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                        DRAFT


           ENVIRONMENTAL IMPACT STATEMENT

                         on

        MANAGEMENT PLAN FOR WASTEWATER SLUDGE
BY METROPOLITAN DENVER SEWAGE DISPOSAL DISTRICT NO.  1
                  DENVER, COLORADO

            EPA Project Number:   C0080341
                         by
        U.S.  ENVIRONMENTAL PROTECTION AGENCY

                 REGION VIII,  DENVER
                      May 1976

            Approved  By:    John  A.  Green
                           Regional  Administrate
                      &
  Prepared under Contract Number 68-01-2860 between
                              Engineering-Science, Inc.
     EPA          and              600 Bancroft Way
                             Berkeley, California  94710

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       Metropolitan Denver Sewage Disposal  District  No.  1
                        Denver, Colorado
                    EPA Project No.  C-0030341


(x) Draft                 ( )  Final  Environmental  Impact Statement

1.  Name of Action:      (x) Administrative        (  )  Legislative

2.  Description of Action:  The Metropolitan Denver  Sewage Dispos-
al District No. 1  (Metro) has  proposed to construct  the necessary
facilities to transport sludge to a  site in Adams  County for air
drying in earthen basins, stockpiling in above-ground windrows and
distributing to the farming community to be reused on land for grow-
ing crops.  It is envisioned that anaerobically digested sludge--
digester construction already being  funded by EPA--in the
amount of 107 dry tons per year will  be produced in  the design
year 1985.  The types of lands expected to receive sludge from
Metro include city parks in the metropolitan area, sod farms, mine
spoil sites, irrigated farms,  nonirrigated farms and home gardens.
It is assumed that application rates will be consistent with the
nutrient uptake rate of the growing  plants and that  sludge applica-
tion on a given piece of land will be terminated when the heavy
metal loading limit specified for that particular land will  have
been reached.

3.  Environmental  Impacts:

    A.  At the sludge drying and distribution center:

        (1) Soil, as an agricultural  resource, will  be lost from
the 600-acre drying basins.

        (2) Groundwater quality will  gradually be deteriorated by
the leachates from the bottom of the drying basins,  carrying salts,
including nitrates, to the water table.

        (3) An increased amount of water over that now consumed in the
existing sludge disposal practices of Metro will be carried in sludge,
purge water and additional irrigation water to the Adams County site,
reducing flows in the South Platte River downstream of the Central Plant,

        (4) A sizable saving in transport -energy (8 million KWH/
yr) will be realized over the current method of sludge disposal.
In addition, about 20 million KVJH/yr of equivalent energy will be
saved if all the sludge is successfully marketed to replace com-
mercial fertilizer.  If the digester gases are converted into
usable energy, another major saving of  50 million KWH/yr will be
realized.
ing
ers
    (5) Odors generated in the drying basins—especially dur-
digester upsets--may be objectionable to the surrounding farm-
and other residents.

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          (6)  Severe effects on soils, plants and the groundwater
 would occur  if the site were to be used for a disposal area.


     B.  At the sludge reuse areas:

          (1)  Introduction of heavy metal elements, particularly cad-
 mium, into the soils and the food chain, and their gradual  concen-
 tration magnification in various tissues, poses a health hazard to
 humans and possible reduction in yield of crops.  These hazards are
 the greatest in home gardens and on irrigated farms.

         (2) Longevity of certain parasites such as Ascaris  beyond
 the drying/storage period comprises a public health hazard, espe-
 cially in home gardens and city parks.

         (3) Water quality degradation from salt and nitrate movement
 below the root zone in home gardens,  irrigated farms,  city  parks  and
 sod farms is  a long-term, cumulative  impact.

         (4) Air quality may be  degraded by particulates and aero-
 sols during severe windstorms,  especially in dry-farmed areas.

         (5) Soil  productivity will  improve (although salinity will
 gradually increase)  with the  addition of the organic matter in  the
 sludges,  resulting in  improved  vegetative growth and crop produc-
 tion.

         (6) Conservation of natural resources,  especially fossil
 fuels  and  plant nutrients,  is a  prime reason for,  and  the most
 salient beneficial  impact of, the  project.
    C.  At  the  Lowry  Bombing Range sludge disposal area:

        (1) Heavy metal elements are introduced into the food chain
through grazing of livestock on the sludge-amended fields.

        (2) A potential public health hazard to the operators at
the Bombing Range is  posed by the raw sludges now deposited.

        (3) There is  a threat to groundwater quality from the move-
ment of salts (particularly nitrates) below the root zone.

        (4) Even though soil structure and water-holding capacity
will increase, excessive salt and nutrient loading rates will some-
what limit the increase in productivity.


        (5) The sludge drying practices and transport method to carry
sludge to  the Bombing Range use large amounts of energy.

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        (6) Large amounts of chemicals are used to reduce odors
and dewater the sludge under present operation.

        (7) The Metro Central  Plant will  experience increases  in
loadings of suspended solids,  BOD and ammonia due to return  of
supernatant from the anaerobic digesters.
4.  Alternatives:  Sixteen alternatives, ranging from no action to
heat treatment-air drying-landfill  to vacuum filtration-pipeline
transport and recycling with solid wastes were considered.   They
are summarized in Tables 1 and 2.

5.  Distribution:  The distribution list is presented in Appendix H.

6.  Draft Statement Sent to Council on Environmental  Quality:


7.  Final Statement Sent to Council on Environmental  Quality:   N.A.

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                        TABLE OF CONTENTS
List of Figures

List of Tables

Section

  I         BACKGROUND                                           1
               Introduction                                      1
               The Reason for  This  Document                       2
               History of the  Project                             5
               The Proposed Action                                7
                  Financing the  Project                          10

  II        ALTERNATIVES  TO THE  PROPOSED ACTION                  11
               Introduction                                     11
               Historical  Development of Alternatives            12
               Comparative Evaluation of Sludge Treatment        14
                 System Alternatives
               Sub-System Alternatives                           22
                  Sub-System Alternatives  to  the Metro  Land      22
                    Recycling  Proposal
                  Sub-System Alternatives  to  the Present         32
                    Lowry Disposal  System

  III        ENVIRONMENTAL SETTING                                35
               Climate                                          36
                  Temperature                                    36
                  Precipitation                                  36
                  Wind                                          36
                  Regional Climatic Variations                   41
               Topography                                       41
               Geology                       -                   44
                  Earthquakes                                    51
               Soils                                            52
               Water                                            54
                  Groundwater                                    54
                  Surface Water                                  55

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                   TABLE OF CONTENTS  (Continued)


Section                                                      Page

               Biology                                         56
                  Cultivated Lands  Unit                         58
                  Uplands Unit                                 59
                  Riparian and Aquatic Unit                     59
                  Urban/Residential Unit                        60
                  Rare and Endangered Species                   61
               Air Quality                                     64
                  Odor                                         68
               Archaeology and History                          71
               Land Use                                        71
               Land Tenure                                     73
               Population                                      73
                  Regional Population                           73
                  Metropolitan Denver Sewage Disposal Dis-      75
                    trict No.  1
                  Adams County                                 75
                  Population Projections                        76
               Transportation  and Circulation                   76
               Recreation                                      80
               Institutional  and Governmental Agency Juris-     80
                 dictions
               Socio-Economic  Setting                           82
                  Adams County Agricultural Economy             82
                  Sources of Fertilizer                         82
                  Urban/Rural  Characteristics                   84
                  Land Values                                   84
                  Employment                                   86
               Visual  Aesthetics                                86
               Public  Health                                   87

  IV        DESCRIPTION OF PROPOSED ACTION                      39
               Sludge  Treatment                                89
               Sludge  Transport System                          91
               Sludge  Drying and Distribution Center            92
                  Sludge Drying and Distribution  Center  Site    92
                    Selection
                  Drying and Distribution Center  Operation      93
                    and Layout
               Proposed Land Application of Sludge  by Metro     96
                 Denver
                  Sludge Recycling  Areas                        98
                  Sludge Disposal at  Lowry Bombing  Range       105
                    (No Action)

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                  TABLE OF  CONTENTS  (Continued)


Section

  V         ENVIRONMENTAL  IMPACTS OF THE PROPOSED ACTION       109
               Introduction                                   109
               Impact of Sludge  Processing, Transfer,          109
                 Drying and Distribution
                  Soil  Loss                                   109
                  Water                                       110
                  Public Health                                112
                  Loss  of  Habitat                              117
                  Air Quality                                 117
                  Noise                                       120
                  Energy Use                                  121
                  Aesthetics                                  123
                  Plant Operation and Plant Effluent           124
                    Quality
                  Natural Resources                            124
                  Archaeology and History                      125
                  Land  Use                                     126
                  Land  Tenure                                 127
                  Population                                  127
                  Transportation and Circulation               127
                  Recreation                                  129
                  Governmental Agency Jurisdiction             130
                  Employment                                  130
                  Land  Values                                 130
                  Construction Impacts                         131
                  Secondary Impacts                            132
                  Summary of Impacts at the Sludge Drying      135
                    and Distribution Center
               Impacts  of Land Application of Sludge on        137
                 the Recycling Areas
                  General                                      137
                  Food  Chain                                  141
                  Public Health                                143
                  Water Quality                                145
                  Soil  Properties                              148
                  Air Quality                                 154
                  Flora and Fauna                              156
                  Noise                                       162
                  Aesthetics              -                    162
                  Natural Resources                            163
                  Traffic and Circulation                      164
                  Agricultural Economy                         164
                  Land  Values                                 165
                  Summary of Land Application of Sludge on     165
                    the Recycling Areas

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                  TABLE OF CONTENTS  (Continued)


Section                                                      Page

               Impacts  of Subsurface  Injection of Liquid       166
                 Sludge at the  Drying/Distribution Center
               Impact of Sludge Disposal at Lowry Bombing      167
                 Range
                  Food  Chain                                   167
                  Public Health                               169
                  Plant Operation and  Effluent Quality         169
                  Soil  Properties                              170
                  Water Quality                               170
                  Flora and Fauna                              171
                  Noise                                       174
                  Air Quality                                  175
                  Aesthetics                                   175
                  Traffic  and Circulation                      176
                  Public Reactions                             176
                  Natural  Resources                            176
                  Land  Use                                     176
               Impact of Sludge Landfill ing at Lowry           177
                 Landfill
                  Soil  Properties                              177
                  Water Quality                               177
                  Flora  and Fauna                              178
                  Air Quality                                  178
                  Explosive Gas  Production                     179
                  Land  Use                                     179
                  Resources                                    179
                  Summary of Impacts of Sludge Disposal at     179
                   the  Lowry Bombing Range

 VI        NEGATIVE  IMPACTS AND RECOMMENDED MITIGATIVE        181
             MEASURES
              Processing, Transfer, Drying and Distribution   181
                  Groundwater Pollution by Nitrates and        181
                   Salts Leaching from Sludge Drying Basins
                  Surface Water  Pollution from Experimental    182
                   Plots
                  Potential Threats to Public Health           182
                  Proliferation  of Insect Vectors on Sludge    182
                   Drying Basins
                 Air Pollution  from Particulate Matter of     182
                   Sludge Origin
                 Production of  Nuisance Odors in Drying       182
                   Basins
                 Negative Public Reaction to Establishment    183
                   of the Drying and Distribution Center

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                  TABLE OF CONTENTS  (Continued)


Section                                                     Page

               Land Application in Sludge  Recycling Areas     183
                  Heavy Metals Accumulation  in Soil,          183
                    Plants, Animals  and  the  Food Chain
                  Nitrate Pollution  of Groundwater, Espe-     185
                    cially in  Irrigated  Farms, Sod Farms,
                    Home Gardens, City Parks
                  Nitrate Pollution  and  Eutrophication of     185
                    Lakes and  Other  Water  Bodies
                  Air Pollution from Particulate Matter of    185
                    Sludge Origin
                  Exposure of  Humans to  Viable Pathogens      185
                    and Parasites
                  Exposure of  Animals to Viable Pathogens     186
                    and Parasites
                  Odor                                       186
                  Adverse Public Reactions                    186
                  Initial  Toxicity of Liquid Sludge to        187
                    Seeds and  Young  Plants
                  Ingestion of Sludge from Foliage and Soil   187
                  Heavy Metals Accumulation  in Soil, Plants,  187
                    Animals and the  Food Chain
                  Possible Loss of Unique Vegetation Type     137
                  Possible Destruction of Rare and Endan-     187
                    gered Plant Species
                  Possible Loss of Black-Footed Ferret Habi-  188
                    tat
                  Initial  Toxicity of Liquid Sludge to        188
                    Seeds and  Young  Plants
                  Air Pollution from Particulate Matter of    183
                    Sludge Origin
                  Reduction of Grazing Resource               138
               Lowry Landfill                                 188
                  Removal  of Uildlife Habitat                 188
                  Groundwater  Pollution                       188
                  Explosive Gas Production                    189

  VII        LONG-TERM CONSIDERATIONS                         191
               Adverse Impacts that  Cannot J3e Avoided         191
                  Sludge Drying and  Distribution Site         191
                  Land Application Sites for Recycling        192
                    Sludge
                  Lowry Bombing Range Sludge Disposal         193
                    Area (No Action)
                              vn

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                   TABLE OF CONTENTS  (Continued)


 Section                                                       Page

                Irreversible and  Irretrievable Resource          193
                  Commitments
                   Destruction  of Soil  Profile-                  194
                   Energy Use                                   194
                   Groundwater  Use as Receiving Medium           194
                   Application  Site Soil Commitment              194
                Relationship Between Short-Term Uses of the      194
                  Human  Environment and the Maintenance and
                  Enhancement of  Long-Term Productivity
                   Conservation of Non-Renewable and             195
                    Renewable  Resources
                   Potential  Cumulative Long-Term Environ-       196
                    mental  Damage
                   The Long-Term  Environmental Perspective       197

  VIII      COORDINATION  WITH AGENCIES AND PUBLIC INVOLVEMENT   199
               Governmental  Agencies                            199
               Public Involvement                               199
                   Public  Reaction to Drying and Distribution    202
                    Site
                   Public  Reaction to Land Application Sites     202

  IX        REFERENCES                                          203

Environmental Team                                              213

                           APPENDICES
Appendix
   A        Evaluation of Alternative Sludge Handling and       A-l
              Disposal Systems

   B        Soils                                               B-l

   C        Biology                                             C-l

   D        Sludge Application to Land                          D-l

   E        Environmental Settings of Drying and Distribu-      E-l
              tion Site and Specific Land Application
              Sites for Metro Denver Sludge

   F        Examples of Approval  for or Interest in the         F-l
              Proposed Project

   G        Summary of Impacts  at Alternative Sludge Drying/    G-l
              Distribution Sites

   H        Distribution List                                   H-l
                              vm

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                          LIST  OF  FIGURES
Figure                                                       Page

   1      Project area  and  example  sludge application sites       8

   2      Potential  drying  and  distribution center sites         24

   3      Irrigated  and dryland farms,  sod farms and parks       26
           of the Denver area  in relation to the sludge
           distribution site

   4      Generalized  precipitation pattern in the Metropoli-    38
           tan Denver  region

   5      Topography of project area                             45
   6      Geologic map  of areas in  the  vicinity of Metropoli-    47
           tan Denver

   7      Soil associations in  vicinity of Denver                53

   8      Natural  vegetation of Colorado                        57

   9      Summary of biotic community characteristics, Metro-    62
           politan  Denver  area

  10      Colorado Air  Quality  Control  Regions                   65

  11      Annual  frequencies of winds of various velocities      67
           at Stapleton Airport, Denver, Colorado

  12      Metropolitan  Denver proposed  sludge drying and dis-    94
           tribution center

  13      Ammonia and total  Kjeldahl nitrogen concentration      95
           as a  percent of the total solids concentration
           in three layers in  air  drying basins

  14      Relationship  between  allowable sludge application     101
           rate  and uptake of  mineralized nitrogen for
           sludges  containing  different amounts of nitrogen

  15      Annual  sludge application rates                       103

  16      Summary of impacts at the proposed sludge drying      136
           and distribution center for Metro Denver

  17      Summary comparison of relative impacts of sludge      138
           recycling on various land application sites in
           the vicinity of Denver

  18      Summary impacts of sludge disposal at the Lowry       168
           Bombing  Range

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                    LIST OF FIGURES  (Continued)

 Figure                                                       Page
   A-l     Process  trains for various alternatives              A-12
   D-l     Daily consumptive water use of crops grown near      D-21
            Denver,  Colorado
   E-l     Sod farm and dryland wheat farm                      E-6
   E-2     Soils on the sod farm and adjoining dryland farms    £-7
            in Adams County
   E-3     Representative mine spoil site                       E-12
   E-4     Representative agricultural reuse areas              E-17
   E-5     Lowry Bombing Range disposal  area                    E-26
   E-6     Soils of tne Lowry Bombing Range sludge disposal      E-30
           areas
Table
                         LIST OF TABLES
   1     Summary of Sludge System Alternatives  Evaluation       16
   2     Final  Sludge Handling Alternatives  Comparison          20
   3     Temperature, Precipitation,  Snow and  Freeze  Data,      37
           Denver (WB City)
   4     Maximum Precipitation Frequency,  Thunderstorm  and      39
           Relative Humidity Data,  Denver
   5     Wind  Data, Denver (WB Airport)                         40
   6     Temperature, Precipitation,  Snow  and  Freeze  Data,      42
           Denver (WB Airport) and  Fort  Lupton
   7     Temperature, Precipitation,  Snow  and  Freeze  Data,      43
           Cherry Creek  Dam  and  Byers
   8     Typical  Elevations  for  Sites Within the Study  Area     44
   9     Stratigraphic Units and  Their Water-Bearing  Proper-    50
           ties  in  the Vicinity  of  Denver
  10     Population by County,  1970-1975                        74
  11      Population Growth Rates, Adams  County                  75

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                    .1ST OF TABLES  (Continued)
Table                                                        Page
  12     Selected Population  Projections for Counties in        77
           Vicinity of Metro  Denver
  13     Population Forecasts for  the  Five-County Denver        78
           Region in the Year 2000
  14     Population and Sludge Load  Projections for Metro       79
           Denver District
  15     Value of Crops Produced  in  Adams  County, 1972-1973     83
  16     Livestock on Farms,  1  January 1973, Adams County,      83
           Relative to All  Colorado  Counties
  17     Contrasting Socio-Economic  Characteristics             85
  18     Adams County Employment  Patterns,  1973                 86
  19     Changes  in Characteristics  of Sewage Sludges Through   90
           Digestion
  20     Survival Times of Pathogenic  Microorganisms in        114
           Various Areas
  21      Estimated Capital  Cost and  Approximate Allocation     134
           to  Land,  Labor  and Materials
 A-l      Cost  of  Alternative  Systems                           A-6
 A-2     Cost  of  Alternative  Systems Treating the Capital      A-7
           Cost of Anaerobic  Digestion as a Sunk Cost
 A-3     Cost  Summaries Using 10 Percent Discount - No        A-28
           Inflation
 A-4     Cost  Summaries Using 10 Percent Discount and         A-29
           8 Percent Inflation
 B-l      Soil  Associations in the  Vicinity  of Denver           B-l
 C-l      List  of  Plant Species  Observed During Field Recon-    C-l
           naissance,  August  7, 1975
 C-2     Commonly Occurring Range  Species  in the Denver Area   C-3
 C-3     Native Trees  and  Associated Shrubs in the Denver      C-5
           Area
 C-4     Common Birds  of the  Denver  Region                     C-6
 C-5     Common Mammals of the Denver  Region                  C-10
 C-6     Common Amphibians and  Reptiles of  the Denver Region  C-12

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                   LIST OF TABLES  (Continued)
Table                                                        Page

 C-7     Common Fishes in Streams  and  Lakes  of  the Denver     C-13
           Region

 D-l     Three Main Categories  for Waste  Organics Applica-    D-3
           tion to Land

 D-2     On-Farm Fertilizer  Used in Denver Area, 1970         D-18

 D-3     Reported Nutrient Removal  by  Crops                   D-20

 D-4     Sludge Heavy  Metals Content Computed from Samples    D-25
           Obtained and Analyzed over  a Period  of Four
           Months in Early 1975

 D-5     Comparison of Metro Denver Sludge Heavy Metal Con-   D-26
           tent with Suggested Limits

 E-l      Comparative Fertilizer Usage  at  Selected Sod Farms   E-9
           in  the Denver  Region

 E-2     Temperature,  Precipitation, Snow and Freeze Data,    E-13
           Berthoud  Pass

 E-3      Value and  Area of Crops Harvested in Weld, Adams     E-l6
           and Arapahoe Counties in 1973

 E-4      Pertinent  Characteristics  of  Selected Soils Under    E-19
           Irrigation  in  Weld County

 E-5      Pertinent  Characteristics  of  Selected Soils in Dry-  E-24
           land  Farming in Adams County

 E-6      Pertinent  Characteristics of  Soils  in Lowry Bomb-    E-28
           ing Range Sludge Disposal Sites

 G-l      Summary  of  Impacts at Alternative Sludge Drying/     G-l
           Distribution Sites

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h

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     This section provides an introduction to
the problem of sludge handling at Metro and a
brief description of the proposed land-recycling
system.  It also explains the role of EPA in the
project and its requirements for fulfilling the
National Environmental Policy Act.

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                            SECTION I

                           BACKGROUND
INTRODUCTION

     Victor Hugo's Paris was discarding some five million francs
worth of sewage per year, by his estimates, in the mid-19th Cen-
tury.  His graphic and prophetic lament on the wastage of this
valuable material was in part motivated by the untenable  social
and economic conditions dramatized in Les Miserabies.   While many
underlying conditions have drastically changed ana new types of
social problems and technologies have since emerged,  it appears
that we nave come full circle back to the realization  of  the po-
tential resource value of our waste products.

     The outbreaks of cholera in Europe in tne early  19th Century
led to the beginnings of sanitation systems.  Today,  in many de-
veloping countries which have not adopted such systems, the rate
of incidence of enteric diseases is still vivid testimony to the
need for the protection of human health.   The  potential health
problems of waste application to land have multiplied  since
Victor Hugo wrote his masterpiece by the  introduction  into the
sewers of large quantities of exotic elements  and by  the  sheer  in-
crease in the size of our metropolitan areas.   Thus, realistically,
waste products of human beings are both a valuable resource and  a
potential environmental hazard.

     Placement of sludge upon the land is at once the  oldest and
the most recent concept in the use and/or disposal of  this mate-
rial.  It is an old practice in all parts of the world.  Before
communities evolved into complex social structures that required
proper sanitation facilities, land disposal of human  wastes was
the most logical approach.  In many developing countries, these
wastes are even now directly utilized for crop fertilization, and
as such they are traded as a valuable commodity.

     Application of sludge to land is a relatively new concept  in
the more technologically advanced countries—particularly in the
United States—because of recent concerns over water  quality degra-
dation caused by the various other existing sludge disposal prac-
tices. Modern widespread consciousness ot the  energy  and  resource

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 values that could be derived from sludges  is  anotner  impetus for
 land application.  Thus,  in a recent  revision to  EPA's  grant regu-
 lations and procedures,  it  is stipulated that:

           Grantees must participate in  the  National Energy
      Conservation Program by fostering, promoting, and
      achieving energy conservation in their grant programs,
      Grantees must utilize  to the maximum practical extent
      the most energy-efficient equipment, materials,  and
      construction and operating procedures  available.
                                             (Reference  1)

      A main Tactor causing  the great  difference between the "new"
 land application  ana  reuse  of sludges and the "old" fertilizer use
 of human wastes  is the altered chemical properties of the respec-
 tive materials involved.  Modern  plumbing systems, and  industrial
 inputs into municipal  sewers  have changed the character of sludges
 by introduction of potentially toxic  and otherwise dangerous mater-
 ials.   This,  coupled  with the ever present  microorganisms, includ-
 ing  pathogens, makes  sludge  application to  land a very  sensitive
 matter which  must be  subject  to careful design, surveillance and
 management  control.

      The environmental impact of  land application of  sludge in-
 cludes the  beneficial  impacts (such as conservation of  energy and
 nutrients and improvement of  physical characteristics of the soil)
 and  adverse impacts  (such as  potential degradation of ground and
 surface water quality  ana soil  chemical characteristics as well as
 human  health  and  the  food chain).  The degree and extent of these
 impacts  vary  qualitatively and  quantitatively from one  proposed
 application site  to another,  sometimes in an  entirely opposite fa-
 shion.   Therefore,  the impacts  of sludge application are clearly
 identified  with the category  of land use to which the sludge might
 be applied.   For  each  category, typical sites were selected and
 studied  in  detail,  and the conclusions are  expected to  be typical
 for  other areas of similar character and use.

 THE  REASON  FuR THIS DOCUMENT

     The National  Environmental Policy Act  (NEPA) requires every
 Federal  agency to  prepare a detailed statement on environmental
 impact  for  each of  its major  proposed actions significantly affect-
 ing  the  environment.   In this  case, the Environmental  Protection
 Agency  is proposing to approve a facilities plan tor the management
 and disposal  of sludge, by the Metropolitan Denver Sewage Disposal
 District No.  1.

     EPA's  responsibility for  the approval  of a wastewater treat-
ment facility  is given to it  under Public Law 92-500,  known as the

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Water Pollution Control Act Amendments of 1972.

     EPA has decided that approval of this plan  constitutes a major,
significant action under NEPA and is therefore preparing a detailed
environmental impact statement.  An environmental  impact statement
(EIS) must consider the environmental impacts of a proposed action,
both short and long term (and especially the irreversible, adverse
kinds), and alternatives to the action.

     Under Title II of the Water Pollution Control Act Amendments,
EPA is given authority to distribute construction grant fundings
for municipal wastewater treatment facilities,  [his section of the
Act defines a three-step process of planning (Step I), design (Step
II) and construction (Step III] that must be fulfilled for an eli-
gible grant applicant to construct a facility with Federal funds.

     Tne Step I process works as follows:  an applicant who is cer-
tified through a State priority system prepares  a facilities plan.
EPA will pay 75 percent of tne costs of such a plan.  Before a plan
can proceed to the design and construction phase,  the plan must be
approved by EPA.  Design (Step II) review is delegated to the State.
EPA has determined that the approval process ot  a facilities plan
constitutes the Federal action under NEPA.

     Sludge treatment and disposal units are considered an integral
part of the wastewater treatment process and hence are eligible for
funding.  Section 212(A) of the Act defines  such facilities to in-
clude land acquisition costs  if they are part of the treatment process:

          The term "treatment works" means any devices and
     systems used in the storage, treatment, recycling, and
     reclamation of municipal sewage or industrial wastes of
     a liquid nature ... including site acquisition of the
     land that will be an integral part of the treatment
     process or is used for the ultimate disposal  of residues
     resulting from such treatment.

     The Congressional philosophy for the need to recycle and re-
claim many of the pollutants  in sewage,  including sludge, in a
beneficial  manner is clear in Sections 201(d), (e) and (fj of the
Act:

          (d)  The Administrator shall encourage water treat-
     ment management which results in the construction of
     revenue producing facilities providing for—

               (1)   the recycling of potential sewage pollu-
          tants through the production of agriculture, silvi-
          culture,  or aquaculture products,  or any combination
          thereof;

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                (4)   the ultimate disposal  ot  sludge in a
           manner  that will  not  result  in environmental
           hazards.
           (e)   The  Administrator shall encourage waste
      treatment management which results in integrating fa-
      cilities  for sewage treatment and recycling with faci-
      lities  to treat, dispose of, or utilize  other indus-
      trial and municipal wastes,  including but not limited
      to  solid  waste and waste heat and thermal discharges.
      Such integrated facilities shall be designed and oper-
      ated to produce revenues in  excess of capital and
      operation and  maintenance  costs and such revenues
      shall be  used  by the designated regional management
      agency  to aid  in financing other environmental improve-
      ment programs.
           (f)   The Administrator  shall encourage waste
      treatment management which combines "open space" and
      recreational considerations  with such management.

      In  addition  to  the environmental considerations required under
NEPA, EPA must determine whether  the facility considered in this
plan  meets the goals  of  the Federal Water  Pollution Control Act
Amendments of  1972 stated above.

      The  Metropolitan  Denver Sewage Disposal District No. 1 (re-
ferred to  as "Metro")  has submitted a facility plan to EPA and the
State of  Colorado to  process and dispose of its sludge by recycling
it to the  land.  This  EIS considers the effect such a plan would
have  with  regard to requirements of the following Federal environ-
mental laws, among others:

      (1)  Federal Water Pollution  Control Act Amendments of 1972
      (2)  Clean Air Act (of 1970)
      (3) various legislation regarding noise, solid waste and pesti-
         cides
      (4)  Historic Sites, Buildings and Antiquities  Act of 1935
      (5) the Endangered  Species Act of 1973 and Endangered Species
         Conservation Act of 1969 and amendments

     Because sludge is being considered for use on  products that
could reach the human and animal food chains, the expertise of the
Food and Drug Administration and the Department of  Agriculture
will be solicited.  All appropriate State  standards and regulations
will have to be met, including the Solid Waste Disposal  Sites and
Facilities Act requirements.  This act is  administered jointly by
the State Health Department  and the Board  of County Commissioners
for the county in  which the  proposed site  is to be  located.

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     While the Department of Health makes recommendations,  the
County must approve specific site locations for any solid waste
disposal area.  State law defines sludge as a solid waste for
purposes of this Act.

     Agency expertise and public opinion are thus  being  sought  by
EPA for this project.  Atter this draft EIS has been distributed
for review, EPA will conduct a public hearing, if  necessary, to
solicit additional information.  ATter a period of not less than
60 days from release of the draft EIS, a final Elb will  be  distrib-
uted.  This document will contain a resolution of  any issues raised
in the course of the review of the draft EIS.  Only after EHA  has
determined that all of the important issues have been satisfactorily
resolved, and after at least 30 days from tne release of the final
EIS, would this facility plan be approved.

     EPA assigned the consultant Engineering-Science, Inc.  to  assist
the agency in reviewing this very complex plan, to obtain additional
expertise and to help prepare the EIS document.  This document rep-
resents the position of the Environmental Protection Agency regard-
ing this plan except where the consultant's own recommendations or
positions are explicitly identified.

HISTORY OF THE PROJECT

     The Metropolitan Denver Sewage Disposal District wastewater
treatment facilities were originally constructed in 1966 with  a
design capacity of 5.15 cu m/sec [117 mgd].  The overall BOD reduc-
tion goal was 80 percent.  Sludge processing involved dewatering
through dissolved air flotation, vacuum filtration, flash drying
and/or incineration.  At that time, it was expected that the rela-
tive proportions of raw primary sludge, anaerobically digested
sludge and undigested waste-activated sludge would be such  tnat the
vacuum filter would produce a filter cake solids concentration of
22 to 25 percent.

     By 1967, the District realized that the proportion of  waste-
activated sludge in the mixture was much larger than nad been  ex-
pected, giving rise to increased difficulty in dewatering the
sludge mixture (achieving only 14 to la percent solids concentra-
tion of the filter cake).  Thus, tne need for chemicals for vacuum
filtration more than doubled, and the increased moisture content
overloaded the design capacity of the flash dryer-incinerator.
Corrosion of the stainless steel components of the dryer-incinerator
resulted from the heavy doses of ferric chloride used in sludge
conditioning, further compounding the problems with the sludge hand-
ling system.

     This problem became intolerable in the fall of 1968.  More than

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 half of the evaporative capacity of the dryer-incinerator had  be-
 come unavailable because of mechanical  problems;  and  activated
 sludge was accumulating in the biological  treatment system,  rapidly
 deteriorating the effluent quality.   Therefore,  lagoons  were con-
 structed for the winter months of 1968  and 1969.   Odors  generated
 in these lagoons brought about loud  complaints and forced the  Dis-
 trict to shift to land disposal  of the  filter cake in May 1969.
 Since that time, land disposal,  with various  types of equipment, at
 various rates and under different conditions, has  been practiced at
 an abandoned portion of the Lowry Bombing  Range,  some 40 km  [25
 miles] southeast of the treatment plant.

      Some of the land application operations  were  conducted  by
 District personnel,  while others were performed by contractors.
 Odor problems resulting from the method  of disposal used by  con-
 tractors gave rise  to adverse neighborhood reactions  and complaints
 to Arapahoe County  Commissioners.  A public hearing was  held on 20
 June 1972 at which  the District  was  committed to a  new,  revised
 land application method aimed at eliminating  odor  and fire hazards
 (Reference 3).   The  new method has since been utilized during  dry-
 weather conditions,  as described in  Section IV under  Land Applica-
 tion at Lowry Bombing Range.   Inclement weather operation is simi-
 lar  to  standard  sanitary landfill ing  of solid wastes.

      In  1971,  the District  consultants prepared an expansion plan
 for  the  central  plant and recommended an agricultural  reuse  scheme
 for  the  sludges  produced  (Reference  4).  After two public meetings
 with  residents of the proposed reuse area  in  the winter  of 1972-
 1973,  some  revisions  were made,  and a new  agricultural reuse pro-
 gram  was  prepared by  the  District  (Reference  5).   The  system has
 since been  further refined  in  concept, and in February 1975 a  four-
 volume  sludge management  plan  was published,  comparing alternatives,
 describing  the recommended  agricultural reuse scheme  in  detail  and
 assessing the environmental  impact of the  recommended  plan (Refer-
 ence  6).

      That report comprises  a facilities plan,  which was  submitted
 to the U.S.  Environmental Protection Agency on 27 February 1975.
 Earlier, applications  for a Step  I grant for  the sludge management
 plan  had been made to  the State and to EPA (on 19 November and  22
 November 1974, respectively).  On 9 June 1975, the Regional Admin-
 istrator of  the U.S.  Environmental Protection  Agency  sent a "Notice
of Intent to Prepare an Environmental Impact Statement" for the pro-
posed sludge management program of the Metropolitan Denver Sewage
Disposal District No.  1.

     On 30 June 1975,  EPA authorized Engineering-Science, Inc.  to
prepare an Environmental Impact Statement on the  proposed action  in
                                6

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the plan in accordance with all  relevant legislation  and policies
and the regulations of EPA.  EPA required an  additional evaluation
of the environmental  impact to off-site  areas being considered  by
Metro for land application of sludge.  Engineering-Science pre-
sented a preliminary draft EIS to EPA  incorporating the analysis
of off-site impacts.   This draft EIS was written  by Engineering-
Science under EPA management using much  of the information in
the preliminary report prepared by Engineering-Science.


THE  PROPOSED  ACTION

     The sludge management  plan  proposed  by Metro involves treat-
ment,  pipeline transport, drying, distribution and application on
land of anaerobically digested  sludge from the Metropolitan Denver
Sewage Disposal District  No.  1  sewage treatment plant in Commerce
City.  Figure 1 shows the  location of various components of this
plan in the Denver Metropolitan  area.

     All of Metro's sludge  would  first  receive anaerobic digestion
treatment  at  the  central  plant  before further disposal.  This pro-
cess stabilizes the sludge  and  reduces  odor and pathogens.  EPA
recently gave the District  a  $5.5 million grant to construct anaer-
obic digesters at the central plant.

     The sludge would then  be transported by  pipeline to a drying/
storage center site located  in western Adams  County near Irondale
Road and about 18 kilometers  [11 miles]   southeast of Barr  Lake.
There  the  sludge would be dried  in open  basins and stored  for fu-
ture use.  This processing  site would also be used for marketing,
research and  demonstration  areas, and as  a disposal  site on occa-
sion.

     Metro contemplates marketing the dried or liquid sludge to
local  dryland and irrigation  farmers, for municipal  parks, for
mine-land  reclamation, and  perhaps for  individual garden use.  At
worst, Metro  could dispose  of the dried  sludge in a sanitary land-
fill if no markets were available.

     Land  areas that might  utilize the  sludge extend from the AMAX
mine spoils site, near Berthoud  Pass, to many of the park areas in
the metropolitan  Denver areas.

     The impacts  of the various  processing alternatives and the dry-
ing/distribution  center were  assessed during  the facilities plan-
ning and are  summarized in  Section V.   This  environmental  impact
statement  deals primarily with  the land  application processes in
such areas as City parks,  sod farms, mine spoil sites, irrigated
farms, dryland farms, the  Lowry  Bombing  Range and the Lowry landfill,

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                                                                                 PROJECT AREA

                                                                              AND EXAMPLE  SLUDGE

                                                                               APPLICATION  SITES

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 It  is  proposed  that  air-dried  sludge be trucked to application
 sites  of the  types described above and incorporated into the top
 layers of soil  for ready  use of  nutrients by plants and improve-
 ment in the physical  condition of soils.  A very important assump-
 tion implicit in  the environmental analysis of the proposed action
 is  that sludge  application rates  (metric tons per hectare per year)
 ana quantities  (ultimate  metric  tons per hectare) recommended for
 a given piece of  land,  and other required cultural practices, will
 be  adhered to by  the recipients  of the materials.  However, the
 reliability OT  such  adherence  cannot be guarded or guaranteed, and
 to  the extent that these  recommendations are not followed, the
 number and severity  of  impacts will increase beyond those enumerated
 unaer  tne basic assumption.  Thus a thorough familiarity witn such
 basic  assumptions, presented in  Section IV under Description of
 tne Proposed  Action,  is essential to the understanding of the most
 important conclusions of  this Statement.

     The proposed project will encompass primarily Adams County,
 Colorado but  will also  include the City and County of Denver and
 perhaps  portions of  Arapahoe, Weld, Douglas, Elbert, Jefferson and
 Clear  Creek counties.   In fact, the cost of transport of air-dried
 sludge may become the main factor limiting the distance the mater-
 ial  is shipped  for land application.*  For the purposes of envi-
 ronmental impact analysis, six representative land application
 sites  are selected,  as shown on Figure 1.

     The  service area contributing wastewaters to the sewage treat-
 ment plants,  which in turn produce sludges from the wastewaters, is
 most of  the metropolitan  Denver area, comprised of more than 20
 political entities.  Excluded from the service area at present are
 tne separate  districts of Commerce City, Rocky Mountain Arsenal,
 Glendale, Littleton and Englewood.

     In  order to construct facilities considered in any one of the
 alternatives  (excluding the no-action alternative) discussed in
 Section  II for  the full projected sludge generation rate of 150 dry
 metric tons [166 tons] per day, a capital  expenditure ranging from
 $2.2 to  $29 million would be required, depending on the alternative
 ultimately selected.  The currently recommended alternative, de-
 scribed  in detail in Section IV, has a capital cost of $25.9 mil-
 lion.
 At a trucking cost of 50.08/cu meter-kilometer [SO.lO/cu yd-mile],
a distance of 100 km [60 miles] would represent the limit at which
transport cost of dried sludge (with 5 percent nitrogen and 50
percent solids content] equals the current price of equivalent com-
mercial chemical fertilizer nitrogen ($0.55/kilogram [$U.25/lb])
alone.

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Financing ^the Project

     If approved, the U.S. Environmental Protection Agency would
pay 75 percent of the-grant-eligible-portion of the capital cost if
further'Congressional funding became'available, and the District
would bear the remaining5 25 percent-,' as provided by~!the Federal
Water Pollution Cpntrol Act as"amended in 1972.

     The local share  (25 percent) of the capital cost would have to
be borne proportionately by the users; i.e., the individuals, indus-
tries and businesses' using the District's sewerage facilities.  At
present, however,-no further funds are available to Colorado for
construction in the Denver metropolitan area, unless the Congress
authorizes additiona-1 money for wastewater treatment works.  Approv-
al of this plan would allow EPA to reimburse Metro for 75 percent
of the eligible design costs of this project.

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 h
H

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     This Section considers the alternatives to
the proposed project.  It looks at the historical
development of alternatives and provides a com-
parative evaluation of reasonable alternatives,
using environmental, engineering and cost para-
meters.  Areas where alternatives were considered
include processing and disposal, site locations
and transportation.

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                           SECTION II

               ALTERNATIVES TO THE PROPOSED ACTION
INTRODUCTION
     The National Environmental Policy Act requires Federal  agencies
to consider "alternatives to the proposed action" in every environ-
mental impact statement.  The law does not specify how thorough
the alternatives must be, but courts have interpreted it to mean
that a "reasonable" number of alternatives must he considered,
especially any which may have merit in reducing the negative environ-
mental impacts of the project as originally proposed.

     This very broad definition of alternatives suggests that not
only are very broad "total  system" alternatives to be considered
but, where particular features of a given proposal may have unusual-
ly severe impact, subalternatives within a system should also be
evaluated.  In the case of Metro Denver's proposal, site location
alternatives or drying basin design alternatives might be sub-
alternatives worthy of consideration.

     A second factor must be borne in  mind in the review of alter-
natives for a construction grants program project.  EPA does not
initiate a proposal  for construction grant funding; that is the
prerogative of any legal wastewater management district.  Upon
certification by the State, a district evaluates alternatives and
develops a plan.  The plan is then sent to EPA for final review.
Although EPA has developed guidelines  to assist grant applicants
in order to make them aware of EPA's responsibilities in consider-
ing project alternatives, it is inevitable that the applicant will
view the alternatives from a somewhat  different perspective than
will EPA.

     To overcome this difficulty, EPA will give equal consideration
to all alternatives but will recognize the effort that has been
invested in the development of the proposed project.  Only if there
are significant environmental or other objections to the proposed
overall system will  a wholly different system be advanced.  Even
within a given proposal, however, major changes could be required
if the situation so warranted.
                               11

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      This Section describes the historical  background of Metro
 District planning leading to the development of alternatives and
 to the present proposal; compares total  system alternatives; and
 reviews subalternatives to both the proposal and the existing sys-
 tem.

 HISTORICAL DEVELOPMENT OF ALTERNATIVES

      The Metro Denver Central  Plant,  built  in 1965,  is  a secondary
 biological  treatment facility.   The plant not only processes
 residual  solids from its own aqueous-phase  treatment units  but
 also handles anaerobic digested sludge pumped from the  Denver North-
 side Plant.   Sludge treatment  and disposal  has always been  problem-
 atical  at the plant, as evidenced by  the  fact that Metro has re-
 ceived  a  number of research grants to evaluate alternative  sludge
 treatment processes.

      When the Metro plant was  built,  flash-dry incinerators  were
 installed to dry sludge for reuse as  a soil  conditioner in  local
 parks.   Because of operational  problems,  Metro abandoned  the in-
 cinerators  in 1971  in favor of  dewatering on vacuum  filters  and
 disposal  by  landfill ing at the  Lowry  Bombing Range.   Subsequently,
 complaints about  odors forced Metro to modify its  method  of  sludge
 disposal  from landfill ing to landspreading  at  Lowry.

      In 1971, Metro hired the firm of CH2M-Hill  to develop plans for
 the  Central  Plant expansion, including an evaluation  of alternatives
 to the present sludge treatment  and disposal  system,  which was be-
 coming increasingly expensive.   CH2M-Hi11 studied  and evaluated
 from  an engineering  point-of-view three basically  different  sludge
 treatment and disposal  systems:

      1.  The  present  Metro  system.
      2.  Multiple  hearth  incineration.
      3.  Land disposal  of digested sludge.

      While the incineration  and  land  disposal  alternatives were
 felt  to be close  in overall  costs  and much preferable operationally
 to the present system,  Metro adopted  the recommendation of land
 disposal  because  of  an  environmental  "net benefit" and  the possi-
 bility of revenue from  the  sale  of agricultural products.  In
 its land recycling proposal, Metro would have  sprayed anaerobically
 digested sludge on about  6,000 acres of farmland either owned and
operated outright by Metro or leased to fanners.

     When Metro presented this option to the farming community in
western Adams  County,  it encountered considerable resistance.
Farmers objected to the loading rates, the effect of having Metro
                                12

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entering the farming business in a large-scale operation  and po-
tential effects of odors on land values  and  health  in  the area
where the sludge would be stored.  As a  result, Metro  concluded
that more land would probably be needed  to accommodate lower load-
ing rates and became less enthusiastic about engaging  in  a farming
operation itself.

     CH2M-Hill was authorized to evaluate in more detail  the land
recycling alternatives and in March 1973 produced a study entitled
"An Agricultural Reuse Program" (Reference 5).   This study eval-
uated in much more detail a comprehensive approach  to  land re-
cycling, using the latest information then available.   The report
considered issues such as various sludge characteristics  and their
effects on the land; water-rights issues; state-of-the-art compost-
ing and landspreading systems; fertilizer considerations; loading
rates for semi-arid areas; and the types of  crops most likely to
benefit from sludge applications.  A number  of land application
alternatives were evaluated in the study. The more promising sys-
tems identified were drying beds with application to agriculatural
land, permanent subsurface injection on  Metro-owned land  and re-
cycling on private farm land with short-term injection on Metro-
owned land.  Two other alternatives (spray  irrigation  or  subsurface
injection on privately owned dry farmland, and irrigation of crop-
land owned by Metro) were eliminated because of high cost and
water-rights problems.

     The report included a preliminary site  evaluation which served
as a basis for a more detailed site evaluation in the  facilities
plan (considered below).  A preliminary  design configuration for
the most favored alternative, recycling  on private  land with short-
term injection on Metro-owned land, was  presented in the  report.

     Metro remained committed to the concept of land recycling but
required the facilities planner to develop a more comprehensive  re-
view of all alternatives.  In the facilities plan,  a wide range  of
processing and disposal alternatives was evaluated  and eight over-
all processing and disposal alternatives were evaluated in detail.
These included:

     1.  The existing system--"no action",
     2.  anaerobic digestion—pipeline transport to a  drying/dis-
            tribution facility—beneficial reuse,
     3.  dewatering by filter presses—incineration—landfill,
     4.  heat treatment—dewatering on vacuum filters—landfill,
     5.  heat treatment—pipel ine transport—drying—landfill,
     6.  heat treatment—vacuum filtration—incineration—landfill ,
     7.  anaerobic digestion—dewatering by  filter  presses—com-
            posting—beneficial reuse, and
                               13

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      8.   dewatering  by filter  presses--composting--beneficial reuse.

      The facilities  planners recommended the second alternative:  i.e.,
 anaerobic digestion, pipeline  transport to a drying/distribution fa-
 cility and beneficial  reuse.   This  alternative  became Metro's pro-
 posed system and is  the principal focus of this particular EIS pro-
 cess.

      In  June 1975,  EPA retained  Engineering-Science (ES) to review
 the facilities  plan  and develop  the EIS.  Part  of  Engineering-Science's
 task was to evaluate the existing alternatives  and to propose addi-
 tional  alternatives  that appeared promising.  A total of 17 alterna-
 tives for the processing and disposing of sludge were developed and
 evaluated for this  EIS, including the eight alternatives studied by
 CH2M-Hill.

      Table  1  shows  the 17 alternative systems evaluated by Engineering-
 Science.   The basic  form of disposal is shown next to the process de-
 scription.   Cost information includes present-worth values with and
 without  anaerobic digestion as a sunk cost, with and without an eight
 percent  inflation rate and with  and without revenue.  Generally, cost
 information showed that many of  the process options were close in
 overall  costs,  but land recycling became much more cost-effective
 when revenues,  inflation and sunk costs were considered.  Alternatives
 in  which  Metro  sludge  would be processed together with municipal
 refuse also appeared to  be economically advantageous.

      Further  evaluation  might be warranted if these latter types of
 systems were  to  be developed.  However, the latest information
 available indicates  that the Colorado legislature has failed to act
 on  a Denver Regional Council of Governments (DRCOG) bill sponsored
 to  develop  a  solid waste recycling  system.   Therefore, while the
 systems are  promising,  the possibility that an actual  system might
 be  developed  in  the  near future seems unlikely.

      Environmental,  engineering and cost factors considered, Engi-
 neering-Science  also concluded that the "apparent best alternative"
 involved  the  Metro land  recycling proposal.  The Engineering-Science
 evaluation  is contained  in Appendix A, which summarizes the perti-
 nent assumptions  made  in  evaluating the alternative systems.

COMPARATIVE EVALUATION OF SLUDGE TREATMENT
SYSTEM ALTERNATIVES

      In considering the  work performed by the consultants and the
Metro District, a useful  perspective can be gained by comparing
the  disposal  element in  each alternative,  since this is the ele-
ment of a sludge management system that has the most significant
environmental impact.  The processing alternatives generally
                                14

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have a relatively small environmental impact; the most important
in-plant consideration is the selection of a combination of pro-
cesses that will efficiently and economically produce a treated
sludge with the requisite characteristics for each particular dis-
posal mode.  Thus, the comparative evaluation of sludge management
alternatives for the Metro system has as its focus the disposal
elements of the alternatives.

     EPA recently proposed tentative sludge management guidelines
(Reference 79) that provide an indication of the way in which the
agency approaches the issue of sludge disposal  from an environmental
point of view.  The guidelines recognize that disposal of the solid
material in sludge can have significant impact on the environment;
disposal can simultaneously affect air, land and water and may en-
compass such varied considerations as human health, animal health,
plant growth and the protection of ground and surface water from
pollution.  A basic distinction made by the guidelines in consider-
ing the final  disposal of sludge is the division of management
techniques into those in which sludge is utilized as a resource
and those in which sludge is not used for any beneficial purpose.
Examples of beneficial use include land recycling or incineration
for heat or power, while in the case of nonbeneficial disposal,
landfill ing or incineration would simply dispose of the unwanted
sludge without any return benefit.

     Semantic confusion surrounds the word "disposal."  In a gen-
erally accepted sense, the word is taken to mean the last step in
the sludge handling process, regardless of whether beneficial reuse
is involved.  In the distinction often made, the word "disposal"
is used only to indicate those forms of sludge management where  no
beneficial reuse occurs.

     The basic intent of disposal is simply to take the sludge,  as
an unwanted residual material, out of the sewage treatment process
and put it into some other system where it is relatively "harmless."
An environmental concern that must be kept in mind, however, is
that a residual material like sludge is never destroyed by a dis-
posal process but simply converted to another form of matter and/or
energy that continues to exist in the biosphere.

     A distinction between "beneficial" and "nonbeneficial" dis-
posal methods worth noting is that a beneficial method allows
some re-entry of previously unwanted materials jnto the socio-
economic system; the nonbeneficial system simply puts the residual
material into larger environmental systems—air, land or water.
As a way of maintaining this distinction, disposal systems are re-
ferred to in this EIS as beneficial or nonbeneficial.
                               15

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Table 1.
SUMMARY OF SLUDGE
SYSTEM ALTERNATIVES EVALUATION3
(millions of dollars)



Cost comparisons
Anaerobic digestion costs included Anaerobic digestion not included (sunk cost)
Alter- Description
native of
number alternative
1A Existing system — waste-activated and
other sludges trucked to Lowry Bomb-
ing Range for landspreading


IB Existing system with anaerobic digestion

2 Anaerobic digestion, pipeline transport,
air drying and beneficial reuse (prod-
uct: 100 percent air-dried sludge)
J Filter presses, incineration, landfill
of ash
4 Heat treatment, vacuum filtration,
landfill
5 Heat treatment, air drying, landfill
6 Heat treatment, vacuum filtration, in-
cineration, landfill of ash
7 Anaerobic digestion, filter presses,
compost (product: 100 percent nutrient-
enriched composted sludge)
8 Filter presses, compost (product: 100
percent nutrient-enriched composted
sludge)
9 Anaerobic digestion, centrifugation, com-
post (product: 100 percent nutrient-
enriched composted sludge)
10 Anaerobic digestion, pipeline transport,
air drying, compost (product: 50 per-
cent air-dried sludge; 50 percent
nutrient-enriched composted sludge)
Basic
disposal
method
predominantly
land disposal
(spreading)
with some
landfilling
land disposal
(spreading)
land recycle


incineration

land disposal

land disposal
incineration

land recycle


land recycle


land recycle


land recycle



Unadjusted 82 Unadjusted 8%
for inflation inflation for inflation inflation
Ab Bc A B A B A B
24.1 24.1 34.3 34.3 24.1 24.1 34.3 34.3




24.7 . 24.7 30.1 30.1 18.6 18.6 26.4 26.4

24.0 19.3 17.7 10.8 17.8 13.1 14.0 7.1


24.2 24.2 26.8 26.8 24.2 24.2 26.8 26.8

22.5 22.5 25.9 25.9 22.5 22.4 26.0 26.0

33.3 33.3 30.2 30.2 33.3 33.3 30.2 30.2
23.6 23.7 23.6 23.6 23.7 23.7 23.6 23.6

30.3 19.6 35.1 19.3 24.2 13.5 31.4 15.6


34.0 17.0 45.1 20.1 33.9 17.0 45.1 20.1


33.8 25.9 40.1 28.5 27.6 19.8 36.3 24.8


28.8 '20.5 24.4 12.3 22.7 14.4 20.7 8.6




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  11    Anaerobic digestion, centrifugation,          land disposal
        landfill

  12    Anaerobic digestion, pipeline transport,      land recycle
        air drying, landfill, compost (product:            and
        33 percent air-dried sludge; 33 percent       land disposal
        nutrient-enriched composted sludge; re-
        mainder to landfill)

  13    Anaerobic digestion, vacuum filtration,       land recycle
        compost (product:  100 percent nutrient-
        enriched composted sludge)

  14    Vacuum filtration, compost (product:          land recycle
        100 percent nutrient-enriched composted
        sludge)

  15"   Anaerobic digestion, vacuum filtration,        conversion
        pipeline transport to solid waste re-
        cycling plant

  16^   Vacuum filtration, pipeline transport          conversion
        to solid waste recycling plant
26.4   26.4      30.8   30.{
26.9   20.7      24.5   12.4
28.4   20.5      33.8   22.2
27.0   14.5      36.4   18.0
16.8   16.8     17.8   17.8
10.1   10.1     13.3   13.3
                                            20.2   20.1      27.1    27.1
                                            22.8   14.5      20.9     8.7
22.2   14.4      30.1   18.5
30.0   14.5      36.4   18.0
10.6   10.6      14.1   14.1
10.1   10.1      13.3   13.3
 By Engineering-Science, Inc.
b,,. ,
 Without revenue.
 With revenue.
 Sludges containing less than 25 percent solid materials would require the expenditure of additional resources  for  the  removal of water.

