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�. BLACK & VEATCIO <br /> CONFERENCE MEMORANDUM <br /> Summit County, Colorado <br /> Continuing Consultation on B&V Project 6913.007 <br /> Plant Operations 2 May 23, 1990 <br /> The CDH Notice of Authorization will be issued to Summit County as the <br /> generator/applicator of the digested sludge. Incorporation of the sludge <br /> onsite does not require that Climax acquire a permit from the CDH. Phil <br /> said he will send a letter to Climax confirming that Climax does not need <br /> a CDH permit if they are simply allowing sludge to be applied to their <br /> tailings areas and incorporating the sludge into the soil. Phil also indi- <br /> cated that a certificate of designation is not required for this beneficial <br /> use sludge application program. The Board of Summit County Commissioners <br /> may, however, issue one to themselves if their own regulations require that <br /> they do so. <br /> While the vegetative cover will not be a food chain crop, Phil requested <br /> that crop tissue testing be performed as if it were. This data will help <br /> him evaluate the overall effect of the land application program. Summit <br /> County agreed to provide crop tissue, soil, and thickened sludge testing in <br /> accordance with CDH's Domestic Sewage Sludge Regulations. In addition, the <br /> County will perform CDH's end-of-application tests for those acres which <br /> receive the reclamation loading of 25 dry tons/acre. Summit County will <br /> send copies of all such tests to Climax. <br /> Colorado Division of Mined Land Reclamation (MLRB) <br /> To allow for the sludge application program, John indicated that Climax <br /> would need to submit a technical revision to their current reclamation <br /> plan. Upon receipt of a complete and approvable revision, the MLRB will <br /> issue a letter amending the current plan. John also indicated that <br /> three test plots be utilized to evaluate the use of sludge for interim <br /> reclamation of the tailings areas: <br /> • Adjacent undisturbed soil and vegetation. <br /> • Reclamation soil with Climax's fertilizer and seed mix. <br /> • Sludge-amended reclamation soil with Climax's seed mix. <br /> Climax/AMAX <br /> As a precaution, Climax asked Summit County to continue performing TCLP <br /> metal tests on its thickened sludge on an quarterly basis. Summit County <br /> agreed to provide quarterly testing for TCLP metals and will send copies of <br />