner. Public opposition to incinerators, changes in
regulations governing beneficial uses of sludge, and availability
of markets for sludge products have all contributed to
uncertainties regarding the implementation of these long-term
alternatives.

    Constructing incinerators has evoked strong public opposition
in communities proposing this long-term alternative because of
concerns over air quality and odor. originally, five sewage
authorities selected the incineration option. Because of the
public opposition to incineration, however, these authorities
investigated beneficial use options instead. Currently, it appears
that one of the five will proceed with incineration while four may
be able to implement beneficial-use alternatives.

    However, while beneficial-use alternatives for long-term
disposal of sludge are desirable and encouraged by EPA and the
states, they also face a number of barriers. First, they will have
to meet stringent new pollution requirements scheduled to take
effect in 1992. Presently, those using sludge for beneficial uses
must comply with existing state or federal contaminant levels to
determine whether their sludge can meet health and environmental
protection requirements. In February 1989, EPA proposed
regulations that would substantially strengthen these limits. As
we reported in March 1990, however, many state sludge program
officials, treatment plant officials, and scientists expressed
concern that EPA's proposed regulations were so stringent that they
would reduce or eliminate beneficial uses of sludge.' We reported
that a survey by the Association of Metropolitan Sewerage
Authorities found that only I of the 25 responding treatment plants
with beneficial-use programs could continue if EPA's regulations
were implemented.

    On the basis of revisions recently made to the proposed
regulations, EPA officials, state sludge program officials, and
officials of the sewage authorities planning on implementing
beneficial uses now believe that EPA's final regulations will not
be so stringent as to preclude beneficial use. However, until the
final regulations are issued, their impact cannot be assessed.

    Even if EPA's final sludge regulations do not preclude
beneficial uses, an effective beneficial-use program requires a

'Water Pollution: Serious Problems Confront Emerainq Municipal
Sludue Manaciement Procxram (GAOIRCED-90-57, Mar. 5, 1990).

                                 8







steady market for the sludge product. With many sewage authorities
considering beneficial-use options, some authorities are concerned
that the market for sludge products could quickly become Saturated.
To reduce the impact of such market fluctuations for sludge
products, some"O'uthorities are planning to implement a variety of
beneficial uses. New York City,, for examp~le, plans to market some
of its sludge as a fertilizer additive, some as a landfill cover,
and some for direct land application on permitted farms and
range lands.

    Thus, achievement of the act's goal of finding alternatives to
c,~ean dumping of sludge depends on the ability of sewage
authorities to surmount a number of potential obstacles. While
some of these obstacles may not be as insurmountable as once
anticipated, finding environmentally safe alternatives to ocean
dumping will likely pose challenges to sewage authorities in the
future.



    In summary, Mr. Chairman, we found that the collection and
disposition of ocean dumping fees has been implemented in
accordance with the provisions of the ocean Dumping Ban Act. We
also found that implementing long-term alternatives to ocean
dumping faces some formidable challenges.

    This concludes my prepared statement and our reporting on this
issue. We would be pleased at this time to respond to any
questions.
























                                 9






ATTACHMENT I                                                                                       ATTACHMENT I


                               PAYMENT OF OCEAN DUMPING FEES




                                                 Fee







                           85%
                   Ocean Dumpers Trust
                   Accounts To DevelopEP
                   and Implement Ocean            EPAisrbtino
                                 Dumping Alternatives                     ~~~$5/Dry Ton Each To




                                                                        EPA For Permits,
                                                                       Impacts, and Studies

                                                                  -   NOAA For Monitoring

                                                                -       ~~Coast Guard For
                                                                          Surveillance










                   Clean Ocean Fund                                          Clean Water Act
               Fund Payments Are Returned                                     Revolving Fund
               To Ocean Dumpers Annually                                 For Water Pollution Coh~trol
                  For Use In Developing                                   Projects. But Restricted
                 and Implementing Ocean                                    From Use By Persons
                   Dumping Alternatives                                         Paying Fees











                                                   10







ATTACHMENT II                                             ATTACHMENT II


                    SEWAGE SLUDGE DUMPED IN OCEAN
                               (Dry Tons)

                         Aug. 15, 1989    Jan. 1, 1990
                              to               to
Sewaae Authority         Dec. 31, 1989    Dec. 31, 1990         Total
New York City                    46,622           123,441      170,063
Nassau County                     7,337            17,066       24,403
Weschester County                 5,011            13,244       18,255
Passaic Valley                   50,490           134,392      184,882
Middlesex County                 13,936            40,779       54,715
Bergen County                     4,221            11,566       15,787
Joint Mtg. of Essex &             2,725             8,511       11,236
  Union Counties
Rahway Valley                     1,553             3,905        5,458
Linden Roselle                      529             1,796        2,325
  Total                         132,424           354,700      487,124