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      The Congressional  philosophy expressed  in the Water Pollution
 Control  Amendments  of  1972 makes it apparent that the Congress was
 very much concerned with  developing and promoting beneficial ways
 to  use  both  sludge  and  treated wastewater.   In the portions of the
 Act quoted  in  the first Section of this EIS, beneficial disposal
 of  sludge can  be accomplished either separately by the wastewater
 treatment entity or in  combination with municipal solid waste sys-
 tems.   Because cost, engineering, institutional and, to a certain
 extent,  environmental considerations differ  between these two ap-
 proaches, they are  distinguished in the comparative evaluation
 that follows.   A separate wastewater district might find it very
 uneconomical to incinerate sludge for power  purposes, but, in com-
 bination with  municipal refuse incineration, the system could prove
 attractive.

      Table 2 compares environmental  impact, engineering considera-
 tions,  institutional factors and costs"as they relate to a number
 of  courses of  action.   The alternative courses of action are or-
 ganized  in three groups--nonbeneficial disposal, separate beneficial
 use and  combined municipal refuse and sludge beneficial use.  It
 should be noted that the ranking shown in the Table is, at present,
 simply serving  as a guide in the process of comparison; it is not
 yet being used  as a decisive factor in the selection of alternatives.

     The  comparative evaluation shows the general preferability of
 separate  land  recycling schemes.  Were the DRCOG solid waste re-
 cycling alternatives a  real  possibility, some of these alternatives
 would be more  attractive.   Metro has evaluated air basin drying
 versus composting approaches and decided upon the former as the
 method of land  recycling.   There appear to be no outstanding reasons
 from EPA's point of view as to why one should be chosen over another
 in  this case.  Recent work on composting sludge shows great environ-
mental and economic promise (Reference 129).

      Other disposal  and recycling systems do not fare as well for
 a variety of reasons.   Incineration (whether heat or power benefits
 are gained or  not)  involves air quality problems and is highly en-
 ergy-demanding  with Metro sludge.  Land disposal methods such as
 landfill  or  land spreading do not rate as high overall because of
 greater  adverse environmental impact, little or no positive bene-
 fit and  higher costs.   Other schemes involve unproven technology
 or  are associated with  higher costs.

      It  is concluded, from a review of all the available informa-
 tion at  hand,  that  some form of land recycling, utilizing air-dried
 anaerobically  digested  sludge, is a generally environmentally sound
 and cost-effective  alternative for the Metro District.  At this
 point in  time,  EPA  does not feel that a further evaluation of al-
 together  novel  sludge handling and disposal systems need be con-
 sidered.

                                18

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     However, in view of the fact that Metro has an ongoing sludge
handling and disposal system at the Lowry Bombing Range that would
be replaced by a different system, EPA feels that the alternative
of continued use of the Lowry disposal system (perhaps modified to
a certain extent) must be considered in detail.   The National  En-
vironmental Policy Act requires a Federal agency to review the
null or "no-project" alternative.  It seems reasonable for EPA to
question whether a new system, even with the inclusion of environ-
mental improvements, should be funded in lieu of the existing system.
Past evaluations by the Metro District and consultants have indi-
cated problems with groundwater contamination and excessive soil
loadings at Lowry.  Therefore, the Lowry system is evaluated further
in this document.

     The EPA guidelines recognize that the choice of a disposal
method is not as important as properly evaluating the chosen method
with respect to a wide range of environmental conditions.  The EIS
process functions to evaluate in detail any impacted environmental
elements in order to insure the least environmental degradation.
The guidelines indicate that for land recycling schemes the follow-
ing elements must be considered:

     1.  Soils.
     2.  Groundwater.
     3.  Stabilization of sludge.
     4.  Sludge characteristics (heavy metals, nutrients).
     5.  Pathogen reduction.
     6.  Crop suitability.
     7.  Public access.
     8.  Surface runoff.
     9.  Application methods.
    10.  Application rates (nutrients and trace elements).
    11.  System operation control.
    12.  Monitoring.
    13.  Food chain considerations.

     Thus, in the body of this Environmental Impact Statement, EPA
considers in detail the following two sludge management systems.

     1.  Metro's proposed land recycling system using anaerobic
Digestion, pipe!ine transport, drying beds, storage and distribution
to the land.  Metro has proposed that dried sludge could be used  on
irrigated areas, dryland areas, sod farm operations, metropolitan
Denver parks and reclamation of some mine spoil  areas.  It has also
been suggested that dried sludge might be made available to individ-
ual  home gardeners.  Metro has also indicated the possibility that
the sludge could be bagged and sold commercially.
                               19

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Table 2. FINAL SLUDGE HANDLING ALTERNATIVES COMPARISON
FOR METRO DENVER DISTRICT
Sludge
handling
alternative

L*rul disposal
Landfill





Lanjspreading




Incineration-
ash disposal




Environmental impacts
Beneficial


None





Can improve soil
structure and add
nutrients


Minimal, material
volume reduced




Adverse


Crounduater leachate
problems, soil sta-
bility, explosive
gas production


Can harm soil quali-
ty by excessive met-
al loadings; can af-
fect grounduater,
food chain
Releases participates
and gases to air; ash
disposal can create
leachate problems in
grounduater; high
energy utilization
Engineering factors
Feasibility
Dlsp

High





High, but requires
large land areas
an& constant moni-
toring

Moderate, moisture
content of sludge
could affect oper-'
ation


Reliability
osal

High, but requires
close control of
deposition and must
be mixed with dry
solid waste and/or
soil
Moderate, requires
standby system for
winter and wet days


High, except air
pollution control
equipment may have
problems


Institutional
ability to
implement


High-existing, but
would require new
disposal sites



High-existing, but
would require new
land spread ing sites


Moderate, because
of air pollution
problems




Costs


All disposal operations
have no revenue, low
capital costs and high
operating, energy and
chemical costs

Low capital costs;
moderate operating
costs; high energy
and chemical costs

High capital and energy
costs; moderate operat-
ing costs; chemical
costs could be high


Overall3
rating


Marginal





Acceptable




Marginal





Recycling — Separately
Land recycling
Air drying




Composting




Incineration
Drying-
recycle


Improves soil
structure; adds
nutrients; mini-
mizes energy use

Improves soil
moisture; high
nutrient value;
minimum energy
use

Cattle feed;
soil amendment


Localized groundwater
problems at drying
site; pathogen prob-
lem; control of final
use difficult
Same as air-drying





Odor problems; ash
disposal; low inten-
sive energy use


High, but requires
complex coordina-
tion for recycling


Moderate, requires
good market for re-
cycled material



Low with past Metro
experience; could be
higher with anaero-
bic sludge

High, except for
occasional digest-
er failure


High, except for
potential contam-
inants



Low to moderate be-
cause of incinerator
breakdowns


High, except for
farming community
resistance to land
i se aesthetic de-
terioration
Limited Metro ex-
perience or re-
search in this
area


Low, Metro exper-
ience with drying
unfavorable


High capital coats and
low operating, energy
and chemical costs;
high revenue likely

Same as air-drying;
revenue could be high.
uncertain at this time



Same as air-drying;
revenue could be high,
uncertain at this time


Most fa-
vorable



Favorable





Acceptable



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Ash-heat
production

Conversion
Pyroly«i«


Cattle feed


Land recycle —
composting


Incineration —
power production





Conversion
Supplemental
boiler fuel

Synthetic gas
production



The overall rating
Produce* useful
heat


Useful carbon-
black produce

Valuable cattle
feed supplement


Large amounts of
fertiliser and
soil amendment*

Useful heat or
steam energy
produced in
large amounts




Energy source
for Industrial
uae
Synthetic natural
gas for indus-t
trial/domestic uaa


scale (unacceptable,
Disposal of ash and
leachate to ground-
water problems

Heavy metal contam-
inants; releases
gases
Unknown, potential
metal contaminant!
in food chain

Control of patho-
gens difficult;
odor problems

Ash disposal; re-
lease of gases to
air





Air pollution, ash
residue

Ash residua




marginal, acceptable,
Low a* a separat* Low
system


Experimental Unknown


Experimental Unknown

Combined Recycling with Municipal Solid Wastes
Probably high High



Potentially high; Vrobably high
water content in
sludge lowers heat
value; past oper-
ating problems
with CO from in-
cinerators

Very low, imprac- Low
tlcal with DRCOG
proposal
Moderate, caloric High, if sludge
and high water con- quality constant.
tent of Metro but unknown re-
sludge somewhat liability for
unfavorable overall system
favorable and most favorable) was developed through
Moderate.


Low; untested


Low; untested


Low; lack of leg-
islative support
f c r financing sol-
id waste systems
Low; lack of leg-
islative/financial
support





Low; lack of leg-
islative/financial

Low; lack of leg-
islative/financial
support


a semi-quantitative
ranking and evaluation of the alternatives on the bail* of parameter presented la this Table. The subjective nature of this method
High capital, operating
energy and chemical
costs; low revenues

High capital, operating
energy and chemical
costs; revenue unknown
Same as pyrolysls


Costs unknown to a
great extent for all
combined options

Costs unknown, could
be low for Metro






Costs unknown, could
be low for Metro

Costs unknown, could
be low for Metro



! relative
is shared
Unaccept-
able


Unaccept-
able

Acceptable


Marginal



Marginal







Unaccept-
able

Acceptable






by all such attempts at numerical evaluation.

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      2.   Metro's existing  disposal  operation  of  landspreading and
 occasional  burial  at the Lowry Bombing  Range.  The  system will be
 modified by the addition of  anaerobic digesters  at  the Metro plant.
 Other possible modifications are  also discussed.

      The analysis  of the alternative systems  is  prefaced in this
 Section  by  a discussion  of the sub-system  alternatives within each
 of the major alternatives.

 SUB-SYSTEM  ALTERNATIVES

      Many environmental  impacts can be  lessened  by  careful attention
 to the design details of the chosen system.   The National Environ-
 mental Policy Act  requires that consideration be given to lessening
 environmental  impact of  a  project by evaluation of  alternatives and
 selection of an  environmentally sound option  and then by mitigation
 of negative impacts  through  careful attention to design details.
 This  Section of  the  EIS  discusses the basic components of the major
 alternatives,  their  environmental impacts  and the means by which
 their impacts  might  be mitigated.

 Sub-System  Alternatives  to the Metro Land
 Recycling Proposal

      Stabilization--.

      Some form of  sludge stabilization  is  necessary before sewage
 sludge can  be  applied to the  land.  Stabilization involves the des-
 truction of  volatile matter  in the sludge.  If sludge were applied
 to the land  unstabilizeds odiferous conditions would result.

      The most  commonly applied stabilization process is digestion,
 either aerobic or  anaerobic.   Based on many years experience with
 both  digestion processes, Metro has selected the latter for this
 project, for the following reasons:  (1)  Anaerobic digestion is a
 well-established process in the sewage treatment technology field;
 it has very  low energy use requirements, whereas aerobic digestion
 requires considerable energy  to supply air to the mixed sludge,
 (2) The methane gas from anaerobic digestion can be used to power
 the digestion  process and perhaps other units, and  (3)  Aerobic
 sludge must  be very well  digested in order to avoid odor problems,
 if the sludge  becomes septic.

     An issue within the general choice of anaerobic digestion is
whether the   process should  be mesophilic (operating at  temperatures
between 21°C and 39°C [70°F and 103°FJ), or thermophilic (operating
between 40°C and 54°C [104°F  and 130°F]).  Thermophilic digestion
results in a better stabilized sludge that can be more  easily de-
                                22

-------
watered.  Pathogen reductions are also reported to be more effective
with  this process.  The principal negative aspects of thermophilic
digestion are the high additional costs for insulation and extra
heating.  Metro has decided to operate the system in the mesophilic
range.

      The actual range of choice for the digestion sub-systems is
extremely limited because EPA has already provided the Metro Dis-
trict with funds for anaerobic digesters.  EPA intends to evaluate
whether operation in the thermophilic range is desirable and within
reasonable cost limits, given the present design of the anaerobic
digesters.

      Transportation--

      The principal means of conveyance to a sludge drying/storage
facility in the Metro proposal is by pipeline.  Two pipes (25 and
30 cm [10 and 12 in.]) will carry the sludge, with a pumping station
at the Central Plant and an intermediate pumping station.  Although
design of the pipeline is not completed at the time of this writing,
the lines would be sized to carry the expected sludge volume pro-
jected for 1985 at a speed required to keep the solids in suspension.
A more detailed description of the pipeline design is given in
Volume III of the facilities plan (Reference 55) and Section IV of
this  EIS.  Generally, EPA has not had any outstanding conceptual
problems with the pipeline design and, hence, no design alternatives
are offered here at this time.

      Pipeline routes were also considered to be of minor importance.
CH2M-Hill considered two pipeline alternatives depending on the sites
for the distribution center.  Since Site B-2 is preferred, the route
along Irondale Road is the corresponding alternative for the pipe-
line.  Because the pipeline will  follow roadway right-of-ways, min-
imum  environmental  or social impact is expected.

     Sites for Drying and Distribution Center —

     The most controversial  element in Metro's proposed system is
the location of the drying and distribution center.   When Metro first
proposed its spray irrigation system for sludge disposal  in 1972,
the agricultural  areas to the northeast of Denver in Adams County
were felt to be best for this type of system.  At that time, it was
anticipated that dryland farming  would be the principal user of the
sludge.   Six sites in this general area were evaluated (See Figure 2)
and a site near the present B-2,  although much larger in area, was
selected.

     Metro modified its land recycling proposal  after meetings with
                               23

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        LEGEND

I	[ORIGINAL 6 SITES DESIGNATED
I	| IN PHASE I REPORT
    REVISED  POTENTIAL SITES
    (AGRIC. REUSE PROGRAM REPT.)

    ALTERNATIVE SITES SELECTED
   [FOR FINAL CONSIDERATION
    (AGRIC. REUSE PREDESIGN REPT.)
                                                                                             [^RECOMMENDED
                                                                                             ~   SITE
                                                         SLUDGE CONVEYANCE
                                                         PIPELINE TO SITE
                                                                                             I  IRONDALE RD
                                           ROCKY
                                          MOUNTAIN

                                           ARSENAL
METRO
CENTRAL
PLANT
                                                                                    SOURCE: CHgM HILL


                                                                 POTENTIAL  DRYING
                                                                         AND
                                                           DISTRIBUTION  CENTER SITES

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local farmers who felt the loading rates for nutrients were too
high and that sludge directly applied to crops could have detri-
mental effects.  The 1973 study (Reference 5) recommended a drying
system whereby Metro would dry and store the sludge and make it
available to private farms.  A preliminary site evaluation for a
drying/processing/storage site was made in the same general area
of Adams County.  Eleven sites were evaluated, as shown in Figure 2.
A rating system was used to compare factors such as distance from
the Metro plant location with respect to markets, nearness to exist-
ing populations, soil suitability, number of homesites that would
have to be removed, visibility, elevation and land costs.  No eco-
logical factors were evaluated.  The evaluation led to the selec-
tion of three sites to be studied in more detail.  Figure 2 shows
the location of the original  six sites, the eleven sites under the
modified proposal and the three preferred sites—A, A-2 and B-2.
An environmental assessment of the three preferred sites was in-
cluded in the facilities plan and is reproduced in summary here in
Appendix G.

     The environmental assessment included an ecological  comparison
of the three sites and an archaeological investigation.  The archaeo-
logical investigation identified only one prehistoric site of pos-
sible concern located on site A-2.  The ecological evaluation con-
cluded that sites A-2 and B-2 were floristically rich areas with  a
greater potential as wildlife habitat.  This was in large part due
to the presence of "relictual prairie areas" within the sites.  On
the basis of this information, Metro redefined the sites to avoid
the relictual prairies.  Detailed information on soil  conditions
and groundwater depth and quality is not available; thus these
factors, although important,  played only a minor role in the eval-
uation.

     Metro's reasons for preferring site B-2 are described in
Chapter 6 of Volume III of the facilities plan.  Environmentally,
only land-use considerations  were felt to be significantly dif-
ferent for each site.  Metro's overwhelming reason for selection
of the B-2 site was to stay as far away as possible from concen-
trated population areas to avoid any further controversy.  This is
candidly admitted to be the principal reason for the selection
indicated in the facilities plan.  From the point of view of prox-
imity to markets and ease of  land acquisition, B-2 compares un-
favorably with the other sites.  Figure 3 shows the relationship
of the three sites to the expected principal users of the dried
sludge:  irrigation farms, sod farms and Denver park areas.  The
cost of construction and operation at the preferred site is also
estimated to be greater than  at the other sites.  More information
is provided  on the relative merits of the three sites on pages 92 and 93.

     On 8 May 1975, EPA, recognizing the controversial nature of

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                                          FIGURE  3
                                    S'arnesv.ne DENVER CITY MAP
                            GITY PARKS ARE APPROXIMATE" LOCATIONS,
IRRIGATED AND DRYLAND FARMS, SOD FARMS AND PARKS
     OF THE DENVER AREA IN  RELATION TO  THE
            SLUDGE  DISTRIBUTION SITE

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site selection, requested that the Metro District Board of Direc-
tors refrain from any actions to acquire the B-2 site until  the
National Environmental Policy Act process was completed.   EPA feels
that the work done to date by the District and CH2M-Hill  represents
a reasonable effort at evaluating the sites considered so far; how-
ever, it is necessary to evaluate a wider range of sites, which have
been suggested by others.  For example, suggestions have been made
to use the Rocky Mountain Arsenal or the Lowry Bombing Range as a
drying/distribution site.  The facilities plan did not discuss
these possibilities.  Others have expressed a desire to know why
the site could not be located further north in Weld County or fur-
ther to the southeast in the vicinity of Lowry Bombing Range.

     The Metro District has indicated to EPA that the Defense De-
partment is opposed to any use of the Arsenal site for a sludge
drying/distribution center.  At this point, it would be difficult
to say how favorable or unfavorable the Arsenal would be from a
soils or groundwater standpoint.  It is likely that unless the
Defense Department has developed a definite plan for the long-
range use of this facility, it would be reluctant to provide a por-
tion of the Arsenal on a piecemeal basis.  The site does contain
significant wildlife and natural areas; it also contains sites
where very toxic materials are stored.  It has recently been indi-
cated that the Army will have to exhaustively search any
part of the Arsenal that becomes open to public access for stored
poisons or weapons.  The Army Department also informed Metro that
no Arsenal  land could be used until the nerve gas detoxification
program is completed in 1977.

     The Lowry Bombing Range would seem to be an ideal site for the
proposed sludge drying and distribution operation since Metro has
already been operating there.  However, the pipeline would have to
traverse a developed urban area with a consequent increase in cost
and inconvenience.  A second consideration is that the elevation
of the Lowry site is about 150 m [500 ft] higher than the B-2
site which would approximately double the pumping costs.  In addi-
tion to the above disadvantages, there is a rapidly developing
urban fringe in the southeastern Denver area within eight km [five
miles] of the site, which may cause a future land-use conflict.
There are also institutional problems in acquiring the site.
Finally, the site is remote from most potential markets, as shown
on Figure 3.

     The principal way to avoid  some of these conflicts  is to obtain
some part of the Lowry Bombing Range that would not involve popula-
tion conflicts.  The institutional arrangement at present does not
allow an easy transfer of land within the range.  Metro District
utilizes a portion of the bombing range that has been leased to
                                27

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 the City and County of Denver from the U.S.  government.  Again,  it
 is premature to develop any detailed comparison  of the benefits  and
 costs of this site unless indications could  be obtained from the
 Defense Department that such land could potentially become  avail-
 able.  Were this the case, environmental  and engineering informa-
 tion would be required to evaluate the merits of sites in the gen-
 eral  vicinity.   Finally, it would appear  that the site would be
 located at some distance from its potential  markets,  especially
 irrigated farms.  However, sod farms and  Denver  parks would per-
 haps  be somewhat closer than with the B-2 site.

      Lands to the north and west  of the Platte River would generally
 be unfavorable  because of their proximity to populated areas.  Weld
 County has already indicated a lack of interest  in  having the Metro
 District  locate their  sludge distribution center within the county.
 However,  the presence  of large amounts of irrigable  lands and sod
 farms makes this area  attractive  from a potential market standpoint.
 Lands lie at lower elevations  in  this general  direction and would
 result in lower pumping costs;  land values are higher, however, and
 would increase  the capital  costs  of the project.

      The  principal  conclusions  of EPA at  this  time with regard to
 site  locations  would be the following:

      1.   There  appears  to  be no site that  is  overwhelmingly superior
 from  an overall  standpoint.
      2.   It is  generally true  (at  least in the predominantly dryland
 areas  selected  for  site consideration)  that  there are no significant
 environmental issues involving vegetation or wildlife areas that
 could  not  be  avoided.
      3.  There  is  a lack of  specific  soils and groundwater data in
 all areas  either  studied or  suggested  to  indicate the beneficial  and
 adverse impacts of locating  there.
     4.  Cost differentials  between  sites considered are small.   The
 cost  implications of some of the  suggested sites are unknown.
     5.  A  potential health  risk may  be associated with actual  phys-
 ical contact with the sludge.  However, no significant health risk
 exists as a result of the presence of members of the public living,
 working or merely visiting within the  environs of the sludge drying
 and distribution center as long as appropriate precautions  are ob-
 served.
     6.  No matter which site is selected, there will be  public  con-
 troversy about the location of a facility of this kind.   A  possible
 exception could be one of the two  Federal  areas--Lowry or the  Ar-
 senal .  However, it does not appear that these areas will  be easy
 to acquire.
     7.  Selection of an area that is reasonably close to market
areas  could be important if trucking costs are high.  However,
                                28

-------
with the range of potential uses suggested for the dried  sludge--
from sod farms to parklands--and with no definite information about
the preponderant users of the sludge, the optimal location of the
site from this viewpoint is impossible to determine at  this point.

     At this time EPA tentatively accepts the Metro District's
judgment for the B-2 site; however, no final  determination will  be
made until the EIS process is complete.  The principle  which was
advanced in the discussion of overall alternatives pertains here
as well:  it may be more important to evaluate a given  site in de-
tail and suggest design features to minimize effects on the natural
and human environment, rather than try to select an optimum site.
Those factors which could be important from, a locational  standpoint-
distance from market, soils, groundwater conditions—are  either  in-
significantly different from a cost and environmental standpoint,
or else not enough is known about particular characteristics of  the
entire area to make a judgment.

     Drying Basin Design Alternatives--

     Although there are a variety of design alternatives  that could
be of potential interest, only one at this point has been identified
as an environmental  issue:  control of percolation waters from the
drying sludge that could result in groundwater contamination.

     At present, Metro is planning to take the supernatant from
anaerobic digestion that is usually treated at the wastewater treat-
ment plant to the drying site.  In order to pump sludge the distance
called for in this plan, a sludge of two to three percent solids is
necessary.  This involves the use of some of the supernatant which
normally runs at about one percent solids.  There is an agricultural
advantage to pumping the supernatant with the sludge, since it con-
tains considerable amounts of nitrogen and phosphorus.

     A difficulty occurs when the sludge is applied to  the drying
basins.  With the sludge in a liquid form, most of the  free water
will percolate downward toward the water table.  Some water will
be lost to evaporation and some will stay in the dried  sludge, but
most will move downward where it will likely result in  degra-
dation of water quality to a degree that would make the groundwater
unacceptable as a source of drinking water.  High nitrate concentra-
tions in drinking water can cause infant methemoglobinemia.  High
concentrations of dissolved solids will deteriorate groundwater
quality for both potable use and irrigation.

     Nitrate concentrations in the percolating water may  be reduced
by bacterial  denitrification, a process that occurs under aerobic
or least depressed dissolved oxygen conditions.  It is  not known
                               29

-------
 to what degree the process might occur  in  the  drying  basins.

      Metro believes that the likelihood  of groundwater contamination
 is low and proposes to monitor  groundwater quality  in order to
 rapidly detect any deterioration.   If deterioration occurs, Metro
 would install  a system to collect  and treat percolating waters.
 Alternatively, the drying basins could  be  lined.  Both mitigation
 measures would be extremely expensive.

      Before the design of the drying basins is finalized, the issue
 of the potential  for groundwater contamination must be resolved.
 To this end, Metro's on-going experimental  work at a test site near
 Greeley might  be expanded to include studies of denitrification in
 ponds.

      Alternative Design Capacities —

      The presently proposed  system  is designed to handle the sludge
 loads from the Metro system  projected to occur in 1985.  The facili-
 ties  plan indicates  that the sludge loads  will increase from 30,000
 dry metric tons [33,000 tons] in 1974 to 55,000 dry metric tons
 [61,000 tons]  per year  in the early 1980's.  These sludge quantities
 are proportional  to  the wastewater flow volumes to be treated at the
 Metro central  (and  possibly  satellite plant) facilities.

      EPA has become  sensitive to the possible secondary impact of
 funding  large  excess  capacities  for utilities such as sewage treat-
 ment  facilities.   The  issue  becomes especially critical  in air
 quality  priority  areas  such  as Denver where water quality benefits
 obtained  from  providing  treatment to future residents conflict with
 the additional  air quality degradation from the automotive habits
 of  these  newer  residents.  EPA has funded a Section 208 study under
 the Federal Water  Pollution  Control Act Amendments of 1972 that will
 evaluate  and guide population projections of facilities plans in the
 Denver area.  The designated planning agency is the Denver Regional
 Council  of Governments(DRCOG).  At present, DRCOG has been working
 with  facilities planners  to  reduce the somewhat inflated earlier
 individual Districts' population projections, to conform with the
 planned growth  figure of  2.35 million persons in the overall  Metro
 area  by the year  2000.  The  latter goal  has been adopted by the
 DRCOG and approved by its members.

     The  sludge loads projected   by  the Metro District and its
 facilities planning consultant were developed as far back as  the
 1972 predesign  study.  The values presented in Volume III of  the
facilities plan (Reference 55) on page 4-1  are essentially un-
changed from earlier projections.  The annual rate of population
growth and hence growth in sludge loads  is  estimated to  be at
                                30

-------
 5.5 percent per annum over the 1975-1985 period.   While this rate
 did occur  in the early seventies, current growth rates in the metro-
 politan area are much closer to the recommended DRCOG growth rates
 of 2 to 2.5 percent per annum.  Thus it appears that at least the
 amount of  excess capacity designed into the sludge handling system
 may be beyond that necessary to support the aqueous stream treat-
 ment facilities sized on the basis of the lower population projec-
 tions.  Whether this excess capacity will have an influence on
 secondary  growth impacts and whether this capacity is "excessive"
 should be  evaluated further.

     There appears to be little direct correlation between the
 addition of sludge handling capacity and induced growth.   That is
 to say, additional capacity will not in itself induce individuals
 to settle  in the metropolitan Denver area.   However, EPA has gener-
 ally tried to coordinate its planning efforts for wastewater facil-
 ities with other plans in a given area for consistency.  Because
 additional capacity accommodates additional growth, it can still
 contribute toward excessive growth that may be inconsistent with
 other planning efforts.  In this case, the planning involves EPA's
 own responsibilities under the Clean Air Act.

     "Excessive" capacity is also exceptionally difficult to define
 in the case of the design of this project.   The only 'average'
 figures available for design purposes are the projected sludge
 loads.   Design values for most of the equipment are based on peak
 flows that vary with the particular unit.  Anaerobic digestion
 equipment  is already under construction and therefore not really
 an issue.  Pipeline sizing and pump sizing  is based on peak flows
 for limited time periods.  These can be related to an average flow,
 but sizing requirements are not very sensitive to average changes.
 The basin sizing is a function of the amounts of sludge and waste-
water to be dried, but two constraints apply.  First, an average
value of wet sludge, about three percent solids,  is assumed, but a
change in consistency to say 2.5 percent solids might be more im-
 portant than the actual solids amounts involved.   Secondly, the
 actual  time needed for drying in the basins is not precisely known.
A year's time is assumed for design purposes, but longer or shorter
drying times might be needed.  Construction of basin volume can be
 staged to meet needs as demonstrated in the early years of the
 project.   Metro District has indicated that no more than 180 hec-
tares [450 acres] of the proposed 240 hectares [600 acres] drying/
storage area need be developed immediately.

     The principal  alternative to the present sizing may be to
limit the monies spent on the drying/storage system.  From the
point of view of secondary impacts, since control of the size of
aqueous stream treatment facilities will  accomplish control of the
                               31

-------
 rate of wastewater utility growth, control for sludge management
 facilities  may not be  necessary.

 Sub-System  Alternatives  to the  Present
 Lowry Disposal System

      In a sense,  sub-system alternatives to a null alternative are
 a  contradiction in terms.  However, the null alter-
 native may  be  improved by certain changes which can be regarded as
 mitigation  measures or sub-alternatives.  This may be important be-
 cause, although the proposed system appears most advantageous, some
 modified version  of the  existing system is the most likely option
 in the event that the  proposed  system proves infeasible.

      Variations to the present  Lowry system presented here are
 tentative;  they have had neither the benefit of a cost evaluation
 nor an engineering and environmental evaluation.  EPA simply sug-
 gests  these alternatives at this time as somewhat less preferable
 alternatives that may  have to evaluated in more detail if funding
 is  not available  for the more capital-intensive land recycling sys-
 tem now proposed  by Metro.

      Sludge Conditioning and Digestion--

      It has already been mentioned that Metro has received a Federal
 grant  to construct facilities at the Central Plant to anaerobically
 digest all  Metro  sludges.  Part of the problem at the Lowry site
 has  been the deposition of large amounts of unstabilized sludge con-
 taining large  quantities of chemicals used for conditioning.  These
 chemicals include ferric chloride, lime and polymers.  While they
 have  not been  considered to be deleterious to the soil, it would be
 preferable  to  keep them out of the sludge if possible.

     The performance of anaerobic digesters on the raw and waste
 activated sludges  now treated at Metro must be considered an un-
 known  area  at  present.   Anaerobic digestion can improve the dewater-
 ing  characteristics of sludges  (resulting in less chemicals for
 conditioning).  However, digestion of secondary waste activated sludge
may  not perform in the same fashion.  It might be expected that odor
 and chemical-related problems at the Lowry site will  be reduced by
 the measures already under construction.  Conversion of the diges-
 ters to the thermophilic mode might further improve sludge dewater-
 ing characteristics.

     Transport—

     CH2M-Hill indicated in its evaluation of the present alterna-
tive that it might become more economical  for Metro to purchase its
                                     32

-------
own fleet of trucks to haul sludge to Lowry.  A pipeline would
appear to be a reasonable alternative only if Metro were guaranteed
long-term use of the Lowry site.

     The Lowry Site--

     As discussed previously, use of the Lowry Range is  contingent
upon Federal (Defense Department) approval and possibly  the  granting
of a long-term lease for some part of the bombing range  to Denver
or the District.  The present operation is predominantly a land-
spreading operation where sludge is being loaded onto the land at
annual rates considered highly excessive for good land recycling
practices on dryland.  As long as the area involved is small,  the
use of a "sacrifice area" is probably reasonable.  Some  plant  species
including wheat will grow on the site even with the high loading
rates.  The sacrifice would generally be in the potential  contamina-
tion of groundwater supplies and food chain hazards posed by grazing
animals.  A modification might involve restriction of grazing  ani-
mals from direct contact with sludge-amended areas.

     If grazing were to be permitted but controlled, additional
forage growth might be provided for cattle.  This could  be expensive
for Metro since large land areas would be involved and Metro would
have to purchase sludge spreading equipment.

     A second alternative might be to develop some modified  type  of
drying/windrowing operation to store anaerobically digested-vacuum
filtered sludge at Lowry for sale or distribution to local farmers,
sod farms, etc.  This would involve a substantial change of  the use
of the bombing range that would need approval by the Federal mana-
gers.  The alternative suggested here differs from the site  alter-
native consideration for the Metro proposed system in that minimal
capital investment for new facilities would be required.  Metro could
store some sludge and landspread the remainder until a market  de-
veloped.  Such a system would need large amounts of land available
in order to remain flexible.
                               33

-------
                                   ivx-.

 *****.
* '••-«•
 ., '^mm
     :P$'&-- -V-
     C-- r .   .>.<


-------
w
wm
H

-------
      This  section  contains a description of the
 general  setting for  the project.  The environ-
 mental and social  areas covered are ones that
 might reasonably be  expected to affect or be
 affected by this project or its alternatives.
      Because sludge  applications could occur
 almost anywhere  in the Metropolitan Denver area,
 it  is necessary  to broaden the focus of study to
 include  the overall  environment.  EPA is partic-
 ularly concerned about impacts that could occur
 after the  sludge has left the drying and distri-
 bution site  and  is finally applied to the land.
 Therefore,  the environmental settings for actual
 use sites  (Denver parkland, sod farms, mine-
 spoil reclamation sites, irrigated and dryland
 farms) are described to the extent that there
 are recognizable differences in the way the im-
 pacts might  occur at different sites and with
 different uses of the land.  These site-specific
 descriptions are found in Appendix E, which also
contains a description of the Lowry Bombing range
since that site is considered a basic alternative
 to the project proposed.

-------
                          SECTION III

                      ENVIRONMENTAL SETTING
     The study area is comprised of several sites, which are
highly diverse in natural and artificial characteristics.  The
service area of the wastewater management system and the City
parks are in a highly urbanized setting; most of the proposed
sludge reuse sites are rural, and the mine spoil reclamation
sites are extremely remote and isolated from public access.
While most potential land application sites are within 50 km [30
miles] of the proposed sludge drying and distribution site and
to the east of the site, the mines are generally much farther
away, to the west.

     The environmental setting for the proposed action comprises
the entire Denver region.  The general discussion of the region
in this Section is supplemented in Appendix E by descriptions of
environmental settings in five specific sites, providing examples
of possible agricultural reuses of anaerobically digested, air-
dried sludge.  For each category of reuse potential, a represen-
tative site was selected—mainly by virtue of the interest ex-
pressed by the owner and/or operator of the site in the use of
sludge in the operation—for detailed investigation of the envi-
ronmental setting and the probable impacts.

     The representative sites serve to pinpoint the impacts which
can be expected from sludge application to all areas of similar
characteristics.  For those areas which have very different char-
acteristics, the impacts may vary widely.  Therefore, it is impor-
tant that, prior to drawing generalizations from assessments made
here, one compare the environmental characteristics of the pro-
posed sites with those of the representative sites.  Clearly,
some extrapolations and approximations will be possible in many
cases; but, in some cases, it may be necessary to reevaluate the
impacts and adjust application rates and management conditions to
match the requirements of the particular site._

     A discussion of the environmental setting at the Lowry Bombing
Range sludge disposal  area is presented, also in Appendix E, to
serve as a basis for the evaluation of impacts of the "no-action,"
present alternative.
                              35

-------
 CLIMATE

      The Metropolitan Denver region,  lying on the western edge of
 the Great Plains,  near the foothills  of  the  Rocky Mountains, is
 an area of transition from the  climate of the plains to the cli-
 mate of the foothills.  The region  has a high-elevation continen-
 tal climate that has been characterized  as semi-arid, Steppe-type
 clime (Reference 9).

 Temperature

      Temperatures  are generally moderate, with a mean annual tem-
 perature of 11.3°C L52.3°F].  Ranges  in  extremes have been recorded
 from -34°C [-30°F] to 40°C [|Q5°F].   Mean monthly temperatures for
 Denver are presented in Table 3.

 Precipitation

      Monthly precipitation data for Denver are shown in  Table  3,
 Generalized precipitation patterns for the Denver region and sur-
 rounding areas  are shown  in Figure 4.  Precipitation is relatively
 light ^average  annual  depth:  31 cm [12  in.]), with a large pro-
 portion  of the  rain  falling during the growing season from April
 to September.   Much  of this summer precipitation occurs as a re-
 sult of  thunderstorm activity.  Table 4  shows the seasonal occur-
 rence of thunderstorms.   Heavy  thunderstorms in the eastern foot-
 hills and  plains area  occasionally cause damaging flash floods.
 Maximum  expected precipitation  frequencies as flood-producing
 events are  also  shown  in  Table  4, together with relative humidity
 data.  The  generally low  relative humidity is a major factor in
 the  areal  potential  evapotranspiration rate of 610 mm [24 in.]
 per  year (Reference  9).   This amount  is twice the average precipi-
 tation and  is an indication of  the aridity of the area.   Periods
 of drought  one to  two years  in  length are fairly common in portions
 of Adams County  (Reference  10).

      Snowfall is generally  not  heavy, with most snow occurring
 between  November and April.  Mean monthly snowfall  data for Denver
 are  shown in Table 3.   Extensive flooding caused by snowmelt in
 the mountains occurs only at times when there has been either a
 heavy accumulation of snow or a  sudden increase in high-elevation
 temperatures (Reference 11).  The growing season is approximately
 five to six months long, from April  to September, when the temper-
 ature does not fall  below freezing.

Hind

     Wind data  for the Denver airport are presented in Table 5.
                               36

-------
                    Table 3.   TEMPERATURE,  PRECIPITATION, SNOW AND FREEZE DATA, DENVER (WB CITY)
CO
Mean
Temperature
°C
[°F]
P re c ip it at ion
trim
[in.]
Snowfall
^m
[ia.]
Freeze
Jan

1.2
34.1

8.6
0.34

15.7
6.2

Feb

1.8
35.3

16.3
0.64

23.6
9.3

Mar

3.6
38.5

20.6
0.81

29.7
11.7

Apr

8.8
47.8

36.8
1.45

27.2
10.7

May

14.7
58.4

65.0
°.56

3.0
1.2

Jun Jul

20.8 23.6
69.4 74.5

25.9 37.3
1.02 1.47

0.3 T
0.1 T

Aug Sep

22.9 18.4
73.2 65.1

30.5 19.3
1.20 0.76

T 3.3
T 1.3

Oct

12.1
53.7

24.4
0.96

8.1
3.2

Nov

4.7
40.5

14.2
0.56

17.5
6.9

Dec

2.6
36.6

10.7
0.42

17.0
6.7

Annual

11.3
52.3

309.6
12.19

145.5
57.3

             No.  days with     25     22     21    10      1     +a     0      0     +      5     18    24       126
               temperature
               <  0°C [32°F]
Freeze threshold
°C [
0 [
-2.2 [
-4.4 (
-6.7 [
-8.9 [
temperature
°F ]
32 ]
28 ]
24 ]
20 ]
16 ]
Mean number of days between
spring occurrence and first
166
192
212
231
239
date of last
fall occurrence





           "+ - 0 >  .5
           Source:   Decennial Census of  United States Climate,

-------
                                     »-  ,-;'
 FbRT'LUPTON

CITY1  '            355
                  (14)
  RY CJREER DAW   A   I

  380 ',       :
\ (is) :       i
       ©  SL7LECTED REPORTING WEATHER STATION

          ISOHYET ,  mm (inches)
   |   SOURCE' WATCH QUALITY MANAGEMENT PLAN REPORT
         GENERALIZED PRECIPITATION
              PATTERN IN THE
        METROPOLITAN DENVER REGION

-------
Table  4.  MAXIMUM PRECIPITATION FREQUENCY, THUNDERSTORM AND RELATIVE HUMIDITY DATA, DENVER

Maximum amounts of precipitation to be expected within different time periods
(frequencies)
Frequency, 6-hour total 24-hour total
years mm [in.] mm
2 36 to 41 [ 1.4 to 1.6 ] 46 to 56 [1
5 46 to 51 [ 1.8 to 2.0 ] 61 to 71 [2
10 56 to 64 [ 2.2 to 2.5 ] 66 to 86 [2
25 71 to 76 [ 2.8 to 3.0 ] 86 to 97 [3
50 76 to 86 [ 3.0 to 3.4 ] 97 to 117 [ 3
100 86 to 97 [ 3.4 to 3.8 ] 107 to 127 [ 4
ir> Thunderstorms, mean number of days
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
0+a +16 10 12 8 4 1 + 0
Relative humidity
percent percent of time
0 to 29 27
30 to 49 28
50 to 69 23
70 to 79 10
80 to 89 9
90 to 100 4
[in.]
.8 to 2.2 ]
.4 to 2.8 ]
.6 to 3.4 ]
.4 to 3.8 ]
.8 to 4.6" ]
,2 to 5.0 ]

Annual
43

The symbol + indicates a range between 0 and .5.
Source: Water Quality Management Plan, Denver Regional Council of Governments.

-------
Table 5. WIND DATA, DENVER (WB AIRPORT)

Wind speed Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Mean hourly speed
mps 4.3 4.5 4,8 4.7 A. A A. A 4.0 3.7 3.7 3.8 A. 3 4.5
[niph] 9.6 10.1 10.7 10.6 9.9 9.8 9.0 8.3 8.3 8.5 9.7 10.0
Prevailing direction SSSSSSSSSSSS
Fastest speed
mps 18 22 2A 23 19 21 20 18 21 18 18 23
[raph] Al A9 53 52 A3 A7 AA AO A7 AO AO 51
Direction NW NW NW SE NW S SE SW NW SW NE NE
o Frequencies of wind speed percent
0 - 1 aps [ 0 - 3 mph] 9.6 9.2 8.6 8.0 9.1 9.8 11.6 1A.3 13.1 13. A 10.1 10.2
2 - 3 mps [ A - 7 mph] 25.6 25.1 23.2 23.5 2A.8 25.2 28.2 27.6 30. A 33.5 26.9 25.8
A - 5 nips [8-12 mph] 3A.A 33.0 33.5 31. A 33. A 3A.O 35. A 35.6 3A.1 33.0 33.6 3A.2
6-7 mps [13 - 18 mph] 2A.2 2A.1 22.7 2A.3 2A.2 23.0 20.5 19.3 18.9 16.6 23.1 22.2
8-10 mps [19 - 2A mph] A. 6 5.8 7.0 7.9 6.3 3. A 2.6 2.9 2.9 2.7 A. A 5.2
11 - 13 mps [25 - 31 mph] l.A 2. A 3.6 3.9 1.6 1.5 0.8 0.7 0.6 0.6 1.4 1.8
14 - 16 mps [32 - 38 mph] 0.2 O.A 1.1 0.7 O.A 0.3 0.1 +a 0.1 0.3 O.A 0.5
17 - 20 mpo [39 - 46 mph] 0 + 0.2 0.2 + + + 0 0 0.1 + 0.2
> 21 mps [ > A7 mph] 000 + 00 + 00000
+ •» < 0.5 percent.
Source: Water Quality Management Plan, Denver Regional Council of Governments.
Annual
mean

4.2
9.5
S

24
53
NW

10.6
25.7










-------
Air- quality is adversely affected by low wind speeds and special
atmospheric gradients.  Air pollution in Denver can occur when wind
speed  is  1 mps [3 mphj or less.  A wind blowing at 2 mps [4 inph]
will usually clear polluted air out of the city in about two hours
(Reference 9).  At the airport (see Table 5), wind speeds of 1 mps
[3 inph] or less occur 10.6 percent of the tine; winds blowing at
3 inps  [7  mphj or less occur 36.3 percent of the time.

     Chinook winds periodically blow from the mountains with great
turbulence.  This phenomenon results from high-elevation westerly
winds  being warmed in their rapid descent through a shallow layer
of cool air covering the plains.  Sudden rises in temperature ac-
companying these gusty winds exert a moderating influence on winter
temperatures.

Regional  Climatic Variations

     Additional climatic data are presented for the six weather
stations  whose locations are snown in Figure 4.  Climatological
data for  the city of Denver was presented previously in Table 3.
Information from this table is applicable to the city's parks.
Data provided by the Denver Airport and Fort Lupton weather sta-
tions  (Table 6) are applicable to sod farms, irrigated farms and
dryland farms.  The Cherry Creek Dam and Byers weather stations
(Table 7) are at the western and eastern extremes, respectively,
of the Lowry Bombing Range.  Data from these stations also pertain
to some of the sod farms south of the Denver Metropolitan Area.
These five weather stations fall within the Denver region, an area
that is generally uniform climatically, although there are some lo-
cal variations.

     The  sixth selected weather station, at Berthoud Pass, is lo-
cated on  the crest of the Continental Divide and experiences a dif-
ferent climate altogether.  Discussion is deferred to a separate
heading under Mine Spoil Site in Appendix E, as data from this sta-
tion are applicable to that area only.

TOPOGRAPHY

     The  Metropolitan Denver region is located along the western
periphery of the high plains of Colorado, which slope gently up-
ward for  almost 300 km [186 miles] from the eastern border of the
state to  the base of the foothills of the Rocky Mountains.  The
relief can be characterized as rolling prairie, with some hills and
ridges intersected by nearly flat floodplains along watercourses.
Much of the land currently under cultivation, mostly to the east
and northeast of Denver, is nearly flat ana level.  Most of the
land in Adams and Arapahoe counties has a slope equal to or less
                               41

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         Table 6.  TEMPERATURE,  PRECIPITATION, SNOW AND FREEZE  DATA,
                       DENVER  (WB  AIRPORT) AND FORT LUPTON
Mean
Teaperature
Denver AF
•c
[•FJ
Ft. Lupton
•c
I'll
Precipitation
Denver AP
ma
[in.]
Ft. Lupton
na
[in.]
Snowfall
Denver AP
ca
r 4 i
[in.]
Ft. Lupton
CO
[in.]
Freeze
No. days with
teaperature
i O'C [32*F]
Denver AP
Ft. Lupton








Jan Feb Mar Apr


-0.3 0.7 2.9 8.1
31.5 33,3 37,3 46.6

-1.2 -0,3 3.1 9.3
29.8 31.4 37.5 48,8


13. Q 23.4 34,5 45.5
0,51 0.92 1.36 1.79

12.2 14.5 23.4 26.7
0.48 0.57 Q.92 1.05


19.8 27.9 38.9 30.2
70 Tin 111 1 1 Q
, O .LJ.aU JL3,J 1.1. * 7
21.8 18.5 12.2 6.4
8.6 7.3 4.8 2.5




29 25 25 13
30 27 28 15
Freeze threshold
temperature
•C [ -F 1
0 32
-2.2 28
-4.4 24
-6.7 20
-8.9 16
May Jun Jul Aug


14.1 20,2 23.1 22.3
57.4 68,3 73,5 72,2

14,9 20.5 23,4 22.2
58.8 68.9 74.1 72.0


77.0 25.4 50.8 39.1
3.03 1.00 2.00 1.54

54.1 16.8 32.5 36.6
2.13 0.66 1.28 1.44


3.3 0.3 T 0.3

0.8 0 0 0
0.3 0 0 0




1 +a 0 0
2 + 00
Sep Oct Nov Dec


17.8 11.3 3.7 0.9
64,0 52,4 38.6 33.7

17.6 10.9 3.1 -0.2
63,6 51.7 37.5 31.6


23.6 29.7 20.3 14.7
0.93 1,17 0.80 0.58

23.6 24.6 11.4 10.7
0.93 0.97 0.45 0.42


4.3 9.4 23.4 19.3

0 0.3 5.3 8.6
0 0.1 2.1 3.4




+ 7 23 29
1 13 27 30
Annual


10.4
50.7

10.3
50.5


397.0
15.63

287.0
11.30


177.0
£Q -J
07./
73.9
29.1




153
173
Mean nuuber of days between date of last
spring occurrence and firs
Denver AP
160
184
198
222
230
jt fall occurrence
Ft, Lupton
143
175
196
213
226







 + - 0 > .5
Source:  Decennial Census of United States Climate.
                                       42

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       Table 7.   TEMPERATURE,  PRECIPITATION,  SNOW AND FREEZE DATA,
                          CHERRY  CREEK DAM  AND BYERS
Mean
Temperature
Cherry Cr. Daa
•c
t'F]
Byers
•c
IT]
Precipitation
Cherry Cr. Daa
na
[in.]
By era
IBS
[ln.1
Snowfall
Cherry Cr. Daa
ca
[la.]
Byer»
ca
[in.]
freeze
No. days with
teaperature
< O'C [32'F]
Cherry Cr. Daa
Byers
Jan Feb Mar Apr


-0.3 0,6 2,8 8,1
31,5 33.1 37.1 46,6

-1.1 0.2 2.6 7,9
30.1 32.4 36.6 46.2


7.9 16.3 20.1 41.4
0.31 0.64 0.79 1.63

11.2 13.0 22.1 34.0
0.44 0.51 0.87 1.34


22.1 21.6 28.7 22.9
8.7 8.5 11.3 9.0

20.1 22.6 26.9 19.3
7.9 8.9 10.6 7.6




29 27 28 17
30 27 28 17
Freeze threshold







temperature
•c [ •? 1
0 32
-2.2 23
-4.4 24
-6.7 20
-8.9 16
Kay Jun Jul Aui? Sep


13.5 19,7 21,9 21,3 17.3
56,3 67.4 71,5 70.3 63,2

14.0 20.1 23.0 22,1 17.8
57.2 68.2 73.4 71.8 64,1


78.7 28.4 43.7 30.7 18.3
3.10 1.12 1.72 1.21 0.72

65.3 30.7 58.2 40.9 20.8
2.59 1.21 2.29 1.61 0.82


3.0 0 0 0 1.5
1.2 0 0 0 0.6

3.0 I T I 2.3
1.2 T T T 0.9




3 +a 0 0 1
2 + 0 0 1
Oct Hoy D«c


11,2 3,7 0.7
52,2 38,6 33.3

11.2 3.1 0.1
52,1 37.6 32.1


26.9 13.7 11.2
1.06 0.54 0.44

21.8 14.0 8.9
0.86 0.55 0.35


16.0 15.7 22.9
6.3 6.2 9.0

4.8 18.5 12.7
1.9 7.3 5.0




10 26 29
9 25 30
Annual


10.1
50.1

10.1
50.2


337.3
13.28

341.4
13.44


154.4
60.8

130.3
51.3




170
169
Kean cumber of days between o-te of last
spring occurrence and first fall
Cherry Creelt Daa
135
155
190
211
222
occurrence
Byers
133
168
133
204
222







 •*• • Q > .5
Source:  Decennial Census of United State* Climate; Cliantologicil Dau for th« U.S.:' Colondo.
                                      43

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than nine percent, as shown below (References  10,14).

                       Percent of total  land area  In county
County
Adams
Arapahoe
<. 5% slope
63.7
55.7
1 9% slope
75.5
73.0
     Elevation in the eastern plains section  of  Colorado  ranges
from 1,020 m [3,350 ft] at the lowest point in the  state  (where
the Arkansas River crosses the border]  to  about  1,600 m [5,280 ft]
around the Denver area.  West of Denver, the  plains give  way abruptly
to the foothills, with elevations of 2,100 m  to  2,750 m [6,890 ft
to 9,025 ft].  Typical elevations for sites within  the study area
are shown in Table 8.  General elevations  for the region  are shown
in Figure 5.


   Table 8.   TYPICAL ELEVATIONS FOR SITES  WITHIN THE STUDY AREA

Study site
City park
Sod farm
Sou farm
Sod farm, irrigated farm,
dryland farm
Irrigated farm
Dryland farm
Lowry Bombing Range
Lowry Bombing Range
Nearby city or
weather station
Denver
Littleton
Brighton
Fort Lupton

Platteville
Wat kins
Cherry Creek Dam
Byers
Elevation
m
1,609
1,634
1,518
1,497

1,469
1,685
1,721
1,584
[ft]
[ 5,280 ]
[ 5,362 ]
[ 4,982 ]
[ 4,914 ]

[ 4,820 ]
[ 5,530 ]
[ 5,649 ]
[ 5,200 ]
     Many rivers and creeks flow out of the mountains and foothills,
mostly in a south-to-north direction through the Denver region, in
the Platte Drainage watershed.  The South Platte River and Cherry
Creek flow through the heart of Denver.

     Separate discussion of the topography of the mine spoil  sits
is presented under that heading in  Appendix E.

