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aa~e ayye e4-~rrri rrt~ 5r~-nit rxvU 5rnnw-~ i~ i~~ma~ ~ <br />- Sludge m mclamatam • Apri12. 1996 • Page <br />Substitute Plant Growth Medium <br />As I understand, there is little available soil material on the slopes of tl :axes: <br />According to the BLM, application of sludge would add organic material to the :xistin <br />decomposed rock material and form a substitute plant growth medium. This 1, gic ha <br />sot been proven in practical applicadon. Plant gn ~wth materials and topsoil c main <br />mix of decomposed parent material and organic material, sorted and modified o er lon. <br />periods of time. Application of sludge (orgaxuc material) over rack (decomF ,sod o <br />not) will not provide a suitable plant growth material. Short term benefits may :xist i. <br />the establishment of graminoid species, but long term studies indicate a ;energy <br />senescence of the species and decline in biological diversity. Further, woody specie <br />(trees and shrubs) have not persisted long term in these situations. <br />Ruuot7 Coataminatlon <br />Alluded to earlier, sludge contains constituents which axe mobile in the envirr nment <br />through release in a gaseous state, or dtxough suspension it ~ water. Sludge app Ocatio <br />would subject Mid-Continent Resources and Firkin Iron to long-term monitcring c <br />surface water (and possibly groundwater) resources in the area of sludge application t <br />ensure that regulated constituents do not exceed maximum allowable releases. 1 <br />exceedances owurred, Mid~ontinent Resources and Pitlrin Iron would then be liabl . <br />for mitigation through treatment, containment, or other means. <br />odor <br />One of the greatest drawbacks with sludge is the odor of the material. Foun I <br />objectionable by many people, this one factor inhibits the use of sludge nearly as muc <br />as the chemical rnmposition. Initially, one might not consider this a problem at thi; <br />site, however, downwind residents may have thoughts on the application of sludge. <br />Sledge Application <br />My experience with sludge application has been in water reclamation projects where the <br />sludge was applied over xr=iatively flat areas (agricultural fields or flat mice sites). 1 <br />question whether it is practical to apply sludge to the reladv~ ty steep slope of the <br />quarry site with any sucxegs. 1 further question the need the ap, ly sludge to the roads <br />to ba reclaimed. Based on my experience, acrd experience of ,thcr mines and plant <br />matwriata researchers in the intermountain west, establishment o woody species (trees <br />and shrubs) is best accomplished is environments devoid of grasses, that is, soil <br />mat 'At with less organic material and coarser texture, which favor woody species <br />growth. Application of sludge on the roads would favor she t-term graminoid re- <br />establishment at the expense of shrubs and trees. <br /> <br />TOTRL P.03 <br />• 09/03/95 15:24 ~X N0.0177 P.003 <br />