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<br />The general procedure for obtaining approval from MI.RD is as follows: <br />a. Obtain and submit a "letter of approval" from the Department of Health, <br />Water Quality Control Division. <br />RESPONSE: Pursuant to correspondence between CYCC and the Water Quality Control <br />Division, a letter of approval was granted for the application of <br />sewage sludge as a reclamation practice. The letter of approval is <br />presented in Exhibit 1 (Letters of Approval). <br />b. Contact the Colorado Air Pollution Control Division to determine what, if <br />any, information will be needed to bring the existing air quality permit <br />into compliance. Document that this has been accomplished either by a <br />letter from APCD, which states nothing is required, or a copy of the <br />revised application/permit. <br />RESPONSE: The Colorado Air Pollution Control Division determined that nothing <br />will <br />be required to retain air quality compliance; by the addition of <br />sewage sludge, on a reclamation practice. The letter of approval is <br />presented in Exhibit 1 (Letters of Approval). <br />c. If it was not covered in the original permit, the applicant should provide <br />a discussion of the probable hydrologic consequences of the activity (Rule <br />2). <br />RESPONSE: Due to the low proposed application rate, there are no forseeable <br />hydrologic consequences from the addition of sewage sludge as a re- <br />clamation practice. A discussion of hydrologic consequence is pre- <br />sented in greater detail in the approved Permit 79-177, Section <br />816.21(c), page 780-175. <br />d. Submit all relevent data required by MLRD to show compliance with the , <br />Performance Standards of Rule 4. <br />In developing the information needed to verify compliance with the Performance <br />Standards, the applicant should consider and address all of the potential prob- <br />lems associated with sludge disposal. Sludge characteristics vary according [o <br />the properties of the raw waste water entering the treatment plant and, in turn, <br />the raw waste water characteristics vary according to the type and amount of <br />industrial, commercial, and domestic waste dischargers to the plant. The type <br />of processing units used at the treatment plant will also have a bearing on the <br />characteristics of the sludge. Depending on the application rates, sludge <br />disposal may affect [he environment in many ways. The constituents in the <br />sludge may be toxic to some plants, which would inhibit or prohibit their <br />growth. Other plants may be tolerant to these elements, but may accumulate <br />harmful quantities in the leaves and stems. This may pose a problem to animals <br />who utilize these plants. Ground water contamination has also been shown to be <br />a problem if significant amounts of soluble elements are leached from the <br />sludge. Surface water may be contaminated from spills, from the contaminated <br />ground water, from contaminated interflow, or from surface runoff in contact <br />with the sludge. Pathogens, although short-lived, may pose health concerns. <br />Finally, odors may be present from the decomposition of the sludge. Again, the <br />presence and significance of these problems will depend in part on the sludge <br />characteristics and the application rate. <br /> <br />.:a.: <br />^ rrZ.'. <br />.. ~ .:..?.. f <br />