GEOLOGY

      he Metropolitan Denver area is located in the Denver Basin
    T
                              44

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j
            '
                   A    , R     A    ,P    A

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 near its  boundary with  the  Front Range.  The strata of the Denver
 Basin dip slightly  toward the  east, while the strata of the Front
 Range have a  steep  dip.  The two geologic regions are separated by
 a  zone of sharp, almost vertical folds.  Thus the dip of a forma-
 tion several  kilometers west of Denver would be high (>90 percent),
 while the dip of the  same formation several kilometers east of
 Denver would  be slight  (
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                                      FIGURE  6
                        GEOLOGIC MAP
                 OF AREAS IN THE VICINITY OF
                    METROPOLITAN DENVER
                  FOR EXPLANATION OF SYMBOLS
                  SEE THE FOLLOWING 2 PAGES

                  SOURCE: GENERALIZED SURFICIAL GEOLOGIC MAP
                        OF THE DENVER AREA,COLORADO
   OCKY MfN.
ARSENAC WELL
           47

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                                                                                                               FIGURE   6   (cont.)
                                                    EXPLANATION
                                     Loess, eolian sand, colluvium
                                           undifferentiated
                               Wind-deposited silt, sand: sand and cvbbtfs on
                                 foothill slopes. Silt and sand deposits 0-$0
                                 feet thick, sand and cobbles as much as 10
                                 feet thick.  Saturated sand and yraref may
                                 yield 1 to 5 gpm to tcells
                               Post-Piney Creek alluvium, Piney Creek
                                 Alluvium,  pre-Piney Creek alluvium,
                                 Broadway and Louviers Alluviums
                               Sand, grartl. Kilt, and clay.  Deposits range
                                from 0-60 feet thick.   Saturated sand and
                                grartl yield ox much a,s J,OfjO gpm to icells.
                                Chemical quality of teat er generally good
                                  Slocum, Verdos, and Rocky Flats
                                             Alluviums
                              Reddish-brown silty clay. silt,  sand,  pebble
                                lenses, and /w.s-s.  Course gravel and sand
                                and  rolcanic axh  underlie high  terract
                                re tn Hants. L'nit may exceed 50feet in thick-
                                ness  locally.   Yields J to  5 gpm  to irells
                                tcher? material* are saturated.  Gravel and
                                sand near Barr Lake yield as much as 200
                                gpm  to  icflh.    Water generally  of poor
                                quality.^ contains excess ire  concentrations
                                of fluoride
                                             L
                                               TKcd
                              Castle Rock  Conglomerate, upper p£-t
                                of  Dawson   Formation,  and  upper
                                part of Denver Formation
                              Gray,  broicn.  tan. and greenish-gray shale.
                                clay, and siltstone. and numerous lenticular
                                beds  of  light-colored  conglomerate  and
                                Hand* tone.   .\ndesitic  mudflotc breccias
                                common  in  vicinity  of Table  Mountains
                                and  Green Mountain. Beds of sandy lime-
                                stone, lignite, coal,  and  carbonaceous shale
                                are common. L'nit ranges in thickness from
                                3Wt to 1,+ 00 feet. Yields lefts than 25 gpm
                                to u'eils in mr.xt of the area, but as much a*
                                150 gpm  in southeast part.   Locally u-ater
                                contains  high concentrations of ditsoh'ed
                                solids,  iron,  radioactive constituents, and
                                hydrogen suljlde gas
                                             I
                                                Kdl
                              Lower part of Dawson Formation, Arap-
                                ahoe  Formation, and lower part  of
                                Denver Formation
                              White  to yelion- arkotic sandstone and con-
                               glornfrate  interbedded  irith gray,  green.
                               and  red  .thole and  claystone.   Contain*
                               all u rial and mudflotc ande^itic detritn*.
                               CoH'jfornerrtte hrdx thicken  itt xpper f»irt.
                               and nrt> thtckvr nnd mure nttititrmut ton-(ird
                               avuthir .if part  of the  tmm'n.  L'nit  ranyex
                               from ±wtn l, + 'mfftt thifk.  Yittd* to irellt
                               areruye 100 up m and arena much ax^OfJgpm.
                               Water generally nfad quality
                                 Upper part of Laramie Formation
                             Blxe-gmy nilty shale, thin xilty Hdnd-itnne.
                               limestone, and coal: cvxi/ thickest in  fa>rtr
                               part.  Yield* 1 to 2 QP^  of poor quality
                               water to trflft.   Witter contains hydrr^jen
                               sulfide. iron, and methane
                   Volcanic rocks
               Lai-afloirson Table Moun-
                 tains,  rent source near
                 Kalstoit Creek, and ask
                 flow tuffs  neur  Castlt
                 Rock.   Ash jloir tuffs
                 underlie  Castle   Rock
                 Conglomerate.      AV
                 knou-n to be saturated
Ift
D
o
LJ
"
u
u
Geological  map  of  areas   in  the  vicinity  of  Metropolitan  Denver   (cont'd)

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                                                                                                        FIGURE   6    (cont.)
              I
                                        Klf
 Lower part of Laramie Formation and
          Fox Hills Sandstone
Medium-grained   sandstone   (60-80  feet),
  orerlying and grading into  finer grained
  thin-bedded  sandstone  interbedded   with
  siltstone and shale  fJO-100 feet}.   fine
  grained  qitartzost  sandstone,  siltstone,
  shale (80-230 feet).  Wells penetrating en-
  tire unit generally yield 100 gpm and a few
  yield as much as $00 gpm.  At places water
  may  contain  objectionable  amounts  of
  methane, hydrogen sulfide, iron,  and fluo-
  ride
                                       Kpb
                         Pierre Shale, Xiobrara Formation,
                                and Benton Shale
                     Gny, blue, and black shale, sandy shale, and
                       thin limestone; some silty sandstone, ben-
                       to/iite seams, chalky marl, and lijrustone.
                       Units may total S,000 feet in Denver Basin.
                       Fractured zones in shale may yield 1 to 2
                       gpm of poor quality water to icetlt
                                    [   Kd
                                  Dakota Group
                     Upper 100 feet gray-tchite fine-  to medium
                       grained sandstone,  thin-bedded, to massive.
                       Middle 350 feet  dark-gray silty carbona-
                       ceous  shale,  contains  refractory   clay.
                       Lou-er60feet gray coarse sandstone, locally
                       conglomeratic.  cros.f bedded.     Sandstone
                       yields 5 to 30 gpm ta  u-ellx  near outcrop.
                       Water contains excessive iron locally
                        Sedimentary rocks undifferentiated
                     Includes Upper Jurassic Morrison (300 feet)
                       and Ralston Creek 1120 feet) Formations;
                       Triajssic(f) and Permian Lykins Formation
                       (£00 feet); Permian Lyons Sandstone (200
                      feet); and Lower Permian and L'pp€r and
                       Middle Pennxylranian Fountain  Forma-
                       tion (1,200 feet).  Lyons Sandstone, shotrn
                       by stipple, generally yields 5 to 10 gpm, and
                       as much  as 80 gpm  to u~ells  near outcrop
                      areas. Fountain Formation sandy conglom-
                       erate may yield 1 to 5 gpm to icells.  H'afer
                       may contain extexstire iron and fluoride
                         Igneous and metamorphic rocks
                                 undifferentiated
                     Granite, gneisx. schist,  quartzite, pegmatite.
                       quartz reins, intruaire igneous rocks.  Yield
                       1 to 5 gpm of generally good quality u-ater
                       to veils that tap fractures or it-fathered
                       xnnes
                                     Contact
                                      Fault
                                                                    y
                                                                  ZU)
                                             •I
                                               I-
                                            f
                                            o
                                            UJ
                                            tr
Geological  map  of  areas  in   the   vicinity  of  Metropolitan  Denver   (cont'd)
                                                            49

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in
o
Table 9. STRATIGRAPHIC UNITS AND THEIR WATER-BEARING PROPERTIES IN THE VICINITY OF DENVER
System
Quaternary

Tertiary
Cretaceous
Series

lecent «nd
Pleistocene
Pleistocene
Paleocene
Upper
Cretaceous
Subdivision
Dune sand
Slope wash
Valley-fill
deposits
Upland
deposits
arkose
Dawson
Denver
formation
Arapahoe
formation
Laramie
formation
Fox
a
Hills
andstone
Thick-
ness
ma
0-15
0-9
0-40
0-5
0-60
0 - 185
0 - 185
0-75


Fine to medium sand and minor amounts of clay
and silt.
Poorly sorted clay, silt, sand and gravel;
grades into val ley-f ill deposits*
Interbedded clay, silt, sand and gravel that con-
tains some cobbles and boulders and beds of al-
tered volcanic ash. Underlies the flood plain
and terraces on the South Platte River valley and
underlie floor of Bccbe Draw and Bex Elder Creek
Valley, Include some slope wash along the edges
of Beebe Draw and Box Elder Valley.
Deposits of sand, gravel, conglomerate and vol-
canic ash that mantle the bedrock in the upland
arens. Include colluvium, r -siduum and remnants
of pediment and terrace deposits.
Varicolored clay, soft shale and siltstone con-
with lenticular poorly sorted generally moder-
ately indurated yel lowish-hrown sand s tone and
conglomerate. Local ly contains andesitic mate-
rial and beds of weathered volcanic ash and ben-
tonltlc clay .
Upper part (120 m) : Soft predominantly blue or
lenticular boils of sandstone.
Lower part (60 m) : White to yellow sand, gravel
and conglomerate, variously Indurated and in-
cluding minor amounts of shale and clay.
Upper part (120 m) : Chiefly olive-gray silty
shale and si'ltstone and lenticular sllty sand-
stone; contains numerous carbonaceous clay
beds and 1 ignit Ic s earns .
Lower part (60 m) : At top, a sequence of thin
beda of blue-gray ailty shale, sandstone and
thin beds of sandstone, fairly thick beds of
a ubb 1 1 urn 1 nous coal, and several other thinner
sandstone units that locally coalesce with the
thick basal sandstone.
Uniformly bedded buff to pale-yellow friable
medium-grained sand atone interbedded with gray
to black sllty shale and sllty sandstone. About
15-18 m of massive sandstone at top.
Water-bearing
properties
Serves mainly as medium for recharge from pre-
cipitation . Local lv vie 1 ds srr.,i 11 quantit_tjs of
vatrr to donrst ic and sti-r- vM ] s .
Yields small to arderat**
domestic and stock wells
we 11 s .
quantities of water to
and to a f ft. irrigation
The most important aquifer In the report area and
the source of groundvater for nearly all the
large-capacity wel Is. Yield r.oderat e to large
quantities of water to many Jcnestic, stock,
irrigation, public-supply and industrial veils.
Topographically high and
medium for recharge from
Yields small quantities
of water to domestic
and stock wells In the
southern part of the
report area.
Yields small to moder-
ate quantities of water
to domestic, stock, pub-
lic-supply and inJustri-1
al wells in the southcrr

UP 1 1 drained. Not a
precipitation.
The Pawscn arkose.
stratipraphically
equival pni tc part
of the Denver and
Ar 3 pa hoe f orir,at 1 ons ,
yields srr.al 1 to
moderate quantities
of water to domestic,
sfc c'r- , puM I c- supply
and industrial veils
in the southeastern
part of the report
area .
Some of the sandstone unl ts in the upper part
yield smal 1 to modera ', e quantities of water to
domestic, Etock and industrial wells through-
out the report area.
The basal sandstones in the lower part yield
small to moderate quantities of water to domes-
tic, stock, public-supply and industrial wells
throughout the area.
Yields small to moderate quantities of water to
domestic , stock , public-supply and industrial
wells throughout the report area.
Water y le1. d ,
litc-rs per s*-cc r- j
0.1 - 0.3
!
I
1:5
125
0.3 - 13
1 - 9
1 - °
6-25
upp^r : 0.1
lower: (, - :5
6-25
i
*l nwter - 3,261 feet
1 liter per second * 15.85 gallons per minute
S-iurce: Ground Water Resources of the South Platte River Basin in Western Adams and Southwest Weld Counties, Colorado

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The  Dawson Arkose and Denver formations, unlike the Arapahoe, have
poor groundwater yield and serve as an aquitard.  The upper parts
of these formations outcrop in southeastern Arapahoe County.

      Most of the surface of the study area is covered by unconsoli-
dated Quaternary deposits which range in thickness from 0 to 20 m
[0 to 66 ft].

      Early in the Quaternary, before the Wisconsin glaciation, de-
bris from the Front Range formed large deltas in the Denver Basin.
The  deltas included layers of silt, sand and gravel as well as some
volcanic ash.  The pre-Wisconsin Quaternary deposits are designated
as Qsi on the geologic map presented on Figure 6.  The water yield
of these deosits is small and generally of poor quality.

      During the Wisconsin glaciation, the Denver Basin, particularly
the  western portion near the city of Denver, served as an outwash
area  for the glaciers in the mountains to the west.  The torrential
flow of the outwash streams eroded the underlying deltas and depos-
ited  as much as 20 m [66 ft] of sand, gravel, silt and clay over
them.  Thus outcrops of the Qsr formation represent topographic
highs which v/ere not destroyed by the outwash streams.  The allu-
vium  from the glacier forms an aquifer with good water quality and
yield as high as 125 Ips [2,000 gpm].  The Wisconsin alluvium is
depicted as Qpl on the geologic map.  Strong winds capable of car-
rying heavy bedloads also characterize outwash areas.  The winds
shift the unconsolidated alluvium.  These eolian deposits, depicted
as Qs on the geologic map, cover more of the surface than does any
other deposit in the study area.  They range in tnickness to about
three meters [10 ft] and have a small yield (about 0.3 Ips [5 gpm]).

     The proposed sludge reuse sites, except for the irrigated farms
in Weld County, are plotted on the geologic map.  In general, water-
bearing formations used intensively as a groundwater source, are
less  suitable for sludge disposal.  Many other factors are impor-
tant, however;  the geologic character of an area cannot be the only
criterion for site selection.

Earthquakes

     During the history of Denver, only one earthquake of damaging
proportions has been reported near Denver.  In the mid-1960's, how-
ever, several mild earthquakes occurred.  These earthquakes centered
around the Rocky Mountain Arsenal  well, where millions of gallons
of contaminated water were injected into the highly faulted pre-
Cambrian bedrock (Reference 19).  In the future, it is unlikely that
major earthquakes will  occur in the Denver area.  It will probably
not  be necessary to incorporate earthquake lateral force considera-
                               51

-------
 tions into  design features  for  the  sludge disposal systems.

 SOILS

      Soils  in  the study  area  have been surveyed by the U.S. Soil
 Conservation Service  (SCS)  in recent years.  Final reports on de-
 tailed  soil surveys have been published for Adams County (Refer-
 ence  10)  and Arapahoe  County  (Reference 14).  As for Weld County,
 a  detailed  survey has  been  completed, but no published report is
 available.  Official soil series descriptions and interpretations
 for the Weld County soils which may be subjected to sludge appli-
 cation  were obtained from the SCS field office in Greeley (Refer-
 ence  22).

      Soils  in  most of  the potential areas of sludge application
 are for the most  part  calcareous.  They fall within about 20 dis-
 tinct associations with  characteristics typical of their geographic
 setting.  The  topography, drainage, texture and parent materials
 of these  soils are presented  in Appendix B and are shown graph-
 ically  on Figure  7.  Specific characteristics of soils in each
 typical site under investigation are presented separately under
 the discussion of  the  environmental setting of the particular site
 in Appendix E.  The published soil surveys are indispensable as a
 tool  tor planning  sludge use  in agriculture on a regional basis.
 However, for application on a specific field, this information
 should  be augmented with additional field investigations by soil
 scientists and/or  agronomists.

      An important  soil property which should be carefully consid-
 ered  in sludge application  is the micro-community inhabiting the
 soil.    Microbial  populations living in the soil include viruses,
 bacteria, actinomycetes, fungi, algae and protozoa.   Soil aeration,
 acidity, temperature,  moisture content,  organic matter, inorganic
 nutrient supply and other parameters determine the relative popula-
 tions of the various microbial groups.  Some of the  important func-
 tions of soil  microorganisms, insofar as  sludge application is con-
 cerned, are (1) uptake of nutrient elements and their conversion
 to organic matter, (2) production of growth factors  stimulating
 other organisms,   (3) breakdown of complex organic molecules to
 simpler, more readily usable forms, (4)  production of antibiotics
which inhibit some organisms, (5) symbiotic relationships between
certain organisms, (6j predation and parasitism between organisms,
 (7) nitrogen fixation  from the atmosphere under certain conditions
and (8) production of  enzymes which promote many different  biochem-
ical  reactions.
                               52

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                               FIGURE  7
         SOIL ASSOCIATIONS IN
          VICINITY OF DENVER
               0      468
                  KILOMETERS
           02468
  SOURCE : WATER QUALITY MANAGEMENT PLAN
        U.S. SOIL CONSERVATION SERVICE
           ADAMS COUNTY
             RAPAHOE "COUNTY
53

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 WATER

      The Metropolitan  Denver  area  is water-deficient.  It is
 through large-scale transmountain  diversions that the demands of
 the area are balanced  with  imported supplies.   Intricate and long-
 standing water rights  and allocations dictate ownership and use of
 the existing and  developed  supplies.  Municipalities, irrigated
 farms,  industries,  recreation projects, fisheries and stream aes-
 thetic  requirements impose  cumulative and sometimes conflicting
 demands upon quality and quantity  of water in the study area.

      Even though  sludge-handling is an important phase of the to-
 tal  water management picture  in the region, it neither demands nor
 supplies significant quantities of water to the total system.  How-
 ever, sludge must be viewed as a potential threat to the quality
 of  waters, both in  the ground and  on the surface.  Thus, the dis-
 cussion that follows is not aimed at" being a comprehensive eluci-
 dation  of the  water supplies  of the region; rather, it is meant to
 provide the  basic background  for the impact statements which are
 presented in the  succeeding sections.

 Groundwater

     The water-bearing properties of strata underlying the study
 area are presented  in  Table 9 under Geology.  Valley fill deposits
 of  Recent and  Pleistocene series, ranging in thickness from 0 to
 40 m [0 to 125 ft]  comprise the most important aquifers in the
 area.   These aquifers  underlie various thicknesses of dune sand
 and  slope wash.   The valley fill deposits yield moderate to large
 quantities of water  to the domestic, stock, irrigation, public
 supply  and industrial wells.  Depth to water table ranges from a
 meter [a  few feet]  to  30 m [100 ft].  Detailed data on groundwater
 occurrence and movement are not available.

     Below this aquifer formation,  strata with low permeability
 (aquitards)  separate the upper aquifer from the important Laramie-
 Fox Hills aquifer, which lies at considerable depths (90 m [300
 ft] at  Platteville;   520 m [1,700 ft] at Lowry Bombing Range;  400 m
 [1,300  ft] at the proposed sludge drying  and distribution center)
 from the  land surface.   Wells penetrating the full  thickness  of
 this aquifer can yield  from 6 to 60 liters per second [100 to 900
 gallons  per minute].

     Water quality in the upper aquifer is generally good,  although
 scarcity of data preclude adequate  evaluation.   The  Laramie-Fox
 Hills aquifer water  quality varies  from one place to another.   Near
 its recharge sites,  to  the south and east,  the quality is superior
to that at some other locations,  where objectionable amounts  of
                               54

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methane, hydrogen sulfide, iron and fluorides are encountered.

Surface Water

     Even though the study area is interlaced with many of the  trib-
utaries of the South Platte River, most of the creeks in the east-
ern part of the study area are dry during most parts of the year.
Some streambeds are wet only on rare occasions:  once every several
years.  Streams draining the western parts of the Metropolitan
Denver area flow during most of the year and include St. Vrain
Creek, Boulder Creek, Coal Creek, Big Dry Creek, Clear Creek, Sand
Creek, Cherry Creek, Bear Creek, Plum Creek and many smaller creeks.
Many diversion structures across streams on the western slopes  of
tne Continental Divide have been constructed to transfer water
through the mountains to the eastern slopes and to discharge the
water in the above-mentioned streams.  These water diversions,  res-
ervoirs built on the creeks themselves, groundwater withdrawals,
irrigation diversions and their return flows have drastically
changed natural flow patterns in these streams.  A discussion of
the quantities and quality of water in the streams, as well as  a
model of stream water quality in the Denver Basin, are presented in
the recently published Water Quality Management Plan (Reference 9).

     During the period 1966 through 1970, annual stream flow into
the Metropolitan Denver area totaled 450 million cubic meters
[185,600 cfsd], 95 percent of which was diverted from the streams.
Fully 38 percent of the streamflow into the Denver Area in that
period was wastewater treatment plant effluents from upstream areas,
and over half of the water leaving the metropolitan area was gen-
erated within the area (Reference 9).

     The lakes in and around the metropolitan area are of special
significance.  Most of the lakes were used for irrigation before
the area became heavily urbanized.  Most are now used for recreation
and as centers of real estate development.  There are some 50 lakes
with surface areas greater than 10 hectares [25 acres], with a  total
combined area of 3,686 hectares [9,103 acres] and a total shoreline
of 185 km [115 miles].  The three largest lakes are:
Lake
Barr
Stand! ey
Chatfield
Surface area
hectares L acres J
708 [ 1,750 ]
492 [ 1,216 ]
465 [ 1,149 ]
There are another 113 lakes of 2 to 10 hectare [5 to 25 acre] sur-
face area, with a total area of 526 hectares [1,300 acres] and a
shoreline of 110 km i63 miles] {.Reference 23).
                               55

-------
      Water quality in the  lakes  nas deteriorated progressively
 over the past decades with chemical and  biological pollutants
 emanating from the increasingly  heavy use and development of the
 surrounding area.   A recent investigation of the present quality
 of waters in these lakes,  including parameters such as salinity,
 pH, transparency and coliform  bacteria,  is reported by the U.S.
 Geological  Survey in graphic format (Reference 23).

 BIOLOGY

      The Metropolitan Denver region is part of the high plains area
 that extends from the Great Plains to the foothills of the Rocky
 Mountains.   The  elevation  of the study area ranges from 1,400 m to
 1,800 m [4,600 ft to 6,000 ft], placing  it within the Upper Sonoran
 life zone (Reference 24).   This zone begins at the Transition zone
 of the  foothills  of  the  Rocky  Mountains  and extends beyond the
 eastern border of  Colorado.  The growth  and distribution of vegeta-
 tion is largely  dependent  upon climate,  relief, substrate, fire and
 the occurrence of  human  activities such  as grazing and agriculture.
 With an average  annual precipitation rate of only 30 to 40 cm [12
 to 16 in.],  water  availability is the chief limiting factor leading
 to the  low  growth  of grasses and forbs on the plains.

      Prior  to  settlement,  the plains supported a mixed prairie which
 v/as  made  up  primarily of perennial bunchgrasses.  Short grasses such
 as  blue grama  and  buffalo  grass dominated on drier sites, and taller
 grasses  (western wheatgrass ana little bluestem) occurred on sites
 with  higher  moisture, such as along eastern stream courses and to-
 ward  the mountains to the west.  Prior to settlement,  a very complex
 mosaic  of steppe communities existed in  the Denver area in response
 to  the  numerous soils (Reference 9).   Under natural  conditions, the
 three major  plant communities probably were (1) upland prairie or
 short-grass  plains,  (2) meadow and (3) cottonwood-willow.  The
 plains  did not support tree growth except along the watercourses,
 which were fringed with cottonwoods and willows.  Dense thickets of
 wild  plum and ciiokecherry,  with scattered clumps of hackberry and
 box elder, occurred  sometimes in gulches and arroyos (Reference 24).
 The original distribution of natural  vegetation in the Denver region
 (Reference 25) is shown in  Figure 8.

     Human activities, mainly in the form of cultivation and live-
stock grazing, have altered the natural  vegetation considerably.
Sixty-five percent of Adams County is  currently under  cultivation,
and 35 percent of Arapahoe  County is  similarly  utilized.   The remain-
ing uncultivated lands are  generally used for pasture  and range or
urban and residential purposes  (References 10,14).

     The present biotic communities can  be classified  according to
                                56

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      NATURAL  VEGETATION OF COLORADO

LEGEND

1-GRASSLANDS OF THE PLAINS-Blue gramma is the dominant
    grass.
2-GRASSLANDS OF THE PLAINS-Blue grama, sand dropseed,three-
    awn,  sand reed,  bluestem, sideoats grama, and yucca,
3-GRASSLANDS OF THE PLAINS-San reed, bluestem, sand drop-
    seed  and sand sage  on  sandhills,
4-GRASSLANDS OF THE FOOTHILLS-Wheatgrass, needlegrass, sand
    reed, bluestem,  and blue grama mixed with areas of
    shrub and occasional ponderosa pine,
5-WOODLANDS OF THE  LOWER MOUNTAINS-With stands of ponder-
    osa pine (and often Gambel Oak) with Douglas-fir,  blue
    spruce, white fir and  occasional aspin mixed with
    fescue, muhly,  bluegrass, shrubs and forbs,
6-WOODLANDS AND GRASSLANDS OF SUBALPINE AREAS-With stands
    of spruce and fir or lodgepole pine, or aspen.
    Thurber's fescue grassland parks intermingle with
    timbered areas.
7-GRASSLANDS AND MEADOWS OF ALPINE REGIONS ABOVE TIMBERLINE
    With  sedges, grass,  willow, birch and forbs.

SOURCE: SOIL CONSERVATION  SERVICE, OCTOBER 1972
                                                                                 METROPOLITAN
                                                                                 DENVER SEWAGE
                                                                                 DISPOSAL DISTRIC
                                                                                 (MDSDD-I)
                                                                                                                                        c
                                                                                                                                        -R
                                                                                                                                        m
                                                                                                                                        CD

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 the following general  vegetation  units;   (1)  Cultivated,  (2) Uplands
 Vegetation,  (.3)  Riparian and  Aquatic  and  (4)  Urban/Residential.  A
 listing of common plants and  animals  in these units  is given in Ap-
 pendix C.
                TYPICAL UPLAND VEGETATION UNIT WITH
                COTTONWOOD TREES  INDICATING SEASONAL
                           RIPARIAN ZONE


Cultivated Lands Unit

     Cultivated vegetation includes sod farms,  irrigated farms and
dry farms.  Thousands of hectares of the plains are devoted to irri-
gated farming along the South Platte River, and to dryland farming
on adjoining uplands.  In some areas,  such as in Arapahoe County,
irrigated farmland has decreased significantly  in the past 30 years
because of community development and the diversion of water from
the South Platte River for domestic purposes.

     Agricultural  lands are typically  cultivated as monoculture
units.   The allocation of large parcels of land to only a few plant
                                58

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 species  leads  to a  simplified environment with low animal diversity.
 Animal populations  are generally characterized by numerous small
 burrowing  rodents,  seed-eating birds and a few wide-ranging preda-
 tor  species.   Although a monoculture yields little variety in habi-
 tat,  the crops provide an important food source for wildlife.  This
 is particularly significant in migratory bird wintering areas near
 Riparian-Aquatic habitats.  The stubble, fence rows and unharvested
 remains  are often vital to wildlife for sustenance and cover during
 the  winter months.

 Uplands  Unit

      Uplands vegetation includes pasture and range lands whose spe-
 cies  composition varies with soil character and past use.  Current
 Upland vegetation on uncultivated soils is typically a weedy grass
 type  that  has  suffered from too heavy grazing.  The two major short-
 grass species  of the mixed prairie, blue grama and buffalograss, are
 hardy perennials that can withstand heavy grazing since they grow
 close to the ground and form a cover of bunchy sod.  Both of these
 grasses  increase when tall-grass associations are overgrazed.  When
 overgrazing occurs  on the short-grass units, the sod mats weaken and
 are  invaded by annual grasses and annual and perennial weeds (Refer-
 ence  26).  Good examples of the tall-grass prairies and mixed-grass
 prairies are now becoming scarce in the Denver region (Reference 9).

     Wildlife  patterns have also changed in response to prairie suc-
 cession  and alterations in land use.  Formerly abundant animals such
 as the prairie dog, American buffalo and pronghorn antelope have be-
 come  limited in distribution because of human intervention and changes
 in the short-grass  prairie habitat.  The black-footed ferret, which
 had a nistoric range dependent upon that of the prairie dog, is con-
 sidered  an endangered species (Reference 27).  The greater and the
 lesser prairie chicken are examples of species which are endangered
 by the diminishing  size of the mixed prairie habitat.  The Uplands
 vegetation area is  now primarily inhabited by jackrabbits, rodents
 and many reptiles which are tolerant to change and can coexist with
 human activities.

 Riparian and Aquatic Unit

     Riparian  and Aquatic units occur along major watercourses, such
 as the South Platte River and Cherry Creek.  Associated with most
watercourses are wide, nearly flat floodplains.  Many of the creeks
 in the study area seldom flow for more than two weeks, generally in
March and April and during heavy storms in the summer.  Most of the
 suitable terrace soils along streams have been cultivated, and other
 Kiparian zone  sites, which have not been utilized for gravel mining
 or occupied by industrial sites, have been grazed for 100 or more
years.   In bottom lands where there is no current grazing, there is
                               59

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 a  greater  variability  in vegetative cover  (Reference 9).

      Colorado's  semiarid Front  Range Urban Corridor has many lakes
 of high value.   In  the past,  they were used to store water for irri-
 gation  and domestic uses, with  occasional use for recreational acti-
 vities.  As a result of rapid suburban development, their importance
 at present is as  recreational areas and centers of real estate de-
 velopment.  The major  lakes of  the Denver region are Cherry Creek
 Lake, Chatfield  Lake,  Marston Lake, Standley Lake and Barr Lake.
 The network of smaller lakes, ponds and reservoirs also plays an im-
 portant role in the natural ecosystem.

      Riparian and Aquatic units include some of the most important
 wildlife habitat  in the area.   The Platte River Valley and its trib-
 utaries  produce one-third of  Colorado's annual water fowl crop and
 provide  winter habitat for tens of thousands of migrant birds.  The
 trees of the floodplain supply  nesting and roosting areas for large
 numbers  of  birds  of many kinds, including small numbers of bald
 eagles.  In the metropolitan  area, most marshlands have been elimi-
 nated,  although many floodplain oxbow lakes, ponds and marshes per-
 sist  in  the more  rural  areas.  Marshes provide a valuable wildlife
 habitat, serving  as home for amphibians and aquatic mammals, and as
 nesting  and feeding grounds for waterfowl.  The dense vegetation
 provides excellent winter storm cover for pheasants, rabbits and
 many other  kinds  of wildlife  (Reference 9).

     The larger lakes  of the Denver region are stocked with gamefish
 such as  brown trout and rainbow trout.  All lakes generally contain
 several  species of roughfish, which provide important food supply
 for wildlife as well as maintaining the aquatic ecosystem.  Lakes
 and ponds that are less disturbed by human activities comprise the
 necessary aquatic habitat for migrant waterfowl.

 Urban/Residential Unit

     Tne original site  of Denver was a virgin prairie traversed by
 two tree-lined streamcourses.  With urban growth and development, a
 large variety of non-native shrubs and trees have been introduced
 into the Denver area.    A vast City park system interlaces the city,
 providing a wealth of  greenery, open space and artificial lakes and
 ponds.  Denver has more than 100 parks covering more than 1,100 ha
 [2,800 acres], as shown on Figure 3.

     The present vegetation is a cross-section of many plant types
 from midwestern and eastern United States.  Parks and residential
 areas are lined with shade ana fruit trees, ornamental  shrubs and
 flower gardens.   Many  large areas are landscaped with grasses and
other ground covers for recreational  use.   This wealth of foliage
                                60

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 ha?  attracted  several midwestern birds, such as the red-eyed vireo
 and  bronzed  grackle, unknown within the area before 1910 (Reference
 28).   Thus,  in the  past century, the urbanization of Denver has re-
 sulted in  the  creation of v/oodland, shrub and aquatic habitats in
 formerly barren areas.

     A summary of the major biotic units, with their characteristic
 plant  and  animal species, is shown in Figure 9.

 Rare and Endangered Species

     The Federal Register for rare or endangered plant species was
 reviewed for the State of Colorado (Reference 34).  No plant species
 were considered to  be threatened in the Denver Region.

     The Nongame and Endangered Species Conservation Act (Reference
 35) for the  State of Colorado is consistent with Title 50, Part 17
 of the U.S.  Conservation of Endangered Species Act.  The Colorado
 Division of  Wildlife further protects several wildlife species not
 covered by the Federal Conservation Act.  The Wildlife Division has
 recognized the stress on wildlife caused by a growing population and
 changing land  use,  and endeavors to protect wildlife habitat as well
 as endangered  wildlife species.  Animals protected by State and Fed-
 eral regulations (Reference 34) that may occur within the study area
 include the  black-footed ferret, peregrine falcon, white pelican,
 and river otter.

     Black-Footed Ferret—

     The black-footed ferret (tiusteia nigripe] occurs within snort-
 grass  prairies.  Its historic range coincides closely with that of
 its prey species, the prairie dog.  The population has been dras-
 tically reduced and its range decreased due to changing land uses
 and programs to control or eliminate prairie dogs.  Scattered re-
 ports  of the black-footed ferret indicate nearly statewide distri-
 bution, with tendencies toward the eastern grasslands.  The lands
within the study area are largely cultivated or grazed and probably
 represent a marginal habitat for the black-footed ferret.

     Peregrine Falcon—

     Colorado  has two recognized subspecies of the peregrine falcon:
a winter nesting resident, the American peregrine (Faico peregrinus
anatum), and the arctic peregrine (raico p. tundrius), a migratory
visitor during  the spring and fall (Reference 36).  The resident
 subspecies is  of greater concern within the Rocky Mountain area.  Hu-
man activities  such as road-building, forest- and sagebrush-clearing,
game-hunting and outdoor recreation have deteriorated the quality of
                               61

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   Unit
Location and examples
Characteristic vegetation
Characteristic birds
Characteristic animals
titivated
 Lands
Flat or rolling farm-
  lands; east and
  north of Denver.
  Major portions of
  Weld and Adams
  counties.


Rural dwellings;
  farm buildings.
               Steep dirt  banks;
                 along ditches  and
                 seasonal  streams.
Alfalfa, corn, sugar beet,
  vegetables, wheat, oats,
  barley, rye, forage sor-
  ghum.
                                      Sunflower, prickly let-
                                        tuce, Russian thistle,
                                        tansy mustard, dande-
                                        lion, garden escapes.
Brewer's blackbird,
  western vesper
  sparrow, ring-
  necked pheasant,
  western meadow-
  lark, lark bunt-
  ing.
Barn swallow, Say's
  phoebe, housefinch.
                                                    Bank swallow, king-
                                                      fisher.
Meadow vole,  pocket
  gopher, ground
  squirrel, harvest
  mouse, western jump-
  ing mouse,  weasel,
  bullsnake,  garter
  snake.

House mouse,  raccoon,
  feral cat,  spade-
  foot toad,  garter
  snake.

Fence lizard.
Uplands
  Vegetation
Arid plains region;
   typically found in
   eastern Adams and
   Arapahoe counties.
Blue grama grass, buffalo
   grass, western wheat-
   grass, little bluestem,
   Junegrass, needle-and-
   thread, red three-awn,
   locoweed, sunflower,
   aster, fanweed, prickly
   pear, plantain, yucca.
Burrowing owl, desert
  horned lark, moun-
  tain plover, turkey
  vulture, red-tailed
  hawk.
Jackrabbit, prairie
  vole, -pocket mouse,
  Ord kangaroo rat,
  coyote, pronghorn
  antelope, prairie
  rattlesnake, bull-
  snake, central
  plains milksnake,
  sagebrush lizard,
  horned liaard.
               Bluffs and cliffs
                                                    Cliff swallow,  prairie
                                                      falcon,  ferruginous
                                                      roughleg hawk.
               Summary of  biotic community characteristics,  Metropolitan Denver  area

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CO
Unit
Riparian and
Aquatic






















Urban/Resi-
dential







Location and examples
Cottonwoods; along
rivers and streams
such as South
Platte River and
Cherry Creek.



Shrubbery; along
streams and creeks
and intermittently
between stretches
of cottonwood.
Lakes and ponds ;
storage reservoirs
such ao Barr Lake
and ponds through-
out farming region
and urban areas.
Marsh areas and
swamps ; along the
floodplain of
South Platte
River.
Greater Denver Metro-
politan area; in-
cludes residential
environs , City
parks and other
recreational faci-
lities.


Characteristic vegetation
Plains cottonwood, box
alder, willow, narrow
leaf cottonwood.





Chokecherry, wild plum,
buffaloberry , hawthorn,
rabbitbrush, willow.


Willow, rushes, cattail,
sedge, salt grass and
aquatic plants.



Salt grass, bulrush and
other rushes, sedge.



Ornamental shrubs, flow-r
ers , lawn-type grasses,
soft maple, elm, weep-
ing willow, Carolina &
Lombardy poplar, ash
sycamore, Norway pine,
Russian olive, and
several varieties of
fruit trees.
Characteristic birds
Red-headed woodpeck-
er, Rocky Mountain
screech owl, Swain-
son's hawk, crow,
Bullock's oriole,
kingbird, western
mockingbird, white-
rumped shrike.
Black-headed gros-
beak, catbird,
brown thrasher,
yellow warbler,
song sparrow.
Grebe, gull, tern,
goose, green heron,
mallard, pintail,
shoveler and other
ducks, shorebirds.

Rail, coot, heron,
bittern, duck, red-
winged blackbird,
ycllowthroat .

Robin, starling,
mockingbird, house
sparrow, black-
capped chickadee,
chipping sparrow,
rock dove, red-eyed
vireo , bronzed
gracklc.

Characteristic animals
Raccoon, fox squirrel,
shrew, weasel, bat,
barred tiger sala-
mander, yellow-
bellied racer, gar-
ter snake.


Striped skunk, rac-
coon, eastern wood-
rat, deer mouse,
yellow-bellied ra-
cer, garter snake.
Snapping turtle, box
turtle, boreal
chorus frog, carp,
brown. trout, chub,
minnow, shiner, cat-
fish.
Musk rat, coyote, bull-
frog, leopard frog,
boreal chorus frog,
garter snake, nor-
thern watersnake.
House mouse, Norway
rat, pocket gopher,
feral cat,






           Source:  References 28,  29, 30,  31, 32 and 33.
                  Summary of biotic community characteristics, Metropolitan Denver area  (contined)

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 the environment for this species.   The peregrine  falcon  requires
 high cliffs for nesting sites and  a food  supply of  small  birds.
 Accurate information about breeding pairs has  been  difficult  to
 obtain.  However, the plains area  may still  have  some  value as a
 feeding range for this species (Reference 36).

      White Pelican--

      The white pelican (peiicanus  erythrorhynchos)  is  common  in
 portions of the United States and  is  not  considered  endangered on
 a  national  basis.  Within Colorado,  it is presently  considered en-
 dangered as a nesting summer resident.  White  pelicans may be found
 at several  reservoirs along  the  South Platte River drainage;  how-
 ever,  they nest and rear young only at Riverside  Reservoir, outside
 of the study area.

      River Otter—

      The river  otter (Lutra  canadensis) formerly  ranged over many
 of the rivers and lakes  of North America.  Due to hunting and human
 encroachment, otters have been eliminated or their numbers reduced
 over much of their  range.  However, the river otter  is not consid-
 ered endangered  on  a national  basis.   The otter has  probably always
 been rare in Colorado I Reference 36).  Scattered  sightings have
 been reported in  the South Platte River drainage  in  Weld County,
 and  it is unlikely  that  a  breeding population is  present.  Because
 this species is  usually  limited to wilderness areas, it is unlikely
 that it  could ever  exist in  any numbers in the study area.  Most of
 the  streams  and  lakes  are  influenced  by adjacent  homes, industry or
 other  incompatible  human developments.

 AIR  QUALITY

     The  project  study area  is located within Air Quality Control
 Region 2  (AQCR2)--Metropolitan Denver  (see Figure 10).  Air pollu-
 tion control  priorities  for  this region have been determined by the
 Colorado  Air  Pollution Control Division and the U.S. Environmental
 Protection Agency on the oasis of the following five considerations:

     1.   existing air quality  data
     2.   population  status and trends
     3.   degree and  type of  industrialization (emission inventory)
     4.   amount of vehicular traffic
     5.   topographic and meteorologic factors

     On the basis of these criteria, pollutants are given priority
rankings of  1, II or III, with Priority I  as the most severe.   Par-
ticulates, carbon monoxide and reactive hydrocarbons and  oxidants
                               64

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                                                            LOGAN
                                                                      i SEDGWICK
                                                         __ JRAWNEEf5
                                                                      PHILLIPS
                                                             	i	j
                                                             WASHINGTON |YUMA     I
                  J Y A M PA     — ;
                      — -I
 _______
 '       ""    '
                                                  METR_0

                                                 DENVER
                                          / METRO

                                         X \ \ \
       fDELTA


  emf-  "GRAND";  MESA
                                     _
                                                               COMANCHE
                                       SAN  ISABEL
                                              \ \ \
                                              PUEBLO
I            ^^ JUMN
                                    	
                          'RIO GRANDE  lALAMOSA

                           SAN LUIS
                          ii
                           rnuF.inc;   '—
I MONTEZUMA
I
    I {'"""1 1  J        ARCHULETA   1 CONEJOS   '	'


j        /FOUR  CORNERS k


SOURCE:  COLORADO DEPARTMENT~OF HEALTH, ~
AIR POLLUTION CONTROL COMMISSION.
                                                           STATE AIR POLLUTION CONTROL
                                                           DESIGNATED AREAS.
                    COLORADO AIR QUALITY CONTROL  REGIONS

-------
 are ranked Priority I  and sulfur  dioxides and  nitrogen oxides are
 ranked Priority III;  Priority II  ranking has not been assigned to
 any pollutant (Reference  37).   These pollutants mentioned are gen-
 erally related to human activity  and thus decrease markedly as one
 leaves the urbanized regions.   Carbon monoxide in AQCR2 is due al-
 most entirely to vehicular traffic.   It is currently felt that com-
 pliance with  Federal carbon monoxide standards will not be achieved
 in  AQCR2 by the 31  May 1977 target date (Reference 37).  Reduction
 in  vehicular  traffic will  be  needed  to achieve the standard, par-
 ticularly during the winter months when frequent inversions occur.
 The very small  traffic flows  in rural Adams County preclude carbon
 monoxide pollution  problems.

      Ozone, produced as a  product of reactions between oxides of
 nitrogen and  reactive  hydrocarbons in the presence of sunlight, is
 one of the photochemical  oxidants which cause the unpleasant effects
 of  "smog." Federal standards for ozone levels are commonly exceeded
 in  AQCR2.   Control  of  these levels is achieved by reducing the pri-
 mary pollutants,  hydrocarbons and NOX.  In order to meet Federal
 standards, hydrocarbon emissions must be reduced by about 80 percent
 (110,000 metric tons/yr [120,000 tons/yr]) by 31 May 1977.  It is
 not expected  that this reduction will be attained.  In the rural
 setting  of the  project area,  however, ozone concentrations are not
 as  high  as  in urban areas,  although  sporadic violations may occur.

      The Federal  primary and  secondary standards for particulates
 are exceeded  in  AQCR2.  The primary  standard is set to protect the
 public  health at  75 yg/m3,  geometric mean.   Levels in the urban
 Denver  area are  generally  over 100 ug/m3, diminishing to two-thirds
 this  level  in outlying  areas.  Contaminants previously discussed
 are monitored at  only  six  stations in the Metropolitan Denver area.
 The particulate  concentrations are sampled more widely (22 stations).
 The monitoring  station  nearest the project is in Brighton, about
 16  km  [10 miles]  northwest  of the sludge drying sites.  In 1974, a
year  of  average meteorological conditions,  the annual  arithmetic
mean  particulate  level was  103 yg/m3.  The State standard is 70
 yg/m3.   Hhile rural areas may experience high particulate levels
due to agricultural operations, these levels are generally lower
than  those of urban areas.  For tnis reason, particulate levels
around the project site are not presently considered significant.

     Wind transport of pollutants into or away from the project area
can be surmised from wind  speed and direction,  as  described on Fig-
ure 11.  The data used  in this figure, from Stapleton Airport on
the northeast edge of  Denver, are representative of wind patterns
in  the study area.  The average wind speed  and  direction is 15 km
[9.5 miles] per hour from the south.   Infrequent strong,  destructive
winds generally come from the northwest.
                               66

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                                                      FIGURE  I
                                 N
                   NNW
     NNE
         NW
                NE
WNW
   157.
W
WSW
                       ENE
                       ESE
         SW
                SE
                   SSW
SOURCE: BASED ON 10 YEARS OF DATA
(DECENNIAL CENSUS), 1951-I960, BY
JOHN BENCI, DEPT OF ATMOSPHERIC
SCIENCE, COLORADO STATE UNIVERSITY
(REFERENCE 38).
     SSE
     LEGEND

SYMBOL       WIND SPEED
        H.8-5.4 mps (4-l2mph)
        5.4-11.0 mps (13-24 mph)
         > 11.0 mps (> 24 mph)
    ANNUAL FREQUENCIES OF WINDS  OF VARIOUS VELOCITIES
          AT STAPLETON AIRPORT, DENVER  COLORADO
                               67

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      The average annual temperature is about 10°C [50°F],  with the
 highest temperatures usually occurring in July and the lowest in
 January.  Daily differences fn temperature extremes (high-low) are
 usually about 17°C [30°F] in most months (Reference 8).  The summer
 temperature conditions are favorable for smog formation, while win-
 ter conditions cause frequent inversions.  The mean morning  mixing
 height is relatively low in Denver, averaging only about 60  m [200
 ft].  This limits the dilution of air pollutants.  However,  this
 low mixing height rises quickly in the afternoon  due to the  sun's
 heat.  During the summer months, the afternoon mean mixing height
 is about 1,000 m [3,300 ft].

      Precipitation is relatively mild,  averaging  about 41  cm [16
 in.] per year, as discussed under Climate.   These dry conditions
 cause additional  particulate emission problems.

 Odor

      Background odors generally associated  with the study  area are
 those normally associated with urban,  suburban and  farming communi-
 ties.   The petroleum refineries east of Denver emit characteristic
 odors  which are especially noticeable  at distant  locations during
 calm periods  when mixing with  the upper air layers  is  minimal.
 Other  odorous materials  are those commonly  associated  with farming
 operations in the area.   For example,  a chicken farm may heat-
 pressurize chicken  manure,  producing  very offensive odors.   These
 fertilizer and manure odors  are generally accepted  as  part of  normal
 farm operations and  are  therefore tolerated.

     Odors  are regulated  by  Odor  Emission Regulation No. 2 of  the
 Colorado Department  of Health,  Air  Pollution  Control Commission
 (Reference  37).   This  regulation  sets forth three types of odor
 limits.  For  residential  or  commercial  areas,  odorous  substances
 must be undetectable  from  beyond  the property  line  of  the emission
 source after  being diluted with seven volumes  of odor-free air.  A
 scentometer allows this dilution  and measurement  to  be taken.  For
 other areas,  a dilution of 15 volumes of  odor-free  air must render
 the odor undetectable.  A  special regulation exempts agricultural
 and manufacturing processes, provided the best practicable methods
 have been employed to control odors.  For all odor  sources, however,
 there is an upper limit which must not  be exceeded:  they  must not
 be detectable after having been diluted with 127 volumes of odor-
free air.

     Because of the potential for emission of odorous air  contami-
nants from the drying and distribution center, an  emission  permit
from the Air Pollution Control  Division of the Colorado Deparcment
of Health will be required.
                               68

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CTl

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'  •
I

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ARCHAEOLOGY AND HISTORY

     Transient and sedentary Indian tribes once associated with
eastern Colorado and the general Great Plains complex include the
Ute, Cheyenne, Arapaho, Comanche, Kiowa, Pawnee and Plains Apache
(Reference 42).  Because of the locational association with the
proposed project, an archaeological survey was undertaken and was
completed in August 1974 (Reference 8).  The primary survey area
was the proposed drying basin site, where major excavation activi-
ties would take place.

     During its investigation, the archaeological  team found no
surficial evidence of existing archaeological sites on the proposed
drying basin site; a single, isolated mano, probably of Ute origin,
was discovered immediately to the northeast of the site.   The team
determined that, since the proposed site has been under long-term
cultivation, any artifacts lying on or near the surface would have
been scattered during plowing and seeding activiites.  During the
course of the survey, the team did discover evidence of a nearby
archaeological site, approximately 8 km [5 miles] to the northeast
of the proposed drying basin site.

     While land beneath the Metro Denver Plant may contain a con-
cealed archaeological site, the land has undergone development,
and any surficial evidence would have been scattered or destroyed.

     As indicated on Figure 1, the proposed pipeline route lies be-
neath various roadway rights-of-way.  Consequently, any evidence of
associated archaeological sites would have been obliterated through
adjacent road-building activities.

     Representative off-site distribution areas have also been dis-
turbed in the last century by human activities such as cultivation,
mining and park-building.  Surface archaeological  remnants would
not be present on these areas.

     In terms of historical importance, no known historical site
has been officially designated on or near project sites which lie
in Adams County (Reference 43).  Since the proposed project opera-
tion will not disturb any existing historical sites on or near
sludge recycling areas, no historical survey was conducted for
this project.

LAND USE

     Areas in the proximity of the proposed project are presently
used for a variety of urban and rural land use purposes.   Those
areas which are entirely urban in function include land in the
                              71

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 immediate vicinity of the Metro Denver Central  Plant  and  various
 parks in the Denver area which will  become project  distribution
 sites.  Areas which are rural  include the drying  basin  site,  the
 Urad Mine and the sod, irrigated and dryland  farms.   Other  project-
 related areas consist of the proposed pipeline  route  and  the  Lowry
 Bombing Range site, which also contains  the landfill  site.

      The Metro Denver Plant facility which will house the anaerobic
 digesters is located within the Denver urban  core area. Use of the
 lands immediately surrounding  this facility is  industrial and in-
 cludes a rendering plant, a refinery and  a variety  of factories.

      The site proposed for the drying basins  is rural in  character.
 Hhile some of the site and the land  adjacent  to it  is used for pas-
 turing,  the majority is under  dryland cultivation, with wheat as the
 principal  crop.   Buildings within one kilometer of this site  include
 a  farmhouse and  two structures related to  agriculture, all of which
 are  located 0.4  km [1/4 mile]  east of the  site.  Subdivisions in the
 vicinity are located on five four-hectare  [10-acre] lots  to the north-
 west of  the site,  but none is  closer than  six km [four miles] (Refer-
 ence 44),   The area is  zoned for agriculture and large subdivision
 lots.  County land use  plans would continue agriculturally related
 uses but also propose an  airport facility  for this area (References
 45,46).   As  proposed,  the Adams County General Aviation facility
 will  be  in  excellent conformity with  the drying basin site since the
 facility will  be  flat,  low  and  sparsely populated (Reference 47).

      The Urad  Mine,  under consideration for sludge application, lies
 in a rural  area of Clear  Creek  County approximately 13 km [8 miles]
 west of  the  city  of  Empire.  While the mine is not presently used,
 evidence of  mining  operations  remains, including deforested land
 and  large volumes  of tailings  and other mining wastes deposited near
 the  vacant mines.  Amax,  Inc.  plans  eventually to revitalize the
 area  by  application  of  its  "Comprehensive  Plan for Land Reclamation
 and  Stabilization  at the  Urad Mine"  (Reference 48).   In time,  the
 area will be  restored through  reforestation and revegetation activi-
 ties  (Reference 48).

     The sod  farm  chosen  as  representative for sludge recycling lies
 close to the  drying  basin site and,  like that  site,  is part of a
 rural, agricultural  area where wheat  is the primary  crop.   Because
 of its proximity to  Box Elder Creek,  turf and  river  bottom grasses
 are  also grown here.  The only structures on the property  are  a few
 farm buildings.

     The representative irrigated farm also lies in  an area which is
devoted to farming activities.   It is located  approximately 0.8 km
 [0.5 mile] east of Platteville, which is  a small,  rural  community.
                               72

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 Buildings lying on the property include a farmhouse, barn and stor-
 age  shed.

      Dryland farms to be used for sludge application are coterminous
 with the representative sod and irrigated farm areas and therefore
 have common environmental characteristics.

      The pipeline proposed for transport of the processed sludge
 from the Central Plant to outlying drying basins will traverse both
 urban and rural land.  Initially the line will pass through the in-
 dustrialized area surrounding the Central Plant.  It will then cross
 into Commerce City, a suburb of Denver, and skirt the Rocky Mountain
 Arsenal.  From that point it will run beneath the Irondale Road
 right-of-way, through land which is rural in character, until it
 reaches the drying basin site in Adams County.

      Because the area surrounding the Lowry Bobming Range is sparse-
 ly developed and lightly populated, it may be characterized as rural.
 No change from its present use as a sludge deposition and landfill
 site  is proposed at present.  However, potentially detrimental levels
 of heavy metals may have accumulated in the soils (Reference 45),
 and  this situation may force a change or limitation in land use.

 LAND TENURE

     The Metro Denver treatment plant facilities are situated on
 publicly owned lands.  Various roadway right-of-way areas which will
 accommodate the proposed pipeline are also publicly owned, as are
 the  project-related parks in the Denver area.  The Lowry Bombing
 Range, which contains the Lowry Landfill site, is part of a U.S. Air
 Force military reservation.  Privately owned lands include the pro-
 posed 800-hectare [2,000-acre] drying basin site, the Urad Mine area
 and  the representative sod, irrigated and dryland farms.

