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The applicant should start with a discussion of the reason(s) for the utiliza- tion of the sludge. The discussion should be accompanied by a map showing the locations of the application and a timetable of application on each area. A brief discussion of terrain, soils, overburden, ground water, and vegetation at the site would be appropriate. The applicant should then discuss the source of the sludge and a brief dis- cussion of the industrial, commercial and domestic sources from which the sludge is derived. Based on this discussion, the Division and operator can decide on the required chemical analysis to be performed on the sludge, with the minimum analysis being the attached list. If the producer of the sewage sludge has already analyzed the sludge, the applicant should obtain and submit all data available. The applicant may wish to make a proposal on the required chemical analysis. The proposal should be justified as much as possible. The applicant should address the biological stability of the sludge and whether it meets Department of Health guidelines. This information is needed to process sludge weight and volume, pathogen content, odor and putrescibility. A general discussion is then needed on the method of transportation and method of application and incorporation of the sludge. Transportation and application should be tailored to the site to minimize the possiblity of pollution or con- tamination. Based on the results of the chemical analysis, the applicant should propose an application rate in tons/acre/year. This rate should be adjusted to achieve the operator's goals, prevent surface and ground water pollution, and insure effect- ive revegetation and the post-mining land use. The application rate should be justified by including loading calculations for nitrate and any other con- stituent of the sludge in high concentration. Erosion rates, soil texture and characteristics, depth to ground water, location of wells, location of surface water bodies, and vegetation types should be discussed to verify that the ap- plication rate will be environmentally safe. Finally, the application should discuss and propose a monitoring plan to insure the consistency of the sludge characteristics and verify the effects on surface water, ground water, or vegetation. The plan should detail sludge sampling frequency, method of collection, the list of parameters the sludge is to be analyzed for, the location of surface and ground water monitoring sites, a list s of surface and ground water parameters to be analyzed, and the frequency of analysis. Sludge analysis should include at least the list of parameters out- lined on Table 1 of this document, but the Division may require additional parameters based on application rates and the applicant's discussion of the source of sludge and waste contributors. RESPONSE: In recent years the disposal of sewage sludge has become a problem. In the past sludge has been disposed of by incineration, landfilling, ocean dumping, or land application. Several economic and environ- mental factors have made land application the best disposal system for the Steamboat area. As defined by H111, 1976, there are two types of land application practices: I. Land disposal calls for multiple applications of sludge, which could cause a build up of pollutants; and ,rr~4 rti 9.:. ~.