ATTACHMENT III                                          ATTACHMENT III


                      TOTAL OCEAN DUMPING FEES
             AUGUST 15, 1989, THROUGH-DECEMBER 31, 1990


                             Amount         Amount       Over/(Under)
Sewaae Authority              Due             Paid          Payment
New York City             $18,414,083    $18,735,145    $   321,062
Nassau County               2,671,117       2,671,117
Weschester County           2,048,514       2,048,514
Passaic Valley             19,657,469      19,639,120         (18,349)
Middlesex County            6,037,047       6,037,047
Bergen County               1,729,944       1,729,944
Joint Mtg. of Essex &       1,247,958      24,897,719      23,649,761
  Union Counties
Rahway Valley                 618,908         626,236           7,328
Linden Roselle                272,335         272,335
  Total                   $52,697,375    $76,657,177    $23,959,802


Note: See notes in appendixes IV through VI for explanations of
       over/(under) payments.


























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ATTACHMENT IV                                           ATTACHMENT IV


         PAYMENTS OF OCEAN DUMPING FEES TO. TRUST ACCOUNTS,
             AUGUST 15, 1989 ,THR6[UWD  EM    31 990

                             Amount        Amount      Over/(Under)
Sewaqe Authority               Due           Paid          Payment
New York City             $15,651,970    $15,924,866    $   272,896
Nassau County               2,270,449      2,270,449
Weschester County           1,741,237      1,741,237
Passaic Valley             16,708,848     16,690,499         (18,349)
Middlesex County            5,131,490      5,131,490
Bergen County               1,470,4521  1,470,452
Joint Mtg. of Essex &       1,060,764     24,710,52'5 23,649,761
  Union Counties
Rahway Valley                 526,071        533,399           7,328
Linden Roselle                231,485        231,485
  Total                   $44,792,766    $68,704,402    $23,911,636


Notes: 1. New York City bases its fee payments on the actual volume
       of sludge dumped in the first 2 months of a calendar quarter
       and an estimated amount for the third month of the quarter.
       The next quarterly payment is then adjusted to reflect the
       proper fees for the prior quarter, on the basis of the
       actual amount of sludge dumped. The excess fee payments are
       attributable to this sludge-estimating practice.

       2. The shortage in trust account deposits by Passaic Valley
       was due to a clerical error.

       3. With EPA concurrence, Joint Meeting established a
       multipurpose trust account to deposit the required ocean
       dumping fees and to pay for developing and implementing its
       ocean dumping alternative system for disposal of sludge.
       Thus, deposits to the trust account exceeded the minimum
       amounts required on the basis of the volume of sludge dumped
       in the ocean.

       4. Rahway Valley mistakenly deposited $7,328 intended for
       EPA to its trust account.






                                 13








ATTACHMENT V                                               ATTACHMENT V


             PAYMENTS OF OCEAN DUMPING FEES TO STATES'
               'CLEAN OCtANS'FUND AND REVOLVING FUND,
             AUGUST 15, 1989, THROUGH DECEMBER 31, 1990

                           Amount Due    Amount Paid    Over/(Under)
Sewaae Authority            Each Fund       Each Fund        Payment
New York City                 $343,800        $351,623          $7,823
Nassau County                   48,435          48,435
Weschester County               38,686          38,686
Passaic Valley                 365,211         365,211
Middlesex County               116,087         116,087
Bergen County                   32,696          32,696
Joint Mtg. of Essex &           24,386          24,386
  Uiion Counties
Rahway Valley                   11,590          11,590
Linden Roselle                   5,487           5,487
  Total                       $986,378        $994,201          $7,823


Note:  New York City bases its fee payments on the actual volume of
       sludge dumped in the first 2 months of a calendar quarter
       and an estimated amount for the third month of the quarter.
       The next quarterly payment is then adjusted to reflect the
       proper fees for the prior quarter, on the basis of the
       actual amount of sludge dumped. The excess fee payments are
       attributable to this sludge-estimating practice.




















                                  14







ATTACHMENT VI                                            ATTACHMENT VI


               PAYMENTS OF OCEAN DUMPING FEES TO EPA,
             AUGUST 15, 198:9w HR0GH'DEG  ER-3'71990

                              Amount        Amount       Over/(Under)
Sewaqe Authority               Due            Paid          Payment
New York City              $2,074,512      $2,107,032         $32,520
Nassau County                 303,798         303,798
Weschester County             229,905         229,905
Passaic Valley              2,218,197       2,218,197
Middlesex County              673,383         673,383
Bergen County                 194,099         194,099
Joint Mtg. of Essex &         138,422         138,422
  Union Counties
Rahway Valley                  69,657          69,657
Linden Roselle                 29,877          29,877
  Total                    $5,931,850      $5,964,370         $32,520




Note:  New York City bases its fee payments on the actual volume of
       sludge dumped in the first 2 months of a calendar quarter
       and an estimated amount for the third month of the quarter.
       The next quarterly payment is then adjusted to reflect the
       proper fees for the prior quarter, on the basis of the
       actual amount of sludge dumped. The excess fee payments are
       attributable to this sludge-estimating practice.



















                                 15
















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