 POPULATION

 Regional Population

     The service area where the sludge originates and the areas to
 receive the dried sludge are located within the jurisdiction of the
 Denver Regional Council of Governments (DRCOG).  Recent DRCOG popu-
 lation trends, disaggregated according to county, -are given in
Table 10.

     In common with major metropolitan areas throughout the country,
there has been a recent shift in population from the central city
to the suburbs.  During the year 1974-75, while Denver County's
population remained essentially static, two of the three counties
                               73

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                         Table  10.  POPULATION BY COUNTY, 1970-1975

County
Adams
Arapahoe
Boulder
Clear Creek
Denver
Douglas
Gllpin
Jefferson
Region
1970
183,000
161,000
130,000
4,600
514,000
8,000
1,200
231,000
1,232,800
1971
191,600
166,800
136,700
5,500
518,600
9,700
1,500
245,700
1,276,100
1972
202,800
179,000
145,200
5,700
523,700
10,900
1,600
264,500
1,333,400
1973
213,200
196,000
156,300
5,700
528,000
13,100
1,900
292,300
1,406,500
1974
225,600
211,300
164,200
5,700
529,600
15,800
1,900
310,800
1,464,900
1975
232,100
224,800
171,500
5,900
529,700
18,000
2,000
322,800
1,506,800
Note:  All estimates as of January 1 of each year.
Source:  "Population Change in the Seventies."

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which contain the suburban communities around Denver grew at a rate
faster than that for regional annual population growth, which was
2.97 percent:  Arapahoe County, 6.4 percent, and Jefferson County,
3.9 percent; the third, Adams County, grew at a rate of 2.9 percent,
nearly equal to the regional rate (Reference 49).

     Regional growth reached a peak rate of 5.5 percent per year in
1972-73 and has since declined to a rate close to the 1960-1970
average of 2.6 percent.  This decline in growth rate is attributed
to declining fertility rates, restrictions on new gas and water con-
nections which began in 1972 and a general economic slowdown, which
has reduced the rate of immigration into the region and has brought
new residential construction almost to a standstill (Reference 49).

Metropolitan Denver Sewage Disposal District No. 1

     The population within Metropolitan Denver Sewage Disposal Dis-
trict No. 1 (Metro Denver) in 1975 was 1,081,000 (Reference 50).
The District serves most of the population of Adams, Arapaho, Jef-
ferson and Denver counties.

Adams County

     Adams County, a rapidly growing section of the Denver Metropoli-
tan area, had the highest growth rate among the DRCOG counties from
1940 to 1950.  In the 1950's it almost tripled its population.  This
growth has leveled somewhat over the past two decades, as shown in
Table 11.

         Table 11.  POPULATION GROWTH RATES, ADAMS COUNTY
                        (percent per year)

Growth period
1940-1960
1960-1970
1970-71
1971-72
1972-73
1973-74
1974-75
1970-1975
Growth
Annual


4.7
5.8
5.1
5.8
2.9

rate
Average
6.8
4.4



- -

4.9
Source:  Reference 49.
                               75

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      Almost  two-thirds of the population of Adams County is concen-
 trated in the  cities  of Aurora,  Northglenn, Commerce City, Thornton
 and  Westminster.   About 95 percent of the population is in urban
 areas.   The  sewage from 78 percent of the population of Adams County
 is generated and  treated within  the Metro Denver district.  Adams
 County accounts for 17 percent of the population in the Metro Denver
 service area.

 Population Projections

      Projections  of population for the counties of concern are given
 in Table 12.

      DRCOG population estimates  were adjusted by Metro Denver staff
 for  use in their  Long Range Planning Study.  These figures give a
 total  District projection for the year 2000 which is 16 percent
 higher  than  that  projected by DRCOG for the same area for that year
 (Reference 9).  Table 13 shows a range of eight projections for the
 five-county  Denver region for the year 2000.  On the basis of the
 16 percent difference mentioned, it would appear that Metro Denver's
 projections  fall  somewhere near  the middle of the range of projec-
 tions made by various agencies.

     The  projected  sludge load increases used to estimate the 1985
 levels  are given  in Table 14 along with Metro Denver and DRCOG popu-
 lation  growth assumptions for a  similar time period.

 TRANSPORTATION AND  CIRCULATION

     Roadway, railroad and air travel  are the primary modes of trans-
 portation  used in the region of the proposed project.  While road-
 ways serve most areas, railroad travel is concentrated on lines pass-
 ing through Denver and airplane travel facilities are interspersed
 throughout the region.

     Roadways of a variety of types serve the region.  Minor streets
 and arterials are found  in urbanized areas, particularly those sur-
 rounding the City and County of Denver, along with state, interstate
and federal highways (Reference 56).   In rural  and sparsely populated
 areas, roadways are limited to minor streets and arterials, which
are variously classified,  depending on surface composition character-
 istics and design width  (Reference 57).  In general, these roads are
 infrequently travelled,  with average daily travel (ADT) ranging from
90 to 230; however, many are adequate in design to carry heavy, agri-
culturally related trucks  and can accommodate an ADT as high as 6,200
 (Reference 59),

     Railroads  in the region are concentrated around Denver.  These
                                76

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                    Table  12.  SELECTED POPULATION PROJECTIONS FOR COUNTIES
                                  IN VICINITY OF METRO DENVER

County
Denver
Adams
Arapahoe
Jefferson
Weld

Population,
1975a
529,700
232,100
224,800
322,800
114,000

State of Colorado
low
392,000
314,000
322,000
483,000
138,000



projections5, 1995 DRCOG proiections0
high
538,000
432,000
443,000
664,000
160,000
1990
602,000
295,000
345,000
515,000
(not
2000
709,100
326,000
413,000
658,000
in DRCOG)
 Source:   Reference  51  for Weld County, Reference 49 for all others.

 Source:   Reference  51.
"Source:   Reference  52, Denver Regional Council of Governments.

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      Table 13.  POPULATION FORECASTS FOR THE FIVE-COUNTY DENVER REGION IN THE YEAR 2000


	Agency	Population estimate

       U.S. Department of Commerce, Office of Business and               1,981,000
         Economic Research Service  (OBERS)

       Colorado Land Use Commission                                      2,175,000

       Denver Regional Council  of Governments  (DRCOG)                    2,350,000
          (policy forecast)

       Denver Research Institute  (DRI)                                   2,675,000

       Colorado Division of Planning  (county  total)                      2,886,000

       Colorado Division of Planning  (city  total)                        2,892,000

       Metropolitan Denver Water  Study  Committee                         2,000,000

       Colorado Division of Planning  (adjusted  city  total)               3,399,000


 Source:   "Appraisal of the DRCOG  Policy Population Forecast."

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           Table 14.   POPULATION  AND  SLUDGE LOAD  PROJECTIONS FOR METRO DENVER DISTRICT

Projections
DRCOG population projection
for Metro Denver district ,
persons
Metro Denver population pro-
jection , persons
Metro Denver sludge load
projection0, dry metric
tons/day
Time period
1970-1985

1970-1985
1977-1985
Year Average
1970 1977 1985 growth
1,074,775 1,469,420 2.

1,080,032 1,683,400 3.
68 97 4.
annual
rate, %
1

0
8
 Source:   Reference 9.

 Source:   Reference 47.
£
 Source:   Reference 55.

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 include the Union Pacific and Burlington-Northern Railroad lines.
 Although there is variation in routes, most of the lines pass
 through Denver (Reference 56).  The line closest to the proposed
 sludge drying basin site lies 11 km [7 miles] to the south.

      Airport facilities located within the region include Stapleton
 International Airport in Denver and a variety of noncommercial  pri-
 vate facilities in Adams, Arapahoe, Weld and Denver counties  (Ref-
 erence 60).  The proposed Adams County General  Aviation Airport is
 located in the proximity of the area slated for the sludge drying
 basins.

 RECREATION

      The State of Colorado is divided into several  recreational
 regions.  Denver, Adams, Held and Arapahoe counties are included
 in Metro Region No.  9,  while Clear Creek County lies in the North-
 Central  Colorado Region No.  7 (Reference 43).   There are a number
 of officially designated recreational  areas within  these two re-
 gions.   They include reservoirs, rivers  and streams, natural lakes,
 cold springs,  forests the parks  (Reference 43).   Recreational areas
 of several  types  are found near  the proposed project.   The proposed
 South Platte River recreational  area is  located  approximately 1.6 km
 [one mile]  east of the  Metro Denver Plant; Barr Lake and Barr Lake
 Duck Club  lie  18  km  [11  miles]  northeast of the  proposed drying  basin
 site.   In  the  vicinity  of sludge recycling sites  are the Big Bend
 Picnic  Grounds,  about 1.6 km [one mile]  northeast of the Urad mine;
 the  Old  Fort Vasquez site,  about 1.6 km  [one mile]  southwest of  the
 Platteville sod  farm; and 120 developed  neighborhood parks in Denver
 County  (Reference 40).

 INSTITUTIONAL  AND GOVERNMENTAL AGENCY  JURISDICTIONS

      The jurisdictional  issue of principal  concern  for  the proposed
 project  is  the conflict  between  Adams  County and  Metro  Denver over
 final approval of the drying  and  distribution center.   Since the
 proposed site  for this operation  is  within  unincorporated  County
 territory,  and therefore  under the jurisdiction of  the  Adams County
 Planning Commission,  the  County  feels  it should have the power to
 accept, modify or veto the operation.  Very  recent  litigation has
 determined  that Metro Denver  needs a Certificate of  Designation
 from the Adams County Board of Commissioners in order to proceed.
 The application for  Certificate of Designation, including support-
 ing documents  (such  as this Draft EIS), would be reviewed by the
 Colorado Department  of Health, who would recommend approval or dis-
 approval to the County Commissioners (Reference 61).  If approval
 is not forthcoming,  the District can attempt to exercise its power
to condemn property required for its operations (Reference 62).
                                80

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There  is also a possibility that the law will be amended to ex-
clude  requirement of approval by the Board of Commissioners.

     Most of the farmlands affected by the proposed project are
within  unincorporated County territory and are under the jurisdic-
tion of the Adams County Planning Commission.

     The Colorado Land Use Commission is the Statewide planning
body responsible for the management of State lands.  The State of
Colorado owns about 130 hectares [320 acres] of the recommended
site (B-2).

     The regional planning body with jurisdiction in the study area
is the  Denver Regional Council of Governments (DRCOG).  This is a
planning agency whose purpose is to coordinate plans of local and
county  governments and to ensure, through the A-95 review process,
that federally funded projects are in harmony with these coordi-
nated  plans.  DRCOG is presently studying the feasibility of coor-
dinating a solid waste management program with Metro Denver's
sludge  management system.  The plan under consideration would com-
bine the Metro Denver sludge with solid waste from the City of
Denver  to provide fuel feedstock for generation of electricity.
As of March 1976, the Colorado legislature has let die proposed
legislation which would have made regional solid waste management
possible.

     The U.S. Environmental Protection Agency is the Federal body
charged with managing the Federal funds provided for construction
of the  proposed project.  Another Federal agency with jurisdiction
and interest in the proposed project is the U.S. Food and Drug
Administration (FDA).  The FDA generates and enforces regulations
for the application of sludge on crops which enter the human food
chain if they are to be used in interstate commerce.  Jurisdiction
over the immediate health concerns associated with the project is
held by the Tri-County District Health Department.  This Department
oversees the present operations at Lowry Bombing Range and would
also be responsible for checking the proposed operation in Adams
County.

     The City of Denver uses a small portion of the Lowry Bombing
range for the disposal of its solid wastes.  Metro Denver Sewage
Disposal District also uses this area on an interim basis for its
sludge  disposal operations; however, the City maintains jurisdic-
tion over the area, and no long-term or written agreement is in
effect  between the two entities.  The City may have need_of the
additional  Lowry space for its own future sanitary landfill opera-
tions  (Reference 63).
                              81

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 SOCIO-ECONOMIC SETTING

 Adams  County Agricultural  Economy

     Agriculture  has  been  the mainstay of the Adams County economy
 since  homesteaders  first arrived in the 1860's  (Reference 45).  Al-
 most 95 percent of  the area of  the county is presently in agricul-
 tural  use.

     In 1973,  Adams County ranked seventh among the 65 counties in
 the  state  in winter wheat  production, tenth in barley, seventeenth
 in sugar beets, nineteenth in corn for grain, twentieth in sorghum
 for  grain  and  eleventh in  total crop production.

     Truck  farming activities in western Adams County are concen-
 trated  along the  Platte River.  The main irrigated crops are alfal-
 fa,  corn,  barley, sugar beets,  oats and rye.  Greenhouses and turf
 farms are increasing,  and  this trend is expected to continue (Ref-
 erence  45).  Dryland  farming is carried out primarily in the east-
 ern  part of the County (including the vicinity of the proposed dry-
 ing  and distribution  center site).  The main nonirrigated crops are
 winter  wheat,  forage  sorghum and barley.  The values of the various
 crops produced  in Adams County are shown in Table 15.

     Livestock  population  in Adams County is shown in Table 16.

 Sources  of  Fertilizer

     Nitrogen  fertilizers  are manufactured using nitrogen from the
 atmosphere  and hydrogen from fossil  sources (coal, petroleum and
 natural  gas) within the state.  Phosphorus is imported from other
 states.  Adequate sources of potash exist in southwestern Colorado;
 additional  supplies are available from southeastern Utah, where it
 is mined exclusively.

     The main source  of organic fertilizer in Colorado is livestock
 manure.  Dried manure comprised about 83 percent of the total or-
 ganic commercial fertilizer sales in 1972 in the Mountain States;
 about 10 percent consisted of activated sewage sludge; the other
 two percent was composed of other sewage organics and tankage, and
dried blood.  Similar percentages are assumed to hold for Colorado
 (Reference 5).

     There were 281,000 metric tons  [309,551 tons] of fertilizer
sold  in Colorado in 1972, up from about 175,000 metric tons [193,000
tons] in 1965.   During the same period,  the commercial sale of natu-
ral  organic materials dropped from 16,000 metric tons [18,000 tons]
to 6,600 metric tons  [8,000 tons].
                                82

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               Table 15.  VALUE OF CROPS PRODUCED  IN
                     ADAMS COUNTY, 1972-1973

Crop
Wheat
Corn, grain and silage
Barley
Sorghum grain
Sugar beets
All other crops3
TOTAL
1972
Value
$ 6,752,900
2,310,000
832,000
25,100
744,400
4,529,300
$15,193,900

%
44
15
6
—
5
30
100
1973
Value
$13,768,000
2,467,100
763,500
35,700
—
5,590,500
$22,624,800

%
61
11
3
—
—
25
100
o
 Includes dry beans, rye, hay, potatoes,  oats,  broomcorn, fruits
 and vegetables.

Source:  Comprehensive Plan:  Adams County.
         Table 16.  LIVESTOCK ON FARMS, 1 JANUARY 1973,
         ADAMS COUNTY, RELATIVE TO ALL COLORADO COUNTIES

Livestock
Cattle and calves
Milk cows
Hogs and pigs
Stock sheep
Cattle on feed
Number
70,000
5,000
22,500
4,300
40,000
Ranking
13
3
4
_25
5
Source:  Comprehensive Plan:  Adams County.
                               83

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      The fertilizer required for the agricultural  economy of  the
 state is presently in short supply,  and these  shortages  are ex-
 pected to continue (Reference 5).   This situation  is  linked to
 fuel and natural  gas shortages and to increased  demand in this
 country and abroad.

 Urban/Rural Characteristics

      The socio-economic characteristics of  the Metro  Denver service
 area differ greatly  from the characteristics of  the area  proposed
 for the sludge drying and distribution  center.   This  difference re-
 flects the urban/rural  contrast:   Metro Denver serves the urbanized
 Metropolitan Denver  area, while the  proposed site  is  situated in
 rural  eastern Adams  County.   There are  perhaps even greater differ-
 ences  between the eastern and western parts of Adams  County than
 between Denver County and Adams County,  as  indicated  in  Table 17.

      Table 17 shows  some of the contrasts among  socio-economic
 characteristics of the  three areas (Reference  43).  In 1972, about
 95  percent of the population of Adams County was urban rather than
 rural,  with approximately 65 percent  of the population concentrated
 in  five cities in the far western  part  of the  county adjacent to
 Denver  (Aurora, Northglenn,  Commerce  City, Thornton and Westminster).
 Census  Tract 084  consists of that  part  of Adams  County east of Box
 Elder  Creek (roughly  the eastern two-thirds of the county), the
 area in which the sludge drying and distribution center would be
 located.

 Land Values

     The  site under consideration  for the drying and distribution
 center  has  a  present  market  value  of  approximately $1 million for
 the 810  hectares  [2,000  acres]  required  (Reference 55).   This pre-
 liminary  cost estimate thus  sets the market value of the  site at
 about $1,200/hectare  [$500/acre].

     Market  values fluctuate considerably, but the current market
 for land  bought by a  farmer  in  large  tracts in the general area of
 the proposed  project  site  is approximately $500/hectare [$200/acre]
 for dry  farmland  and  $l,000/hectare [$400/acre] for farmland with
wells adequate for irrigation  (Reference 66).

     Through  speculation, often in anticipation of a special demand
for a particular parcel, property values may rise as high as $5,000/
hectare [$2,000/acre], or prices may be increased because of a trans-
action which  involves a  low downpayment  (Reference 66).   The recent
trend in land values  in  the area is one of sporadic increases in
property value.  The general trend in Colorado shows a 25 percent
                                84

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Table 17. CONTRASTING SOCIO-ECONOMIC CHARACTERISTICS

Characteristic Criterion
Total population Numbers of people
Mobility/ stability Lived in same house, 1965-1970
Commuting patterns Work in county of residence
Education High school graduates, 25+ yrs old
College graduates, 25+ yrs old
co Family size Children born/women married, 35-44
01 yrs old
Income Median family income
Age Median age
Farm population Number of farm-related jobs: farmers,
mgrs, foremen, workmen
Farm and related jobs/100,000 population
1
r\
Approximately the eastern two-thirds of Adams County.
Source: 1970 Census of Population and Housing (Reference 64);
(Reference 65) .
Denver Adams Census
County County tract 084a
514,678 185,789 2,233
44.0% 46.6% 50.6%
78.1% 32.7% 69.4%
61.5% 62.7% 58.0%
15.5% 8.6% 5.2%
3.0 3.0 2.7

$ 9,654 $10,409 $ 6,374
28.6 22.8 28.2
1,020 1,613 277

198 868 1189


1970 Census of Population


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 increase in land value from 1972 to  1973,  a  14 percent increase
 from 1973 to 1974 and a seven  percent  increase from  1974 to 1975
 (Reference 66).   Land values may change  near the proposed site in
 response to a number of currently unpredictable factors, including
 changes in farm  prices and the rate  of growth of the Denver region.

 Employment

      The employment-generating facilities  associated with the pro-
 posed project will  be located  in Adams County.  The major employ-
 ment classifications in Adams  County are given in Table 18.


          Table 18.   ADAMS  COUNTY EMPLOYMENT  PATTERNS, 1973
 	      Employment  category       	Number employed	

      Retail  trade                                   3,700
      Manufacturing                                  7,300
      Contract construction                          5,100

      Services                                       4,900
      Farm-related jobs  (farmers, man-               1,800
       agers, foremen, workmen)

      Wholesale trade                                1,600
      Transportation and other public                1,600
       utilities
      Finance, insurance, real estate                1,200

 Source:  1970 Census of Population (Reference 65); Adams County In-
         formation Service (Reference 43).

      The Urad mine is one of the sites being evaluated as a sludge
 recycling area.  The mine is one of three owned by Climax Molybdenum
 Company, which is the largest private employer in Colorado, employ-
 ing 3,500 workers (Reference 41).

      The unemployment rate in the eight-county Denver-Boulder Labor
Market Area in September 1975 was 5.7 percent; the Adams County rate
was 5.8 percent (Reference 67).  The national rate at that time was
eight to nine percent.

VISUAL AESTHETICS

     The rural  regions within the study area are characterized by a
                                86

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broad,  rolling  topography.  While there are generally no particu-
larly striking  features  in this agricultural area, an expansive
and  restful atmosphere gives the area a pleasant contrast to the
urbanized areas  to the west.  Dryland farms bear relatively few
signs of agricultural activity and thus do little to disturb the
area's  original  prairie  impression.  Irrigated farms are more ac-
tive; their green crops  exist in greater variety and provide a
more stimulating rural backdrop.

     The Denver  Parks provide a variety of well-maintained, attrac-
tive areas within the city.  The 1,800 acres of parkland range from
quiet,  secluded  neighborhood parks to the spacious City Park, which
includes a number of lakes and provides a setting for many culutral
and recreational activities.

     To reach the mine reclamation site farther to the v/est, one
leaves  the flat, rural regions and climbs into the rugged, moun-
tainous terrain  more commonly associated with the Rocky Mountain
region.  The Urad Valley is one of the many high, scenic valleys
along U.S. Highway 40, but its scenic value has been impaired by
mine tailings deposited on the floor of the valley.

     Specific descriptions of the environmental setting of the
various representative sludge application areas are presented in
Appendix E.

PUBLIC HEALTH

     The agency  charged with maintenance of the public health in
Adams, Arapahoe  and Douglas counties is the Tri-County District
Health Department.  This agency monitors the present Metro Denver
sludge disposal  operations at Lowry Bombing Range in Arapahoe
County and would also monitor the health impacts of the proposed
project.  A project requiring a Certificate of Designation is sub-
ject to review by the Colorado Department of Health, who would
have veto power  over the project (Reference 78).

     The U.S. Environmental Protection Agency takes public health
impacts into consideration in awarding grant monies.  These consid-
erations are contained in the tentative guidelines presently being
circulated for review before being formally released by EPA (Ref-
erence 79).

     The Agricultural Research Service of the U.S. Department of
Agriculture sets down criteria to ensure that heavy metals in
sludge (zinc, copper, cadmium, etc.) will not harm plants or the
soil.  The U.S.  Food and Drug Administration has yet to promulgate
guidelines for control of levels of possibly harmful substances in
sludge applied to crops which enter the human food chain.
                              87

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h

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     The principal features of Metro's proposed
sludge management plan are described in this
Section.  Main features include anaerobic di-
gesters, pipeline and pumping facilities, the
drying/storage/distribution center and proposals
for on-site irrigation and disposal.  Metro is
planning to market the sludge to farmers and
other users.  The type of uses considered and
their general locations are described here.
Discussion of recommended loading rates and
limits based on research in each type of land
use is presented.

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                           SECTION IV

                 DESCRIPTION OF PROPOSED ACTION
     Metro Denver's  proposed sludge management plan involves
 treatment of sewage  sludge at the District's Central  Plant and
 pipeline transport to a sludge drying and distribution center 40
 km  [25 miles] east of the Metro Denver Central Plant.   Air-dried
 and liquid sludges will be taken from the center and applied to
 the land in various  ways.  Each component in the proposed sludge
 management system is described in this Section.  A predesign and
 site selection study was conducted for Metro Denver in 1974-75.
 The recommended plan is discussed in detail in the "Metro Denver
 District Sludge Management, Volume I - Summary Report and Volume
 II  - Agricultural Reuse Predesign" (References 55 and 118).   Ex-
 cerpts from these reports are used extensively in this Section
 for the description  of the proposed action.

 SLUDGE TREATMENT

     Raw sewage sludge is generally unacceptable for land appli-
 cation due to the problems of odors, vectors and disease trans-
 mission.  These aesthetic and public health problems can be al-
 leviated by stabilization of the putrescible organic material in
 the sludge.  Sewage  sludge at the Metro Denver Central Plant will
 be stabilized by anaerobic digestion.  The Denver Northside Plant
 sludge is digested prior to conveyance to the Central  Plant.  This
 process will involve the decomposition of most of the organic ma-
 terials by micro-organisms in the absence of oxygen.  The sludge
 will be processed in mesophilic digesters with a constant temper-
 ature maintenance at 35°C [95°F] and continuous gas-diffusion
mixing.

     The digesters are designed for loadings of 2.1 kg of volatile
 suspended solids (VSS) per day per cubic meter of digester [0.13
 Ibs/day/cubic foot] and a 22 day digestion period. _At the end of
 this detention period, 50 percent volatile solids destruction and
 three percent solids concentration should occur.  Most of the organic
material will be converted into water, methane, carbon dioxide
 and other gases.  A comparison of changes in sewage sludge char-
 acteristics through  anaerobic digestion is given in Table 19.
                              89

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Table 19. CHANGES IN CHARACTERISTICS OF
SEWAGE SLUDGES THROUGH DIGESTION3
Concentration from treatment nreceedine analysis



Primary settling
Constituents
Total solids, Z
Suspended solids, Z
Volatile sollda,
Z of T.S.S.
Chemical oxygen
demand, ppm
Total nitrogen, ppm
Organic nitrogen,
ppm
Phosphate, ppm
Grease, ppm
Alkalinity, ppm

Cadmium , ppra
Nickel, ppra
Lead, ppm
Sliver, ppm
Zinc, ppm
Copper, ppm
Arsenic, ppm
Chromium, ppm
Typical ranges and
Range
4.25- 8.90
-
72.0 -94.5

36,800-98,280

1,070- 2,734
340- 2,626

1,237- 2,257
8,544-13,916
1,000- 2,420
Dissolved
0.02
0.67
Total:
Total:
1.55
11
0.01
0.09
Mean
6.4
-
80.2

61,267

2,066
1,874

1,795
11,080
1,603
Suspended
2.48
10.43
8.00
2.40
119
52
1.0
45
means were obtained from
Primary to secondary sludge solids ratio 15:
Activated
sludge
Calculatedb Mesophilic
Secondary settling Combined sludges digestion
flange
0.44- 0.89
0.10- 0.79
57.3 -92,0

4,224-11,408

481- 799
462- 580

963- 1,360
248- 528
330- 520
Dissolved
0.03
0.38
0.25
0.30
0.25
0.50
0
0.07
data at the City
Mean
0.69
0.58
73.1

7,106

541
512

1,148
400
430
Mean
4.02
-
79.8

38,699

1,431
1,30:

1,525
6,630
1,114
Suspended . Dissolved
0.77
1.42
2.25
2.00
12.8
11.5
0.14
16
of Los Angeles
1; primary to secondary sludge
0.02
0.55
Total:
Total:
1.01
6.6
0.006
0.08
Range
1.15- 2.98
1.04- 3.23
35.8 -71.5

12,900-42,400

1,840- 2,173
720- 969

1,250- 1,734
1,576- 2,672
4,900- 6,700
Suspended Dissolved
1.77 0.02
6.68 0.36
5.71 0.50
2.36 Total:
75 0.06
35 11
0.64 0.01
33 0.06
Mean
2.12
2.22
59.9

24,195

2,000
869

1,570
1,981
5,520
Suspended
2.98
9.14
7.5
3.30
77.3
32
0.08
50.3
Thermophilic
digestion
Range
1.67- 3.64
1.06- 3.67
37.8 -70.5

19,200-47,200

1.516--2.079
320- 790'

1,101- 1,697
2,468- 3,264
5,190- 7,900
Dissolved
0.02
0.45
0.45
Total:
0.20
0.27
0.04
0.15
Mean
2.35
2.49
62.0

33,420

1,992
697

1,604
2,820
6,190
Suspended
2.78
11.1
7.55
2.40
67.8
36.7
0.87
52.5
Hyperion Wastewater Treatment Plant.
flow ratio
1.4:1.




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The example data are drawn from the Hyperion Wastewater Treatment
Plant in Los Angeles which treats sludges with higher metal  content
than Metro Denver's and utilizes thermophilic digestion.  While
the changes in characteristics of sludges occur at a faster rate
in thermophilic digestion, the change in characteristics is gener-
ally similar to that from a mesophilic process.  However, it is
expected that microorganisms  (pathogens in particular) will  not be
reduced in numbers as effectively with the mesophilic process.

     At the anticipated design loading, ten digesters would be  re-
quired with a total volume of 2.4 million cubic feet.  First, eight
concrete anaerobic digesters with a total volume of 54,000 cu m
[1.9 million cu ft] would be built to accommodate 1977 sludge load-
ings at the Central Plant of 2,047 cu m/day [547,000 gal/day].
These digesters are now being constructed as part of the present
Central Plant expansion.  Two additional digesters would be con-
structed sometime prior to 1980 to handle the 1985 design capacity
of 3,100 cu m/day [824,000 gal/day].

     In the predesign study, it was assumed that all initial eight
units would operate as primary digesters.  Four of these units,
however, have been designed with the flexibility of operating as
secondary digesters for gravity thickening of the digested sludge.

     Three existing sludge holding tanks at the Central Plant
would be used in the sludge digestion and agricultural reuse sys-
tem.  One tank would provide storage for the undigested Central
Plant sludge.  Another tank would store the Central Plant sludge
after it is digested as well as the Denver Northside digested
sludge.  The sludge in this latter tank would be pumped to the
sludge drying and distribution center.  The third tank would be
used for storage of the liquid sludge in the event of some emer-
gency in the system.

SLUDGE TRANSPORT SYSTEM

     The liquid sludge would be transported from the Central Plant
to the distribution center through two pipelines, 25 cm [10 in.]
and 30 cm [12 in.] in diameter.  Each pipe would be capable of
handling 40 I/sec [600 gal/min] of sludge or secondary effluent.
Secondary effluent would be pumped tnrougn the force mains to
clean out solids deposits.  At the distribution center the efflu-
ent would be used for irrigation, dust control and fire protection
of on-site facilities.

     The proposed pipeline route to the sludge distribution center
site is shown on Figures 1 and 2.  The criteria used for locating
the route were length of route, elevation along the route and
                               91

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 proximity to estaolished rights-of-way for easy access to power
 lines.  These criteria were used to minimize costs and environ-
 mental impacts.  The pipeline will run parallel to the railroad
 tracks heading northeast from the District's plant and then  turn
 eastward along the northern boundary of the Rocky  Mountain Arsenal.
 From there the pipelines will  turn east to the distribution  center
 along Irondale Road.

      A system of Central  Plant pumps and booster pumps at an inter-
 mediate pump station  would be used to produce the  required head of
 240 m [800 ft] to pump the material  from the Central  Plant to the
 distribution center.   The Central  Plant pumps would develop  120 m
 [400 ft] of head, and the additional  120 m [400 ft] would be sup-
 plied by the booster  pumps.

      All  transport system pumps would be controlled from  the Cen-
 tral  Plant.   Gauges and meters at both the Central  Plant  and dis-
 tribution  center would monitor the operation of the transport
 system.

 SLUDGE DRYING AND DISTRIBUTION CENTER

 Drying and Distribution Center Site  Selection

      The three  potential  sites for the drying and  distribution
 center,  shown on Figure 2, were compared  to  determine  the best
 location on  the  basis of  economic  and  environmental  considerations.
 Factors  examined in making the site  selection are  shown in an ap-
 pendix to  the  Environmental Assessment for  the  Metropolitan  Den-
 ver Sewage Disposal District  Sludge  Management  (Volume  IV) (Ref-
 erence 8) and reproduced here  in Appendix G.

      The environmental  factors  investigated  in  comparing  the  sites
 included historic  value of each  site,  climate,  plant and  animal
 ecology, traffic and  aesthetic  impacts, economic investment  and
 land  use.  Land  use was found  to  be  the most  distinguishing  factor
 among  the  three  sites.  The least  amount of  project  impact on pres-
 ent and potential  land  use would occur  at  site  B-2.  Both sites A
 and A-2 have  the disadvantage  of  being  located  near an existing
 housing subdivision which  is scheduled  for future  expansion.   Be-
 cause  site B-2 is  near  the fewest  number of  private homes, loca-
 tion  of the facility  at that site  would be more acceptable to the
 local  community.

      In an economic comparison  conducted in Appendix A of "Agri-
 cultural Reuse Predesign"  (Volume  III), the  present worth for 10
years  of design,  construction  and  operation for sites A, A-2 and
 B-2 is $11,948,000, $11,695,000 and $12,899,000, respectively.
                                92

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Thus, on  the  basis of the economic comparison, site A-2 would be
the  preferred  location, and site B-2 the least desirable location.
However,  site  B-2 was recommended as the best location for the
drying  and distribution center primarily because it was not near
any  major residential development.  The potential social  problems
associated with locating the distribution center near a subdivision
far  outweighed all other differences among the three sites.  Solu-
tions or  compromises could be worked out for most of the environ-
mental  and economic problems.  However, strong public opposition
to the  project would be difficult to resolve and could be detri-
mental  to the  success of the project.  Locating the distribution
center  at site B-2 would minimize this problem.  Furthermore, the
projected location of a new regional airport near site B-2 com-
prises  a  highly compatible land use.

Drying  and Distribution Center Operation and Layout

     The  sludge drying and distribution center would operate as a
drying, storage, marketing and research and demonstration center.
Facilities which would be used for these functions are illustrated
on Figure 12 and are described in the following paragraphs.  Sludge
could be  purchased at the distribution center in both dry and liq-
uid  forms.  Liquid sludge could also be distributed from the Cen-
tral Plant and booster pump station.

     The  sludge would be air-dried in earthen drying basins which
would occupy about 240 ha [600 ac] at full development of the pro-
ject.   The open, unlined basins would be separated by earth berms.
The  drying basins could process about 33,000 dry metric tons
[36,000 short tons] of sludge per year.  Sludge applied to the
basins  in layers of 60 cm [24 in] can be expected to dry to 40 to
50 percent solids in about twelve months.  It should be noted that
during  the drying process further changes occur in sludge charac-
teristics.  The probable changes over 50 days in nitrogen content,
for  example, are shown in Figure 13, as measured at the Colorado
State University Agricultural Experimental Farm at Fort Collins
using anaerobically digested liquid sludge in the winter of 1974.

     Dried sludge will be removed from the basins when tests in-
dicate  that the required solids content has been achieved.  Front-
end  loaders will  load dried sludge into special trucks (not yet
specifically determined) for transport to the stockpjle area. Jhe
stockpile area will serve as the storage area and as the distribu-
tion point where users could obtain dried sludge.  The dried
material will be stored between the drying beds as shown in
Figure  12.  Fences will be erected around the drying_basin and
stockpile area to keep out grazing animals and wildlife.   The
capability for manual wetting of the stockpiles will be provided
                               93

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                                         FIGURE 12
                        SOURCE^ SLUDGE MANAGEMENT PLAN FOR
                              METRO DENVER DISTRICT.
   METROPOLITAN  DENVER PROPOSED
SLUDGE DRYING  AND DISTRIBUTION  CENTER
                     94

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                                                   FIGURE  13
  16
  15
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                                      LEGEND AND NOTES

                                             -N
                       TKN


                       —B-
TOP LAYER   	S-——

MIDDLE LAYER	A	

BOTTOM LAYER	-<•>-	
   I. BASIN DEPTH = I METER (40 INCHES)


^  2. BOTTOM OF BASIN WAS LINED

 \
 \
       -X--^.
            SOURCE: METROPOLITAN DENVER SEWAGE DISPOSAL DISTRICT NO. I
               J_
  0      5     10     15     20    25    30    35    40    45     50

   TIME .DAYS SINCE LIQUID SLUDGE WAS INTRODUCED INTO  DRYING BASIN
           AMMONIA AND TOTAL KJELDAHL NITROGEN
    CONCENTRATION AS A PERCENT  OF THE TOTAL SOLIDS
  CONCENTRATION  IN THREE  LAYERS IN AIR DRYING BASINS

-------
 as a means of preventing air pollution  during  strong  windstorms.
 Dried sludge will  be transported  by truck  to agricultural  users'
 farms and to other land application areas.

      On-site subsurface and surface application  areas would  be  used
 to test and illustrate the effects  of using liquid  or dried  sludge
 for agricultural  purposes.  The subsurface  injection  area  would  show
 the effect of Metro Denver's sludge on  crop production.   In  the
 later stages of operation, Metro  proposes  to inject up to  ten per-
 cent of the liquid sludge into  the  soil  at the sludge injection
 areas unless a market develops  for  additional  dry or  liquid  sludge.
 These injections would be at very high  rates of  875 tons/ha  [390
 tons/acre].

      Land  application of sludge on  the  research  and demonstration
 plots would  test the effects  of various  sludge loading rates on
 crop production.   Both irrigated  and  dryland crops  would be  grown
 on these  plots.  Various control  features would  ensure reliable
 and efficient  operation  and maintenance  of the distribution  center.
 A  control  and  administration  building,  a maintenance  building, and
 liquid  sludge  and  secondary  effluent  storage tanks  would be  parts
 of the  on-site  control complex.   All  of  the automatic controls and
 monitoring devices  for operating  the  distribution center would be
 housed  in  the  control  and  administration building.  Another  control
 feature would  be the  collection and impoundment of  the on-site sur-
 face  runoff  water  by  a system of  earthen channels and dams to pre-
 vent  possible  contamination  of  surface waters, as shown on Figure
 12.   Offsite runoff would  be diverted around the site.  Also, soil
 and  groundwater would  be monitored continually to provide informa-
 tion  for research purposes and for protection against potential  en-
 vironmental  damage.

 PROPOSED LAND APPLICATION  OF SLUDGE BY METRO DENVER

     The Metropolitan  Denver Sewage Disposal  District No. 1 pro-
 poses to make sludge available for recycling on various agricultural
 areas in the vicinity of Denver.  The agricultural  reuse program
would involve controlled seasonal  applications  under careful  nutri-
 ent and toxin management.  Disposal  landfill ing would probably occur
only under emergency conditions at the Lowry Bombing Range Sanitary
 Landfill.  High-rate sludge application, as proposed by Metro Den-
ver, would be conducted  in the open lands of the  Lowry Bombing
Range if the proposed sludge recycling plan is  not implemented.
Controlled sludge application areas  may  include Denver Parks, sod
farms, mine  spoil  areas, irrigated and dryland  farms and  possibly
some home gardens.
                                96

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      It  is envisioned that no single type of application will be
used  for  the ultimate disposal of the entire sludge generated in
Denver.   More  likely, a combination of two or more types of land
application, with  varying proportions from year to year (and
greater variety  in the years following the initial few years) will
take  place.  Because of the varying environmental settings of the
different sites  and the different possible impacts of each type of
land  application,  separate discussions of each type and the methods
of application envisioned for those types are presented.  Figure 3
shows potential  areas for each category of sludge application.
No definite contractual arrangements have yet been made for specific
sludge recycling areas.
       SPECIALLY EQUIPPED TRUCK SPREADS SLUDGE ON FARMLAND


     In the following paragraphs, the proposed sludge recycling
areas and the present disposal operations at Lowry Bombing Range
(the no-action alternative) are discussed with a view to recom-
mended methods and rates of application and operation.

-------
 Sludge Recycling  Areas

      Denver Parks--

      Over  the  past  few  years,  some dried sludge  (containing 20 to
 30 percent solids)  has  been used  in preparing topsoil for estab-
 lishment of new city  parks in  Denver and other cities in the area.
 The stockpiled and  air-dried sludge has been incorporated into top-
 soil  at about  112 metric  tons/ha  [50 tons/ac] prior to spreading
 the topsoil  on new  park areas  for seedbed preparation.

      In the  future, if  the proposed reuse scheme becomes operational,
 anaerobically  digested  and air-dried sludge will be spread during
 winter  months  on  already  established parks.  It  is expected that the
 sludge  will  be applied  to the  grass at the same total rate (112
 metric  tons/ha [50  tons/ac]) during the wintertime.  The City and
 County  of  Denver  Parks  Department has received sludge free of charge
 in  the  past  and expects to utilize up to a maximum of 4,500 metric
 tons  [about  5,000 short tons]  per year on that basis.  However, if
 a  charge is  imposed or  if the  delivery responsibility is shifted to
 the  recipient,  a  change in this projection may occur.

      Other  communities  indicating interest in sludge application to
 park  areas are Northglenn, Commerce City and Aurora.  Parks in the
 Denver  area  which are potential sludge candidates are graphically
 shown in Figure 3.

      Sod Farms—

     Application  of anaerobically digested air-dried sludge on sod
 farms will  probably be conducted by broadcasting of the dry material
 using manure spreaders or similar equipment.   The relatively fre-
 quent sprinkler irrigation, typical  of such farms, will  provide the
 necessary mechanism for moving sludge particles and soluble mate-
 rials into the soil  root zone.

     With the cyclic removal  of thin layers of soil during the har-
 vest operations, residual  sludge and its  components—not used by
 plants—are also removed from the site and transported to the con-
 sumer.  At the final destination, sludge  materials in the sod root
 network and the soil carried  with it are  gradually dispersed into
the soil and eventually taken up by  plant root systems.

     Representative locations of major sod farms in the  Denver area
are depicted in Figure 3.
                                98

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     Nine Spoil Sites—

     In many parts of the Rocky Mountains, the natural  landscape
has been marred by large piles of mine tailings created in the  pro-
cess of extracting molybdenum and other elements from mined ores.
Without a deliberate effort to reclaim these spoil  areas and im-
prove their potential productivity, these inert heaps may remain
unvegetated for many decades.  On some sites, where particle sizes
are uniformly coarse (large gravel, boulders and rocks), larger
particles may have to be crushed or finer materials imported before
attempting to add organic materials.

     For the example mine spoil site—the URAD mine near Berthoud
Pass—it is expected that Climax Molybdenum will furnish the neces-
sary trucks and other equipment needed for transporting and applying
dried sludge.  Sludge will be mixed with wood chips in  equal  pro-
portions and applied at an initial rate of 45 metric tons/ha [20
tons/ac] of the sludge (90 metric tons/ha [40 tons/ac]  of the mix-
ture).  It is planned to add another 22 metric tons/ha  [10 tons/ac]
of sludge within the first two years after the initial  application.
Thus, a total of 67 metric tons/ha [30 tons/ac] of sludge will  be
added to reclaimed spoil areas.  It is expected that this applica-
tion rate will prove to be lower than optimal for spoil reclamation.
With a total spoil area of 50 ha [125 ac], this will amount to  a
total sludge dry solids utilization of 3,400 metric tons [3,800
tons] at this particular mine.

     Another area of potential sludge usage is the Watkins Project,
approximately 17 miles east of downtown Denver on Highway 70.  The
Watkins Project is a conceptual plan to develop largely untapped
reserves of lignite coal near Denver.  Under this scheme, the coal
resource would be combined with solid wastes and converted (gas-
ified) into pipeline quality natural gas.  The energy source for
operation of the coal mine, the coal gasification plants and re-
clamation and restoration programs, as envisioned by the Mintech
Corporation, may potentially be derived from Denver sewage sludge
and solid wastes.  Briquettes pressed from mixtures of  solid waste
(garbage) and liquid sludge could supply approximately  20 percent
of the fuel feedstock.  Dried sludge may also be used as an alter-
nate energy source.

     The earliest projected date for project completion is 1981,
depending upon various financial arrangements and approvals by
State and Federal regulatory agencies.

     Irrigated Farms--

     Sludge application on irrigated farms will be the  most sensi-
                               99

-------
 tive of the agricultural  reuse schemes,  because  of the  intensive
 food crop production on such farms.   It  is  important  to  note that
 the sludge application procedures  and rates  described here are those
 best suited for the specific site  studied.   Impacts discussed in
 Section V are similarly site specific.   Therefore, an examination
 of the characteristics of each site  is necessary prior  to embarking
 upon a sludge application program.   Such examination  should include
 analyses of soil  cation exchange capacity (C.E.C.), pH  and back-
 ground heavy metals.

      At the present time, barnyard manure is  used on many irrigated
 farms, particularly in sugarbeet fields.  Conversion  to  use of
 sludge or supplementation of this material can be readily accom-
 plished with existing  equipment and  procedures.

      Annual  Application Rate Limitations — It  is  expected that an-
 nual  sludge application rates will be limited to  the quantity which
 provides nitrogen in amounts that can be taken up by the crops
 grown on the farm.  A  formula of this general character  requires
 a  number of assumptions,  regarding the basic  parameters  determining
 nitrogen balance.   The more  significant  of these parameters are:

      1.   potential  annual  uptake of  nitrogen  by  each crop, U, in
          kilograms  per hectare per year

      2.   total  nitrogen content of applied sludge, N as  percent
          of  sol ids

      3.   proportion of crop  nitrogen  removed from the land at
          harvest, Cj

      4.   percent  of nitrogen  which is mineralized (made available
          to  plants) in a  given year,  c2

      5.   total  background  nitrogen in soil, p, in metric tons
          per hectare

      Using these  values,  annual application rate, R, in metric tons
 per hectare,  is given  by  the  formula:


                               C, U
                        R  = 1 ,000 C2 M " P             (Equation!)


     A plot  of this equation  is shown on  Figure 14, in which p is
assumed to be zero.  Under most conditions this is a reasonable
assumption for the first year of sludge application.   On a farm
which has received sludge or other nitrogenous organic materials
in past years, p can be approximated by assuming  that 30 percent
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      UPTAKE OF MINERALIZED NITROGEN BY PLANTS


          NOTE : ASSUMING C, = 95%; C2 = 30?^; p = 0



  RELATIONSHIP  BETWEEN  ALLOWABLE  SLUDGE

APPLICATION RATE AND  UPTAKE  OF MINERALIZED

 NITROGEN FOR  SLUDGES CONTAINING DIFFERENT

 AMOUNTS  OF  NITROGEN - PLOT OF  EQUATION  I
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 of the nitrogen in applied sludge  becomes mineralized  (made availa-
 ble for plant uptake)  in the  first year, 15  percent  in the second
 year, 10 percent in the third year and  5 percent in  the fourth and
 succeeding years.   While controlled  experimental data  in this area
 are rather sparse, this decay series  provides a tentative and con-
 servative guide for protection against  over-application.  Using
 these assumptions  and  further assuming  that  sludge contains 3.5
 percent nitrogen on a  dry weight basis, allowable application rates
 over time are graphically portrayed  in  Figure 15.  For other sludges
 with different sludge  concentrations  (other  than 3.5 percent) the
 plots should  be adjusted proportionately, i.e.,


                           RN  = IT* R3.5               (Equation 2)


 to obtain the proper application rate, RN-

      Sludge application rates  which are greater than the rates
 given in  Figure 15 for  a given crop will result in leaching of ex-
 cess  mineralized nitrogen beyond the root zone and eventually to
 the groundwater table.   It  has  been estimated by Pratt that it
 takes from 10 to 50 years for  excess nitrogen to travel 30 m [100
 ft] vertically in  an unsaturated medium, depending on the inter-
 vening  soil types  present (Reference 96).   The nitrogen balance
 is  discussed  more  fully in Appendix D.

      Total Sludge  Application  Surface Rate Limitation—The total
 sludge  quantity which may be  permitted on  a piece of land is lim-
 ited  by the heavy  metals  which  can safely be tolerated in the soil.
 A  quantitative guide on the tolerable amount of sludge which can
 be  allowed is  that the  total  amount of heavy metals introduced
 therewith should not exceed ten percent of the soil cation exchange
 capacity.  A  formula proposed  by the EPA (modified to metric units)
 in  the  tentative guidelines (Reference 79)  suggests:

  Total Sludge  (dry solids, metric tons per hectare)  =

         73,000 x Cation  Exchange Capacity (meg/100 g soil)
      Zinc (mg/kg) + 2  Copper  (mg/kg) + 4  Nickel  (mg/kg)  - 200

                                                      (Equation 3)

The implicit assumption of this formula is  that  copper is twice as
toxic as zinc  and nickel  is four times as  toxic.   Soils that might
receive Denver sludge in Arapahoe or  Adams  County  may have a cation
exchange capacity of 20 meq/100 g.   Typically, Denver sludge con-
tains 1,145 mg/kg zinc, 808 mg/kg copper and  282 mg/kg  nickel
                               102

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                                              FIGURE  15
                                                   200
                                                  - IOO
                                                        o
                                                        CD
                                                        0)
                                                        o.

                                                        O)
                                                        1_
                                                        o
                                                        o
                                                        0>
                                                        Q.

                                                        CO
                                                        c
                                                        o
                                                        o

                                                        10
                                                  100
                  TIME , years
NOTES:
1.  ASSUMING 3.5% N IN SLUDGE WITH 0.30, 0.15, 0.10,

    0.05--" DECAY SERIES FROM YEAR 1 ON.
2.  RATES NECESSARY TO MINERALIZE  (MAKE AVAILABLE)

    CONSTANT NITROGEN QUANTITIES FOR VARIOUS  CROPS

    AND/OR LEACHING OF EXCESS N TO GROUNDWATER.

3.  1 Kg/ha = 0.892 Ib/ac



ANNUAL SLUDGE  APPLICATION  RATES
                     103
ENGINEERING-SCIENCE, INC.

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 (chemical  characteristics of Denver  sludge  are given  in Appendix D).
 Equation 3 yields a total permissible  sludge  application of about
 400 metric tons/ha [180 short tons/ac].   Comparing this representa-
 tive total loading with annual  rates given  earlier for irrigated
 farms, it appears that sludge application can be conducted on a
 given piece of land for 20 to over 100 years  (depending upon ap-
 plication and uptake rates)  before the limit  is reached.

      It is very important that  the limit  should be computed for
 each soil  on each farm.   Average  values and representative condi-
 tions can  be deceiving with  respect to actual field implementation
 of a project.   For the purposes of this environmental impact state-
 ment, values found on  the farms studied are used as a means of
 assessment of impact on  those sites as reported in Section V.  The
 specificity of the impacts to the site cannot be overemphasized.
 The applicability of these impacts to  the entire study area is
 valid only insofar as  planning  is concerned.  Design and implemen-
 tation  should  be  viewed  from  an entirely  site-specific point of
 view.   Using safe average application  rates,  if all the 1985 pro-
 jected  sludge  quantities  were to  be applied to irrigated farms, a
 total  of about 3,000 ha  [7,000 ac] of  irrigated farms would be
 needed.

      Dryland Farms--

      As noted  in  Figures  14 and 15, wheat grown under dryland
 farming practices  uses very little nitrogen due to the lower pro-
 duction rates,  compared with  irrigated crops.  Therefore, sludge
 application  rates  consistent  with nitrogen uptake are rather low,
 ranging from less  than one to three metric tons/ha [0.3 to 1.5
 tons/ac] per year.   At such low rates, rather extensive areas of
 application  and,  consequently, greatly increased operation expendi-
 tures are  involved.  On the other hand, due to the lower applica-
 tion  rates,  the dryland farms can be utilized for sludge reuse over
 a much prolonged  period  (over 300 years)  before the total  limit of
 heavy metals loading is reached.  Furthermore, impacts would occur
 at  a  proportionately slower rate, providing greater opportunity
 for mitigation and amelioration.

      Experimentation with methods of direct injection of liquid
 sludge at various depths  has  been conducted in the Denver-Boulder-
 Fort Collins area and equipment is available from commercial  manu-
facturers  (References 97  and 98).   These  methods  have promise par-
ticularly for dryland farms with the  lower application rate re-
quirements.  The effort involved in such  methods  is about  equal  to
land scarification procedures widely  utilized by  farmers  for water
conservation.  Sludge injectors achieve both functions in  the  same
operation (Reference 97).
                                104

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     Application of air-dried sludge with manure spreaders  or other
 similar  equipment can be controlled to achieve proper application
 rates.   Due to  the relatively low rainfall rates and minimal  culti-
 vation processes in the dry-farmed areas, it is expected that in-
 corporation of  sludge within the soil root zone will be a rather
 slow process; loss of nitrogen to volatilization would be greater
 and the  rate of breakdown of organic matter would be accelerated.

     If  all the 1985 projected sludge quantities were to be ap-
 plied to dryland farms within safe application rates, a total  of
 about 43,000 ha [100,000 ac] of non-irrigated farmland would  be
 needed.  If non-cultivated range land is to be included in  sludge
 application, adequate areas exist within reasonable distances from
 the proposed distribution center.

     Home Gardens—

     The dried  sludge could possibly be made available to the gen-
 eral public for use in home gardens.  Users would purchase the
 sludge at the distribution center and apply it to ornamental  plants,
 such as  lawns and flowers.  Although highly unadvisable, home gar-
 deners may choose to apply sludge to vegetable gardens.  Metro
 Denver could recommend appropriate usages of the sludge, similar to
 the criteria for irrigated farmlands, but would not be able to con-
 trol or  restrict ultimate uses of the sludge by the home gardener
 once the material is in his or her possession.  Metro Denver also
 contemplates marketing the dried sludge (presumably fortified and
 sanitized) in bags for use by home gardeners in a similar fashion
 to the Milwaukee "Milorganite" and the Rhode Island "Organiform."

 Sludge Disposal at Lowry Bombing Range (No Action)

     The present sludge disposal practice involves a large-scale
 trucking operation from the Metro Denver Central Plant 40 km [25
mi] southeast to the Lowry Bombing Range.

