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04-02-1996 04.50PM FROM SRVAGE RtJD SR4IRGE TO 19`?~ P. 02 <br />• • • III IIIIIIIIIIIIIIII <br />999 <br />Savage and Savage <br />l.aed Rrstararicm and Reclamamn s~.w <br />Aiemorandnm <br />To: Diane Delaney, Pitlda Iron Corporation <br />Fltom: Michael Savage <br />Date: April 2, 1996 <br />Subject: Proposed use of sludge in reclamation of the Mid-Continent Quarry <br />kTile ti`: <br />I have reviewed portions of the approved mining and reclamation plan for tl~e E4id- <br />Continent limestone quarry. I have also reviewed the BLM proposed modifications to <br />the reclamation plan which, among other things, proposes the use of sludge as a "soil <br />enhancer.' At your request, I have evaluated the merits of using sludge as a soil <br />amendment at the Mid-Continent limestone quarry and have concluded that use of <br />sludge is not advisable at this site. My reasons follow. <br />Hazardous Waste Potential <br />Sludge, being a by-product of municipal and/ar industrial waste treatment has the <br />potential to ~~~+~ materials or chemicals which may be characterized as hazardous or <br />toxic by the U.S. Environmental Protection Agency. Further, while the sludge may <br />not contain hazardous or toxic materials, it will lila;ly contain small amounts of <br />hydrocarbons and heavy metals. None of these chemicals or metallic constituents <br />would be desirable to reintroduce into the environment at the quarry site. Aside from <br />potential liability under RCRA, the Clean Water Act and other aMS regulating <br />placement and disposal of haanrdaus and toxic materials, Mid-Continent and Pitldn Iron <br />would assume responsibility four initial assessment of sludge composition and post- <br />application monitoring of the sludge to ensure that any constituents contained in the <br />sludge did not violate limits of any NPDIsS or discharge permits. <br />Nutrient Cycling <br />Presuming the sludge originated from a municipal source, the ma}ortty of the sludge <br />would be carbon based materials. Application of the sludge with high carbon content <br />to material which is predominantly decomposed rock, could bind plant growth macro- <br />and micro- nutrients within the sludge, making the nutrients unavailable to plants. This <br />phenomenon has been observed at mine sites where heavy applications of mulch <br />(usually straw, hay, wood chips, or sawdust) have been applied fA retain moisture and <br />reduce erosioe_ Plant nutrients are bound within the mulch, and remain unavailable to <br />plants, thereby resulting in roduoed biomass production and stunted growtit_ <br />• 04/03/95 15:98 ~RX N0.0179 <br />TOTRL P,02 <br />P.002 <br />