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i ' Response to Payment Summary Sanitary Sewer Discharge and NP DES Permits USTCF Claim # 009449 Page 2 of 2 approve such a request, they could require a fee which has not been determined. The permit application fee (and annual renewal fee) to the State is currently $5 , 688, and does not include the cost for application development. At a minimum, it is anticipated that the additional testing for application consideration would exceed $ 6,000 . These analytical costs would result primarily from conducting the three-species toxicity testing (which is an annual requirement of the permit) . We contacted two sources for estimated costs for this testing and one said "over $ 6,000" and one said "over $ 10, 000 . " The permit also requires monthly upstream and downstream testing that is in addition to all the monitoring we are currently conducting. Of course, it is possible that even if we conducted all the required testing and paid the fee to submit the application, discharge under the permit could be denied by the Regional Board. The result of all this is that it is likely that discharge under the permit would not be allowed, and if allowed, would not result in any significant savings (and could actually cost more) . A brief evaluation of land disposal was dismissed as all the surrounding land is developed. A brief evaluation of transport for disposal was also dismissed due to costs of $35,000 to $ 85,000 per month based on costs of $0 . 50 to $ 1 . 10 per gallon for transportation and disposal. If you have any questions, or if you would like to discuss this further during your review of this claim, please call me at (209) 234-0518 . Respectfully, CONDOR r'EARTH �TECHNOLOGIES , INC . Suz�Cotton UST Cleanup Fund Administrator cc : Remo Canepa Jeffrey C. F . Wong, SJPHS/EHD . PAI 000 jri\1707 Canepa\USTCF\RR 22\1707 Payment Summary Lor RR 22 5-11 -05.doc 4M ; � CONDOR