     For the high-rate sludge applications, the transfer trucks
 are unloaded on a special ramp at the Bombing Range into an en-
closed hopper which in turn drains into smaller spreader trucks.
The spreader trucks convey the dewatered (10 to 16 percent solids)
 sludge to the application areas where sludge is dumped in a uniform
 layer (about 15 cm [6 in.] thick) atop the ground surface and left
 to dry partially.  The sludge is later plowed into the topsoil
using moldboard plows pulled by a track-type tractor along the
contours.  Alternate contour strips are used to plow in the sludge
while the intervening strips are cropped and used for pasture.
A given contour strip receives sludge in this manner once every
 nine months until a total of 392 metric tons/ha [175 tons/ac] are
                               105

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 added.  The operation then moves  on  to  a  new  tract.   It  is expected
 that if the agricultural  reuse plan  is  fully  implemented, disposal
 operations in the Lowry Bombing Range will  be phased  out.
      SLUDGE  IS SPREAD ON  LOWRY BOMBING RANGE BEFORE DISCING


      During winter months when land application becomes impeded by
 ice and snow on the ground, this operation is temporarily replaced
 by direct dumping of the  sludge into pits in a manner similar to
 solid waste landfilling.

     Sludge Landfill ing--

      Landfilling sludge along with other municipal solid wastes is
 a widely accepted practice, generally used for ultimate disposal
 of the solid wastes.  Typically, partially dried sludge is dumped
 into the landfill and covered with other refuse.  However, under
 well-managed sanitary landfill ing procedures—increasingly in use
 in communities across the country—strict operating techniques are
 followed.   Foremost among these techniques is a sound site selec-
 tion process in which the environmental  implications of candidate
 sites are exhaustively researched and compared.  The U.S.  Environ-
mental Protection Agency has published a recent design and opera-
tion manual  incorporating site selection, construction, operation
and maintenance procedures (Reference 98).  The methods and pro-
visions standard  on truly sanitary landfills are aimed at  odor
control,  protection of public health, groundwater quality  protec-
tion and  prevention of various hazards.   Monitoring provisions are
aimed at  determination of long-term impacts  and early warning of
                               106

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adverse impacts.  At the Lowry landfill, sludge disposal  is  expected
to occur only during emergency periods when the normal  operations
are temporarily disrupted.  Also, if the proposed sludge  recycling
plan is somehow aborted, and if Metro Denver is also barred  from
landspreading at the Lowry Bombing Range, it is possible  that  sani-
tary landfill ing would be the reasonable alternative.
                              107

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'
'

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w
 h
•I

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      This Section  is  the  core  of the Draft EIS.
It is here  that the impacts of the proposed action
are presented and discussed.

     Because of the highly site—specific nature
of the impacts, this Section is organized to empha-
size the most important issues likely to arise at
the most vulnerable sites.  It is divided into
three main parts.  First, impacts expected during
the processing, transfer, drying and stockpiling
of the sludge are analyzed.  Second, impacts at
the land application sites (sludge recycling areas)
are presented.  Finally, impacts at the Lowry land
disposal and landfill—which comprises the "no-
action" alternative—are discussed.

     Throughout, an attempt has been made to pre-
sent the impacted environmental parameters and
criteria in descending order of importance and in-
tensity of impact,  as perceived under the existing
state of knowledge and as judged from the perspec-
tive of overall human welfare.   A great deal of
research in the field of land application of sludge
is currently in progress and is planned for the
future.  Therefore, many of the stated impacts must
necessarily be considered tentative in intensity
and, in some cases, in magnitude and direction, as
well.

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                            SECTION  V

           ENVIRONMENTAL IMPACTS  OF  THE PROPOSED ACTION
 INTRODUCTION

      The  Metro  Denver sludge  management plan, proposing the re-
 cycling of  organic  solids  on  land,  is a relatively complex scheme
 involving several treatment subsystems and numerous different
 types  of  application  sites.   Such complexity and diversity gives
 rise  to different types  and intensities of impact, necessitating
 separate  and distinct evaluation in the decision-making process.
 The reader  who  is interested  in only one type of application site,
 under  a given local condition, is cautioned to read this draft EIS
 with  a special  view to the specific sites and conditions discussed
 under  each  impact category.   In the present draft, impacts are ar-
 ranged in order  of  general severity and with particular reference
 to the sites  of  sludge application where they will be encountered.

 IMPACT OF SLUDGE PROCESSING,  TRANSFER,
 DRYING AND  DISTRIBUTION

     The  environmental impact of the proposed action was partially
 assessed  in  the  facilities planning process and reported in Febru-
 ary 1975  (Reference 8).  A summary of environmental impacts of
 sludge drying and distribution activities at the alternative sites,
 prepared  by  the  facilities planners (CH2M Hill) is presented in
 Appendix  G.   Impacts  attributable to the reocmmended sludge drying
 and distribution site (B2) are summarized in this Section.

      Impacts  of  processing and transfer (pipeline) will be rather
 temporary and slight  compared to those of the sludge drying/distri-
 bution site and  those at the  application sites.

 Soil Loss

     The  excavation of Z40 hectares [600 acres] of land to 1.5-m
 [5-ft] depth  for the  drying basins would effectively disturb all
 soil in this  large area.   Even though the disturbed soil mass
would  remain at  the drying/distribution site, soil profile charac-
 teristics, structure  and other physical  properties would be so
 thoroughly destroyed  or modified that an agricultural  substratum
                             109

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 would no longer exist.  Furthermore,  the soil  mass  thus  removed
 would cover over other soil  areas,  gradually changing  their  physi-
 cal, chemical and microbiological  characteristics.   Thus, an irre-
 trievable loss of the soil  resource from the site would  occur.

      Soils in the proposed  drying/distribution site are  largely
 in soil  capability unit Ill-e (irrigated)  or IV-e  (nonirrigated).
 This indicates that, with a  moderate  degree  of management control
 (especially to prevent erosion),  the  soils can be generally  produc-
 tive (particularly under irrigation).   Soil  impacts arising  from
 experimental  programs on the distribution  site will  be highly vari-
 able due to the wide range  of application  rates and methods  typi-
 cally used in a controlled  experiment.   It is  expected that  these
 experiments will  be conducted with  adequate  monitoring of the vari-
 ous sludge components and environmental  parameters  during and be-
 yond the experimental period.   Results  obtained from monitoring
 programs should provide the  necessary information for minimizing
 and mitigating adverse impacts.  The  size  of the experimental
 areas will  be generally limited, and  accumulations  of excess quan-
 tities of heavy metals in plots receiving  high  application rates
 will  eventually be dispersed,  in part to surrounding soils (by cul-
 tivation practices)  and in part to  underlying  strata.

      The impacts  of sludge reuse on agricultural land per se are
 discussed in  later parts  of  this Section.  Many of  the statements
 made  with reference  to off-site impacts are  equally applicable to
 conditions  on  the distribution site insofar  as  irrigated crop pro-
 duction  is  concerned.

 Water

      Groundwater  Quality—

      Due  to the low  permeability of soils in the distribution site,
 it  is expected  that  water movement toward the groundwater reservoir
 will  be  very slow,   notwithstanding the slow initial rates of water
 (and  sludge leachate)  movement and the further clogging of soil
 particles, salt-laden  water will eventually move past the upper
 soil  strata.   In  time,  this  drained water and the solutes it car-
 ries will percolate  into the water table and deteriorate ground-
water quality.  It is  expected that the extent of groundwater pol-
 lution from this  source will be significant considering  the
proposed  240 hectares  [600 acres] of unlined  sludge drying basins.
With a total dissolved solids concentration of about 6,000 mg/1,
the percolate is a threat to groundwater quality.   Both the inor-
ganic components and the stable organic  portion of  this leachate
can damage the groundwater quality and thus gradually reduce per-
missible  uses of the water.   The contamination of groundwater by
                              no

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 nitrates  is  discussed  under Public Health, below.

      The  soils  in  the  proposed drying basins have a permeability
 of 0.02 to 0.08 cm/hr  [0.008 to 0.03 in./hr].  Assuming that the
 soil  permeability  to sludge leachate will eventually decrease to
 0.0001 cm/hr [0.00004  in./hr] by clogging of soil pores, and as-
 suming that  half of the  drying basins will be wet enough to re-
 lease water  to  percolation at any given time, it can be computed
 that  27,000  cu  m [nearly one million cu ft] of leachate per year
 will  move toward the groundwater table.  With a total  dissolved
 solids concentration of  6,000 mg/1, this amounts to 160 metric
 tons  [180 tons] of salt  per year moving toward the water table.
 The rate  of  movement will be slow; it would take 20 to 100 years
 for the water to reach the groundwater table.  It would take a
 similar length  of  time to terminate pollution from this source at
 the end of a  long-term use of this land area.  Thus, a lack of
 evidence  of  water  pollution in the initial decades of operation
 cannot be viewed as a  sign of absence of impact.  The groundwater
 mound eventually created will move horizontally and will affect
 wells in  the vicinity.

      In light of these calculations—recognizing the limitations
 implicit  in  their  assumptions—it may be necessary to line drying
 basins with  (pigmented)  bentonite or some other effective barrier.
Other, partial,  solutions include separation of decant, use of
underdrains,  pumping leachate from the ground and vacuum filtration
of the sludge at the site before air drying.  Mitigation measures
against this  severe impact are discussed in Section VI.  Monitoring
of leaching water quality and movement rates will be necessary
whether or not  basins are lined.

      Surface Water Quality--

      Surface water protection will be effectively provided with
 the provision of drainage channels and earthen dams with adequate
 impoundment areas.  These features have already been incorporated
 into  the  facilities plan for the drying and distribution area.
 Provision is made  for analysis of impounded water for BOD, COD,
 biological indicators, nitrogen, total dissolved solids and other
 parameters, as  set forth by agencies regulating discharges to sur-
 face  water.  Contaminated water would not be discharged to streams
but would instead  be used for surface irrigation (see above for
groundwater quality effects).

      Water Rights—

      In the process of transporting liquid sludge to the drying
and distribution center, and during tne periods of purging the
                             111

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 pipelines with secondary effluent and any additional  irrigation  water
 beyond what is now consumed in the sludge disposal  process  will  be
 carried from the Central Plant to the Adams  County  site.   It  is  anti-
 cipated that this removal of water will  have some impact  on appropria-
 tions downstream of the Central  Plant discharge  into  the  South Platte
 River.  Under the existing system of appropriations,  the  treated and
 discharged sewage would belong to senior consumptive  users  downstream.
 However, under Colorado Supreme  Court decisions, water  transferred
 interbasin belongs to the diverter and can thus  be  reused.  In this
 particular case,  the Denver Water Board  is the owner  of the water
 transferred from the western slopes and  will  presumably allow Metro
 to use these additional  waters as part of the treatment process.

 Public Health

      General--

      Biological  health hazards associated  with sludge include patho-
 genic bacteria,  viruses  and parasites  which  may  have  survived the ini-
 tial  treatment process.   The major bacterial  diseases have  been con-
 trolled  well  by traditional  treatment  processes.  Statements  about
 viral  health problems must be more guarded and uncertain  because of
 the difficulty in measuring viruses and  the  lack of standards for vi-
 rus levels.   In  general,  however,  viruses  are more  short-lived than
 bacterial  pathogens  (References  39,80).   Intestinal  parasites may
 also  be  present  in various  forms  in the  sludge.  Parasites  and their
 eggs  or  cysts  are only partially destroyed by traditional treatment
 processes.   Other biological  hazards associated with sludge are such
 disease-carrying  vectors  as  flies,  mosquitoes and rats.

      Threats to health from  chemicals within  the sludge are generally-
 chronic  and  indirect.  Before  the  chemicals can reach the human body,
 they  usually pass through at  least  two biological systems (plants and
 livestock); acute effects can  be noted at these intermediate  stages.
 The treatment process itself  is a  relatively  sensitive  biological sys-
 tem which can be  upset at the activated  sludge or anaerobic digestion
 stage  if high concentrations  of certain  elements enter  the  system.
 Chemicals applied to  the  soil would affect the crops if they  built up
 to dangerous levels.  Present standards  for heavy metals are  based on
determinations of the levels at which there is toxicity to  plants (Ref-
erence 79).  The  human health effects of long-term,  low-level  consump-
tion of these materials cannot be determined at this time.  Therefore,
potential adverse effects on  human  health cannot be  overemphasized.
Traditional sludge treatment processes do not reduce hazards to human
 health from heavy metals  in  the sludge.  An  interim primary standard
 has been established  by the  EPA for nitrates  at 45  ppm  (as  nitrate)
 in drinking water supplies.   If  levels are kept below this  thresh-
old, a safe water supply  is  generally presumed.  Regulations  also
exist to control  the  levels  of persistent organic chemicals in certain
                                112

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components of the food chain,

     Health Protective Factors Associated
     with Sludge Management—

     There are a number of factors which help to ensure  that the
potential health hazards associated with sludge will  not be  real-
ized to the extent of creating actual health problems.   The  an-
aerobic digestion process destroys most of the human  pathogens.
Fecal coliforms, an indicator of pathogens,  are reduced  by  97  per-
cent or more in a well-run anaerobic digester (Reference 79).  An-
aerobically digested sludge is generally considered  biologically
safe to use on farm crops without further treatment  (Reference 81).
Eggs and cysts of enteric parasites are able to survive  the  diges-
tion process and remain alive for relatively long periods of time.
The subsequent drying and soil incorporation processes are  deadly
to pathogens due to the exposure to ultraviolet light, desiccation
and unsuccessful competition with the indigenous soil  organisms.
However, many parasites have long survival periods in the soil in
cyst form or in the egg stage.  Long-term storage of  sludge  is an
effective reducer of pathogenic organisms (Reference 82).  Storage
of liquid digested sludge for 60 days at 20°C [68°F]  or  120 days
at 4°C [40°F] has been reported to be a successful pathogen  reduc-
tion measure (Reference 79).

     Pathogens--

     Because potential hazards exist in the use of recycled, di-
gested sludge, proper precautionary measures must be provided to
assure that no significant harm to human health will  result from
this practice (Reference 39).

     Pathogenic microorganisms will not pose a  significant public
health threat at the distribution site if the proposed project is
operated as designed.  The project will include a soil and ground-
water monitoring system to monitor environmental quality.  Six on-
site wells around the perimeter of the drying site and other near-
by wells will be used to monitor approximately  15 biological and
chemical parameters.

     The survival times of various pathogens as_sociated with sew-
age sludge are given in Table 20.  Ascaris ova  (eggs of a para-
sitic worm) are particularly long-lived and thus are good indica-
tors for monitoring the general sanitary quality of the sludge.
salmonella, relatively common pathogenic microorganisms, are also
                             113

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Table 20.  SURVIVAL TIMES OF PATHOGENIC MICROORGANISMS  IN VARIOUS MEDIA

Organism
Ascaris ova



Cholera
vibrios







Endamoeba
histolytica
cysts


Enteric viruses




H'.okwona larvae

Leptospira

Salmonella typhi















Medium
soil
soil
plants and
fruits
spinach, lettuce
cucumbers
non-acid vegeta-
bles — onions ,
garlic, oranges,
lemons, lentils,
grapes
rice and dates

river water
soil
tomatoes
lettuce
roots of bean
plants
soil
tomato and pea
roots
soil

river water
soil
dates
harvested fruits
apples, peats,
grapes
strawberries
soil
soil
soil

pea plant stems
radish plant
stems
soil

lettuce and
endive
Type of application
not stated
sewage
ACb

AC
AC
AC




infected
f eces
AC
AC
AC
AC
AC

AC
AC

infected
feces
AC
AC
AC
AC
AC

AC
AC
AC
AC

AC
AC

AC

AC

Survival time
2.5 years
up to 7 years3
1 month

22 - 29 days
7 days
2 days




hours to
3 days
8-40 days
8 days
18 - 42 hours
18 hours
at least
4 days
12 days
4-6 days

6 weeks

5-6 days
15 - 43 days
68 days
3 days
24 - 48 hours

6 hours
74 days
70 days
at least
5 days
14 days
4 days

up to
20 days
1-3 days

                                114

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           Table 20  (continued).   SURVIVAL TIMES OF PATHOGENIC
                      ORGANISMS IN  VARIOUS MEDIA
Organism









Salmonella,
other than
typhi




Shi gel Jt a




Tubercle bacilli
Medium
soil
soil
lettuce
radishes
soil
soil
soil
cress, lettuce,
and radishes
lake water
soil
vegetables
tomatoes
soil
potatoes
carrots
cabbage and
gooseberries
streams
harvested fruits
market tomatoes
market apples
tomatoes
soil
grass
sewage
soil
Type of application
AC
AC
infected
f ecps
infected
f eces
infected
f eces
AC
AC
AC
AC
AC
AC
AC
sprinkled with
domestic sewage
sprinkled with
domestic sewage
sprinkled with
domestic sewage
sprinkled with
domestic sewage
not stated
AC
AC
AC
AC
AC
AC
•>
?
Survival time
2 - 110 days
several months
18 days
53 days
74 days
5-19 days
70 - 80 days
3 weeks
3-5 days
15 - 70 days
2-7 weeks
less than
7 days
40 days
40 days
10 days
4 days
30 minutes -
4 days
minutes -
5 days
at least
2 days
at least
6 days
2-7 days
6 months
14 - 49 days
3 months
6 months
       warm, moist conditions not encountered in the Denver area.

 AC = Artificial Contamination
Source:  Evaluation of Municipal Sewage Treatment Alternatives  (Reference 80).
                                     115

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 fairly hardy and therefore good indicators  for  monitoring  the
 safety of the sludge.

      Because of the remoteness  of the  site,  human  exposure to  the
 drying sludge will  be  limited,  further ensuring that  no  significant
 health impacts will result from the  proposed project.  However,
 public access to the drying beds  should be  curtailed  while the
 sludge is drying, and  special  periodic medical  examinations and
 preventive treatment by qualified physicians should be made avail-
 able to project personnel  and  to  consumers who  come to the site to
 collect sludge.

      An adequate soil  barrier/filter exists  for protection of  the
 groundwater from any pathogenic microorganisms  in  the sludge.  Sur-
 face water runoff will  be  contained  behind earthen dams  on a site
 about 15 m [50 ft]  above the water table, and access  to  this water
 will  be controlled  to  bar  potential  health and  safety problems.

      Nitrates--

      It is probable that significant quantities  of nitrogen, in the
 soluble nitrate form,  will  move with the leachate water  from the
 bottom of the sludge drying basins toward the groundwater  table.
 The  precise  quantity and rate of  movement of the nitrates  depend
 on several  factors  (denitrification  rates under  anaerobic  condi-
 tions,  mineralization  of organic  nitrogen forms  by microorganisms,
 oxidation of the  ammonia form under  aerobic  conditions,  etc.), each
 of which  may be occurring  at different  times and places  in the ba-
 sins  at different rates.   Once  nitrate  begins to migrate beneath
 the  basins,  it  will  remain  unchanged and may gradually increase in
 concentration  in  the groundwater  reservoir,  eventually exceeding
 the  45  mg/1  standard.   High nitrate  (NO^) concentrations in drink-
 ing water supplies  have  been linked  to methemoglobinemia,  a rare
 "blue  baby"  disease  resulting from reduction of  the oxygen-transfer
 capacity  of  blood in infants.   The problem of nitrate, coupled with
 the other salts  discussed  above under groundwater quality, can be
 handled by lining the basins and  other measures enumerated.

     Vectors--

     Gnats,  flies and mosquitoes  are the most common vectors of
 pathogens expected  to be present  in  the vicinity of the drying ba-
 sins.   It  is  important  that qualified specialist entomologists be
 consulted for the identification  of specific species of insects
 that will emerge in the basins.   While gnats and flies will remain
within one km [O.6 mile] of the  basin boundaries, mosquitoes can
 travel  (even under severe wind conditions)  UD to 40 km [25 miles]
                               116

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away.  Mosquitoes and  some species of flies can transmit certain
diseases;  hence, it  is  important that integrated insect control
measures be  instituted  with a view to maximizing natural control
mechanisms.   The drying  basins  (240 hectares [600 acres] in size)
will provide a  large,  permanent ecosystem with a wide range of
moisture,  food  supply,  breeding environments and surrounding vege-
tation.  It  is  difficult to predict the actual  invertebrate spe-
cies that  will  inhabit  this new ecosystem.  However, it is possible
that a few species will  predominate in the absence of natural  ene-
mies.  Only  after accurate identification of the prevalent species
can proper control measures be  recommended.  Hence, consultation
with specialist entomologists is important at the initial  stages
of operation of drying  basins.  It may be necessary to add safe
insecticides (such as  organophosphates) to sludge at the treatment
plant.

     Experimental sites  for liquid sludge application may also at-
tract some insects and  require  control measures.  Vectors such as
rats and mice are usually not attracted to drying basins or to
stockpile  areas.  The  proposed activities in the experimental  areas
are therefore not expected to influence either the presence or the
size of population of  such vectors.

Loss of Habitat

     Animal  species  diversity at the proposed site will be greatly
reduced due  to  the removal of habitat during the construction of
facilities and  the excavation of vast areas for the sludge drying
basins.  Some species,  including mice, voles and rabbits, may re-
turn to cultivated portions of the site when crops are growing.
Some of the  birds presently found on the proposed site may return
if the level of human activity and the types of crops grown in
these areas  are not  incompatible with their resting and feeding
requirements.   At the  time of facilities planning investigations,
consultants  found "no  nesting areas which might be disturbed" (Ref-
erence 8).    The disturbance to vegetation along the 40-km [25-mile]
pipeline and within  the 300-hectare [2,000-acre] distribution site
would not be of a drastic nature because most native vegetation
has long been replaced  by farming.  Vegetation will be readily re-
stored along the pipeline.  At the distribution center, all vege-
tation at the site of the drying basins and stockpile area will
be removed for  the indefinite duration of the -project.  At the
experimental areas,  a  presumably well-managed farming operation
will  replace the existing dryland farms.

Air Quality

     The proposed project is not expected to cause a significant
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 air quality impact on the alternative drying  and distribution cen-
 ter sites during any but the most severe windstorms.   (Odors are
 discussed as a separate topic in the pages  following.)

      During operation of the sludge drying  center,  dust will origi-
 nate primarily from vehicles driving on  the dirt roads of  the site.
 A problem lesser in magnitude but perhaps greater in  offensiveness
 is the dust which will  be blown from the dried  sludge piles.  Be-
 cause the sludge particles will have been thoroughly  dried before
 becoming airborne,  little odorous,  volatile material  will  be pres-
 ent and pathogenic  organisms will  have been largely desiccated.
 However, spores and certain parasite eggs can survive in dry con-
 ditions for relatively  long periods.

      Normal  winds will  not spread  significant amounts of dried
 sludge, though the  strong (over 11  mps [24  mph])  winds which oc-
 casionally occur (during about two  percent  of the year) will
 spread the dried material,  probably to the  east  or  south (see Fig-
 ure 9  for wind distribution patterns).   It  is difficult to esti-
 mate the amount of  material  blown during  such winds.  During most
 wind storms, the contributions from the  sludge piles  probably will
 not be quantitatively or qualitatively significant  because of the
 cohesive,  fibrous nature of the dried  stockpiled  material.

     Air pollutants  generated  during  transport and  delivery of
 the dried  sludge will not  be of great  enough quantity to signifi-
 cantly affect  air quality.   Impacts  on air  quality  were determined
 assuming "worst case" conditions during  peak periods:  30 truck
 trips/day  and  200-km  [120-mile] maximum roundtrip (Reference 77).
 From these figures and emission  factors appropriate for the trucks
 (Reference 99),  it is calculated that  the maximum amounts of air
 pollutants generated during  the  spring and  fall  peak  delivery per-
 iods are:  hydrocarbons, 10  kg/day  [23 lb/day];  carbon monoxide,
 70  kg/day  [150  lb/day];  nitrogen oxides,   110 kg/day [240 lb/day].
 This will  not  cause a significant air  quality impact, being about
 0.03 percent of  the pollutants  emitted daily in  Air Quality Con-
 trol Region 2  (see Figure 8) (Reference 38).

     Ammonia nitrogen (as N) accounts for three  to four percent
of the dry weight of the liquid sludge (Reference 55); 50 percent
of this will be  lost to  the atmosphere during  drying  (Reference
88).  On the basis of design sludge quantities,  this amounts to
approximately 620 metric tons  [633 tons]  per year of nitrogen-
containing gases emitted.  Liquid sludge  loses about one-fourth
as much ammonia nitrogen and therefore will  emit less of this ma-
terial  to the air.  These emissions have  caused  no knov;n air qual-
ity problems in sinilar operations in Los Angeles County,  Califor-
nia (Reference  100).  It is doubtful that this loss in ammonia
                              113

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 nitrogen  will  have  a  significant effect on air quality (Reference
 101).

      Because  there  is no  air quality standard in Colorado for am-
 monia  emissions,  odor is  the only parameter of concern with regard
 to  this gas.   An  emission permit is required from the Air Pollution
 Control Division  of the Colorado Department of Health under Regula-
 tion  No.  2, promulgated by the  Colorado Air Pollution Control Com-
 mission.   Included  in this permit would be a definitive plan for
 the control of odorous emissions.   In addition, a complete inven-
 tory  of quantities  and rates of emission is required for all odor-
 ous compounds  being emitted from the site.  (Odor conditions are
 described  separately,  below.)

      The  Department of Health further stipulates that significant
 emissions  be modeled  to estimate maximum concentrations and their
 locations  downwind  of the site.  Similarly, it will be necessary
 to  include a plan for the control of fugitive dust.

     Odor—

     Tv/o  sets  of  observations have  been gathered on odors which
 might  possibly enter  the  environment surrounding the proposed
 sludge drying  and distribution  center.  One test was carried out
 by  the Metro Denver staff in cooperation with Colorado State Uni-
 versity on a system similar to  the  proposed new system.  A second
 set of observations of interest was gathered by the Tri-County
 District Health Department on the sludge drying system presently
 operating  at the abandoned Lowry Bombing Range.

      In the first test, the Metro Denver District staff constructed
 and monitored  six 8-m by  9-m [25-ft by 30-ft] sludge drying basins
 at  the Colorado State University research farm at Fort Collins.  A
 panel of Colorado State University  faculty members and wastewater
 treatment  plant operators  was assembled.  The odor tests were taken
 within a few meters of the ba~sins over a period of 6 to 12 months.
 The panel  was  asked to describe the odor level in terms of the fol-
 lowing numerical rating system:
                    0  -   undetectable
                    1  -   faintly detectable
                    2  -   detectable
                    3  -   objectionable
                    4  -   very  objectionable
The basins took from  6 to  12 days to reach the No. 1 level.  The
 panelists noted that  the  odors  did not carry very far beyond the
 basins.
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      The results of the tests were confirmed by Metro representa-
 tives during a field trip to drying basins in Sioux Falls,  South
 Dakota; Topeka and Wichita, Kansas; and Tulsa and Oklahoma  City,
 Oklahoma.  None of those facilities had serious, continuing odor
 problems.  However, odors were a problem where inadequate diges-
 tion occurred due to system failure (Reference 3).

      The present Metro Denver operation at Lowry Bombing  Range is
 monitored for odors and other factors by the Tri-County District
 Health Department.   The Department also receives any complaints
 concerning odor problems of the operation.  There are about 10
 complaints a year concerning odors emanating from the site.   These
 complaints come from areas up to 10 km [six miles]  from the Lowry
 site.  However, complaints coming from this distance were found by
 the Health Department to be unjustified ones:   "The range of what
 were considered justified complaints  was one or two miles [two to
 three km]  from the  Site" (Reference 39).  The complaints  usually
 conincided with unusual  meteorological  conditions and/or  system
 failure.

      Some  past odor problems (such as the one  occasioning the pub-
 lic hearing of 20 June 1972) were due to system inadequacies which
 were subsequently corrected.  About 80 percent of the complaints
 were found by the Health Department to be due  to other odor sources
 in  the area,  such as  the landfill  operation at Lowry and  the gas
 processing  plants in  the vicinity.  The remaining 20 percent of
 the complaints occurred  during  unfavorable weather  or operation
 breakdown  (Reference  39).

      It should  be noted  that the anaerobically digested sludge to
 be  dried as part  of the  proposed project will  be less  odorous  than
 the material  presently deposited at the Lowry  site.   After  the
 sludge has  been dried  prior  to  distribution  to  sludge  recycling
 areas, almost  all of the volatile,  odorous  materials  will have
 left the sludge.  During digester malfunctions  (souring), severe
 odor problems may be expected  if sludge were to be  pumped to the  site.

 Noise

      Traffic,  aircraft and farm  equipment comprise  the main  sources
 of  existing background noise in  the vicinity of  the  proposed drying
 and  distribution  center,  with an average  noise  level of 35 decibels
 on  the A scale  (35 dB-A)  and a maximum  of 60 dB-A (Reference 3).
 It  is expected that the  site will be designed  in  such a way  that
most  of the noise-generating activities will occur at the center of
 the 800-hectare [2,000-acre] site and thus be surrounded  by  experi-
mental fields.  Further,  it  is possible to equip all internal com-
 bustion engines with noise mufflers, reducing noise to 80 dB-A at
15m  [50 ft].
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     Noise levels are expected to rise on Irondale Road  with in-
creasing truck traffic, particularly during the heaviest periods
of sludge application.  These noises, as well  as all  others  dis-
cussed above, would occur only during the least noise-sensitive
daylight hours and would not disturb the comfort of residences or
pose a health threat to operators or other persons on the site.

Energy Use

     Metro Denver Sewage Disposal District No. 1 used about  50 mil-
lion kilowatt hours (KWH) of electricity for its total  operations
in 1975 (Reference 73).  On a per capita basis, this amounts to
about 50 KWH/person/year, which compares to a total per  capita
energy consumption in the United States of about 100,000 KWH/year
(References 74,75).  The current sludge handling and disposal  sys-
tem has total energy costs, for electrical power and fuel, equiva-
lent to roughly 20 million KWH of energy (References 8,55,70), or
20 KWH/person/year.

     Viewing the energy required for sludge handling and disposal
in the perspective of the total energy use within the District's
service area, sludge accounts for about 0.02 percent of the total
energy consumption in that region.  Viewed in absolute terms, it
is roughly equivalent to the total annual energy consumption of
200 people.

     Energy Value of Sludge Nutrients—

     An energy parameter of significance is the amount of energy
required to produce and ship fertilizer in the area.  For produc-
tion of the three macronutrients essential for fertilizers:   ni-
trogen, phosphorus and potassium, costs to the consumer that are
due to energy costs are estimated to be 50, 25 and 30 percent,
respectively (Reference 76).  Assuming that the nutrient elements
are available in proportions of two nitrogen, one phosphorus and
no potassium in Metro Denver sludge, the weighted average energy
equivalent of the nutrient value of the sludge becomes 40 percent.

     If recycling of nutrients in the sludge is successfully
achieved, a saving will be realized that is equivalent to the en-
ergy requirement for mining, manufacture and transport of commer-
cial chemical fertilizers which otherwise would have been needed.
Assuming (a) a nutrient value benefit of $28/metric ton [$25/ton]
for Metro Denver sludge (on the basis that nitrogen is the only
nutrient of value, with five percent of the dry matter in the
sludge worth $0.55/kg [$0.25/lb]); (b) design production of 97
metric tons [107 tons] of dry sludge per day, and (c) an energy
factor of 40 percent of the total fertilizer cost, an energy equiv-
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 alent of about $400,000/yr  is  obtained.  At  $0.02/KWH, this trans-
 lates into energy savings of about  20 million KWH per year.

      Energy Produced in  the Digestion Process—

      Methane gas is  generated  in  the anaerobic digestion process
 at the rate of nearly one cu m/kg [15 cu ft/lb] of volatile mater-
 ials destroyed in the digesters.  The energy value of methane thus
 produced will  be almost  70  million  KWH/yr using conservative as-
 sumptions in basic production  rates.  Since an equivalent of about
 20 million KWH will  be used annually for heating the digestors, a
 net gain of about 50 million KWH/yr would be realized if energy-
 conversion equipment (boilers, steam turbines, etc.) were to be
 available for  utilization of the  excess energy.  At this point,
 however, such  equipment  is  not envisaged in the facilities plan;
 therefore, this rather large energy item is not included in the
 total  energy picture.

      Energy Used in  Transport of Sludge—

      Another major energy economy can be achieved through the more
 efficient transportation system (in comparison to the Lowry dispos-
 al  operations)  designed for the recycling project.  About 680,000
 liters  [180,000 gallons] of diesel fuel per year are consumed in
 the Lowry operation,  assuming 35 truck trips/day, 80-km [50-mile]
 round  trip and  1.5 km/1 [3.5 miles/gal] (References 55,77).  This
 energy  is equivalent to nine million KWH/yr and is included in the
 total  energy figure  given above for the present operation of the
 sludge  handling  and  distribution systems.

      By  contrast,  only about 80,000 liters [20,000 gallons] of
 fuel  per  year would  be required to deliver the present sludge load
 to  the  land  application areas.   Net  savings  accomplished  by the new
transport system (including  the sludge  pumping  energy  requirement)
over the Lowry operation  amount to about eight  million KWH/yr.

      Energy  Balance  in Sludge Transport to Farms—In order for the
 shipping  of  sludge, from the drying  and distribution center to re-
use  areas,  to be economical, the cost of shipping must not exceed
 the  price  of equivalent fertilizer delivered at the reuse site.
This assumes no  value for the soil-structure-enhancing benefits of
sludge recycled  to land.   Assuming further that nitrogen  is the
only constituent of value in sludge, maximum distance—beyond which
shipment of  sludge would  be uneconomical — is obtained  by:


                          U = F
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 in  which:   D  =  distance  from  the distribution center to the
                ultimate  application area,

            F  =  fertilizer  cost,
            N  =  fraction  of nitrogen in the sludge dry solids,

            W  =  fraction  of total solids in the sludge shipped,

            S  =  specific  weight of stockpiled sludge, and
            Y  =  volumetric  unit transport cost.

 With:       F  at $0.55/kg [$0.25/lb] of elemental nitrogen,

            N  at 0.05,  i.e., five percent of the dry matter,

            U  at 0.50,  i.e., 50 percent of the sludge,
            S  at 560  kg/cu  m [35 Ib/cu ft], and
            Y  at $0.08/cu m-km [$0.10/cu yd-mile],

 the breakeven distance,  D,  is calculated to be nearly 100 km [60
 miles].

     In summary, it  can  be  seen from the discussions presented
 above that  a  total energy  saving of at least 28 million KWH/year
 could be realized if a successful sludge recycling program were
 instituted  to replace  the  present system:  eight million through
 abandonment of  the Lowry operation and 20 million from fertilizer
 recycling revenues.  This  is equivalent to the average annual en-
 ergy consumption of  280  people, or about 0.03 percent of the total
 energy consumed within the District boundaries in a year.

Aesthetics

     The visual  impact of  the proposed sludge drying site, as de-
 signed, will  be perceptible mainly from within the site and  from
 above (from aircraft).   The demonstration plots will be visible to
 the passing motorist from  Irondale Road, the most heavily travelled
 road bounding the site (though even this road carries only about
 210 vehicles  per day).   It is expected that the sight of_the drying
 basins may  be unpleasant to those associating the site with  the
 fecal origin  of sludge.  Otherwise, the distinctive geometric pat-
 terns formed  by the  basins  (schematically presented on Figure 13)
 and stockpile windrows could  provide an interesting visual contrast
 (particularly from the air) to adjacent farmland patterns.  The
 association of  the project with energy and resource conservation
 will further  improve its aesthetic status in the minds of people
 who are aware of the limits of our planet.
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  Plant Operation and Plant Effluent Quality

      Because Metro is installing anaerobic digesters at the Metro
  Central Plant, a different strength waste stream will  result com-
  pared to the present system.  In a wastewater treatment plant using
  digesters, supernatant from the digesters is often recycled to the
  plant.  This recycle stream can put an additional  treatment burden
  on the plant operation from addition of suspended solids, BOD, am-
  monia and other substances.

      With the Metro land recycling proposal, the digester super-
  natant would be pumped along with the digested sludge  to the drying
 and distribution site.  This proposal would therefore  leave the re-
 cycle situation at the Metro plant comparable to what  it is now.
 However,  if the use of the Lowry Bombing Range were continued for
 disposal  (and presuming  that the present operation of  vacuum filter
 and truck haul  were also to be continued with digested sludges) the
 Metro Central  Plant would experience additional  loads  on the liquid
 treatment portion  of the plant.   A rough estimate  of the additional
 load  would  be as  follows:  suspended solids:  10  to 15  percent, BOD:
 3 to  6  percent, and ammonia:  4 to 8 percent,  assuming  both  Metro
 and the Northside  plants  were to recycle or add  supernatant to the
 plant.  The first  two  constituents would probably  be further treated
 in the  plant process  and might not affect effluent quality.   Ammonia,
 however,  could  pass through  existing plant treatment units  unchanged
 and increase ammonia  loadings to the South Platte  River.  Any alter-
 native  involving recycled supernatant to the  wastewater  plant would
 have  this effect.

      The  tradeoff  between the Metro proposal  and any alternatives  in-
 volving recycle to  the plant  involves  the additional treatment that
 may be necessary at the drying site to handle  the  supernatant and
 additional  excess water  in the digested  sludge.  No  cost  estimate
 has yet been made for controls which may be necessary  to  prevent mi-
 gration of  soluble  nitrate in  the  sludge water into  the groundwater.

 Natural Resources

      While the  proposed action will conserve a presently wasted re-
 source of significant potential  value, it will require use of  fuel
 for transport and application of sludge  to land and will necessi-
 tate  disturbance of the soil resource on  some 240  hectares [600
 acres] of the proposed drying basins and  stockpile areas.

     Organic Matter and Plant Nutrients —

     The single most important impact of the proposed action  is
the conservation of the soil-conditioning/fertilizing capability
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of sludge.  Within the framework of limitations  discussed  in Sec-
tion IV, sludge comprises a valuable resource whose magnitude  is
only now becoming apparent to the general  public.  Depending on
process train and application type, the total  nitrogen  value alone
of Denver sludge can range from $4 to $4.6 million per  year under
present prices and values.  Sludge contains phosphorus  in  abundant
quantities as well as minor amounts of all other essential ele-
ments.  It also has the ability to improve soil  conditions for
plant growth.  However, it lacks adequate  potassium.  It is ex-
pected that the money-equivalent value of  sludge will increase
snarply in future years as fossil fuels (primary sources of com-
mercial nitrogen fertilizers) become ever  more scarce and  other
shortages of natural resources become more apparent than at
present.

     Use of Fuel for Transport of Sludge—

     As discussed above under Energy Use,  the fuel required under
the proposed action is far less than that  used for present opera-
tions at the Lowry Bombing Range site.  Nevertheless, it is a  sig-
nificant commitment of resources.

     Soil —

     Disturbance of soil profiles at the sludge drying  basins  has
already been discussed in the early part of this Section,  under
Soil Loss, and need not be restated here.

Archaeology and History

     The proposed project should not have an adverse  impact  on
either the archaeologic or the historic characteristics of land
affected by the proposed project.  Land underlying  the  site  of
the anaerobic digesters has already been developed,  as  has the
land adjacent to the proposed pipeline route.  Furthermore,  there
was no surficial evidence at the proposed  drying basin  site  to
indicate underlying archaeologic sites (Reference 3),  and  no  his-
toric sites have been designated in that area (Reference 43).

     While all evidence indicates that the proposed  project_will
not jeopardize archaeologically or historically important  sites,
the remote possibility exists that heretofore unknown  sites  will
be discovered during construction activities connected  with  exca-
vation of areas for the installation of anaerobic digestors,  with
laying the pipeline and with construction  of the drying basins.
In the event of such a discovery, the Colorado State Antiquities
Law should be reviewed and its provisions  implemented.  Jhe  par-
ticular significance of this law in relation to the  National
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 Historic Preservation Act of 1966 and  the Archaeological and His-
 toric Preservation Act of 1974 should  be recognized  in making pro-
 vision for the possible discovery of archaeological  and historic
 resources.

 Land Use

      Land uses within the immediate boundaries of sites to be used
 for the installation of the anaerobic  digesters, pipeline route
 and drying basins will  change as  a result of  implementation of the
 proposed project.  These changes  will  be compatible  with surround-
 ing land use activities and will  not conflict with relevant land
 use plans or zoning regulations.

      Installation of anaerobic digesters at the Metro Denver Cen-
 tral  Plant facility will  cause an internal land use  change.  This
 change will  be compatible with the present use since plant opera-
 tion  will  not change and  use of the land  will continue to be for
 sewage processing.

      The proposed pipeline route, lying  beneath the roadway right-
 of-way areas,  will  not  precipitate adjacent land use changes.  Ex-
 cept  for other utility  and  municipal service lines which lie be-
 neath these  areas,  the  land  is  presently vacant; addition of the
 pipeline will  leave the status  of the  land unchanged.

      The agricultural area  to  accommodate the sludge drying and
 distribution  site will change  in use,   but this change will  be com-
 patible  with  surrounding  land uses since the project will  provide
 fertilizer for  agricultural  use.  Because of this function, the
 proposed  location of these  basins is consistent with Adams  County
 land  use plans  and  with County  zoning  regulations which seek to
 perpetuate both agricultural and agriculture-related land  uses
 (References 45,46).  A potential impact of benefit would result
 from  reduction  of pressure for  future  large-lot subdivision in
 the vicinity of the sludge drying and  distribution center.

      It  is not  likely that the  proposed storage and  distribution
 system will provide the stimulus for any significant land  use
changes  in the  surrounding area.  At this time it appears  that the
major cause of future land use changes  in the area will  be  the pro-
posed Adams County General Aviation Airport.   Sites  to  the  west of
the proposed sludge drying and distribution center are  being con-
sidered for the airport.  A "growth corridor"  running from  the pro-
posed airport northwest to Brighton is  likely.   The  drying  and dis-
tribution center might limit growth which would otherwise  extend
eastward from the proposed airport.  However,  in  general there ap-
pear to be no major negative land  use  impacts  associated with the
proposed drying and distribution center (Reference 44).
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Land Tenure

     Should the proposed project be implemented,  there  will  be
varying effects on land associated with the sludge  processing,
transfer and drying facilities.  In terms  of the  Metro  Denver Cen-
tral Plant, there will be no impact on land tenure  since  no  trans-
fer of ownership is anticipated.  Likewise, no tenure change is
anticipated for the roadway right-of-way areas for  the  pipeline
since an easement will probably be obtained.  However,  ownership
of the drying basin site will be transferred from private into
public ownership.

     No other impacts on land tenure will  be incurred by  the pro-
posed project.  The Lowry Bombing Range and landfill  site will re-
main in public ownership whether or not the project is  implemented.

Population

     The project will not have a significant impact on  the popula-
tion growth rate in Adams County or in the Metro Denver service
area as a whole.  It seems likely that the project  would  encourage
the continuation of agricultural activity and sparse population  in
the region surrounding the drying site.  This impact on population
distribution is predicated on two factors:  (1) The proposed proj-
ect would provide a conveniently located source of  fertilizer/soil
conditioner, to the benefit of farmers; and (2) the project may
inhibit residential development in the immediate vicinity of the
sludge drying site.

     The impact on population distribution is uncertain and will
probably be diffuse.  It would tend to maintain a sparsely popu-
lated rural area in its present state and thus aid  in limiting
sprawl radiating from the Denver area.

     The 18 new jobs generated by the drying/distribution center
will not significantly affect population growth or  distribution
in the area.  It is expected that the project will  have no signifi-
cant growth-inducing impacts.

Transportation and Circulation

     The proposed project could have a variety-of direct impacts
on transportation facilities which will serve the proposed drying
basin site.  Average daily traffic (ADT) will increase, roadways
will deteriorate, highways might become littered and dust will  be
generated as a consequence of sludge trucking.  No  impacts are ex-
pected on transportation facilities located in the  area surround-
ing the Metro Denver Plant or along the proposed pipeline route.
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      Average Dally Travel —

      Average daily travel  will  increase on roadways serving the
 proposed sludge drying  and distribution center as a result of
 trips made by facility  employees  traveling to and from work and
 trucks using various  roadways to  deliver dried sludge.  The ma-
 jority of this traffic  will  be  concentrated on such roadways as
 Irondale Road, Bromley  Lane  and Hacksmount Road, which will serve
 the drying and distribution  center.  The impact declines as road-
 way travel radiates toward destination points.  This increase in
 average daily travel  will  not adversely affect traffic flow since
 the roads in question are  infrequently traveled and have design
 capacities adequate to  carry the  additional traffic.

      Assuming an average daily  sludge production of 190 metric
 tons  [210 tons]  and a truck  capacity of 14 metric tons [15 tons],
 annual  truck traffic  will  total about 5,000 trips.  Assuming a de-
 livery period of four months (tv/o months during the spring and two
 months during the fall), five days per week, daily truck trips
 will  total  60 to 65.  Further assuming a delivery radius of 100 km
 [60 miles]  from  the sludge drying site, this number of truck trips
 distributed  over an area of  over 31,000 sq km [11,000 sq miles]
 will  not  cause a  significant impact on traffic.

      Highway  Bridge Capacity—

      A  potential  problem is  inherent in the fact that highway
 bridges  in  some  areas have posted capacity limits below 14 metric
 tons  [15  tons],  the assumed average truck load.  County Road 30,
 for example,  which  serves  the representative irrigated farm in
 Weld  County,  includes two  bridges, 30/25A and 30/258, the former
 with  a  posted  limit of 4.5 metric tons [five tons] and the latter
 with  a  capacity  of  seven metric tons [eight tons] (Reference 105).
 The routing of trucks will therefore require consideration of
 bridge  capacities  in order to avoid accidents and bridge damage.

      Traffic  Dust—

      Unpaved  sections of roadway,  on Weld  County Road 30, for ex-
ample, can lead  to  dust problems under conditions of heavy traffic.
Because many areas  in which deliveries will  occur are under the
jurisdiction of an air pollution control  district, Colorado's Fugi-
tive Dust Law will apply, requiring a dust abatement plan to be
filed prior to the  start of deliveries over unpaved roads (Refer-
ence 104).

     Dust generated by increased traffic  could annoy residents of
the area.  This problem would be minor,  however,  since most of the

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roadways are paved except for a six-km [four-mile]  segment  of
Hacksmount Road (Reference 103).

     Damage to Roadways—

     It is expected that deterioration of road conditions will
accelerate as a consequence of increased average daily  traffic
associated with the conveyance of three-axle trucks carrying
dried sludge loads estimated at 14 metric tons [15  tons]  (Refer-
ence 77).  Hacksmount Road, Bromely Lane and Irondale Road  have
design capacities adequate for such loads and presently are used
by agriculture-related trucks carrying similar loads.

     Sludge Spillage in Transit—

     Load spillage on these roadways is another potential problem
related to the distribution operation.  However, spillage_occur-
ring on roadways related to the Lowry Bombing Range facilities,
whose operation is similar to that of the proposed  delivery sys-
tem, has been minor, with only two sludge-carrying  trucks having
overturned during three years of operation (Reference 77).  There-
fore, it can be assumed that spillage and littering will  not be a
major problem in the operation of the proposed project.

Recreation

     Odors produced by operation of the proposed project  represent
the only potential impact of the project on recreational  areas  and
their users.  Impact would be limited to the vicinity of  the Metro
Denver Plant, which will house anaerobic digesters.  Should those
digesters fail, odors produced would radiate for a  distance of  1.5
to 3 km [one to two miles] from the Central Plant facilities.  Jhe
only recreational area located within that distance is  a  ten-mile
segment of the South Platte River area proposed for boating,  bi-
cycling and picnicking activities (Reference 106).   Although some
users would be affected by odors once the recreational  area had
been developed, the impact would not be a major one.

     The probability of anaerobic digester breakdown is small;  de-
sign features appear to be adequate, and operational precautions
will presumably be incorporated.  If a system failure does  occur,
the impact period will be limited to the time required  for  repair.
The potential impact of such a failure is considered minimal  be-
cause the Metro Denver facilities are located in an industrial  cor-
ridor.  Other odors generated in this area would tend to  mingle
with and hence lessen the perceptible intensity of  those  produced
by anaerobic digester failure.  There are no recreational  areas
within the odor range of the pipeline facilities or drying  basin
areas.
                             129

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 Governmental Agency Jurisdiction

      The proposed project has precipitated  a jurisdictional dispute
 between Adams County and Metro Denver.   The relative authority of
 these two bodies over the proposed  project  has  become the subject
 of litigation.  The proposed  project  would  remove  the Metro Denver
 sludge management operations  from the Lowry Bombing Range and
 therefore from the jurisdiction of  the  City and County of Denver.
 While the present working arrangement has been  satisfactory, the
 District has no written guarantee for its continuance.

      The project does not appear to be  in conflict with any acti-
 vities of planning agencies concerned,  with regard to jurisdiction
 in the study area.  However,  an important question remains as to
 which agency will  have the necessary  authority, responsibility,
 funding (for monitoring,  surveillance and enforcement of proper
 application  restrictions)  and administrative structure to regulate
 the proposed project.

 Employment

      A full-time staff of  18  people will be required for operation
 of the distribution  center facilities at full  development (1985).
 This  will not have a  significant  effect on  employment in the area.

 Land  Values

      If  the  proposed drying and distribution center is operated
 according to  accepted  sanitary  engineering principles, it is not
 expected  to  have a significant  ultimate effect on  surrounding land
 values  (References 66,52).

      Some impact,  over and above  the various physical  impacts de-
 scribed  elsewhere  in this  report, would probably be felt on the
 value  of  land  surrounding  the proposed project.   A psychological
 impact, which  would make people reluctant to live  near such a cen-
 ter,  would inhibit residential development around  the site.   This
 could  limit future increases  in property values  associated with
 such development.  On  the  other hand,  agricultural  activity might
 be intensified in  the  proximity of  the fertilizer storage and dis-
 tribution system, and  secondary development associated with such
 increased activity might also occur.  Each of  these events would
 be likely to raise property values.

     While it is difficult to generalize fro-n  other sludge recy-
cling operations, land values near other such  Drojects have  not
decreased and it is therefore considered unlikely that decreases
would occur  in the vicinity of this  operation  (Reference 103).
                              130

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Therefore, the net effect of the proposed project on the value of
property surrounding the site is likely to be minor.

Construction Impacts

     Transportation and Circulation--

     Transportation facilities associated with the Metro Denver
Central Plant facility, the proposed pipeline route and the dry-
ing basin site may be affected during the construction phase of
the proposed project.  However, these impacts will be of short-
term duration and in most cases insignificant.

     In order to construct anaerobic digesters, large equipment
will be moved in over roadways surrounding the Central Plant fa-
cility.  This activity may cause a disruption of normal traffic
flow patterns and may even necessitate traffic diversion.   How-
ever, such impacts will be of a temporary nature and will  be in-
significant since the transport of heavy equipment into the in-
dustrialized corridor surrounding the plant is a normal occur-
rence.

     Pipeline construction activities may be of longer duration than
those associated with the digester construction.  Traffic patterns
on adjacent travelways such as Irondale Road and Colorado State
Highway 2 could be affected.  Construction impacts associated with
Irondale Road should not be a problem since activity will  concen-
trate on right-of-way areas and should disrupt traffic on this
infrequently traveled rural roadway to only a minor extent.  Con-
struction activities adjacent to 104th Street may have a more se-
vere impact because this travelway accommodates large volumes of
daily traffic.  Impacts incurred, including delay periods and pos-
sible detours, will be temporary.

     Activities of 80 to 100 construction employees, deliveries,
inspections, etc. associated with construction at the drying ba-
sins will increase average daily traffic on servicing roadways by
360 (Reference 55).  These roadways have the capacity to accommo-
date the temporary increase.  Because current average daily traf-
fic on these travelways is low, temporary slowing of traffic over
tnem will not be significant.  Therefore, any impact incurred
will be negligible.

     iio other construction-related impacts on transportation or
circulation are anticipated as a result of the proposed project.
                             131

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      Flora and Fauna/Habitats—

      The temporary nature of the construction activities at the
 Centra] Plant, along the pipeline and at the drying/distribution
 site tends to minimize impacts upon flora, fauna and  wildlife
 habitats.  With successful quick revegetation and adequate plan-
 ning, construction impacts can be kept below significant thresh-
 olds.

      Soils—

      Soil profile along pipeline route will  be completely de-
 stroyed and replaced by a blending of underlying materials and
 the initial soil  layers.   The linear nature  of this  impact makes
 it of relatively  little concern, especially  since most  of it will
 take place along  the previously disturbed  soils of road easements,

      Utilities —

      In order  to  extend electricity and  telephone service to the
 drying  basin site,  easements  will  be obtained  along farmlands and
 roadway right-of-way areas  (Reference 72).   During construction
 activities,  farming operations  and even  travel  on adjacent road-
 ways may be disrupted.   However,  the impact  would be  of short du-
 ration  and  the area of  disruption  small  in scale.

      Air Quality--

      During construction  of the  drying and distribution facility
 and  the pipeline, dust  will be generated and pollutants  emitted
 by construction equipment.  However,  the effect  on ambient air
 quality will be insignificant.   While much dust  will  be  stirred
 up on the project site, this  impact  will be  temporary and  will be
 localized to a very sparsely  populated area.

      Employment—

      During construction  of the  pipeline and distribution center,
 80 to 100 people will be  employed.  These workers will  be re-
 cruited  from the local Denver area work force.

 Secondary Impacts

     Economy—

     The construction of a large public facility inevitably has
 impact on the local  economy as a result of both the construction
process and the subsequent operation of the facility.
                              132

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     Direct economic impacts, including employment and potential
 impacts on agricultural activity, are discussed elsewhere in this
 volume, both with regard to temporary construction employment and
 to  permanent employment.  With respect to the operation of the fa-
 cility, there appear to be virtually no significant secondary im-
 pacts other than those associated with agricultural activity.
 The small volume of permanent employment and the relatively small
 demand on community resources—when the facility is fully opera-
 tional—suggest that secondary impacts of the operation will be
 negligible or nonexistent.

     The same conclusion cannot be drawn with respect to secondary
 impacts of construction.  The total capital cost of the proposed
 facility is approximately $26 million.  The maximum construction
 employment will be approximately 130 persons.  In addition, a sub-
 stantial portion of the capital cost will be accounted for by
 items other than direct labor, with a fraction of this amount ex-
 pended for local materials and services.

     Two steps are used for estimating secondary impacts.  First,
 an  attempt is made to make preliminary allocation of capital costs
 among labor and materials and to provide an estimate of the allo-
 cation of the material costs between local and imported components.
 The  second step uses an employment multiplier dealing exclusively
 with construction employment to estimate the potential indirect
 employment that will be created.

     The estimates are based largely on experience with other,
 similarly capital-intensive projects in Devner and elsewhere,
 using the lower end of estimates to formulate possible minimum
 dollar impact on the local economy.  The results of the initial
 step are shown on Table 21.

     It is assumed that only half of the "materials, expenses,
 fees, etc." component will be spent in the Denver Standard Metro-
 politan Statistical Area.  This assumption is not as completely
 conservative as it may seem; while many of the materials and ser-
 vices may be purchased in the Denver metropolitan area, their
 original sources lie elsewhere, and the value added in distribu-
 tion within the local metropolitan area may be relatively small.

     Employment--

     The foregoing analysis suggests that approximately $5.2 mil-
 lion in total  payrolls may be generated locally by the project
 along with approximately S9.35 million in local expenditures for
material expenses, professional services, etc.
                             133

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        Table 21.  ESTIMATED CAPITAL COST AND APPROXIMATE
             ALLOCATION TO LAND,  LABOR AND MATERIALS
                                                       Amount,
 	Cost estimate and  allocation	1974 $

 Capital cost (.including digesters)                    26,000,000

   Less estimated land cost  (800 ha @                   1,000,000
     $l,250/ha)a                                     	

 Total  cost of improvements                            25,000,000

   (including contingencies,  process-
   ing  costs and engineering  and other
   professional  costs)

 Approximate allocation

   Direct labor  (20  percent)                            5,000,000
   Indirect labor (5 percent)                           1,250,000
   Materials,  expenses,  fees, etc. (75 percent)        18,750,000
     Spent in  Denver SMSABr         $9,375,000
     Imported:                      $9,375,000

 a[2,000 ac  @  $500/ac].

 Denver Standard Metropolitan Statistical Area.

     These  estimates of expenditures may in turn be subjected to
 further  analysis to develop estimates of indirect employment and
 economic  impacts on the local economy.   The purpose of this exer-
 cise is  to  determine the order of magnitude of such impacts.
 Quantification on any more precise basis would require disaggrega-
 tion of  capital cost, which is not now available.

     As  suggested above, gross payrolls associated with construc-
 tion of  the project are approximately $5.25 million.  It is a rea-
 sonable  inference that approximately 70 percent would be directly
 reflected in the local retail purchases.  This would amount to ap-
 proximately $3.7 million, an amount well under one percent of the
 retail  sales in Adams County.

     Based on an approximate up-date of the 1972 Census of Business
 estimates, the retail sales  per employee are approximately $52,000.
Thus, the introduced $3.7 million would create the annual  equiva-
 lent of approximately 70 additional  person-years of new employment.
                              134

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      The  nonlabor  expenditures  associated with the capital cost
 of the project would  be  spread  over a wide range of materials and
 services, probably concentrating  in the  building and construction
 materials and  transport  services  areas.  A tentative approxima-
 tion of sales  per  employee in these sectors suggests that they
 are perhaps  $60,000 to $70,000  per employee.  On that basis, the
 employment impact  of  these materials and other expenditures would
 be approximately 140  employees.

      On the  basis  of  preliminary  and rough analysis, it is possi-
 ble that  the aggregate impact of  construction of the project
 would be  210 person-years  of employment. Since the additional
 employment impact  will  spread over the  entire Metropolitan Denver
 area, the relative impacts will be fairly trivial, amounting to
 less than l/20th of one  percent of the  areawide employment.

      Other Secondary  Impacts--

      Infrastructure investments discussed above can have serious
 negative  secondary impacts on air quality, urban runoff, sensitive
 areas, etc.  from population growth induced or accomodated by the
 proposed  project.   The sludge processing and disposal project is
 necessary for  the  efficient operation of the overall Metro waste-
 water system.   Furthermore, the issue of secondary impacts will be
 analyzed  in  detail  in an  EIS on Metropolitan Denver Facilities Plans.
 Therefore, discussion of secondary  impacts are deferred to that EIS
 process.   It is apparent that control over population cirowth pat-
 terns can be more  directly effected through  the  individual waste-
 water facilities plans and N'PDES  permits.

      Impacts of Sludge Disposal at the
      Drying  and Distribution  Center--

      Because the disposal  portion of the operations at the processing
 site  involves  land  application  of sludge, the discussion of its im-
 pacts  is  presented  on  page  166  after the discussion of recycling im-
 pacts  and  prior to  disposal  impacts.

 Summary of Impacts  at  the  Sludge Drying
 and Distribution Center

     The most  serious  negative  environmental  impacts at the sludge
 drying and distribution center  are on soil  properties, groundwater
 quality and  the public health through nitrate pollution of ground-
 water  and  pathogen  problems.  Positive impacts are energy and re-
 source conservation.  The  impacts are schematically represented on
 Figure 16  in a  summary format to indicate the rough order of impor-
tance  EPA places on the various impacts  surrounding the drying/
processing operation.
                                135

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                                                                  FIGURE  16
                SUMMARY OF IMPACTS AT THE PROPOSED SLUDGE DRYING AND
                                DISTRIBUTION CENTER
                                 FOR METRO DENVER
          Impact parameter
    Direction and  potential
          intensity
         Soil loss

         Groundwater quality

         Surface water quality

         Water rights

         Public health—Pathogens

         Public health—Nitrates

         Public health—Vectors

         Loss of habitat

         Air quality (including odors)

         Energy use

         Natural resources

         Construction impacts  (overall)

         Secondary  impacts (economy/employment)
            o
            o
  Symbols  signify  relative impacts,  as  defined  below:
         Positive  (beneficial)  impacts:

         Negative  (adverse)  impacts:
    High   Moderate   Low

                       O
O      o
This  schematic representation of  impacts should only be interpreted within the
context of analyses of  impacts presented in the main body of the EIS.  It is
neither an attempt at quantifying the impacts nor reducing the diverse environ-
mental parameters to common bases for comparison.  However, it does provide a
rough ranking of the relative importance of the various impacts.  The scales
denoted by symbols used above are not intended to be compared with those  used
on Figures 17 and 18.
                                       136
ENGINEERING-SCIENCE, INC.

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 IMPACTS OF LAND APPLICATION OF SLUDGE ON THE RECYCLING AREAS

 General

     A large body of new data is being developed in various  parts
 of the country on impacts of sludge reuse in agricultural  and  re-
 lated activities under a wide variety of conditions.   A single
 salient conclusion of the collective evidence to date is that  the
 impacts are site specific.  Thus, statements made in the following
 paragraphs are necessarily applicable to the types of sites  which
 are described in Section III and Appendix E under Environmental
 Setting.  Even though a finite number of sites were investigated
 for the purpose of impact analysis, it is recognized that dried
 anaerobically digested sludge may be used for a rather large
 variety of applications.  It is expected that the city parks,  sod
 farms, mine spoil sites, irrigated and dry farms and home gardens
 will provide examples of the entire range of application site  pos-
 sibilities and provide the information necessary to evaluate the
 advisability of using the material on proposed sites.

     As an introduction to impacts of sludge application on  land
 recycling areas, a graphic representation of the severity of the
 various impact parameters on the representative types of applica-
 tion sites is presented in Figure 17.  All of the subjective impact
 levels assigned can be qualified depending upon prevailing condi-
 tions, management practices and other mitigating circumstances.
 These qualifications are presented below with particular emphasis
 on site specificity.  An overview of the major concerns and  advan-
 tages of each type of land application site is presented prior to
 the presentation of the impact parameters.

     City Parks —

     The application of sludge to city parks is potentially prob-
 lematic because of the high rate of public use of the parks for
 recreation.  Although sludge has been used as fertilizer on the
 parks in the past, publicity resulting from the large scale of the
 proposed project may engender some concern, if not opposition.
 Public involvement is important, and the Denver Department of  Parks
and Recreation should promote a program of public awareness to in-
form the public as fully as possible of the benefits and potential
 effects of sludge application.  Additionally, the use of sludge on
the City parks should be rigorously monitored to ensure the success
 of the program.  The viability of pathogens (especially Ascaris
 ova) is perhaps the most crucial issue and should be closely moni-
 tored.  The use of additional methods for pathogen reduction,  as
described in detail  in Section VI and Appendix D, would provide
additional protection to the public.
                              137

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                                                                  FIGURE  17
    SUMMARY COMPARISON OF RELATIVE IMPACTS3 OF SLUDGE RECYCLING ON VARIOUS
              LAND APPLICATION SITES IN THE VICINITY OF DENVER
                                     Sludge  application site
      Impact
     parameter
                Mine    Irri-             Home gardens
City     Sod    spoil   gated   Dry     Orna-   Edible
parks   farms   sites   farms   farms   mentals  plants
 Food chain

 Public health

 Water quality

 Soil productivity

 Soil salinity

 Soil heavy metals

 Air  quality

 Vegetation

 Wildlife

 Habitats

 Odor

 Noise

 Aesthetics

 Natural resources

 Traffic and
  circulation
o
©     •
ooQ
 •vsjpr     -^iagr-
O     O
o    o    o    o    o    o     o
                ()
 •        •      o                      •
o     O    O    O    O      o     o
 Symbols signify relative magnitude and direction of impacts,  as defined
 below:
                                          High   Moderate   Low   None
      Positive (beneficial) impacts:

      Negative (adverse) impacts:
                     O      o
This schematic representation of impacts should only be interpreted within
the context of analyses of impacts presented in the main body of the EIS.
It is neither an attempt at quantifying the impacts nor reducing the diverse
environmental parameters to common bases for comparison.  However, it does
provide a rough ranking of the relative importance of the various impacts
and a comparison of sites vis-a-vis each parameter.
                                    138
                          ENGINEERING-SCIENCE, INC-

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     Sod Farms--

     The sod farms of the Denver area represent a specialized type
of  irrigated farm.  While impacts are evaluated specifically for
one specific sod farm, many of the impacts may be extended to oper-
ations  in similar situations.  Generally, sod farms represent the
best type of land recycling sites for sludge from the environmental
viewpoint.  The applied sludge and its constituents are transported
away from the  sites and distributed thinly over a very wide area.

     Mine Spoil Sites--

     The proposed mine spoil sites for sludge application are
heavily disturbed unnatural areas.  The proposed action represents
an  initial step towards reclamation of these "waste areas" and,
thus, all impacts are evaluated in this perspective.  No food crops
are assumed to be grown on such spoil sites.  Public access and
exposure to the sites, especially during the reclamation period,
will be limited.  Thus, mine spoil sites are generally the least
problematic for sludge reuse purposes.

     Irrigated Farms--

     Irrigated farms represent the type of land application candi-
date sites which may become major users of the Metro sewage sludge.
Allowable annual application rates are fairly high, as shown in
Figures 14 and 15 in Section IV.  Consequently, the number of years
of  safe application is relatively short.  Thus, the opportunity  for
corrective action, if indicated, is more limited than in the non-
irrigated applications.  On the other hand,  irrigated farms are
generally more intensively and carefully managed because of the
higher value of crops grown on these farms.  In fact, many irrigated
farms have highly sophisticated irrigation equipment capable of
automatic control with sensors connected to tensiometers and other
devices determining plant-soil moisture status.

     The availability of a competent and well-equipped management
system tends to give better assurance of (a) proper control of
application rates, (b) careful monitoring of soil, crop and water
quality responses to applications of sludge to land and (c) accu-
rate recording and mapping of areas receiving measured quantities
of  sludges from the very first application until the limit is
reached, and beyond.

     Application of lime, supplemental phosphorus and potassium,
if  needed, and irrigation water are common practices on these
farms and can be readily adjusted to meet the additional require-
ments imposed by the sludge application.
                              139

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      Therefore, while irrigated farms will  be potentially  the most
 extensively and intensively affected by the sludge  reuse scheme,
 they are also the areas that offer the greatest  opportunity  for
 control and mitigation.

      Non-Irrigated Farms--

      Non-irrigated farms abound in Weld,  Adams and  Arapahoe  Coun-
 ties, surrounded by extensive areas of drylands  used  as non-culti-
 vated pasture.   These areas generally have  very  low fertility, as
 shown by production rates per unit surface  area,  reported  by the
 Colorado Department of Agriculture (Reference 95  and  shown on
 Table E3 in Appendix E).   The low fertility is in part due to con-
 tinuous cropping with little fertilization  or amendment.   It is
 expected that dry farms  will  also become  extensive  users of  the
 Denver sludge at low surface application  rates over large areas
 and  over a  much prolonged period  of time.

      Use of liquid sludge will  probably be  more  successful  on dry-
 lands and non-irrigated  farms with subsurface injection tools than
 use  of the  air-dried material.  This  is because the injectors can
 serve the double function of  soil  water conservation  through scar-
 ring the land surface while applying  sludge at a  safe depth  below
 the  soil  surface.

      In  general,  impacts  of sludge application on non-irrigated
 farms  and drylands will  be  far  less  intensive than the other agri-
 cultural reuse  candidate  sites  discussed  in this  volume.  Further-
 more,  the low application rates provide a safety mechanism and
 greater  opportunities  for corrective  action should unforeseen neg-
 ative  impacts become evident  in the future.

      Home Gardens--

     A  significant number of  gardeners, organic growers and others
 raising  crops on  relatively small  scales  have expressed interest
 in and enthusiasm  for  the use of  anaerobically digested dried
 sludge for  application to their soils  (see Appendix F).  Due to
 the  potentially  large  numbers and  wide separation of  sites  in this
 type of  use of  the sludge,  it could be very difficult for any
 jurisdiction to  provide the supervision, control  and monitoring
 that is  essential  to the success of (including prevention of
 environmental hazards from) sludge recycling on the land.   Further-
more, the potential  for direct human exposure to the material
would be great because automated and mechanical  application is  im-
 practical on small-scale operations.  Some home gardeners  would
use the sludge for amending soils supporting ornamental  plants;
others would use it on edible crops.  There are far fewer  potential
                               140

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 hazards associated with ornamental than edible (especially leafy
 vegetable) crops growing on soils amended with wastewater sludge.
 Regulating proper use of the sludge and maintaining public health
 protection in  home gardens would require a very determined public
 education effort including clear labelling, instructions, warnings,
 spot checks and, perhaps, provision of legal  constraints.

 Food Chain

     The impact of sludge application in irrigated farms  and  home
 gardens upon the food chain is largely dependent upon the types of
 food crops or  feeds grown for direct and eventual  human consump-
 tion.  Leafy parts of vegetables, beets, mint, vine, lettuce  and
 chard are examples of crops which accumulate cadmium in greater
 concentrations (sometimes up to ten times) than found in  the  soil.
 The animals eating such crops and ingesting sludge-amended soil
 will further accumulate cadmium in the kidneys, liver and some
 other organs and tissues.  Eating these tissues could give rise  to
 kidney diseases and hypertension in humans.  Some people  tend to
 consume these  less expensive tissues as a substantial part of their
 diets.  The irrigated crops grown in the area are mainly  wheat,
 corn, barley,  sorghum, beans, beets, oats, hay and potatoes.  None
 of these crops is usually consumed unprocessed and/or raw and none
 is known to be a particularly heavy accumulator of metal  elements
 in their usually edible parts.  On the other hand, leafy  vegetables
 grown in home  gardens such as Swiss chard, spinach and lettuce
 tend to magnify cadmium concentrations in their edible tissues.

     Cadmium is the most important element of concern in  the  Denver
 situation, while copper and zinc are far less important due to very
 low concentrations.  Mo standards have yet been established for  the
 limitation of  cadmium in foods.  The U.S. Food and Drug Administra-
 tion proposes  to establish such standards for cadmium in  the  near
 future.  Generally, as long as sludge cadmium content is  below one
 percent of the zinc concentration, and as long as recommended ap-
 plication rates are not exceeded, cadmium toxicity in the food
 chain will not be expected.  Recent analyses (Table D-4  in Appen-
 dix D) indicate that even though cadmium levels are far  below aver-
 age for municipal sludges, average cadmium in the Denver  sludge  is
 about 1.7 percent of the zinc content.  Although this is  a rather
 high percentage compared with the one percent limit stated above,
 existing mitigating circumstances are expected to adequately  com-
 pensate for this ratio.  The favorable circumstances are  (1)  highly
 calcareous conditions, particularly in the lower soil horizons on
most of the irrigated farms; (2) the conservative nature  of the
 ultimate sludge loading rate, given in earlier sections;  (3)  the
 relatively high phosphorus content of Denver sludge, which tends
 to help make both zinc and cadmium less available to plant species;
                              141

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 and (4) the poorly defined concept of "reversion,"  in  which  heavy
 metal  elements gradually become combined  into  stable,  unavailable
 compounds.  This latter process is most rapid  in  calcareous, alka-
 line soils such as encountered in most of the  study area.  Possible
 lowering of pH during the first few years after sludge application
 may lead to release and uptake of these elements.

      Another important consideration is the  possibility of reduc-
 tion of the quantities of heavy metals in the  wastewater system
 from industrial  and other sources in the  future years.  It is
 probable that significant reduction will  be  accomplished before
 the ultimate surface application limit is reached on most irri-
 gated  farms.

     The other elements of major concern  to  the food chain, in-
 cluding copper,  zinc, molybdenum, selenium and lead, are of suf-
 ficiently low concentration in the Denver sludge  so  that they are
 not expected  to  produce an adverse impact upon the  food chain.
 The favorable soil  conditions  discussed above also  protect against
 most other metals.   Most toxic metals  sharply reduce crop yields
 before  they become  high enough in concentration to  pose a food
 chain  hazard.  This  phenomenon constitutes a safety valve in the
 food chain.   Additionally,  organic  compounds in sludge  are able to
 chelate heavy metals, making them even  less  available.

     Crops grown  on  non-irrigated  farms are  primarily winter wheat
 and  barley with  lesser areas of  grain,  corn, sorghum, oats and
 spring  wheat.  From  the  point  of  view  of  preventing heavy metals
 accumulation  in the  food  chain, more suitable cropping  patterns
 would be  hard  to  accomplish.   The  parts of these plants which are
 used for  animal feed  and/or processed for  human consumption are not
 known to  be accumulators  of cadmium or any other heavy metals.  It
 is  not  expected that  cropping  patterns will change appreciably in
 the  future years; hence,  it is  expected that no significant food
 chain hazards  will exist with  sludge reuse on non-irrigated farms.

     Sludge application,  in excessive amounts on rangeland may re-
 sult in accumulation  of cadmium and other heavy metals  in the
 leafy parts of some weeds.  Domestic animals feeding on these
 rangelands will in time accumulate these elements  in their tissues
and pass them  along to  humans who eat the  meat  (especially liver
and kidneys) thus produced.  As long as recommended application
 rates are not  exceeded, excessive accumulations are not expected
to occur.  However, direct  ingestion of sludge-amended soils  by
livestock  (ten percent of whose diet is soil  particles) can sig-
nificantly increase heavy metal magnification along the food  chain.
The present operations at the Lowry Bombing Range  are most  conducive
to this sort of heavy metals assimilation  by grazing animals.
                               14;

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     The most effective and long-lasting solution to heavy metal
magnification problems in the food chain is removal--or reduction—
of discharges containing toxic elements from the sev/er system, as
mentioned above.  This can be achieved through an extensive program
of source identification, promulgation of standards, regulation
and  intensive enforcement of the discharge quality standards on
industrial dischargers.

Public Health

     Although no documented cases exist in the United States that
associate the use of digested sludge on land with human disease,
two major factors require that the possibility of such an occur-
rence be considered.  First, City parks are heavily utilized by
the  public who may come in contact with sludge in a number of
accidental and unforeseen ways.  Secondly, although sludge proces-
sing destroys a significant number of pathogens, some may survive
over long periods of time (see Table 20 on page 114).  The use of
sludge on City parks is practiced in many parts of the country
with no reported public health problems.

     Pathogens--

     The greatest areas of concern are home gardens where the pos-
sibility of direct human contact with pathogens on the soil, orna-
mental plants and edible crops is quite high.  The long survival
time observed for viruses and Ascaris ova makes it imperative that
(1) no food crops be raised on sludge-amended soil to be eaten
directly (unprocessed, raw) by humans, (2) long field re-entry
periods be established and strongly enforced on areas where sludge
is applied, (3) cases of disease contracted from sludge sources be
identified, documented and followed through and (4) a very rigor-
ous public health monitoring program be established as an integral
part of the reuse of sludge on food crops of all types.

     The pathogen problems associated with the dried sludge de-
livered to sludge recycling sites will be somewhat less intensive
than the material at the drying and distribution center because
of the natural die-off of the pathogens with time.  However, the
greater possibilities for human contact bring up additional pos-
sible public health impacts.  If sludge is used to fertilize crops
or home garden vegetables which will be eaten raw within the first
year of application, adverse health impacts will result.  If the
one-year wait is observed, no significant health impact is ex-
pected.  Recommended waiting periods of from one year (Reference
81) to three years (Reference 79) between sludge application and
growing of crops to be eaten raw have been suggested.  However,
Metro plans presently call for a one-year drying period in the

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 drying basins  only,  before  release of sludge to the consumer.

      The  EPA preliminary  proposed wait of three years before rais-
 ing crops to be  eaten  raw (Reference 79) is a cautious waiting
 period for a cool, dry region like the Metropolitan Denver area.
 Table 20  indicates that Ascaris ova are the limiting factor in
 setting a safe period  for pathogen die-off.  The EPA document is
 nation-wide in scope,  however, and the Ascaris problem is primarily
 of  concern in  moist  tropical regions, such as some southern states
 (Reference 111).

      Ascaris is  not  of  great enough importance in Colorado to be
 listed among the 22  diseases on the Colorado State communicable
 disease report;  the  disease ordinarily has mild--often almost un-
 noticeable--symptoms.   This disease has a very low incidence in
 the area,  and  the long  survival  time for the parasite's eggs,
 applies only under conditions favorable to the roundworm.  The
 arid,  cold  seasons common to this area do not provide this en-
 vironment.

     The  next  hardiest  pathogens are tubercle bacilli, which can
 survive only six months.  Continued application of sludge to park-
 lands  will  have no significant adverse health impacts.  The anaer-
 obically digested sludge will  have fewer pathogens than the ma-
 terial presently being applied to the parks.   If a two-year drying
 period is  instituted, it will  ensure that no  significant impacts
will result  from park application of sludge.   This safety margin
will be necessary because particles of sludge will probably be in-
gested by some picnickers, children playing in the dirt, etc.

     In view of the  differences  in pathogen viability and concentra-
tion in the  different types  of sludges (liquid,  air-dried and stock-
piled for various lengths of time), their respective uses should be
limited appropriately.   For  example:   (1)  liquid sludge should be
applied only by deep injection into the soil,  with no possibility
of surface exposure;  (2) as  the  level  of human contact becomes more
probable for each use (dry farms,  irrigated farms, home gardens,
vegetable  crops,  in increasing order),  required  length of storage
time in the drying  and  stockpile  areas  should  be increased.

     Nitrates--

     Potential  pollution of  groundwater will  not pose a significant
public health hazard.  The primary chemical  constituent of concern is
nitrate.   Nitrate levels over 45 ppm (measured as nitrate) in drink-
ing water are considered to  be harmful  to infants (Reference 112).
However,  as  indicated below  under Water Quality, groundwater contam-
ination under most  land recycling schemes would  be less than or the
same as from use  of commercial  fertilizers.
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     Health Services--

     A significant impact upon the public health department serv-
ices is foreseen as a result of the proposed project.   The  public
health department's monitoring activities will  need to be ex-
panded to cover all the land recycling areas receiving sludge.
This will increase the manpower requirements of the public  health
services.

Water Quality

     Two important water quality hazards posed by sludge amendment
of soils are the total dissolved salts (TDS) and the nitrate form
(NO^) of nitrogenous compounds found in the sludge and supernatant
liquid.  If the supernatant is excluded from the land  application
project, salt problems will largely be prevented.  The nitrate
pollution of groundwater and surface water remains as  long  as there
is a supply of nitrogenous compounds over and above the amount
which plants can take up and denitrifying bacteria in  the soil  can
denitrify.  Water pollution hazards posed at the six typical sites
studied are presented separately below, in order to emphasize the
specificity of impacts to sites and conditions as well as the
typical management practices employed.

     City Parks--

     Of the approximately 500 known wells within the City of Denver
in 1964 (Reference 21) fewer than 50 were used wholly or in part
for domestic purposes.  Most wells are used for irrigation, cooling
water, industrial and other purposes.

     It is expected that at the proposed annual sludge application
rates of 56 metric tons/ha [25 tons/ac] per year and with the
typical irrigation practices on park lands, significant quantities
of dissolved salts, including nitrates, will leach toward the
groundwater reservoir.  In about 20 to 100 years these salt-laden
seepage waters will arrive at the groundwater table and will
gradually increase TDS and nitrate concentration of waters  with-
drawn from the wells.  It is probable—though supportive data  are
lacking—that even under past and present commercial fertilizer
regimes, downward movement of nitrates have been and are proceed-
ing.   Therefore, earlier arrival of nitrates in the well waters
should be expected.

     If domestic uses of groundwaters (for drinking and culinary
purposes) are altogether prohibited or otherwise terminated, the
                              145

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 recommended limit of 45 mg/1  of nitrate  nitrogen may  be  permitted
 to be exceeded in the groundwater.   If,  on  the  other  hand, domes-
 tic uses of groundwater in parts of  the  Denver  area are  indispen-
 sable, sludge and fertilizer  application rates  should  be limited
 to levels recommended in Section IV.   Curtailment of  sludge ap-
 plication, particularly in those parts of the City and County of
 Denver and other cities using  groundwater for drinking purposes,
 is very important and necessary for  public  health protection.

      Pollution of surface waters,  such as streams and  lakes in
 the City, through leaching and/or  runoff is a distinct possibility.
 It can be minimized  through erosion  control and judicious choice
 of sludge application rates and methods  to  balance uptake of salts
 by plants.

      Sod Farms--

      It  is  expected  that with  adherence  to the  recommended sludge
 application  rates (in Section  IV)  negligible nitrate leaching to
 the  groundwater will  result.   Other  soluble salts, however, will
 gradually move downward  with the irrigation waters applied over
 and  above the  evapotranspiration needs of the grass.  The amount
 of these salts applied  with the  sludge is expected to be relatively
 moderate (about 350  kg/ha  [300  lb/ac]  per year) and significant
 only  from a  long-range cumulative point  of view.

      Surface water contaminations from portions of the sod farm
 that  are actively growing  grass will  be  insignificant, because of
 the  highly effective  cover  that sod provides against runoff and
 erosion.  The  soil in the  sod farm studied, Truckton sandy loam,
 is erodible unless it has  adequate cover.  Therefore, without some
 provision for  catchment  of  surface runoff, pollution of streams
may be expected from  portions of the sod farms which have just been
 harvested or which have  been left unplanted.

     Mine Spoil Sites—

     The  thickness of spoil materials heaped on top of the natural
ground surface ranges from  a few meters at the minimum to about
80 m [250 ft] at the top of the spoil banks.  Irrigation water and
rainfall can travel through these highly porous materials with
relative ease after the rocks  reach saturation moisture content.
It is expected that the more successful the reclamation of spoil
banks is, the less excess water will  be available to  leach through
the acidic spoil  materials and the less mine spoil  drainage will
take place.  Irrespective of pollutant constituents  of applied
sludge, mine spoil drainage is generally a severe contaminant of
surface waters.  Hence, use of sludge to  slow  down such drainage
                               146

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through entrapment and evapotranspiration of precipitation  will
help mitigate an existing major water quality hazard.

     At the modest application rates proposed, especially with the
use of wood chips (with high C:N ratio, helping immobilize  nitro-
gen from the sludge), it is expected that nitrate movement  below
the root zone will be minimal, if any.  Heavy metals will probably
remain within the developing soil and become immobile  and unavail-
able if pH is maintained above 7.

     Irrigated Farms--

     Irrigated farms generally possess some tail water  control
provisions and are designed to achieve high water application uni-
formities and efficiencies, resulting in minimal  wastage and con-
trol of excessive deep seepage.  With the use of sludge on  these
farms, these controls are even more important.  Otherwise,  (1)
excessive seepage will result in groundwater contamination  with
nitrates and soluble salts, and (2) runoff could lead  to direct
transport of sludge solids and soluble materials to the surface
water courses.

     It is difficult to quantify the precise impact of sludge
application on water quality.  The impact is not  only a function
of how well the recommended application rate limits are followed;
it is also determined by the manner in which other standard farm-
ing practices (irrigation, drainage, tillage, etc.) are performed.
It can therefore be surmised that the more sophisticated and  suc-
cessful a farming operation is, the less are the chances for
sludge application on that farm to pollute water resources. The
converse would hold true for poorly managed and operated farms.
Therefore, it is important that a judicious selection  procedure
be set up and the material not be given simply to whoever  asks
for it.  Binding agreements, permitting the District  representa-
tives to conduct monitoring and inspection services,  will  help
guarantee against large-scale contamination of the water  supplies.

     Home Gardens--

     If large numbers of homeowners and gardeners adopt sludge
amendment practices, water pollution hazards, orr a large  scale,
will be inevitable.  Ornamental plants and vegetables  are  typically
heavily irrigated and very often over-irrigated.  Therefore,  both
deep seepage into the groundwater reservoir and runoff toward  sur-
face streams occur on a regular basis.  Opportunities  for  improper-
ly high application rates and consequent degradation  of water  sup-
plies are thus abundant in this type of recycling of  the  sludge.
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 Soil Properties

      Once sludge enters the soil , its impacts upon the various
 components of the environment become indistinguishably interde-
 pendent.  Thus, while this discussion is divided into separate
 topics for clarity of presentation, the interdependence of the
 physical, chemical and biological  properties of the soil  and  crop
 responses, as well as animal  and  human reactions to eating the
 crops and animal tissues, should  be clearly recognized.

      Soil Productivity--

      It can be expected that  soil  productivity will  increase  with
 properly controlled and managed sludge application to any of  the
 proposed sites.   Many experiments  with sludge application to  soil
 have borne out this conclusion (References  121,  122 and 123 to
 cite a  few),  and some have shown  increased  productivity even  above
 that which could be expected  from equivalent chemical  fertilizer
 applications  (References 81 and 124).   The  short-term annual  in-
 creases in yield,  attributable to  annual  and residual  releases  of
 sludge  nitrogen, phosphorus and other essential  elements,  are by
 no  means the  only contributions to soil  productivity.   A  long-
 lasting impact of sludge application to soils is  the gradual  in-
 crease  in the organic matter  content of the soil  root  zone.   As
                  rn      M
              SOIL STRUCTURE IS ENHANCED BY SLUDGE


described below under Soil Structure, the increase in organic con-
tent leads to improved root penetration and other enhanced condi-
tions for plant growth, ultimately resulting in increased yield and
productivity.
                               143

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     If application procedures do not guard against uneven spread-
ing and variable incorporation of the sludge into the topsoil,  the
same types of problems as are associated with uneven fertilizer
application may be expected.  A typical  problem is non-uniform
soil fertility, resulting in uneven growth, maturation and yield.
The commercial equipment available, if properly operated  and main-
tained, can provide reasonably uniform spreading of the dry sludge.
Liquid sludge injectors which concentrate applications in a band
along the cutting "knife" will tend to produce a corrugated growth
and yield pattern during the first few years unless successive  in-
jections are performed in a criss-cross fashion.

     Liquid sludge usually has a higher nitrogen content  than dried
sludge and should be applied at correspondingly lower surface load-
ing rates.  Furthermore, liquid  sludge tends to inhibit  germina-
tion and to impose initial toxicity to young plants.  Damage can
be caused by excessive concentrations of ammonia, salts and organic
compounds or by creation of anaerobic conditions in the root zone
which reduce soil microorganisms and deplete oxygen in the soil.
The precise cause of initial organic toxicity has not yet been  es-
tablished.  At recommended application rates, this initial  toxicity
will be limited to the immediate areas of application for only
short periods of time.  If injection of liquid sludge is  limited
to periods far enough in advance of the growing season, the toxi-
city problem and related reduction,in productivity will be mini-
mized.

     Phosphorus content of Metropolitan Denver sludge averages
about three percent of the dry solids (Reference 5).  Within the
recommended range of sludge application rates on irrigated farms,
8 to 35 metric tons/ha [3 to 16 tons/ac], about 240 to 1,050 kg/ha
[180 to 960 Ib/ac] of phosphorus (as P) is applied to the soil.
These excessive amounts of phosphorus would be potentially toxic
to plants were it not for two important considerations.  First,
phosphates in the sludge are primarily in the precipitated form
and thus are not immediately available for plant uptake.   Second,
the calcareous nature of soils in the irrigated farms, for the
most part, provides a ready mechanism for formation of insoluble
calcium phosphate forms which release available phosphorus to
plants over a long period of time.  An important advantage of  the
high phosphorus content of the sludge is its reported ability  to
reduce the availability of zinc and nickel in the soil (Reference
124).

     An important aspect of increased fertility—particularly
nitrogen availability--is that continuous nitrogen availability
may make certain management practices more difficult.  For ex-
ample, in sugar beet culture, farmers have learned that by with-
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 holding nitrogen and water in the last  stages  of growth,  prior to
 harvest, they can increase sugar content  of  the crop.  With the
 use of sludge, this type of ready control  of available nitrogen
 may become difficult, if not impossible.   The  Great Western Sugar
 Company of Longmont, Colorado is presently conducting controlled
 experimentation with the use of sludge  on  sugar beet farms (Ref-
 erence 125).   Other effects of continuous  availability of nitro-
 gen, such as  plant lodging, delayed maturation, color development
 of certain fruits, etc.  generally do  not  apply to the types of
 crops  commonly grown in  the study area.

      Soil  Structure--

      The anaerobically digested  sewage  sludge  contains stable
 humus-like organic compounds which resist  decomposition, particu-
 larly  under irrigated farming conditions.  These molecules, when
 well  incorporated  into the soil ,  tend to bring about changes in
 soil  structure which have  long-term beneficial effects upon the
 physical  properties  of the soil.   The importance of organic mat-
 ter to  soil conditioning has long  been  recognized by farmers who
 have been  applying barnyard  manures, compost and other organic
 wastes  to  soils  since time immemorial.

     The  principal  change  occurring as  a consequence of organic
 matter  additions to  the  soil  is  the gradual  formation of a loose,
 friable  soil  structure,  contrasted with the massive structure of
 clayey  soils  and the  granular character of sandy soils.  Increased
 organic  content reduces  the  possibility of formation of shrinkage
 cracks  in  clay  soils  and gives a more cohesive character to sandy
 soils.   Epstein  (Reference  126) found a doubling of the percent of
 stable aggregates  in  a soil  amended with sludge over a period of
 175 days.  Organic matter  increases the water-holding capacity of
 the soil;  organic  soils can  retain more than their own weight of
 water against gravity drainage, while a sandy loam soil  may hold
 less than  ten percent water.  Thus, successive applications of
 sludge over the years slowly  builds up the water-holding capacity
of the soil so that irrigation intervals may be increased, un-
wanted leaching of excess water reduced and plant  growth and  yield
generally  increased.

     The improved soil structure enhances  root  penetration and
vigorous growth throughout the soil profile,  leading to generally
healthier, more vigorous  plant growth and  increased  crop produc-
tion.

     Soil Permeability--

     Movement  of water through the soil  is governed  principally
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by soil texture, structure, organic matter content,  and  the  degree
of aggregation of clay particles.  Application  of sludge to  soil
can change the latter three parameters drastically,  giving rise to
significant changes in permeability of the soil.  Epstein (Reference
126) reported an initial increase in permeability of a sludge-
amended soil followed by a return to initial  values.  Presumably,
the initial increase occurred due to improved soil  structure, and
the subsequent decline was caused by clogging of  pores.   Although
unsaturated hydraulic conductivities were not measured,  it is sur-
mised from increases in water content at all  soil-water  tension
ranges that these conductivities probably increase with  addition
of sludge to soil.  The increase in unsaturated conductivities
is important vis-a-vis water availability to plant roots because,
commonly, unsaturated conductivity is the limiting factor in
moisture transport within the root zone.

     Soil Erodibility—

     Formation of stable aggregates, discussed above, helps  increase
soil resistance to both wind and water erosion.  Additions of sludge
over a number of years gradually reduces soil erodibility and thus
provides a self-correcting mechanism against contamination of sur-
face waters in addition to conserving topsoil.  Many of  the  soils  in
irrigated areas are naturally moderately to highly erodible  in  the
absence of plant cover.  Over the years, sludge application  can
significantly reduce soil erodibility in these areas.

     Salt Accumulations—

     Liquid sludge from the Metro Denver Central  Plant  contains
about 6,000 mg/1 total salts, with only 180 mg/1  sodium  and  140 mg/1
chloride.  Salt accumulation in the topsoil can be regulated with
proper irrigation and drainage practices.  As long as the necessary
leaching fraction of the total irrigation water requirement  is  pro-
vided, there should be no excessive salt buildup.

     Given a total dissolved solids concentration in liquid  di-
gested sludge of about 6,000 mg/1, it can be calculated  that on
the average about 350 kg/ha [300 Ib/ac] of salts will eventually
move into the groundwater reservoir.  These salts will  be trans-
ported horizontally to downstream areas until the water  is pumped
out again for irrigation or other uses.  Thus, over a very long
period of years (perhaps centuries), it can be expected  that salt
buildup in the whole ecosystem will be  inevitable.  Therefore,  ir-
rigation water salt contents will increase gradually.  Even  though
specific areas of sludge reuse will presumably be returned to non-
sludge culture after the limit surface  application rates are reached,
the salt content of the whole region will inevitably rise over  the
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 long term, as new areas are brought  into  sludge  application cul-
 ture.

      Soil  Impacts on Specific  Sites —

      The general  effects of sludge application on  soils, presented
 above,  are applicable to nearly  all  types of sites, but are most
 representative of the irrigated  farms  and home gardens, whether
 ornamental or food crops are raised.   Specific variations from
 these  generalities can be expected at  other sites  due to the dif-
 fering  water  regimes and other management differences.  These var-
 iations are summarized for city  parks,  sod farms,  mine spoil sites
 and  non-irrigated farms.

     City  Parks—As  discussed  under  Environmental  Setting, most of
 the  City parks are constructed upon  fill material  from other areas,
 landfill covers,  construction  debris and  imported  topsoil.  There-
 fore, there is practically no  indigenous soil profile to be af-
 fected, directly  or  indirectly,  by the  sludge application and reuse
 scheme. The  pre-planting  use  of sludge and the  proposed annual
 additions  will  aid in the  formation  and improvement of supportive
 substrata  for City park  plantings.   Improvements in soil structure,
 water-holding capacity,  root penetration, erosion  resistance and
 permeability  will  occur,  in  similar  fashion to those discussed
 above.

     It is  expected  that much  higher total ultimate loadings of
 heavy metals  can  be  allowed  in City  parks "soils"  than in areas
 intended for  food  production.  Grasses and other plantings on park
 sites are  generally  more tolerant to higher concentrations of
 heavy metals  in the  soil.  Maintenance of high pH  through a regu-
 lar  liming  program along with  sludge application may be indicated
 through testing of soil  pH on  individual parks.  Use of sludge on
 City parks  subjected  to a  great  deal  of foot traffic and compac-
 tion can be particularly effective in improving soil aeration and
 water penetration.

     Sod Farms—The  unique harvesting operations at sod farms in-
 volve the removal  of  a thin layer of soil  (2 to 3 cm [0.8 to 1.2
 in.]) every year.   With this layer, most of the added organic
 matter  and  its constituents contributed by sludge are removed to
 their ultimate location of use.  Thus, most of the direct soil-
 building potential of the applied sludge is  transferred to the
 ultimate consumer of the sod.  Since the amounts of sludge in-
 volved   in one  cycle of sod production are relatively low, it is
 not expected that  the effect upon soil  structure, permeability,
and other physical characteristics  will be significant unless the
consumer also  applies sludge or other humic  matter to the lawns.
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The short-term impact on productivity is quite significant and  can
exceed that of equivalent quantities of commercial  fertilizers.
No significant salt buildup in the soil is expected.

     Mine Spoil Sites—Since at present there are no  soils on the
surface of the mine spoil sites, no soil impacts are  associated
with sludge application to these sites.  Natural soils  are buried
beneath a great thickness of mine spoil materials.  Considerations
for soil building and reclamation of the sites to permit  the nat-
ural succession of plant species are presented below  under Flora
and Fauna.

     Non-Irrigated Farms—The relatively low sludge application
rates recommended for non-irrigated farms and drylands  make the
soil impacts relatively minor.  The amount of organic matter con-
tributed by sludge will average less than 0.1 percent of  the plow
layer mass per year.  Furthermore, because of the dry conditions,
organic matter will be oxidized and destroyed more rapidly than
under irrigated conditions.  Hence, it is not expected  that any
perceptible improvement in soil physical conditions will  material-
ize as a result of sludge reuse.  Short-term soil fertility, how-
ever j will increase dramatically due to rapid availability of
adequate quantities of nitrogen and other essential nutrients.

     Use of liquid sludge usually gives rise to an initial toxicity
whose basic mechanisms are not yet well defined.  Special tools  for
placement of liquid sludge in separate bands below the  soil surface
have been developed and tested.  This type of liquid  sludge appli-
cation, while conserving the maximum nutrient potential of liquid
sludge, minimizes initial toxicity by permitting roots  to grow
around the sludge areas rather than be confined thereby,  and therein.
It is expected that future experimentation at the drying  and dis-
tribution center will increase knowledge of soil fertility/toxi-
city tradeoffs of the various application tools.

     Heavy metals accumulation in soil will proceed at  a  rate  far
lower than that of irrigated farms.  These metals will  have ade-
quate opportunity to "revert" to unavailable forms in the cal-
careous soils typical of non-irrigated farmlands.  It is  expected
that long before critical limits of these metals (defined in
Section IV) are reached, industrial effluent exclusion  or reduc-
tion schemes will have been instituted and implemented  in the
Denver area, permitting almost unlimited periods'of sludge reuse.

     Salt accumulation in the topsoil may become a problem after
many decades of sludge application.  Although annual  salt accrual
rates are much lower than in irrigated farms (less than 20 kg/ha
[20 lb/ac]), lack of irrigation water, paucity of rainfall and
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 the predominance of evapotranspiration rates all  help keep  salts
 in the root zone of the soil.  It would take about  200 years,  at
 the recommended sludge application rates,  for soil  salt  content
 to reach levels which would reduce crop yields significantly.
 Thus, it appears that, instead of heavy metals,  soluble  salts  im-
 pose the upper limit on ultimate surface application rates  of
 sludge in non-irrigated farms and other drylands.

 Air Quality

      If dried sludge is left on the  surface  and  subjected to blow-
 ing in the wind,  hazardous  air pollution conditions  could occur.
 Lead content of sludge is the most important constituent in the
 airborne assimilation of sludge particles  by humans, conceivably
 causing cumulative toxicity to frequent passersby.   Other heavy
 metals in sludge, as well as any surviving microorganisms,  in-
 cluding spores and egge of  parasites,  could  also  be  transmitted
 by aerosols.   It  is expected that proper application timing, sup-
 plemental  sprinkling, and mechanical  incorporation of sludge into
 the soil  will  effectively eliminate  the air  pollution potential
 of sludge reuse.

      Odors--

     Air-dried digested  sludge,  taken  from the stockpiles,  is ex-
 pected  to  be  nearly odorless.   When  broadcast at the  recommended
 surface  application rates and  incorporated into the  soil, it is
 not expected  that  odor  from  the  sludge  will  be detected at the
 boundaries of  the  application  sites  except by those  most sensitive.

     Liquid sludge,  if  applied  with  subsurface injectors (equip-
 ment is manufactured  by  at least  two companies in the Denver area),
 will have  no  noticeable  odor  even  at close proximity  to the ap-
 plication  equipment.  Spraying  of  the  liquid sludge on the surface
 with special  spreaders  behind tank trucks will produce temporary
 odors at close  proximity to the application  areas.  The higher the
 application rate and  the longer the  sludge remains on the surface
 before incorporation, the worse the  odors produced will be.   On
 the whole, however, anaerobically digested sludge is stable enough
 so that the odors  produced are  not very  strong or offensive.

     The city  parks and home gardens would be potentially the most
 odor-sensitive application sites.  However, the fact that sludge
 has been applied to the parks for years with no significant  com-
 plaints is a good  indication that continuation with digested sludge
will have no significant odor impacts.

     There may be some odors the first day or so after a large
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amount of sludge is spread on parkland.  This smell, which most
do not find particularly offensive, may carry for about a block.
The past practice of applying the sludge during low-activity per-
iods in the park reduces the airing-out period.  Similarly, ap-
plying the major portions in the winter when people tend to be in-
doors has effectively limited the number of complaints.

     If  any publicity is given this application practice, past
experience has shown that there will be a temporary increase in
odor complaints following the publicity.  Lately, sludge use has
become more commonly accepted as a positive conservation-minded
practice.

     It is expected that odor produced by sludge application to
such other sites as sod farms, mine spoil sites and other farms
will be of minor significance due to the relative isolation of
such sites and the presence of other normally associated odors
(e.g. manure on farms).

     Air Quality Impacts on Specific Sites--

     Each site offers special opportunities and limitations insofar
as air quality impacts are concerned.

     City Parks — It is expected that quick incorporation of sludge
into the seed bed, at the initial stages of park establishment,
and into the turf during the annual winter applications will mini-
mize air pollution hazards from this source.  The high accessibility
of these parks to human beings and the proximity of residences
make the potential impact on air quality quite  significant.  Dried
sludge, blowing from the trucks as it is hauled to the City parks,
could, if not controlled, have highly undesirable air quality im-
pacts.

     Sod Farms—Small quantities of particulate material may be
released to the air during and immediately after application of
the dreid sludge material.  These effects may be heightened in the
presence of strong winds, especially during seed bed preparation
in the spring.  The frequent irrigation associated with sod farm-
ing would reduce the effect of dust blowing to  insignificant levels.
The remoteness of sod farms further mitigates air quality impacts.

     Mine Spoil Sites—The proposed reclamation of mine spoil areas
is typically relatively short term.  Small quantities of dust may
be released to the air during and immediately after the laying of
fine rock material and composted sludge.  This  effect may be in-
creased if winds are strong.  However, subsequent operation of an
irrigation system and growth of plants will mitigate this effect.
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 The quantities of dust thus generated would only be a  short-term
 contribution to the air quality of the mine operations and  would
 be relatively insignificant, especially in view of the remoteness
 of these sites from human exposure.

      Irrigated Farms—Sludge application on irrigated  farms is  not
 expected to give rise to deterioration of air  quality  if  soil  in-
 corporation of sludge and proper mixing are achieved immediately
 upon application.   A significant threat from improper  application
 procedures, i.e. leaving dried  sludge on the land  surface,  especial-
 ly in windy conditions, can arise with the dispersal of particulate
 matter on and beyond the farms.   Immediate mechanical  incorporation
 of sludge into the soil, followed by  irrigation  (or a  fortuitous
 rainfall),  can control  or minimize air pollution from  this  source.

      Non-Irrigated Farms--The threat  of particulate dispersal from
 non-irrigated farms  and other drylands treated with dry sludge  is
 rather severe.   No matter how well dry sludge  is incorporated with
 the  soil, the dry  nature of these lands  will permit dust  blowing
 during severe winds.

      Application of  liquid  sludge, on  the  other  hand,  with  deep in-
 jectors,  will  alleviate this problem  altogether.   This  is particu-
 larly important  as dryland  farms  generally have  soils  whose deeper
 strata  are  highly  calcareous and  can  rapidly make  heavy metals un-
 available.  The  binding  effect of  sludge on  soil particles  pro-
 motes  aggregate  formation and reduces  the  potential for the soil
 to become easily airborne  in moderate  winds.

 Flora  and Fauna

      Impacts  of  sludge application to  land on vegetation and wild-
 life  is so  highly  site-specific that no  attempt  is made here to
 make any  generalizations.  At the risk of  a few repetitions, im-
 pacts  are qualitatively  described for  each site under a separate
 subheading.   Impacts on vegetation are further discussed in more
 detail  in Appendix D.

     City Parks and Home Gardens--

     Vegetation—Application of sludge to vegetation in the City
 parks and  home gardens should have beneficial  impacts  by stimu-
 lating plant growth.  Sludge contains  all of the elements that are
 essential  for plant growth, and with  proper application will serve
as an effective fertilizer.

     Any adverse impacts resulting from sludge application would
be caused by excessive rates of application.  Grasses are tolerant
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of  heavy metals and have a high rate of nitrogen uptake.   The per-
iodic mowing of grass will remove appreciable quantities  of salts
and nutrients that have accumulated in the plant tissue.   The salts
thus removed will probably be deposited in contained sanitary land-
fills.

     Grasses are effective in the control  of erosion and  runoff.
Surface runoff from the land would be minimized with a vigorous
cover of grass.

     l-Jildl ife--Broad scale sludge applications would probably occur
in the late fall and winter during periods of minimal  park usage.
Sludge application, even on snow-covered areas, followed  by further
snowfall, minimizes the direct contact time for wildlife  and humans.
Overall bird populations are lower during the fall and winter, with
the exception of wintering species and semi-domesticated  species
such as rock doves.

     Sludge incorporation into the soil would probably have simi-
lar effects on burrowing and ground-dwelling rodents, as  discussed
further below under wildlife impacts at the Lowry Bombing Range.
The effects may be less pronounced due to the controlled  sludge
application rates and rodent control programs.

     Seed bed preparation with sludge supplement occurs generally
in the spring and late fall.  Bird species which forage on the
ground — such as robins and towhees--and feed upon terrestrial in-
sects and seeds are exposed to the sludge mixture the most.  These
birds may be exposed to a slight concentration of sludge components
along the food chain.  However, these birds are not confined to
the City parks area and range throughout the urban areas.  Ani-
mals, including dogs, may be exposed to pathogens and parasites
by direct exposure and ingestion.

     Sod Farms--

     Vegetation--The use of sludge as a fertilizer and soil condi-
tioner on sod farms will have beneficial impacts on sod production.
Sludge contains all the essential plant nutrients, and in some cases
sludge has been shown to generate higher crop yields than commercial
fertilizer.  Grass is a good crop for sludge fertilization because
it is tolerant of heavy metals, is not used as feed or food, has
a high rate of nitrogen uptake and minimizes problems from runoff
and erosion.

     VJildl ife--Due to the intensive management of a sod farm, di-
rect effects of sludge application upon wildlife would be few and
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 probably limited to spring and fall  during  times  of  seedbed prep-
 aration.  Bird species which forage  on  the  ground—such as meadow-
 larks and sparrows—feeding upon terrestrial  insects  and grass
 seeds, are exposed greatly to the sludge mixture.  Heavy metals
 and other sludge constituents accumulated by  insects  may be further
 concentrated by bird predation.   On  a well-maintained sod farm,
 however, thick sod growth effectively minimizes uptake of sludge
 constituents by insects.   The monoculture of  selected short grass
 species also represents an unbalanced ecosystem with  only a few
 insect and bird species.   Small  rodent  problems on a  sod farm are
 also minimal  due to the poor burrowing  quality of a thick, fibrous
 turf and constant disturbance and  "grazing  pressure"  of mowing
 equipment.   Thus, incorporation  of sludge constituents by small
 rodents would not be a problem on  this  type of site.

      Mine Spoil  Sites--

      Vegetation—The land  application of stabilized sludge mixed
 with wood chips to mine spoil  sites  will have very beneficial im-
 pacts on vegetation.   Since mine spoil  sites are typically devoid
 of  a substrate capable of  supporting plant  growth, the land appli-
 cation of composted sludge would essentially be a soil building
 process.

      Climax Molybdenum proposes  to transport a total  of 90 metric
 tons/ha  [40 tons/ac]  of sludge mixed with wood chips  (in a 1:1
 ratio)  to the mine spoil sites.  Assuming that this material has
 a density of  400  kg/cu  m [25  Ibs/cu ft], the total amount of com-
 posted  sludge to  be applied will have a depth of 2.3  cm [0.9 in.]
 before  incorporation.   Proper  substrate building procedures for
 vegetation establishment should  include:  (1) application of
 smaller  rocks  above larger  rocks;  (2) application of  well-graded
 materials such  as  finely crushed rock and sand to a depth of 25 to
 30  cm  [10 to  12  in.];  (3)  application of the sludge-wood chip mix-
 ture  and  (4)  incorporation  into  the top 15 cm [6 in.] of the finer
material.  In  this  way, the top  layer of "soil" will   contain ap-
 proximately 13  percent  organic matter after total  composted sludge
 application.  This  is  a high percentage of organic material  and
 should provide a good  substrate for plant growth.

     The establishment  of a ground cover would probably follow the
basic pattern of plant  succession.  Hardy pioneer species  would
first become established and would slowly build up the depth of
the soil profile over time through decomposition of dead material,
thus permitting the growth and establishment of a more diverse
plant community.

     Plant succession  is generally an extremely slow process.   The
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rate of succession would depend on such factors as  the amount  of
sludge and other materials applied and the types of plant  species
that are initially planted.  Grasses are relatively easily estab-
lished, but they do not provide large amounts of organic material
to be decomposed.  Some native shrubs such as bear  berry and buf-
falo berry, which are presently growing on the Urad Mine spoil
site, might be planted with some success.   These would provide
more substantial amounts of detritus in the form of leaf litter
than would grasses, although their rates of growth  might be in-
hibited at first by the penetration of the roots deeper into the
soil profile.  Trees might also be planted, although the penetra-
tion of their roots through the top layer into the  coarse  and
acidic spoils might limit their growth potential for many  years.

     Because the total amount of sludge to be applied is relatively
low, the uptake of hazardous heavy metals, such as  cadmium, zinc,
copper and nickel, should not present problems to plant growth.
Plant growth might be inhibited, however, by the uptake of heavy
metals present in the underlying spoil material, although  this
situation should be alleviated over time as the soil profile in-
creases in depth.

     The establishment of a complete groundcover of vegetation is
highly desirable since it can result in (1) earlier soil stabili-
zation and reduction of erosion; (2) earlier mitigation of acid
drainage in surface runoff through increased water  holding capa-
city and through increased water use by evapotranspiration; (3)
acceleration of the accumulation of organic residues which will
chelate or otherwise make unavailable the soluble iron, manganese
and aluminum.  Organic residues also provide the necessary seed-
bed for plant germination.

     Wildlife—Mine spoils areas are typically rocky, barren and
devoid of normal signs of life.  Application of sludge with in-
corporated wood residues would be an initial step towards  the  re-
clamation of these wastelands.  The successful establishment of
vegetation over a period of time would help to restore some of
the habitat that had been destroyed by mining activities.

     Wildlife habitat would be minimal due to the severity of  the
terrain and presence of limited types of vegetation.  However, the
distinct transition from forested slopes to a broad open  swale with
grass and shrub vegetation would provide an "edge"  habitat favor-
able to wildlife.  Animals feeding upon vegetation  in the  re-
claimed mine spoils area are subject to accumulations of trace
elements as discussed under Food Chain, above.

     Limited sludge applications for only two years at relatively

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 low rates greatly reduce the potential  for hazard.   Within  3  to  5
 years, a permanent ground cover could be established.   Although
 this habitat will not be very diverse,  the variation it provides
 in the heavily-forested woods and Clear Creek Canyon is an  impor-
 tant ecological consideration.  With the decay of  the  mine  spoils
 and long-term formation and maturation  of soils on  the site,  larger
 and more sensitive vegetation forms may become established.   Thus,
 in the long term, partial or full reclamation of the mine spoil
 sites would provide new wildlife habitats and an overall benefit
 to wildl ife.

      Irrigated Farms--

      Vegetation--Areas of irrigated farmland  that are  subject to
 the application of sludge are necessarily under cultivation and
 contain no  native vegetation.   In general,  sludge will  have bene-
 ficial  effects on plant growth by supplying all  of  the essential
 plant  nutrients.    The accumulation of  hazardous heavy metals in
 plants  reduces the yield significantly  before these metals  become
 a  danger  to the food  chain if the cadmium/zinc  ratio is  less  than
 one percent.   In  the  Denver sludge, this  percentage is  about  1.7
 and poses a potential  hazard.

     Selection of crops suitable for growth on  sludge-enriched
 soils  should  be made  in consultation with the local  extension
 service of  the U.S. Department of Agriculture.   Plants  vary widely
 in their reactions  to  sludge  application, and these reactions are
 site-dependent.   Crops  that are grown for their  seeds  or fruit
 rather  than for their  vegetative tissue  and crops whose younger
 rather  than older  vegetative  tissue is utilized  are more desirable
 in terms of trace  element accumulation.

     Wildlife--Insect  populations  and scavenging wildlife will con-
 stitute a problem  on  sludge-amended  farms, depending on the type
 of crop grown.  Large  stands of monoculture represent  a greatly
 simplified  ecosystem with  a preponderance of  only a  few insect and
 animal  species.

     Plants differ widely  in accumulation of  heavy metals and other
materials.  Zinc and copper in  very  small amounts are micronutrients
 beneficial to the animal  and human diet  (Reference  127).  Evalua-
tion of potential effects of sludge on wildlife and on domestic
animals requires  individual analyses of farms and of crop types
and their ability to accumulate  trace elements.  The greatest con-
cern is for grazing animals who  will consume  forage crops such as
hay and alfalfa grown on  sludge-aided soils.  Copper would  be a
special hazard to grazing animals  if sludge of high copper  content
were sprayed on established pastures (Reference 128).  Leaf surface
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copper is rapidly washed off with rain  or  irrigation water  but re-
mains a hazard until removed.  "Dietary copper  and molybdenum in-
teract in the ruminant.  When the molybdenum  content of forage is
known to be low, expected increases in  copper content of  some for-
ages could be hazardous to sheep, while in forages of normal molyb-
denum content copper can be considerably higher"  (Reference 128).

     Insects and small mammals dwelling in or feeding upon  ir-
rigated croplands are also subject to accumulations of trace ele-
ments and other materials.  Foliage-eating insects and burrowing
rodents such as gophers are particularly susceptible.  These
secondary consumers in turn support upper levels  of the food
pyramid.

     Non-Irrigated Farms--

     Vegetation--The impacts to vegetation on dryland farms are
the same as those discussed under Irrigated Farms.  Agricultural
effects of sludge application are discussed in  detail  in  Appendix
D.  In general, dryland farms will sustain a lower rate of  sludge
application than irrigated farms because the rate of  nitrogen up-
take of dryland crops is much lower than that of irrigated  crops.
Seed germination can be inhibited if planting operations  are con-
ducted too soon after liquid sludge application.   If  planting
is done from two weeks to one month after low-rate  sludge applica-
tion, seed germination is uninhibited.

     VJild1ife--Sludge application would occur in the  spring or fall
during seedbed preparation.  Application rates  are  generally much
lower than on irrigated farms or sod farms.  Sludge  constituents
are less likely to accumulate in the wheat and  barley crops typ-
ically grown in dryland farming.  Thus, the  hazards  of high con-
centrations of trace elements are less significant.   The  minimum
supervision and low maintenance required for a dryland farm allow
the fields to remain relatively undisturbed  for long  periods  of
the year; thus, dry fields are easily  incorporated  into the eco-
system and are suitable for wildlife habitat.  Mice,  gophers  and
jackrabbits particularly utilize this  environment and will  be
constantly in contact with the sludge-treated ground.  Acute  ef-
fects of grazing upon the vegetation are discussed  above under
irrigated farm impacts.  The low application rates  and low uptake
of trace elements generally do not constitute a great hazard  to
wildlife on a dry farm.

     Grazing animals and wildlife may  be exposed to  pathogens  and
parasites by direct exposure and ingestion.  Pathogen survival  is
greatly reduced by  stabilization;  however, some parasite ova  such
as Ascaris may remain viable for many years  in the  soil.
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 Noise

      Noise generated by sludge application (broadcasting,  injec-
 tion or spreading) equipment is expected  to be  similar  to  that
 produced by similar farm and landscaping  equipment,  such as  trac-
 tors, trucks and manure spreaders.   Therefore,  no  particular noise
 impact is anticipated.   Some reduction in noise may  be  expected
 to the extent that sludge application  replaces  fertilizer  and/or
 manure application on these operations.

      In city parks, equipment and  heavy machinery  for applying the
 sludge would generate noise levels  that may be  incompatible  with
 residential  areas.  This noise generation is  unavoidable,  but is
 generally limited to short durations a few times per year.   The
 sludge application process is only  a fraction of the parks main-
 tenance program and, to some degree, is acceptable in consideration
 of the benefits to vegetation and overall  maintenance of the City
 parks system.   Use of mufflers on such equipment can inexpensively
 mitigate this  minor problem.

      In sod  farms, irrigated  farms  and dryland  farms, continual
 operation of farm equipment and  the  attendant machine noises during
 the growing  season are  an  integral  part of  the  farming  operations.
 Some additional  noise will  be introduced  by sludge transport trucks
 delivering the  sludge to remote  plains areas.   In  perspective,
 sludge  transport  and  application would only be  a small  fraction
 of farm operations.   The local climatological conditions and open-
 ness of the  plains help to  disperse  sound  well.  In addition, the
 low population  density  and  isolation from  other noise sources
 make contributions from this  part of the  project insignificant.

      In mine spoil  sites,  noise generated  from  sludge transport
 and application operations  would by  typically on a one-time basis.
 The narrow valleys,  steep grades and heavily  forested slopes tend
 to confine noises  within the  local area.  Noise generated during
 sludge  application  and  area seeding and planting would  be greatly
masked  by the noise from ore  processing machinery  at the molyb-
 denum mine.  Therefore,  noise  contributions from sludge transport
 and mine  spoil reclamation would be relatively  insignificant.

      In home gardens, sludge application would probably be per-
formed with small  hand-operated equipment.  Noise from  such
machines as rototillers might disturb neighbors for short periods
of time.

Aesthetics

     Since people generally accept the  fact that fertilizer must be
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applied to the lawns and gardens of the parks, and since the dried
sludge does not have a particularly offensive appearance, no sig-
nificantly adverse visual impacts are expected from the continued
application of the material to the parks.  As an added precaution
to avoid offending anyone's aesthetic sensibilities, the Park De-
partment attempts to apply the material during seasons and times
of the week when park use is low.  Applying the black material  to
snow-covered lawns in winter would make it highly visible until
the next snow.

     Application of sludge to mine tailings has a beneficial
aesthetic impact since it prepares the barren spoil  areas for
the grass and tree plantings, examples of which are now success-
fully in progress.

     It is expected that the inert appearance and the nearly odor-
less characteristics of the dried sludge will help overcome the
psychological image associated with the fecal origin of the mate-
rial.  Positive experience with sludge over a period of several
years might reduce the negative aesthetic impact.
Natural Resources

     The resource value of sludge
is discussed at length above, un-
der the drying/distribution site
impact analysis.

     Intensive farm operations
(such as sod production and
other irrigated agriculture)
can deplete natural resources
over large areas.  The rapidly
growing plants extract large
quantities of nitrogen and
other elements from the soil.
In addition, thin layers of
soil material are removed from
the sod farms during harvest-
ing.  Without soil supplements
or some form of compensation,
a sod farm could deplete the
soil resource in a relatively
short time.  Sludge applications
would serve not only as a
fertilizer but also as a soil
        •
-    .
  DRIED SLUDGE
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 conditioner.  Dried sludge is high in nitrates and contains other
 macronutrients and trace elements required for plant growth.  Per-
 iodic cropping and annual harvesting can remove some accumulations
 of trace organic materials.  However, the long term accumulation
 of salts and trace elements may preclude sludge applications after
 a finite period of time, as discussed in Section IV.  Therefore,
 with controlled applications over a long period, sludge reuse on
 farms can help maintain the soil resource.


      Mine spoil  areas  are generally highly disturbed areas  with
 effectively few resources.   The  application of sludge to these
 waste areas is  the initial  step  towards  reclamation  of the  areas.
 Establishment of ground cover  will  eventually  lead to the buildup
 of a  stable ecosystem.   While  the  reclaimed areas may never be
 able  to  duplicate the  original ecosystem,  they would constitute
 a  vast  habitat  improvement  for wildlife  resources and the natural
 system.   Thus,  the proposed  action  would  accrue  an overall  benefit
 by partial  restoration  of natural  resources.

 Traffic  and  Circulation

      Most of the  sludge application sites  will  not be significantly
 affected  insofar  as  traffic and  circulation  patterns  are concerned.
 For example, if  the  City and County of Denver  Park Department
 ultimately utilizes  4,500 metric tons [5,000 short tons] of  dried
 sludge as anticipated,  average daily trips  will  increase annually
 by 200 (References 40,  77).  Since travelways  such as  Irondale
 Road  and  connecting major highways near the Denver urban core are
 adequate  in  design to accommodate this minimal  increase, no  sig-
 nificant  impact on transportation and circulation patterns  will
 ensue should the  proposed project be implemented.

 Agricultural Economy

     The agricultural economy in the area will be aided by  the pro-
 posed project, since it  will provide a local source  of fertilizer/
 soil conditioner, a resource in  increasingly short supply.   The
 nutrient benefit value of the design production capacity of  97
metric tons/day [107 tons/day] of dried sludge solids  is worth at
 least one million dollars per year at present prices.

     The productivity increases resulting from sludge application
will  undoubtedly vary among the  individual farms using the  material.
However,  field  tests by Metro Denver have verified the general in-
creased productivity results achieved elsewhere with agricultural
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 use of sludge.   For  example,  in well-managed sludge application
 programs there  have  been  2- to 4-fold increases in forage pro-
 duction, 2.5-fold  increases in wheat production, and 20 percent
 higher corn  yields  than were  achieved by commercial fertilizer
 (Reference 81).  Mismanagement of the sludge application on farms
 could  have adverse  economic impacts.  Application rates in excess
 of those recommended by the soil scientists and agronomists could
 limit  productivity  due to high nitrate or heavy metal levels.

     A small  benefit to the farmers in this somewhat arid region
 is the fact  that the "dried"  sludge will be about 50 percent water.
 Assuming design  capacity  production at 97 metric tons/day [107 dry
 tons/day] of dry matter in the sludge, there would be about 36,000
 cu m [30 ac-ft]  per  year  water in the sludge.  This is a relatively
 small  amount of  water and will be distributed very thinly over a
 relatively large area.

 Land Values

     The proposed  project is  expected to provide a free or inex-
 pensive fertilizer/soil conditioner for agricultural operations
 within the delivery  area  of the  sludge drying/distribution center.
 This will probably  have a positive  impact upon land values, based
 on the assumption  that the sludge will  improve the productivity
 of the lands which  receive it.   This assumption seems justified
 by the evidence  from other areas which  have used anaerobically
 digested sludge  as  fertilizer.

     Chicago and Orlando  are  two of a number of cities which  have
 demonstrated the agricultural  benefits  of controlled land applica-
 tion of sludge  for  crop production.  Denver, San Francisco, San
 Diego, New York, Las Vegas, Miami and other cities have used
 wastewater treatment plant sludge for park and lawn development.
 In other countries  too, sludge  is used  for agricultural purposes
 (examples are Melbourne,  Australia; Leipzig, Germany: and the
 West Hertfordshire  Main Drainage Authority in London, England).
 Increases in land  values  in sludge  application areas are  in part
 attributable to  improved  productivity of the land.

Summary of Land Application of Sludge on the Recycling Areas

     The most severe  negative impacts are in  the food chain due to
heavy metals  uptake  by plants and animals.   Public health hazards
and water quality problems also rank quite high in potential  adverse
impact.  The  worst application sites vis-a-vis  reuse of  sludge are
home gardens, city parks  and irrigated farms,  while the  best sites_
are mine  spoil sites, sod farms and dry farms.   The greatest benefi-
cial impacts  are in  improved soil productivity  and conservation of
resources.  A schematic representation  of the  impacts  at  various
sites is presented on Figure  17 (page  138).

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  IMPACTS  OF SUBSURFACE  INJECTION OF  LIQUID  SLUDGE
  AT THE DRYING/DISTRIBUTION  CENTER


       The Metro facilities plan calls for the  injection of some of the liquid sludge on a
  24-ha [60-acre] portion of the proposed site  (located at the eastern end of site B-2).
  The area is contemplated by Metro to be both  a demonstration area and a possible secon-
  dary  disposal area for excess sludge.

       Metro indicates that if the market for sludge does not develop, excess sludge could
  be subsurface injected.  Metro proposes to apply  175 dry tons/ha [78 dry tons/acre] fol-
  lowed by a "rest" period of three years.  This process could be repeated five times for
  a  total soils loading of 875 dry tons/ha [390 dry tons/acre] (Reference 55, page 4-5).
  Metro plans to raise dryland crops on this site during the three-year resting periods.

  The facility plan document recognizes that problems with heavy metals, nitrogen and
  salts could occur.  The loading rates contemplated for this portion of the site are
  considerably in excess of recommended application rates of sludge for this region of
  the country.   Heavy metals levels in this  range of application could have inhibitory
  effects on some plants and pose a danger to animals consuming these plants.  Cadmium,
  in particular, would be available to such  an  extent as to warrant prevention of any food
  or feed from  this  site from  reaching consumers.   The area would generally have to be
  considered as a  "disposal  area for  sludge."

      The salt and  nitrogen loads  on  the  soils  at  this application rate would have an
'adverse effect on  plant growth.   At  a  rate of  175 tons/ha/yr [78 dry tons/yr/acre],  ap-
 proximately 2,500  cu  m/ha  [2  acre-feet/acre] of liquid sludge having a salt content  of
 6,000  rag/':  would leach through the soil  profile.  At these concentrations, a rapid
 buildup of  soil salinity will  result and will   give rise to significant yield reductions.

     The fate  of the  soluble  nitrogen forms at such high  application rates in the soil
 is  an  extremely important  question.  The ammonia  in sludge would partially be tied up
 on  clay particles, making  it  available for longer periods of time for plants.   But with
 dryland crops  and  some inhibitory effects, very little of the,nitrogen would be used by
 crops.  Gradually  some of  this  nitrogen would   be converted  to the nitrate  form and would
 migrate to  the groundwater.   Severe  localized  effects could  be  expected in groundwaters
 receiving the  nitrate  slug with the  leachates.  Since the application area is  located
 on  higher ground to the west  of the upper Lost Creek  drainage,  some  of the nitrate and
 salts  could seep into  this drainage.  Without  more definitive groundwater  information,
 these  estimates are conjectural at this point.

     The prinicpal limitation of the severity  of effects  from this method  of sludge  ap-
 plication is the fact that only 24 ha [60 acres] of the site are  involved.   Although
Metro  suggests use of this area as a secondary disposal site, the amount of  sludge that
could  be put on it in any one year (assuming the need for continuous  use of  this  area)-
would  be only about 1,100 metric tons [1,200 tons] per year.  This amount  represents
only about three percent of the total amount of sludge that must be  handled  at  the site.
Thus,  this area has only minimal value as an ultimate disposal site for Metro's sludge.
Metro  would still  need to develop a contingency plan  (such as landfilling) for  dis-
posing of sludge if no markets were to develop for sludge.

     If  sludge injection is carried on at the  drying/distribution site, very little  in
the way  of mitigating measures could be applied to lessen the impacts.  Irrigation water
could  be applied to flush the soil profile  of  excess  salts.  This might lessen  some of
the severe inhibitory effects on plant growth.   Heavy metals would still remain in the
soil profile.   The  flushing of the soil  profile would have negative impacts because of
the more rapid movement of salts and  nitrogen  toward  the groundwater;  The most realis-
tic  measure would  be  to limit the  amount  of sludge applied at this site, largely for
demonstration  purposes.  Very little  benefit would be gained by using this area as a
disposal site.
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IMPACT OF SLUDGE DISPOSAL AT LOWRY BOMBING RANGE

     The disposal of sludge to the Lowry Bombing Range represents
the "no-action" alternative and would be continued  if  agricultural
reuse of sludge is not implemented.  Since sludge is currently  being
applied at a relatively high rate on the bombing range, this  area
provides the opportunity to assess the effects  of sludge applica-
tion.  The Metro Denver Sewage Disposal  District No. 1  is currently
engaged in several research programs to  determine some of these
effects (Reference 114).  Various types, rates  and  methods of
sludge application are being used to measure the precise impacts.
The results of Metro Denver's research project  should  provide
quantitative data on high-rate sludge application at this site.
The District's history of experience with land  application of
sludges, gained at the bombing range, will be a valuable asset  in
future reuse programs when the results are published.   A summary of
impacts of the present operation is graphically shown  on Figure 18.

            CONTOUR STRIP SLUDGE APPLICATION AT LOWRY
Food Chain
     The entry of heavy metals into the food chain is a potentially
adverse impact on areas of high-rate sludge application.  Animals
accumulate heavy metals not only from eating the plants, but also
through direct ingestion of soil and sludge on the pasture areas.
The composition and amount of sludge that is applied as well as
soil conditions and plant characteristics are crucial factors in
the availability of heavy metals.  These relationships are dis-
cussed in detail in Appendix D.  The Metro Denver research project
should provide quantitative data on food chain parameters.

     Of all the land application areas studied, the present opera-
tion at the Lowry Bombing Range comprises the greatest potential
                              167

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                                                                    FIGURE 18
         SUMMARY IMPACTS OF SLUDGE DISPOSAL AT  THE LOWRY BOMBING RANGE
                           LANDSPREADING  OPERATIONS
 	Impact parameter	Direction and intensity5

           Food chain

           Public health

           Soil productivity                        (  j

           Soil salinity

           Soil heavy metals

           Water quality

           Flora and fauna

           Odor

           Noise

           Air quality

           Plant operation and effluent quality

           Aesthetics

           Public reactions

           Natural resources

           Land  use                                  9

 o
  Symbols signify relative  impacts, as  defined  below:

                                          High   Moderate   Low

       Positive  (beneficial)  impacts:      (   j

       Negative  (adverse) impacts:
This schematic representation of impacts should only be interpreted within  the
context of analyses of impacts presented in the main body of the EIS.   It  is
neither an attempt at quantifying the impacts nor reducing the diverse environ-
mental parameter to common bases for comparison.   However, it does provide  a
rough ranking of the relative importance of the various impacts.
                                     168       ENGINEERING-SCIENCE,

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hazard to the food chain with cattle,  destined for the  slaughter-
house and the grocery store, grazing unrestricted  on  sludge-amended
areas.

Public Health

     In the past, no significant health problems have been  associ-
ated with the Lowry Bombing Range sludge disposal  operations.   If
these operations continue, it is expected that, under most  condi-
tions, the public health situation will not change.   However,  the
relative longevity of pathogens in soil (especially enteric para-
sites and their eggs or cysts, such as Ascaris ova) and the daily
proximity of workers and other project personnel with the sludge-
loaded soil would continue to present a health hazard that  must
not be underestimated.

     Effects on Personnel--

     The present landspreading system in use at Lowry presents an
operating hazard to workers on the site.  The high concentration
of lime used to disinfect the sludge makes the material  to  be  ap-
plied very caustic (pH 11-12).  Injuries to skin and  eyes of
workers have resulted on occasion.  Application by truck of a
semi-solid sludge also poses an operating hazard with the danger
of overturning or losing control of the truck.  With  the advent
of anaerobic digesters, the pH of the sludge would be nearer a
neutral value (7) and would present less of a hazard  to workers.

Plant Operation and Effluent Quality

     If the present Lowry operation is continued,  with  the  addi-
tion of anaerobic digesters, recycle of supernatant from the di-
gesters is expected to have a negative impact on the  Metro  Central
Treatment Plant (see discussion on page 124).
                               169

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 Soil Properties

      As long as soil  incorporation of sludges  at  the currently
 heavy rates are kept below the conservative guidelines (presented
 in Section IV under irrigated farms and  in  Appendix D),  it  is ex-
 pected that soil  conditions and properties  at  the Lowry  Bombing
 Range disposal  site will  improve with increased fertilizer  levels
 and organic matter.  Obviously, nitrogen and other fertilizer com-
 ponents of the  applied sludge will  be far  in  excess of  that
 needed for the  weeds  and  grasses growing on the site.  The  organic
 matter content  of  soils will  rise to about  1.75 percent  in  the top
 15 cm (6 in.) of the  soil,  at the current 400  metric ton/ha [175
 ton/ac] total loadings.  This is a  significant increase  over the
 background levels  of  less than 0.5  percent.  Thus, great immediate
 benefits to the soil  structure, permeability,  water availability,
 root penetration and  erosion  resistance  will accrue.

      The relatively high  natural  pH in these soils will  help keep
 heavy metals  concentrations from becoming toxic to plants and a
 threat to the food  chain.   The main difference between the  bombing
 range condition and that  of the irrigated farms is that  the impact
 occurs  over a much  shorter  period of time in the  case of the bomb-
 ing  range.   Thus,  salt  accumulation in the  root zone will occur
 rather rapidly, especially with the low  rainfall   levels  and lack
 of a  significant additional water source  limiting downward move-
 ment  of  soluble compounds.  At  current application rates, total
 soluble  salt content  of the soil  plow layer will   be increased to
 0.2  percent of  the  soil mass,  assuming that initial  salt content
 is nearly  nil.  This  level of  salt  concentration  is not  expected
 to cause more than  a  30 percent  plant yield reduction (Reference
 115), given the existing vegetation.  In fact, the yield reduction
 will  probably be overshadowed  by  increases arising from  enhanced
 fertility  levels and  soil  conditions.

 Hater Quality

     The Lowry  Bombing Range sewage  sludge disposal  operations pro-
 vide a unique opportunity for a quantitative assessment of impact
 of sludge reuse on water quality.  Already, a  network of catch
 basins, spring  stations and monitoring wells have been established
 by the Metropolitan Denver Sewage Disposal District  No. 1 in the
 immediate areas  of  past and present  sludge disposal.   Sampling and
 analysis of waters from these stations started in 1973 and are
 expected to continue on a  regular basis for an indefinite period
of time.  The groundwater  conditions are  monitored through a large
 number of shallow  and deep wells in the areas  of  soil  incorpora-
tion of sludge.  The cooperative program  was started  in late 1974
by the U.S. Geological Survey and Metro Denver District and  is
                               170

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continuing at the present time.

     Preliminary raw data from the surface  water  analyses  are  still
not enough to help assess actual  impacts.   It  can be  surmised  from
the trends that nitrate nitrogen  is already finding its way  into
surface waters and the shallower  groundwater reservoirs.   Individ-
ual catch basin concentrations of 29,  88  and 95 mg/1  nitrate nitro-
gen (as NO^) measured recently are alarming though not necessarily
indicative of wholesale contamination.  Most of the analyses indi-
cate concentrations below 5 mg/1.

     Preliminary data from the groundwater  analyses show vertical
nitrate migration in areas downstream  of  the older land disposal
areas (8 to 44 mg/1 N03-N) and in the  vicinity of the landfill
(13 to 23 mg/1 N03-N).  Although  these are  single-sample prelimi-
nary results they may indicate real trends. Despite  certain doubts
about the origin of the nitrogenous materials  these trends may
continue.  Nitrate levels in groundwater  could rise over the com-
ing few years to levels above 45  mg/1  (as NOs), the limit  at which
their use for drinking water would be  inadmissible.*

     As  expected,  heavy metals concentrations have not yet increased
in groundwaters, whereas  preliminary measurements in the topsoil
have confirmed  their  accumulation.  These metals  are not expected
to move  downward  in these calcareous, relatively  high-pH soils.
The continuing  monitoring programs are an  important  advance warning
system in  this  regard.

Flora and  Fauna

     Vegetation—

     Continuation  of  high-rate sludge application on the Lowry
Bombing  Range will cause  similar  impacts to the  vegetation that
can now  be observed on that  portion of the  bombing range that has
received sludge.   This site  is referred to  as Site A and is shown
in Figure E5.   The sludge application process itself results  in
the complete displacement of  the  existing vegetation.  However,
no rare  and endangered species have been reported on this site
(Reference 34), and relictual mixed-prairie units, which are  be-
coming scarce in the  Denver  area,  do not occur at the disposal area.
This conclusion was made  from a  field reconnaissance and should be
verified by more thorough site surveys if  land application is to
*Recommended limit for nitrate nitrogen in domestic waters is
 45 mg/1 as NOg.
                               171

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 continue.  The original mixed-prairie unit has long  been  exposed
 to heavy grazing and presently contains many introduced annual
 grasses and annual and perennial  weeds.

      The immediate impact of sludge application would  be  to  stimu-
 late the growth of weeds.  The major weedy species found  on  Site A
 (common sunflower, Russian thistle, summer cypress and tumble pig-
 weed) are fast-growing colonizers of bare  soil  whose growth  has
 been enhanced by the nutrient value of the sludge.   Over  a long
 period of time, certain grass species would become established in
 the absence of grazing.  Other management  inputs, such as weed
 control and planting, would accelerate this process.   As  long as
 the site is grazed, however, cattle will selectively crop grasses
 and the weeds will continue to be dominant.

      The establishment of a vegetative groundcover is  essential to
 control soil  erosion and surface  runoff.   Although grasses are
 superior to weeds  in checking erosion, the dense weedy growth on
 Site  A does serve  to limit problems resulting  from soil erosion and
 runoff.

      Site A is being used for a research project by  Metro Denver
 Sewage Disposal  District No.  1  on  the  effects  of high-rate sludge
 application on vegetation and cattle  (Reference 114).  Two major
 areas  of concern are the high nitrate  levels and the accumulation
 of  heavy metals  in plants and in the  food  chain.  Many common
 weeds  have  high  nutrient requirements  (nitrogen, phosphorus and
 potassium)  which limit  to some  extent  the  amount of  nitrates that
 can be leached  into  the groundwater.   Perennial grasses also have
 a high nitrogen  requirement.  The movement  of  heavy metals into
 plant  tissue depends  on many  factors.  The  high phosphorus content
 of the sludge  tends  to  make zinc, cadmium  and  nickel unavailable
 to plants.  This property might be  somewhat reduced  by the cal-
 careous  nature of  the soils.  Calcareous soils have  a  high pH and
 tend to  make phosphorus  unavailable and immobile.  Cadmium is po-
 tentially hazardous  in  the food chain, and  its movement within
 the soil-piant system can be  controlled by  limiting the amount
 applied  to  less than  one  percent of the zinc content applied.  In
 this way, excess zinc would injure the crop before the zinc or
 cadmium  content of the  crop constituted a health hazard (Reference
 116).   This relationship  is explained more fully in Appendix D.

     Seed germination is  inhibited if planting operations  are con-
ducted too soon after the application of liquid sludge.  If plant-
 ing is done from two weeks to one month after sludge application,
seeds  germinate successfully.
                               172

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     The impacts of high-rate sludge application to this  site will
presumably be quantified when the Metro Denver research  report  is
available.

     Wildlife—

     High-rate application of sludge upon the Lowry Bombing  Range
produces a distinctive plant community as described above.   The
resultant plant growth would exhibit a tendency towards  a variety
of herbaceous annuals.  These fast-growing "weeds"  can compete
with the existing grasses and are often thick-stemmed, fibrous,
and in some cases bearing thorns.  They are generally less suit-
able than the short grasses for animal forage, but  may be grazed
upon in the tender stages or during periods of food scarcity.   The
ability of various plant species to accumulate sludge constituents,
such as heavy metals, depends upon many factors as  discussed in
Appendix D.  High concentrations of zinc, copper and cadmium in
forage could have deleterious effects upon animals. However, se-
vere toxicity injury from metals normally occurs in vegetation  at
lower concentrations than those toxic to animals.   Some  grazing
animals, particularly sheep, are unusually sensitive to  copper  and
could be injured by eating some forages enriched in copper by
sludge.  Few studies have been conducted on particular animal
avoidance by taste or odor of vegetation grown on sludge (Refer-
ence 117).  In general, when suitable grass forage  is available,
grazing animals will eschew the tough and unpalatable  "weed"
species.  Cadmium and zinc are accumulated generally in  the  foliage
and are found only in low concentrations in fruit,  root  and  grain
parts.  Wild grains, seeds and fruit from grasses and  "weeds",
particularly sunflowers, would provide a satisfactory  food sup-
plement for seed-eating birds and small mammals.  This would be
particularly beneficial to wildlife in the fall and winter.

     The shift in plant species would also result in a change  in
the microclimate on the surface and several centimeters  below  the
surface.  The broad-leafed herbaceous plants with relatively
deeper root systems would contrast sharply with the groundhugging
short grasses with shallow, fibrous root systems.  The  combination
of reduced insolation and semi-moist organic material  in the soil
would lead to decreased surface and substratum temperatures  with
slight increases in humidity.  This micro-environment may be par-
ticularly favorable to invertebrate species and may encourage  the
establishment of new species as well.  The low-diversity and un-
balanced plant ecosystem may also lead to the preponderance  of
only a few species.

     High-rate sludge application and mixing into the upper  soil
zone would probably have the greatest direct effect upon burrowing
                              173

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 and ground-dwelling rodents.   Initial  sludge  application would
 temporarily destroy the uplands vegetation  habitat and cause a
 displacement of local  rodent  populations  to adjacent  areas.  With
 the re-establishment of vegetation and aging  and maturation of the
 organic-laden soil, some rodents—such as pocket gophers and ground
 squirrels--may return  to the  area.  Ground  squirrels  are generally
 seed-eating and use the underground burrows chiefly as retreat and
 nesting areas.   Pocket gophers, on the other  hand, reside almost
 exclusively underground, burrow continuously  and feed upon sub-
 terranean root stocks  and other material.  The gopher may actually
 accumulate sludge constituents  such as heavy  metals through direct
 ingestion as well  as digestion  of  plant material.  A decrease in
 rodent numbers  may not be significant  to humans, but nevertheless
 is  important to the ecosystem balance.  Gopher populations within
 an  area may have a contributing effect upon the food chain, as
 these small  animals are preyed  upon by hawks, eagles and coyotes.

      Grazing animals may be exposed to pathogens and parasites by
 direct exposure and ingestion during feeding.  Pathogens will be
 greatly reduced over time and by thorough incorporation.  However,
 parasite  ova such  as Ascaris may remain viable over many years,
 potentially  causing serious animal  diseases.

      The  ecosystem shift  and  effects upon wildlife are localized
 to  the sludge application areas  and  are generally short-term.
 Without further sludge  applications, the altered vegetation com-
 munity would gradually  change to an  upland vegetation unit in
 three  to  five years.  With continuing  periodic sludge application,
 this  altered and unbalanced ecosystem could be perpetuated over
 the long  term.

      Large-scale sludge application  at the Lowry Bombing Range may
 affect  the habitat  of the endangered black-footed ferret.   If the
 project destroys any prairie dog towns on the site, it may affect
 the main  food source of the black-footed ferret.

 Noise

     Continuation of the  present landfilling and  high-rate sludge
application methods would perpetuate the existing noise levels
from machinery and  associated  activities.   As  stated under the
environmental setting, the climatological  conditions and  openness
of the prairie would disperse  sound well.   In  addition, the low
population density  and isolation from other noise sources  make
the noise contribution from the project almost insignificant.
                               174

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Air Quality

     The application of sludge to the bombing range should not ad-
versely affect air quality if the sludge is promptly incorporated
into the soil.  The potential for particulate matter to rise and
be dispersed exists if the sludge is stockpiled or not incorporated
soon after optimum moisture condition is reached.   Particulate
matter can contain heavy metals and microorganisms that might be
ingested by people.  Lead, particularly, is a health hazard.  When
the sludge is well mixed in the soil, the potential  for dust and
particulate dispersal  is reduced by the soil-binding character of
the organic matter in sludge.

     Odor--

     The present operation's odor problems are not now serious and
are not expected to be significant in the future.   Under present
operations, with largely undigested sludge, odors  are easily per-
ceived at close proximity to the application areas, especially
when digester problems are encountered.  The small amount of air-
dried anaerobically digested sludge currently stockpiled is almost
free from odors.

Aesthetics

     Continuance of operations at Lowry Bombing Range would have no
significant adverse aesthetic impact.  The isolated area and neigh-
boring landfill operations place the operation in  an unobtrusive
setting.  Even at the close-range view, the application areas re-
semble newly-plowed fields.
                 SLUDGE ON LAND BEFORE PLOWING
                              175

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 Traffic and Circulation

      Should the proposed project  not  be  implemented, truck traffic
 to and from the Metro Denver Central  Plant  facility and the Lowry
 Bombing Range will  continue at  a  rate of 35 to 40 truck trips per
 day until  such time as the land can no longer accommodate additional
 increments of heavy metals associated with  Metro Denver sewage sludge
 (Reference 39).

 Public Reactions

      Earlier adverse public reactions concerning Lowry operations
 resulted from system inadequacies which  have since been remedied.
 The number and validity of the  complaints about odor have been
 dealt with in the section  devoted to  that topic.  Continued use of
 the Lowry  site would probably result  in  continuance of these com-
 plaints.  Complaints have  averaged about one per month, with 80
 percent found to be due to some other source, and the remaining
 20 percent due to inclement weather or operations breakdown (Ref-
 erence 39).

 Natural  Resources

      The lands on the Lowry Bombing Range are currently utilized
 as range and pasturelands  and,  thus,  this area exists as a grazing
 resource.  As such,  the potential for  grazing has been reduced in
 areas of sludge  application by  the lack  of  range management prac-
 tices that would ensure adequate forage  species composition.  Al-
 though  these areas  have been  reseeded  with wheat and forage grasses,
 the continuation of  grazing combined with the absence of weed con-
 trol  has produced a  site that is dominated  by weeds and has margin-
 al  value as  rangeland.   Continuation  of  sludge application in the
 absence  of sound range  management techniques would thus constitute
 a  reduction  in the grazing  natural resource.

      High-rate sludge application could  beneficially affect this
 natural  resource if  a weed  control program was implemented and if
 the  potential  for hazardous heavy metals to enter the food chain
 were  recognized.

     The application of  excessive amounts of sludge under a high-
 rate application program constitutes a loss of nutrient resources.

 Land Use

     Should the  proposed project not be  implemented, the Lowry
 Bombing Range may continue  to be the application site for Metro
Denver sludge.  There is evidence that heavy metals are building
                               176

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up in the soils as a direct result of intensive sludge application
(Reference 118).  This would reduce the types of uses  which  the
disposal area could otherwise offer.

IMPACT OF SLUDGE LANDFILLING AT LOWRY LANDFILL

     The landfill ing practice near the Lowry Bombing Range is  es-
sentially a winter-weather and emergency practice which comprises
a portion of the "no-action" alternative.  During the  winter,  when
it is difficult to perform the regular soil  incorporation  practices,
sludge is dumped at high rates on prepared bench-and-terrace areas.
Sludge is emptied from the backs of trucks to a depth  of 60  cm [24
in.] and mixed at a 5:1 ratio with soil.  This amounts to  a  loading
rate of 670 dry metric tons/ha [300 dry tons/ac] per year.  Winter
landfill ing during December, January and February has  been prac-
ticed since 1971 but is expected to cease if the proposed  agri-
cultural reuse plan is implemented.

Soil Properties

     Native soil is removed from the landfill areas prior  to dump-
ing sludge.  The soil is stockpiled and used to mix with the sludge
during dumping and for final cover.  At the very high  rates  used,
sludge components will saturate the cation exchange sites  of the
soil and increase its salt content, making it a practically unpro-
ductive material for crop production or pasture.  The  increased
water-holding capacity caused by increased organic content will
help delay leachate formation but will not prevent it  in the long
term.  Overall, the impact upon the soil from landfill ing  will be
destructive and extremely long lasting.

Hater Quality

     Nitrates and heavy metals will gradually be leached by perco-
lating rain water and carried toward the groundwater reservoirs.
Already, concentrations of nitrates in well waters in the  vicinity
of the landfill area are significantly above background levels;
i.e., 13 to 23 mg/1 in contrast to background levels of 0.01 mg/1
or less.  These trends are expected to continue unabated unless  an
impermeable layer is placed on top of the old fill areas and be-
neath the new ones.

     It is expected that heavy metals will gradually move  downward
toward the water table from the landfill unless leachate-prevention
mechanisms are implemented.  Cadmium is the most mobile of metal
elements and will serve as an indicator of incipient arrival of
other heavy metals to the groundwater reservoir.
                              177

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      Surface v/ater pollution from the landfilling  operation  is ex-
 pected to be minimal because of the  soil  cover  provisions and prior
 site preparations minimizing runoff  from  the  sites.

 Flora and Fauna

      Vegetation—

      The impacts of a landfill  on vegetation  are of a complete and
 long-term nature.  Existing  vegetation is  removed  with the excava-
 tion of trenches for sludge  disposal.   At  the completion of dis-
 posal  operations, the District  plans  to overlay the area with a
 topsoil material and revegetate with  annual grasses.  The success
 of the revegetation program  depends primarily on such factors as
 soil  conditions and management  inputs,  such as weed control.
 Grasses are  generally tolerant  of heavy metals  in  the soil, and the
 establishment  of a  permanent groundcover  in this area would prob-
 ably not encounter  any severe problems.  Heavy metals accumulating
 in plant tissues should be recognized  as a reality, particularly
 if the site  is  to be grazed  by  livestock.

      Wildlife—

      Long-term  disposal  of sludge at  the Lowry Bombing Range by
 landfilling  would cause a definite change  in  the local plant com-
 munity and a probable shift  in  wildlife species.

     Landfilling, which would probably  be a seasonal activity, in-
 volves  complete destruction  of  the existing habitat by excavation,
 trenching, and  deposition of  sludge and placement  of soil cover
 over the mound.   Wildlife, particularly small mammals such as mice,
 ground  squirrels  and  jackrabbits,  would be displaced to adjoining
 areas,  causing  temporary population stresses.  The completed land-
 fill cover would  be  relatively  barren because of poorer soil  con-
 ditions, rapid  runoff,  poor v/ater  retention capability and greater
 exposure.  This  anomaly in the  landscape would be difficult to
 incorporate  into  the  upland vegetation  habitat and is effectively
 lost to wildlife  usage.  Landfilling as a method of sludge disposal,
 however, does not disturb as great an area as does broad-scale
 surface application because the material is concentrated  in a
 smaller area.

Air Quality

     Because the landfill ing operation is  restricted to the winter
 season and adequate final cover is provided,  no air pollution po-
tential is expected from this operation.  Safeguards against ero-
sion and removal of the final cover are essential , to maintain the
                               178

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sludge under constant cover and to prevent it from drying  and  blow-
ing in the wind.

     Odor--

     Similarly, if the final cover is maintained,  no odors will
emanate from the site.  Otherwise, the landfill  can be expected  to
produce disturbing odors, detected at considerable distances,  as
past experience with unauthorized dumping  has indicated.

Explosive Gas Production

     Solid waste landfills in general, and sludge  landfills in par-
ticular, produce significant quantities of combustible gases such
as methane during the process of anaerobic decomposition.   Mhen
mixed with air (5 to 15 percent combustible gas  in the mixture),
they are explosive and can pose a safety hazard  to humans  in the
vicinity.  Special provisions for venting  such gases are  necessary.

Land Use

     Whether the proposed project, i.e., beneficial agricultural
reuse of sludge, is implemented or not, general  uses of the Lowry
landfill will be unchanged since the area  will remain a disposal
site for the Denver urban area.

Resources
     Burying the sludge in a landfill constitutes wastage of a  re-
source of potentially high fertilizer and soil-conditioner value.
The extent of this loss can be visualized from the discussion of
impacts of sludge application on the soil, discussed in this
Section and in Appendix D.

Summary of Impacts of Sludge Disposal at the
Lowry Bombing Range

     As currently practiced, the land spreading operation at the Lowry
site exerts the greatest negative impact on the food chain through
pasturing of domestic animals on sludge-amended fields.  Heavy  metals
accumulation in the soil, salinity of the soil and groundwater  quality
problems are other negative impacts of the current practices.   Improved
soil productivity and a partial  conservation of natural resources  are
among the beneficial  impacts of the present disposal  operations.   These
impacts are schematically represented in Figure 18.
                               79

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'•*

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w
 h
1

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     This section contains recommendations for
possible modification of the original project
proposal (or in the case of land application- on
reuse areas, additional controls that were not
contemplated in the facilities plan)  to reduce
or eliminate environmental impacts.  Negative
impacts of major elements of the land applica-
tion plan—processing, off-site application
and the Lowry operation—are listed,  and miti-
gative measures are recommended.

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                            SECTION VI

      NEGATIVE  IMPACTS AND RECOMMENDED MITIGATIVE MEASURES


      Key negative impacts identified and discussed in Section V are
 listed in this  Section with possible mitigative measures which may
 be selected during the review process of this Draft EIS for final
 implementation.  These tentative mitigation measures are recommenda-
 tions by EPA and its consultant (Engineering-Science, Inc.) for con-
 sideration by the reviewing agencies and the public.  Through the
 review process, acceptable effective measures will be selected from
 those presented here and those which may be offered by the reviewers
 of this document.  The measures thus selected will become an inte-
 gral  part of the design and operation of the facilities planned by
 Metro before Step 3 grant monies are extended for the construction
 of the facilities.  The final EIS will include the selected mitiga-
 tion measures.

      It is extremely important that whatever mitigative measures are
 adopted be integrated with the planned monitoring and surveillance
 activities so that symptoms detected by the monitoring system can
 lead directly into specific mitigative action.

 PROCESSING, TRANSFER, DRYING AND DISTRIBUTION

 Groundwater Pollution by Nitrates and Salts Leaching
 from Sludge Drying Basins

     Lining the bottom and sides of basins with impermeable materials
 is the only fully effective way to mitigate nitrate and other salt
 accumulations in the groundwater.  Nitrate movement can probably be
 slowed by maintaining anaerobic conditions in the bottom layer of the
 drying beds (this possibility has not been fully demonstrated as a
 guarantee against nitrate movement).  Provision of drainage networks
 below the basins can be effective against nitrates and other salts
 but will  not stop all leachates from moving to the water table.
 Furthermore, the collected drainage water must also somehow be safe-
 ly disposed.

     Return of the supernatant from the digesters to the treatment
plant headworks (rather than pumping it along with the sludge to the
sludge drying and distribution center) would be a great help in re-
                               181

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 ducing salt pollution of the groundwater.   Drying of  the  superna-
 tant in separate, lined drying basins  and  containment of  the dried
 salts would also be a suitable—though partial—alternative mitiga-
 tion measure against salt buildup in the groundwater.

 Surface Water Pollution from Experimental  Plots

      Impoundment of runoff water in reservoirs  at  the lowest parts
 of the center and treatment or proper  disposal  (e.g.  irrigation  of
 experimental plots and wetting the sludge  stockpiles  on windy oc-
 casions) of the waters gathered can adequately mitigate surface
 water pollution.

 Potential  Threats to Public Health

      Pathogen transmission through the air and through surface run-
 off waters and nitrate contamination of groundwaters  are  two main
 threats to public health which can be  detected through continuous
 monitoring of pathogen longevity and groundwater quality  under the
 drying and distribution site.   Mitigation  measures  for public health
 hazards could include:  (1) lining the  drying  basins with  impermeable
 materials, (2)  provision of special  medical services  for  the employees
 at the center,  (3)  restriction of public access  to  the site, (4) main-
 tenance of optimal  digestion conditions  in  anaerobic  digestors,  (5)
 provision  of special  medical  monitoring  and preventive treatment to
 persons  frequenting  the site for taking  delivery of sludge  loads and
 (6)  a  strict ban against pumping of  undigested sludge at  all times.

 Proliferation of Insect  Vectors  on Sludge
 Drying   Basins

     A  qualified entomologist  should be  retained at the early stages
 of full  utilization of  the  drying  basins to identify  specific insects
 colonizing  the basins.   Control  measures defined through the identifica-
 tion process should be  implemented.

 Air Pollution from Participate Matter of
 Sludge Origin

     Sprinkling  of the stockpile areas  during windy periods and stor-
 age in gently sloping heaps  (in  contrast to high abrupt mounds) would
 help minimize dried sludge being blown  in the wind.   However, with
 above-ground storage it will not be possible to completely prevent loose
material from being  blown.

 Production of Nuisance Odors in Drying  Basins

     Odors can be minimized with proper digestion of sludge and main-
                               1GZ

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tenance of an adequate buffer zone between  the basins  and  site  bound-
aries.  Odor production on the site itself  cannot be wholly  prevented.

Negative Public Reaction to Establishment of
the Drying and Distribution Center

     A proper public relations campaign with full  disclosure of all
environmental, economic, political and social  considerations involved
with the project should provide a healthy atmosphere of  open dialogue.
This will help improve the acceptability of the drying and distribu-
tion center to the neighboring farming community.

LAND APPLICATION IN SLUDGE RECYCLING AREAS

     Lands which will be the ultimate repositories of  dried  sludge
will be the most critical impact areas in the sludge handling process.
This is due to the fact that many of the impacts discussed are  of a
cumulative, long-term nature.  Therefore, mitigative measures are es-
sential for success of the beneficial reuse scheme.  The most import-
ant overall mitigative measure would be limitation of  land application,
in the initial years, to the sites with the least severe adverse im-
pacts  (such as mine spoil sites and sod farms).

Heavy Metals Accumulation in Soil, Plants,
Animals and the Food Chain

     (1) Removal or reduction of sources contributing  heavy  metals to
the wastewater management system will mitigate many of the adverse im-
pacts on soils, plants, animals and the food chain.  This  can be done
by promulgation of a special wastewater ordinance, setting tolerable
limits on concentrations of exotic substances entering the sewer sys-
tem, thus forcing industries to adopt in-plant measures  to curb dis-
charge of heavy metals.

     Exclusion of industrial and other heavy metal discharges from the
wastewater treatment system will allow prolonged use of sludge  on the
various sites.

     (2) Control of cadmium:zinc ratio is another important  mitigat-
ive measure.  If this ratio is kept below one percent, acceptability
of sludge for use on feed crops and foods will be greatly  enhanced
through the plant yield reduction effected  by zirrc, long before either
element accumulates in toxic concentrations.

     (3) Record-keeping, inspection of sludge application  operations
on individual sites and monitoring of environmental parameters  are
functions which must be carried out by the  District or another res-
ponsible agency in close cooperation with individual  farmers and oper-
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 ators.   These  functions will prevent  inadvertent aggravation of im-
 pacts by excessive, non-uniform or careless applications of sludge
 and will mitigate the  adverse impacts.  It may be necessary to ob-
 tain binding agreements with recipients of sludge to permit inspec-
 tion and monitoring and to provide for cessation of sludge supply
 in cases of noncompliance with recommended management practices.

     (4) In many cases, it may be necessary to subsoil the farmland
 prior to or during the first sludge application pass, in order to
 bring to the surface some of the calcareous material in the lower
 soil horizons.  Alternatively, lime amendment would also help in-
 crease soil calcium content, if necessary.  This will help hasten
 the "reversion" of heavy metal elements to unavailable forms.

     (5) Crop selection to favor non-foliar edible parts and younger
 rather than older plant parts can help reduce magnification of cad-
mium and other heavy metals in the food chain.

     (6) Surface spraying of liquid sludge should be avoided, espec-
ially on pasture areas where it may be directly ingested by livestock.

     (7) Exclusion,  at the slaughterhouse, of kidneys and livers from
the meat of animals  having grazed on--or having been fed hay and
other feeds raised on--sludge-amended farms and the disposal of these
organs  at a  sanitary landfill  would be an excellent mitigation mea-
sure.   The  ability of these organs to concentrate heavy metals would
thus  be benefically  used as a device to eliminate them from the food
chain.
            LIVESTOCK  GRAZING ON  SLUDGE-AMENDED  FIELD
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Nitrate Pollution of Groundwater, Especially In
Irrigated Farms, Sod Farms. Home Gardens,  City Parks

     While the  active process of leaching of nitrates  into the
groundwater table cannot be avoided, the extent and duration can
be substantially reduced.  Periodic monitoring should be  conducted
on groundwater assoicated with each site that is receiving  sludge.
Before nitrate concentrations reach 45 mg/1  N as N03, usage of slu-
dge should be curtailed, and the groundwater should be  restricted
from potable use.

Nitrate Pollution and Eutrophication of
Lakes and Other Water Bodies

     (1) The pollution of surface waters can be mitigated by strict
control over application rates so that a balance between  nitrogen
uptake by plants and available nitrogen content of sludge is adhered
to as closely as possible.  Water quality should be monitored to de-
tect any buildup of nitrates.

     (2) Control of the tailwater in irrigation systems and use of
standard runoff and erosion control practices on the  farm can reduce
the threat of surface water pollution.

     (3) Riverbeds, flood plains and steep slopes should  be categor-
ically excluded from sludge application.

     (4) Use of liquid sludge injectors, applying sludge  at greater
depths, should be preferred over application of dried sludge.

Air Pollution from Particulate Matter
of Sludge Origin

     Particulate matter from dried sludge applied to  soils  can be
reduced by several means: (1) deep incorporation of  sludge  into the
soil by mechanical means as soon as possible after application;  (2)
subsequent irrigation to keep particulate matter in  the soil; (3)  ap-
propriate scheduling to avoid or minimize sludge application during
windy conditions—particularly in the springtime; (4) opportunistic
timing to apply sludge immediately prior to forcasted rainstorms  and;
(5) injection of liquid sludge deep below the surface wherever this
is a feasible practice.

Exposure of Humans to Viable Pathogens
and Parasites

     (1) The use of sludge which has been air-dried for at  least  two
years would greatly reduce the numbers of viable pathogens.  Addit -
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 ional  methods  of pathogen  reduction  in  sludge  include:  (a) pasteur-
 ization for 30 minutes  at  70°C  [158°F];  (b)  high pH treatment, typi-
 cally  with lime, at a pH greater  than 12  for three hours;  (c) long-
 term storage of liquid  digested sludge  (if applicable)  for 60 days
 at 20°C [68°F] or 120 days  at 4°C [40°F];  (d)  complete  composting at
 temperatures above 55°C [131°F] for  at  least 30 days; (e) use of chlo-
 rine or other  chemicals to  stabilize and  disinfect sludge.  Current
 research shov/s preliminary  promise in the use  of high energy electrons
 for disinfection of sludqe  passing in a thin stream in  a specially
 adapted process.   The feasibility of use  of  these and other means of
 pathogen destruction should  be  continually considered for application
 and use.

     (2)  The possible introduction of pathogens into surface waters
 will be mitigated if sludge  is  not applied in  the close vicinity of
 lakes  and other  water bodies.

     (3)  Soil  and water monitoring for pathogens should be regularly
 conducted.

     (4)  Use of  sludge  on vegetable  crops (such as in home gardens)
 arid  all  foods  eaten  raw should  be strictly banned.  EPA guidlines sug-
 gest a  three-year waiting period  prior to using sludge-treated land
 for  food  crops to be  eaten raw  by humans.

      (5) Use of sludge  on  parklands  should be  controlled to avoid
 areas  where humans could come in  contact  (e.g. grass areas) and  lim-
 ited to areas  where control  can be maintained  (new sod, flower gar-
 dens).   Sludge applications  should also be limited to times of the
 year when chance of exposure is slight.

 Exposure of Animals  to  Viable Pathogens
 and  Parasites

     Mitigative  measures such as  those enumerated above, under Expos-
 ure  of  Humans  to  Viable Pathogens and Parasites, are equally effec-
 tive in protecting domestic  animals  and wildlife from adverse effects
 of  sludge pathogens  and parasites.

 Odor

     Proper  timing of sludge application will mitigate odor impacts.
 Further mitigation measures  applicable to odor are discussed above,
 under Air  Pollution  from Particulate flatter  of Sludge Origin.

Adverse Public Reactions

     The promotion of a public  education program to inform the public
of the benefits and  potential effects of sludge application will  al-
most certainly increase acceptability of the concept and its wide-
spread  adoption in the  farming community.


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Initial Toxicity of Liquid Sludge to
Seeds and Young Plants

     Where liquid sludge is applied on irrigated or non-irrigated
farms, mitigation can consist of (1) delay of planting until  one
month after application or (2) use of special sludge injectors,
applying the material in separate bands deep into the soil.

Ingestion of Sludge from
Foliage and Soil

     (1) Spraying of sludge on growing crops and pastures  should be
avoided;

     (2) Cattle should not be pastured on land having received sludge
recently;

     (3) Sludge should be incorporated into the soil as soon  as  pos-
sible;

     (4) Use of deep liquid sludge injectors should be encouraged,
particularly on dryland farms and pastures.

EXISTING DISPOSAL OPERATIONS  ("NO ACTION") AT LOWRY
BOMBING RANGE

Heavy Metals Accumulation in  Soil, Plants,
Animals and the Food Chain

     This impact is particularly severe in areas where livestock
grazing is conducted.  It is  somewhat mitigated by the limitation
of total application rates.   However, the high time rate of applica-
tion causes uneven incorporation and high local concentrations,  pos-
ing hazards to the food chain.  For mitigation measures, refer to
page 133.

Possible Loss of Unique Vegetation
Type

     The location of any relictual mixed-prairie units should be veri-
fied by a thorough site survey.  Loss of any existing examples of
this type would be mitigated  by the exclusion of these areas  from
future sludge application sites.

Possible Destruction of Rare  and Endangered
Plant Species

     The occurrence of any rare and endangered plant species  should
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 be verified by a thorough site survey.  Destruction of these plants
 would be mitigated by avoiding areas where they may be found.   Approp-
 riate botanical authorities should be notified of the location  of rare
 or endangered plants.

 Possible Loss of Black-Footed
 Ferret Habitat

      The location of any prairie-dog towns should be noted,  and a
 thorough site survey conducted to determine concurrent habitat  assoc-
 iation for the endangered black-footed ferret.   If the black-footed
 ferret is found on the site,  its  habitat should not be used  for sludge
 application.

 Initial  Toxicity of Liquid Sludge to
 Seeds  and Young Plants

     The inhibition of seed germination  can be  mitigated  by  delaying
 planting operations until  one month  after the  application of liquid
 sludge.

     Application  of liquid sludge in separate  deep  bands,  with  the
 use of special  injectors,  can mitigate initial  toxicity without a
 need for delayed  planting.

 Air Pollution  from  Particulate Matter
 of Sludge Origin

     Mitigative measures are  discussed above, under  Sludge Recycling
 Areas.

 Reduction of Grazing  Resource

     The implementation of range  management  practices, such  as  weed
 control  and the exclusion  of  livestock from  treated  areas  until  a
 forage crop is well established,  will mitigate  this  impact.

 LOWRY LANDFILL

 Removal of Wildlife Habitat

     A rigorous attempt at revegetation of  the  final cover over  the
 landfill  area will help restore the habitat  to  some extent.

Groundwater Pollution

     Unless the bottoms of new fill areas and the surfaces of old
areas  are covered with impermeable materials such as liners or  clay
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layers, groundwater will  be polluted with  nitrates,  salts,  carbon
dioxide gas and perhaps  even heavy  metals  over  long  periods of  time.

Explosive Gas Production

     Use of venting systems, standard  on sanitary  landfills,  can
prevent formation of explosive concentrations of combustible  gases
generated in the sludge  fill area.   Such systems are not  now  in
place at the Lowry landfill.
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w
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•

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     The long-term implications of the Metro
proposal and the continued use of the Lowry
system are reviewed in this Section.  First,
those impacts of an adverse kind that cannot
be avoided—even with the use of mitigating
measures proposed in Section VI—are described.
Next, consideration is given to the irrever-
sible commitments of resource use that will
occur with this proposal or with the existing
system.   Finally, an evaluation of overall
productivity in the long run is presented.

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                           SECTION VII

                     LONG-TERM CONSIDERATIONS
     Major projects such as the large-scale reuse of sludge on the
land have long-term implications which are often different from (and
sometimes far more significant to environmental  parameters than)
those initially envisaged.

     The state of knowledge on precise impacts of sludge reuse on
land is in the state of infancy.  Thus it is relatively difficult
to determine accurately the short-term effects (such as water pollu-
tion, public health hazards, air pollution, food chain disorders,
etc.).  There is even less basis for quantifying long-term effects,
which may be far more pernicious and pervasive than short-term im-
pacts, as a whole.  By the same token, the beneficial  long-term ef-
fects that can now be described only generally and qualitatively
may in time prove to have been totally underestimated or grossly ex-
aggerated.

     The very unknown nature of future cumulative impacts should be
ample warning to proceed with caution, to use sludge on lands where
known impacts are minimal (such as sod farms, mine spoil sites and
dry farms) and to avoid those where we now know the impacts can be
significant (such as home gardens and farms growing crops consumed
directly).  The transitional state of knowledge about sludge reuse
impacts also makes it extremely important that the planned and neces-
sary additional monitoring activities on all environmental parameters
be implemented rigorously and diligently to provide early warnings
of hazardous conditions which may be developing.

ADVERSE IMPACTS THAT CANNOT BE AVOIDED

Sludge Drying and Distribution Site

     Disturbance of 240 Hectares [600 Acres]
     of Soil —

     The destruction of soil profile to create the drying basins can-
not be mitigated.  Once the natural  soil  strata are destroyed, they
cannot be reconstituted, nor can they be restored to those that were
formed under natural  soil-forming conditions over geological time.
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      Destruction of Wildlife Habitat—

      Most of the 800-hectare [2000-acre] drying and distribution
 site will be irretrievably lost as wildlife habitat.

      Salt Movement Toward Groundwater Table--

      Approximately 160 metric tons [180 tons] of salts will  leach
 each year from beneath the sludge drying basins under present de-
 sign conditions.

      Nitrate Pollution of the Groundwater
      Reservoir—

      Unless further research and possible procedural  adaptations can
 assure complete denitrification at the bottom of the  drying  basins,
 pollution of the groundwater by nitrates leaching from the sludge
 drying basins will  be unavoidable under present design conditions.

 Land Application Sites for Recycling  Sludge

      Salt Accumulation in the Region--

      The soluble salts in the sludge  constitute a cumulative,  con-
 servative (i.e.  not subject to breakdown)  pollution of the soils
 and waters of the whole region.   Their dispersal  over a very large
 area,  as expected in the agricultural  scheme,  only delays the  time
 at which their  increasing regional  concentration  will  become per-
 ceptible.   The  time frame for such  accumulation will  probably  be a
 few hundred  years.

      Exposure of  Burrowing  Animals  to
      Pathogens and  Toxic  Elements—

      No  effective long-term mitigation measures exist to prevent
 burrowing  animals from possible  exposure to pathogens  and trace  ele-
 ments by ingestion  or  direct  contact.

     Mismanagement  and Consequent
     Unmitigated  Adverse  Effects--

     Under present  plans, no  firm controls on  the  ultimate users of
 the sludge are envisioned.  The  possibility is  very real that  some
 of the recipients will  fail to include recommended mitigative measures
 in their sludge use activities.  This will cause all  the negative
 impacts enumerated  in  Section VI, under Land Application in Sludge
Recycling Areas, to  be  threats to the region.
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Lowry Bombing Range Sludge Disposal
Area (No Action)

     Salt Accumulation in Soils--

     No mitigation measures exist for the addition and accumulation
of inorganic salts in the soils under present applications  rates
and conditions.

     Nitrate Pollution of Groundwate'r—

     At the current very high annual  application rates, far more
nitrogen is introduced into the soil  than can be utilized by the
plants.  The balance is partly denitrified and partly leached—with
the occasional rainwaters—below the root zone and toward the ground-
water table.  The impact upon groundwater quality will not be evi-
dent for many decades because of the very slow rates of unsaturated
flow of water.  But eventually, perhaps in 50 to 100 years, impacts
will begin to appear.  It will then  take many more decades to re-
verse the trend.

     Ingestion and Direct Contact with Sludge
     by Burrowing Animals—

     No effective long-term mitigation measures exist to protect
burrowing animals from the possible  exposure and accumulation of
sludge constituents by ingestion or  direct contact.

     Exposure of Domestic Grazing Animals to
     Heavy Metals Accumulation, Viable Pathogens
     and Parasites--

     Under present practices, domestic livestock graze the sludge-
amended fields without restriction,  ingesting sludge along with soil
particles which comprise about ten percent of their regular diet.
To the extent that the "no-action" alternative implies continuation
of this and other existing practices, endangerment of animal  health
and the subsequent food chain impact are unavoidable.

     Waste of Nutrient Resources—

     No mitigation measures exist for the loss of nutrient resources
under a high-annual-rate sludge application program, or when sludge
is landfilled under emergency circumstances.

IRREVERSIBLE AND IRRETRIEVABLE RESOURCE COMMITMENTS

     Four main resource commitments  are involved in the proposed
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  project.

  Destruction of Soil Profile

      Destruction of the soil profile on 240 hectares [600 acres] of
  land at the site of the proposed drying basins is irreversible.
  These areas would be forever altered as agricultural areas with  their
  characteristic soils.

  Energy Use

      Commitment of fossil  fuels to produce energy for treatment, pipe
  transport, trucking and other sludge handling  processes  is necessary
  and irretrievable.   The total value of this commitment for the pro-
  posed action has been estimated to be about eight million KWH per
 year.  However, it is estimated that total savings in energy  use accom-
  plished by implementing alternative 2 (compared  with the "no-action"
 alternative) amount to at  least 28 million KWH per year.

 Groundwater Use as  Receiving Medium

      Commitment of  the groundwater reservoir as  final  repository of
 soluble salts  and nitrates leached from the applied sludge is im-
 plicit  under present design conditions  for the sludge drying  and dis-
 tribution  center.   Over several  centuries, salt  accumulations in the
 groundwaters will gradually become increasingly  appreciable.  It is
 a slow  but inevitable  process that can  only be corrected  by nature
 over a  similar length  of time after cessation of land  application
 operations.

 Application  Site  Soil  Commitment

      Commitment of  the  soil  root zone as a final  repository of heavy
 metals  (and  in  some  locations  soluble salts) in  the  sludge is inevit-
 able as  long as sludges  continue to  contain these materials.  This
 allocation of  the soil  resource is  irreversible  in  the sense that up-
 on  completion  of  the land  application it will take many centuries of
 continuous cropping  to  remove  the  heavy metals,  through gradual   up-
 take, from the soil.

 RELATIONSHIP BETWEEN SHORT-TERM USES OF THE HUMAN ENVIRONMENT AND
 THE  MAINTENANCE AND  ENHANCEMENT OF LONG-TERM PRODUCTIVITY

     Tne land recycling proposal by Metro will  probably have a dura-
tion of 25 to 50 years.  This is a  rather long  period of  time, given
the rapidity of change in today's society.   Nevertheless, it is  a
fair and important question to ask  what the implications  of the  proj-
ect may be for  the next few hundred years—with regard to the  soils,
                               194

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the water and other areas of human environmental  concern.

Conservation of Non-Renewable
and Renewable Resources

     Such an evaluation can begin with the baseline  of  how the  pro-
posed system compares with the existing Metro sludge handling and
disposal system.  At present, high doses of lime, ferric  chloride
and polymers are necessary to obtain a dry enough sludge  for truck
hauling.  Furthermore, the dewatering and trucking operations are
fairly energy-intensive, requiring the use of electricity and fos-
sil fuels.

     The Metro proposal represents a positive step in conserving
natural resources by eliminating the need for chemicals.   Over  a
50-year period, more than 200,000 metric tons [220,000  tons] of
ferric chloride and 450,000 metric tons [500,000  tons]  of lime
could be conserved, along with a smaller tonnage  of  complex fossil-
based polymers.  These are chemicals that have little or  no value
to Denver area soils or in the landfills.

     Overall, there is a net energy saving with the  Metro proposal
of at least 8 million KWH per year.  While this overall amount  rep-
resents a small fraction of the total energy used in the  Denver
metropolitan area, it nonetheless represents a significant step
toward an energy efficiency and conservation ethic in wastewater
management.  The chief purpose of chemicals and energy  in inputs
to the sludge handling process is stabilization and  drying of the
sludge.  In the proposed system, anaerobic digestion is used in
lieu of chemicals and energy to stabilize the material; the pro-
posed air-drying process represents a shift toward the  use of solar
energy in the drying basins, replacing mechanical dewatering sys-
tems, which require much energy, derived from use of non-renewable
fossil fuels.  Solar energy is an inexhaustible replacement for
these rapidly diminishing fossil fuels.

     In the long term, the recycling of nutrients to the  soil rep-
resents a forward-looking step for a society that will  have to  rec-
ognize the finite limitations of its natural resources.  At present
the bulk of our commercial fertilizers is produced from fossil
fuels, particularly natural gas.  While future sources  of fertilz-
er (especially nitrogen fertilizers) will probably include coal,
this, too, is a fossil fuel which has its limits.^  If nitrogen
that has already been fixed (that is, made chemically reactive, as
is the case with amino acids, proteins, nitrates, ammonia, etc.
found in sludge) is reused, society will be able  to  make  much fur-
ther use of the resources for which there are no  substitutes.
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      At present, the primary source of  phosphorus  fertilizer  is de-
 posits of phosphate that are extremely  limited.  Because  phosphates
 in wastewaters are concentrated in sludge as  a result  of  the  treat-
 ment process, land recycling can be an  important long-term mechanism
 for reuse of this element,  providing soils with one of the macronu-
 trients essential for crop  production.

      A third long-term benefit of land  application of  sludge  from
 the Metro system is its effect on soil  structure.  Sludge contains
 large amounts of organic matter; in semi-arid areas of the western
 United States, where soils  are poorly developed and are high  in
 clay content, the addition  of organic matter  to the soil mass im-
 proves the friability of the soil  and increases its water-retention
 capability.   Ultimately the soil becomes  more porous and allows
 greater root penetration.   Agricultural experts usually warn against
 depletion of the organic matter in soils  through exclusive use of
 commercial  fertilizers.  The Metro project could reverse this trend
 by recycling carbonaceous matter to the soil.

 Potential  Cumulative Long-Term Environmental Damage

      A long-term view of the Metro proposal must include potential
 harmful  effects.   Because sludge contains  elements that may be toxic
 or that may  occur in combinations  that are  harmful, the potential
 exists for  some  long-term damage to  the productivity of soils for
 growing  crops.

      Many of the trace  elements  of  concern  (zinc,  copper, iron, etc.)
 are micronutrients  when found  within appropriate ranges of available
 concentration in  the soil.   It  is  tneir availability in excessive
 quantities that  can  produce  toxic  or  inhibiting effects on plants.
 Growing  plants continually remove  small  quantities of  these elements
 from the soil  as  they are cropped,  but this removal rate is far too
 slow to  be expected  to  remedy  the  effects of rapid additions of tne
 elements  through  sludge  application—until centuries after applica-
 tion has ceased.

     Another  undesirable aspect  of  sludge application  is the addi-
 tion of  salts  to  the soil profile.  Over a long period of time,
 salts  can have an inhibitory effect on plant growth.   This problem
 is  not confined to the Metro sludge operation but  is  common to all
 irrigated agriculture.   Increased salinity of soils has an extreme-
 ly  harmful effect on the food-producing  capability of a region.  It
 is  generally  recognized  in irrigated agriculture  that proper long-
 term maintenance of an  irrigated soil includes a  leaching  require-
ment, for flushing these salts below the root zone.  This  is accom-
 plished through application  of additional  irrigation  water,  which
cofTinonly is subsequently collected in subsurface drains.  While
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potential soil salinity can be remedied by leaching and  drainage
in  irrigated agriculture, its occurrence on nonirrigated farms as
a result of sludge addition would be inevitable.

     Salts can also become contaminants of the groundwater resource.
On  any given sludge application area, the total  annual  salt load
from applied sludge will be fairly small.  It is at the  sludge dry-
ing and distribution center that the greatest potential  for effects
on  groundwater can occur, hence the need for lined  basins and  other
mitigative measures.

     The chief measure for avoiding the detrimental  long-term  ef-
fects of soil salinization and heavy metal  accumulation  is limita-
tion of the amount of sludge applied to any one area to  what is
considered safe for that type of soil and land use.   Recommended
safe levels are still somewhat tentative; any long-term  assessment
of  tnis project must recognize that some effects may conceivably
occur in a manner different from that stated here.   However, assum-
ing that no change in sludge heavy metal content will  occur, there
is  nothing at present to indicate that any completely irreversible
damaging effects on productivity of the soil, through the proposed
sludge application system, might occur.

     What is most critically needed for the future  is a  research
program to find out what can and will happen on various  soils  with
applications of sludge.  Maximum allowable heavy metal  loading
rates (hence sludge application limits) may have to be adjusted
downward or upward as experience with actual sludge application be-
comes available.  EPA feels that the limits so far  recommended rep-
resent a conservative approach to protection of the soil.

The Long-Term Environmental Perspective

     EPA feels that, viewed from an overall perspective, this  proj-
ect can put into action the goals of the National Environmental Pol-
icy Act.  Although that part of iNEPA requiring environmental impact
statements has received the greatest attention, it  should be remem-
bered that the basic intent of NEPA is a national environmental pol-
icy integrating the actions of people with their environment.   One
item in particular stands out in articulating this  policy in the
Act which the proposed project can help achieve:

     10(b)(6)...[to] enhance the quality of renewable resources
     and approach the maximum attainable recycling  of depletable
     resources.

     The extent to which the proposed project can increase use of
renewable resources (such as nutrients, organic matter and solar
energy) while decreasing dependence on nonrenewable chemicals  and
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fossil  fuels  is considerable.  If the additional measures recommended
to protect against untoward effects .(such as groundwater contamina-
tion and heavy metal accumulations) are  included, EPA believes that
this project  can become a valuable pioneering effort toward building
a society in  which recycling and resource conservation are a way  of
life.
               te fatad 
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     An important provision of the National En-
vironmental Policy Act is that during the EIS
process responsible public agencies and the pub-
lic must be provided ample opportunity to parti-
cipate and make contribution to the EIS.   This
Section is a brief report of the extent and na-
ture of such involvement in the process of prep-
aration of the Draft EIS.

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                           SECTION VIII

        COORDINATION WITH AGENCIES AND PUBLIC INVOLVEMENT
GOVERNMENTAL AGENCIES

     During preparation of this Draft EIS, regular contact was main-
tained with the various public agencies charged with responsibili-
ties for the environment, waste management, public health, food safety,
water supplies, agricultural production, soil  conservation and other
public concerns related to the project.  Among the agencies whose re-
cent, current and planned activities were monitored in relation to
sludge management are:

     Various internal EPA units
     Metro Denver Sewage Disposal District No. 1
     Denver Regional Council of Governments
     Colorado Department of Health
     Adams County Commissioners
     USDA Soil Conservation Service
     U.S. Food and Drug Administration
     U.S. Bureau of Reclamation

     The Preliminary Draft EIS, prepared by Engineering-Science, Inc.
in November, 1975 was reviewed by the EPA and local agencies dir-
ectly involved with the proposed project.  The comments received from
their review have been of value in upgrading the present Draft EIS.

PUBLIC INVOLVEMENT

     The proposed Metro Denver sludge management program has elicited
significant public reaction.  Some of the reaction was solicited by
the District through public meetings and formation of a Citizens'
Advisory Committee, formed in 1972, consisting primarily of represen-
tatives of interested agencies.  Interested groups and property owners
near the proposed site were also represented.  The members of  the com-
mittee were:

     Beverly Fleming        Keep Colorado Beautiful  (Chairwoman)
     Gary Eaton             Adams County Engineering
     Bob Fleming            Adams County Planning
     Alan Foster            Denver Regional Council of Governments
                               199

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      Jim Fowler              Sierra Club, Enos Mills Group, Denver
      William Gahr            Colorado Department of Health, Engineer-
                                ing and Sanitation Division
      Mike Gansecki           U.S. Environmental Protection Agency
      Jack Haines             Adams County
      Richard Heaton          Denver Water Board
      Bernard Korbitz         Presbyterian Medical Center, Department
                                of Medicine
      Glenn Kreag             CSU Extension Service, Adams County
      Fred Matter             Colorado Department of Health, Water
                                Quality Control Division
      Rodney Preator          Soil Conservation Service
      Elizabeth Richardson    League of Women Voters
      Steve Rohlf             City of Commerce City
      Robert Sandquist        Adams County
      Calvin Tupps            Property owner in proposed project  area
      Way!and Walker          City and County of Denver Planning  Office
      Bob Wardell              CSU Extension Service, Adams County
      Ann Ziegler             Property owner in proposed project  area
      Bob Ziegler             Property owner in proposed project  area

      While  the  reactions of environmentalists and public agencies
 were generally  favorable, the public  meetings with citizens of ru-
 ral  Adams County  showed a strong  resistance to locating the site in
 their vicinity.   Earlier plans  to locate  District facilities in  Weld
 County  had met  with similar resistance.   The 1972 meeting in Bennett--
 a  small  town  in  eastern Adams County—drew about  80 persons.  The
 strongest opinions  of those attending  the Bennett meeting were the
 following (Reference 8):

      (1) The  sludge application  site  should  not be located in Adams
 County.

      (2) More experimentation should  be conducted  before committing
 a  large  land area to sludge application.

      (3) The consensus  was  that sludge application  was  not approp-
 riate for dryland wheat farming.

      (4) Subsurface  injection of  sludge would  be  preferred  rather
 than spraying or other  means  of spreading  on  top  of the  ground.

     A petition was  submitted at  this meeting  opposing  location  of
 the sludge application  in Adams County.

     Following the Bennett meeting and a  follow-up meeting  at the
Adams County Fairgrounds, and on  the advice of  the  Citizens' Advi-
sory Committee, the  project was modified  to overcome several of  the
                             200

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most serious objections.  The revised project was  presented  in  the
March 1974 report "Agricultural  Reuse Program" (Reference  5).   Citi-
zens and Commissioners of Adams  County,  however, still  expressed
opposition to locating the project in Adams  County.   At the  four  pub-
lic meetings in 1974, concerns were again expressed  about  possible
condemnation of the land required for the site,  potential  odor  prob-
lems, the feasibility of marketing the sludge, land  devaluation and
the visual aspects of the facilities.  The major outcome of  this
public involvement in the project was its influence  on  the site selec-
tion study.  The relatively isolated site finally  selected (site  B-2
shown in Figure 2) was recommended in large  part to  minimize adverse
socio-economic impacts and public opposition.

     In summary, public involvement in the project since 1972 has in-
cluded seven sessions of the citizens' Advisory Committee  and seven
well-attended public meetings (with 75 participants).  Persons  at-
tending the public meetings were antagonistic towards having the  pro-
posed project located near them  in Adams County.   The substantive
issues brought up (odors, public health  hazards, water  quality  im-
pacts, etc.) are treated elsewhere in this report.  Viewed simply
from the point of view of public opinion indices,  the meetings  dis-
play a negative view of public opinion toward the  project.  However,
these views may be unrepresentative since those believed to  have  ob-
jections to the project were contacted for the public meetings, and
the meetings were held near the  areas of greatest  opposition to the
project.

     A meeting held with the Adams County Commissioners as part of
the EIS process (Reference 83) showed that the Commissioners gen-
erally reflected the views of their constituents at the public  meet-
ings.  While they were not opposed to the proposed project in prin-
ciple, they wished to be more fully assured  that potential environ-
mental degradation had been adequately studied, that Metro Denver was
not going to exploit Adams County and that the citizens of Adams
County were not being treated in a high-handed or  arbitrary manner.

     Environmentalist groups have been in favor of the proposed pro-
ject, generally viewing it as a  beneficial reuse of a resource.  It
has also been favorably received by the general public (since except
in the case of a very few people, the project is located near some-
one else).

     Recent contacts with concerned parties have shown that the gen-
eral attitudes described above are still prevalent at the time of
this study.  The farmers of Adams County have on the whole remained
opposed to the proposed project (References 84, 70).

     Some farmers within a 32-km [20-mile] radius of the drying sites
have expressed a desire to use the dried sludge (References 85, 86).
                              201

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 Some have told the District that they are  interested  in  using the
 sludge but prefer anonymity because the  project  is  so controversial
 in this area.  A sampling of some of the favorable  responses from
 more distant areas is given in Appendix  F.

 Public Reaction to Drying and Distribution  Site

      The future project implementation in  the area  of the drying and
 distribution site will  probably produce  significantly adverse public
 reactions.  One part of this expected impact is  due to the rural/urban
 difference between the  sludge-generating and sludge-receiving areas.
 If the residents of Adams County feel  powerless  to  prevent, and are
 unwilling to accept, the project proposed  by the more populous region
 to the west, public resentment will  be inevitable.

      A second reason to expect adverse reactions is the  history of
 such  reactions to Metro Denver in  Adams  County.  Opposition appears
 to have hardened after  years  of altercations.  Much of this opposi-
 tion  is perhaps  inevitable  with projects of this sort: however, even
 many  sympathetic to the project have  said that in the past Metro Denver
 public relations programs have left much to be desired (Reference 39).
 It will  be difficult though not impossible to reverse this unfavor-
 able  image.   The litigation between Metro Denver and  Adams County con-
 cerning jurisdiction over the  proposed project will probably not im-
 prove relations,  regardless of its eventual outcome.   Future litiga-
 tion  over condemnation  of land and rights-of-way would be probable
 (Reference 113).

 Public  Reaction  to  Land Application Sites

      While a  generally  unfavorable reaction tov/ard  the project can be
 expected,  at  least  initially,  adverse reactions against  particular
 users of  the  dried  sludge are  not expected.  A typical example of the
 reasons for  this  can  be seen  in  the case of a representative farm
 studied east  of  Platteville (Reference 85) in Weld County.  The farmer
 involved  is  interested  in using  the dried sludge from Metro and does
 not expect any problem  with his  neighbors.   His farm  is  large—as are
most  farms in  this  general  area—and the relative remoteness from the
 public makes  nuisance conditions unlikely.   This particular farmer
 has had experience with  similar  uses of sludge in Denver on lawns
 (about 30 years ago) and therefore sees no problem with using it now.
He thinks  that odors are not a problem and that some  neighboring
farmers are using smellier materials on their own land right now (e.g.,
heat-treated chicken manure from a nearby chicken farm).   Such ma-
nure applications are considered an accepted part of  farming opera-
tions.  Finally, he has farmed his land for 30 years and is confident
that other fanners will  generally respect his right to conduct his
operation as he judges best.
                              202

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w
 h
•I

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     References listed in this Section include
published material, unpublished reports and
articles, personal communications,  (telephone,
visits, letters, etc.), meeting notes and other
sources of data.

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                           SECTION IX

                           REFERENCES
1.   U.S. Environmental  Protection  Agency,  "Grant  Regulations  and
     Procedures - 30.420-6 Conservation  and Efficient  Use  of Energy",
     Federal Register, July 1975.
  4
2.   Colorado Department of Health,  Water  Quality  Control  Commission,
     "Water Quality Standards  and  Stream Classification,  Denver,
     Colorado", June 19, 1974.

3.   Martin, W. J.  and J.  D.  Boyle,  "Alternatives  for  Disposal  for
     the Metropolitan Denver Sewage  Disposal  District  No.  1",  pre-
     sented at Second National  Conference  on  Municipal  Sludge  Manage-
     ment Disposal, W18-20, Anaheim, California, August 1975.

4.   CH2M HILL, "Sewage Treatment  Plant Expansion  -  Predesign  Study",
     for Metropolitan Denver Sewage  Disposal  District  No.  1, April
     1972

5.   CH2M HILL, "Agricultural  Reuse  Program", for  Metropolitan Denver
     Sewage Disposal District No.  1, March 1973

6.   CH2M HILL, "Metro Denver District Sludge Management,  Volume  II,
     Alternative Systems", February  1975.

7.   Brehany, John  J., Project Manager for Ralph M.  Parsons  Co.,  Per-
     sonal  Communications, 19 September and 27 October 1975.

8.   CH2M HILL, "Metro Denver District Sludge Management,  Volume  IV
     Environmental  Assessment", February 1975.

9.   Black and Veatch, "Water Quality Management Program,  Volumes I
     through IV", for Denver Regional Council of Governments,  May 1974.

10.  U.S. Soil Conservation Service, "Soil Survey  of Adams County,
     Colorado", October 1974.

11.  Officials of NOAA, U.S. Department of Commerce, Climates  of  the
     States, Volume II, Water Information  Center,  Inc., Port Washington,
     New York, 1974.
                              203

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 12.  U.S. Department of Commerce,  "Decennial  Census of United States
      Climate - Climatic Summary of the  U.S.  - Supplement for 1951 -
      1960, Climatography of the U.S., No.  86-5, Colorado", Washington,
      D.C., 1964.

 13.  U.S. Department of Commerce,  "Climatological Data for the U.S.:
      Colorado",  1962-1975.

 14.  U.S.D.A., Soil  Conservation Service,  "Soil Survey of Arapahoe
      County, Colorado", March  1971.

 15.  U.S. Geological  Survey,  "Generalized  Surficial Geologic Map of
      the Denver Area,  Colorado", Miscellaneous Geologic Investiga-
      tions,  Map 1-731, 1972.

 16.  Smith,  Rex 0.,  Paul  A.  Schneider,  Jr., and Lester R. Petri,
      "Ground Water Resources of the South  Platte River Basin in West-
      ern Adams and Southwest Weld  Counties, Colorado", U.S. Geological
      Survey-Water Supply  Paper  1658, 1964.

 17.  Pearl,  Richard  Howard,  "Geology of Ground Water Resources in
      Colorado", Colorado  Geological Survey, Department of Natural
      Resources, Denver, 1974.

 18.   Schwochow, S. D.,  R. R. Shroba, and P. C. Wicklein, "Sand, Gravel
      and  Quarry Aggregate Resources, Colorado Front Range Counties",
      Colorado  Geological  Survey, Department of Natural Resources, Den-
      ver,  1974.

 19.   Adams, W. and Ed Mansfield, "Engineering Geology Case Histories
      No.  8, Engineering Seismology:  The Works of Man", Prepared for
      the  Division on Engineering Geology of the Geological  Society
      of America, Boulder, Colorado, 1970.

 20.   Price, Don and Ted Arnow,  "Summary Appraisals of the Nation's
      Ground-Water Resources - Upper Colorado Region", U.S.  Geological
      Survey Professional Paper 813-C,  1974.

 21.  McConaghy, J. A. et al., "Hydrogeologic Data of the Denver Basin,
     Colorado", U.S.  Geological Survey,  Denver, 1964.

 22.  U.S.D.A., Soil  Conservation Service,  Greeley Office,  "Official
     soil series descriptions and interpretations for selected soils
     in southern Weld County", 1971-1974.

23.  U.S. Geological  Survey, "Urban Corridor", 1975.

24.  Cary, Merritt,  "A Biological Survey of Colorado", U.S.D.A.  Bureau
     of Biological  Survey -  North American Fauna  £33,  1911.


                              204

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25.  U.S.D.A. Soil  Conservation  Service,  "Natural  Vegetation of
     Colorado", Map and legend,  October  1972.

26.  Phillips Petroleum Company, Pasture  and  Range Plants.  Bartles-
     ville, Oklahoma, 1963.

27.  U.S. Department of the  Interior,  Fish  and  Wildlife  Service,
     "United States List of  Endangered Fauna",  May 1974.

28.  Neidrach, R. J., and R.  B.  Rockwell, Birds of Denver and Moun-
     tain Parks, Denver Museum of Natural History  Popular Series  No.
     5, 1959.

29.  Peterson, Roger Tory, A Field Guide  to Western Birds,  Houghton
     MiffTin Company, Boston, Mass.,  1961.

30.  Yocum, C., W.  Weber, R.  Beidleman and  D. Malick, Wildlife and
     Plants of the Southern  Rocky Mountains,  Naturegraph Publishers,
     Healdsburg, California, 1969.

31.  Beckman, W. C., Guide to the Fishes  of Colorado, University  of
     Colorado Museum, Boulder, Colorado,  1963.

32.  Rodeck, H. G., Guide to the Mammals  of Colorado, University  of
     Colorado Museum, Boulder, Colorado,  1963.

33.  Beidleman, R.  G., Guide to  the Winter  Birds of Colorado,Univer-
     sity of Colorado Museum, Boulder, Colorado, 1963.

34.  U.S. Department of the  Interior,  Fish  and  Wildlife  Service,
     "State Lists of Endangered  and Threatened  Species of the Con-
     tinental United States", Federal  Register, Vol. 40, No. 127,
     July 1, 1975.

35.  Colorado Legislature S. B.  142, "Nongame and  Endangered Species
     Conservation Act", 1973.

36.  Tully, R. J., "Endangered Wildlife", in  Colorado Outdoors,
     Colorado Division of Wildlife, March-April 1973.

37.  State of Colorado Department of Health,  Air Pollution  Control
     Commission, "Regulation No. 2 in Odor  Emission Regulations",
     April 20, 1971.

38.  Benci, John, Assistant Climatologist,  Department of Atmospheric
     Science, Colorado State University,  personal  communication  on
     September 3, 1975.
                              205

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 39.  Berve, Donn W., Chief of Environmental  Health  Services, Tri-
      County District Health Department,  personal  communication on
      September 4, 1975.

 40.  Park Superintendant II,  Denver  General  Parks Department, per-
      sonal  communication on September  4,  1975 and October 9, 1975.

 41.  Brown, Larry,  Environmental  Control  Engineer,  Climax Molybdenum
      Company,  letter to  William Martin of Metro Denver, July 25, 1975.

 42.  Works  Project  Administration in the  State of Colorado, Colorado:
      A Guide to the highest State, Hastings  House,  New York, 1941.

 43.  Community Resource  Development Cooperative Extension Service,
      "Adams County, Colorado:   County  Information Service", Colorado
      State  University, Fort Collins, March,  1974.

 44.  Nichol, Ron, Associate Planner, Department of  Planning and De-
      velopment,  Commerce City,  Colorado,  written communication on
      September 13,  1975.

 45.  Adams  County Board  of  Commissioners, "Comprehensive Plan: Adams
      County, Colorado",  1975.

 46.   Adams  County Planning  Commission, "Zoning Regulations:  Adams
      County, Colorado",  1975.

 47.   Metropolitan Denver  Sewage Disposal  District No. 1, "Long Range
      Planning  Study: 1974", May 31, 1974.

 48.   Amax Inc.,  "Comprehensive Plan for Land Reclamation and Stabili-
      zation at the  Urad Mine", 1975.

 49.   Denver Regional Council of Governments, "Population Change in
      the Seventies",.published pamphlet,  1975

 50.   Henley, Jan, Economic Analyst, Metropolitan Denver Sewage Dis-
      posal District No. 1, personal communication on October 3, 1975.

 51.  Thompson,  Arthur, Statistician,  State of Colorado, Office of
     State Planning, personal  communication  on October 1,  1975.

52.  Rail, Ellis, Communications Director, Denver Regional  Council
     of Governments, personal  communication  on October 1,  1975.

53.  Johnston,  William, Socio-Economic  Analyst,  Denver Regional
     Council of Governments, personal  communication  on October 7,  1975.
                            206

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54.  Denver Regional  Council  of Governments,  "Appraisal of the DRCOG
     Policy Population Forecast",  August  1975.

55.  CH2M HILL, "Metro Denver District Sludge Management, Vol.Ill
     Agricultural  Reuse System Predesign",  January  1975.

56.  Denver Regional  Council  of Governments,  "Regional  Simplified
     Base Map", revised December 1971.

57.  Colorado Department of Highways,  Planning  and  Research  Division
     in cooperation with the U.S.  Highway Administration, Bureau of
     Public Roads, "General Highway Map,  Adams  County,  Colorado",
     revised November 20, 1968.

58.  Kochevar, Robert, Traffic Engineer,  Road and Bridge Department,
     Adams County, Colorado, personal  communication on  August 29,  1975.

59.  American Association of State Highway  Officials,  "A Policy of
     Geometric Design of Rural Highways", revised 1973.

60.  Colorado Department of Highways,  "Colorful  Colorado", 1974.

61.  Colorado Legislature, "Solid Waste Disposal Sites  and Facilities
     Law", Chapter 36, Article 23, CRS 1963 as  amended  by Senate Bill
     132, July 1,  1971.

62.  Colorado, Colorado Revised Statutes, pertaining  to Metropolitan
     Sewage Disposal  Districts, 1974.

63.  Korbitz, William, Manager, Metropolitan Denver,  meeting with
     management and staff personnel, July 18, 1975.

64.  United States Department of Commerce,  Bureau of  the  Census,  "1970
     Census of Population and Housing, Denver Colorado SMSA", March
     1972.

65.  United States Department of Commerce,  Bureau of  the  Census,  "1970
     Census of Population, Colorado General Social  and Economic
     Characteristics", February, 1972.

66.  McDonald, F.  M., Deputy Assessor, Adams County,  Colorado,  personal
     communications on September 8, and 11, 1975-.

67.  Flanagan, Linda, Research and Analysis Section,  Colorado Depart-
     ment of Employment, personal communication on  October  24,  1973.

68.  Adams County Sheriff's Department, Administrative Officer,  Brigh-
     ton, Colorado, personal communication on October 14,  1975.
                              207

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 69.  Mr. Fitch, Fire Chief,  Brighton  Fire  Department,  Unit 500,
      Brighton, Colorado, personal  communication on October 14, 1975.

 70.  Schwing, James E., CH2M-Hill, Denver, Colorado, personal
      communication on October 2 and 17, 1975.

 71.  VanBeek, Marvin,  U.S. Disposal Systems, Commerce  City, Colorado,
      personal communication  on  October  1,  1975.

 72.  Rugtles, Dorothy, Engineering Technicican, and  Union Rugtles,
      Engineering  Technicican, Union Rural  Electricity  Company,
      Brighton, Colorado, personal  communication on October 2, 1975.

 73.  Metropolitan Denver Sewage  Disposal District No.  1, "1976 Budget,
      1975-1980 Program", August  19, 1975.

 74.  U.S.  Department of  Commerce,  Bureau of the Census, "Statistical
      Abstract of  the United  States",  1972

 75.  Ventura  County  Planning Department, "Ventura County Superregional
      Transportation Study, 1974:   Environmental Evaluation, part 1",
      1974.

 76.   Mitts, David, Production Operations Manager, Bendini Fertilizer
      Company,  personal communication on October 6, 1975.

 77.   Martin,  William, Metropolitan Denver Sewage Disposal District
      No. 1, personal communication on October 1, 1975.

 78.   Colorado  Legislature, "Solid Waste Disposal Sites and Facilities
      Law", Chapter 36, Article 23, Section 5, CRS 1963 as amended by
      Senate Bill  132, July 1, 1971.

 79.   U.S. Environmental  Protection Agency, "Technical Bulletin-Muni-
      cipal Sludge Management Environmental Facors", preliminary draft,
      EPA 430/9-75XXX, July 1975.

 80.   Council on Environmental Quality in association with the Environ-
     mental Protection Agency, "Evaluation of Municipal Sewage Treat-
     ment Alternatives", February 1974.

81.  Chaney, Rufus L, "Land Application of Sewage Sludge, Benefits
     and Probe!ems", Proceedings of the 1973 Lime and Fertilizer Con-
    ference,  5:15-23,  1973.

82.  Dotson, G. K., "Constraints to Spreading Dewage Sludge on Crop-
     land", from "News  of Environmental  Research in Cincinnati",
     Environmental Protection Agency,  May 31, 1973.
                             203

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83.  Covy, James, Jerry Grant,  John C.  Campbell,  Adams  County Com-
     missioners; Ralph Anderson,  former Adams  County  Commissioner;
     and Morris Lubow, Adams County Attorney,  meeting on  September
     4, 1975.

84.  Kreag, Glen, Adams County  Cooperative  Extension  Service, per-
     sonal communication on September 29, 1975.

85.  Olin, Ray, Weld County Farmer, personal communication  on October
     9, 1975.

86.  Sharp, William, Adams County farmer, personal  communication  on
     July 30, 1975.

87.  Romero, J. C. and E.  R. Hampton, Colorado Division of  Water  Re-
     sources and U.S.. Geological  Survey,  "Maps showing  the  approxi-
     mate configuration and depth to the  top of the Laramie-Fox Hills
     Aquifer, Denver Basin, Colorado",  1974.

88.  Baxter, John, Agricultural  Research  Specialist,  Metropolitan
     Denver Sewage Disposal District No.  1, personal  communication on
     October 1975.

89.  U.S. Department of Transportation, "Transportation Noise and its
     Control", DOT P5630.1, June 1972.

90.  Sandy's Commercial Turf Farm, Brighton, Colorado,  personal com-
     munication on October 27,  1975.

91.  Rambat, John, Reynolds Turf Farms, Brighton, Colorado, personal
     communication on October 27, 1975.

92.  New, Rex, Denver Turf Farm, Hudson, Colorado, personal communi-
     cation on October 27, 1975.

93.  Rich, Mel, Rich!awn Turf Farm, Parker, Colorado, personal  com-
     munication on October 27,  1975.

94.  Matthews, William, Matthews Sod Farm,  Brighton,  Colorado,  per-
     sonal communication on October 27, 1975.

95.  Colorado State Department of Agriculture, "Colorado  Agricultural
     Statistics, 1974 Preliminary, 1973 Final", Bulletin  1-75,  July
     1975.

96.  Pratt, P. F., "Effects of Sewage Sludge or Effluent  Application
     to Soil on the Movement of Nitrogen, Phosphorus, Soluble  Salts
     and Heavy Metals to Groundwaters", presented at 2nd  National
                              209

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       Conference on Municipal  Sludge Management  and  Disposal, Anaheim,
       California, August 18-20,  1975.

  97.  Danford, Jack, President,  Organic  Earthworm Corporation, per-
       sonal communication on August 7,  1975.

  98.  Maphis, S. W., Principal,  Briscoe-Maphis,  Inc.  Deep-six division,
       personal communication on  August 7,  1975.

  99.  State of California Air  Resources  Board, "Emissions Forecasting
       Methodologies",  July 1974.

 100.  Trammah, Joseph, Supervising  Engineer, Sewage  Treatment Plant
       Monitoring,  Los  Angeles  Air Pollution Control  District, personal
       communication on October 3, 1975.

 101.  Gerardi,  Albert, Colorado  Air  Quality Commission, personal com-
       munication on October  3, 1975.

 102.  Ulwelling, William,  "Smells in the Urban Environment", unpublished
       research  paper on  file in  the U.C. Berkeley School of Environ-
       mental  Design Library, 1972.

 103.   Meyer,  Ron,  Deputy Director of Public Works, Adams County Road
       and  Bridge Department, personal communication on October 15, 1975.

 104.   Spiegel,  John, Engineering and Enforcement Officer, Air Pollution
       Control Department,  Denver, Colorado, personal  communication on
       October 15,  1975.

 105.   Straub, Richard, Engineer,  Weld County Engineering Department,
       Greeley,  Colorado, personal communication on October 15, 1975.

 106.   Searne, Robert,  Staff Coordinator,  Mayor's  Task Force for the
       Platte River  Development Committee, Denver  Planning Department,
       Denver, Colorado, personal  communication  on October 15,  1975.

 107.   Hornback,  Kenneth E., Joel  Guttman, et. al., "Studies  in Environ-
      ment:  Quality of Life, Volume II", prepared for Office  of Re-
       search and Development, November 1973.

108.  Roll, John L., Metropolitan Sanitary District of Greater Chicago,
      personal communication on September 15, 1975.

109.  Thomas, Harold J., Manager, Mountain Bell Telephone Company,
      Aurora, Colorado, personal  communication  on October 6,  1975.
                              210

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110.  McGauhey, P.  H.,  and R.  B.  Krone,  "Soil Mantle as a Wastewater
      Treatment System",  Sanitary Engineering Research Laboratory
      Report 67-11, University of California  Press, Berkeley, 1967.

111.  Bernenson, Abram, ed.,  Control  of  Communicable Disease in Man,
      American Public Health  Association,  Washington, D.C., llth
      edition, 1970.

112.  Feth, J. H.,  "The Urban Environment", U.S. Geological Survey,
      Circular 601-1, 1973.

113.  Deline, James,  Mohaghan Farms Manager,  personal communication
      on October 2, 1975.

114.  Cohen, David  B.,  William J.  Martin and  John  Baxter, "Agricul-
      tural Reuse Program: Applied Research  and Development Budget
      (1975-76)", Metropolitan Denver Sewage  Disposal District No. 1,
      January 16, 1975.

115.  U.S.D.A., "Diagnosis and Improvement of Saline and Alkali Soils,
      Agriculture Handbook No. 60", February  1954.

116.  Chaney, Rufus L,  "Crop  and  Food Chain Effects of Toxic Elements
      in Sludges and  Effluents",  In Proceedings of the Joint Confer-
      ence on Recycling Municipal  Sludges  and Effluents on Land, U.S.
      Environmental Protection Agency, U.S.D.A., and the National
      Association of  State Universities  and Land Grant Colleges,
      Champaign, Illinois, July 9-13, 1973.

117.  Wood, Gene W.,  D. W. Simpson and R.  L.  Dressier, "Effects of
      Spray Irrigation  of Forests with Chlorinated Sewage Effluent
      on Deer and Rabbits", In Recycling Treated Municipal Wastewater
      and Sludge through Forest and Cropland, Edited by William E.
      Sopper and Louis  T.  Kardos, Pennsylvania  State University Press,
      University Park,  1973.

118.  CH2M HILL, "Metro Denver District  Sludge  Management, Volume  I:
      Summary Report",  February 1975.

119.  Mr. Frandsen, Construction Engineer, District 1, Colorado Divi-
      sion of Highways, Denver, Colorado,  personal communication on
      October 15, 1975.

120.  Kelly, George T., Supervising Architect/Planner, Metropolitan
      Sanitary District of Greater Chicago, personal communication
      on September  17,  1975.

121.  Engineering-Science, Inc. /'Pipeline  Transport of Digested Sludge
      to Strip Mine Spoil  Site for Spoil Reclamation", August  1975.
                              211

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 122.  King,  L.  D.  and  H. D. Morris,  "Land Disposal of Liquid Sewage
      Sludge:   I.   The Effect on Yield, in vivo Digestibility, and
      Chemical  Composition of Coastal Bermuda Grass", Journal of
      Environmental Quality, Vol. 1, No. 3, 1972.

 123.   Sabey, B. R. and W. E. Hart,  "Land Application of Sewage Sludge:
       1.  Effect on Growth and Chemical Composition of Plants", Jour-
       nal of Environmental Quality. Vol. 4, No. 2, 1975.

 124.   Lagerwerff, J.  V., "Heavy-Metal Contamination of Soils, in
       Agriculture and the Quality of Our Environment", American
       Association for the Advancement of Science, Washington, D. D.,
       1967.

 125.   Westfall, D., Agronomist, Great Western Sugar, Longmont, Colorado,
       personal communication on July 30, 1975.

 126.   Epstein, Eliot, "Effect of Sewage Sludge  on Some Soil  Proper-
       ties", Journal of Environmental  Quality,  4(1): 139-142, 1975.

 127.   Scott, M. L., "Trace Elements in Animal  Nutrition", In Mi erg-
       nutrients in Agriculture, Edited by J.J.  Mortvedt, P.  M.
       Giordano and W.  L.  Lindsay,  Soil  Science  Society of America, Inc.
      Madison, Wisconsin,  1972.

128.  Chaney,  Rufus L.,  "Recommendations for  Management of Potentially
      Toxic  Elements in Agricultural and Municipal  Wastes",  In Factors
      Involved in  Land Application  of Agricultural  and Municipal  Waste,
      USDA,  ARS,  Beltsville,  Maryland,  1974.

129.  Epstein,  E.  and  G.  B.  Willson, "Composting Raw Sludge", in Pro-
      ceedings  of  the  1976  National  Conference  on Municipal  Sludge
      Management and Disposal,  Anaheim,  California,  August 1975.
                             212

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                         ENVIRONMENTAL TEAM
 MICHAEL A. GANSECKI, B.S., M.S.
*BAHMAN SHEIKH-OL-ESLAMI, Ph.D.,
   P.E.
 JOHN A. DAVIS, M.S., M.I.C.E,
   P.E.
*SAMUEL B. EARNSHAW, B.A., M.A.,
   B.S.
*EMY CHAN, A.B.
 TARAS A. BURSZTYNSKY, M.S.,
   P.E.
 PATRICIA SHOWALTER, A.B.
 PHILIP N. STORRS, M.E., P.E.
 MARY STAUDUHAR, B.A.
Project Officer;  Legal  and Ju-
  risdictional  Aspects, Alter-
  natives Evaluation, Summary
Project Manager;  Agriculture,
  Soils, Water
Sanitary Engineering, Alterna-
  tives Evaluation
Vegetation, Sludge Reuse
  (Appendix D)
Fauna, Habitats,  Graphic Arts,
  Noise
Sanitary Engineering, Alterna-
  tives Evaluation
Geology
Technical Direction
Editing, Typing Supervision
 ALAN D. KOTIN, M.A.
 GEORGE A. JOHNSON, M.B.A., M.S.
*WILLIAM P. ULWELLING, M.P.H.
*JANICE HARWELL, M.A.
 SHLOMO BACHRACH, M.A.
Economics
Economics
Public Health, Socioeconomics
Socioeconomics
Socioeconomics, Coordination
  Members of the Association of Environmental  Professionals
                                 213

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•llll
•

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     This Appendix contains the cost, engineering
and environmental evaluations of basic process al-
ternatives for sludge handling and disposal by
EPA's consultant—Engineering-Science, Inc. (ES).
ES concludes that the "apparent best alternative"
is the system proposed by the Metro District.   The
Appendix also contains a detailed description of
each alternative considered.  Process flow diagrams,
with sludge quantities passing through the process
train, are presented.  Pertinent assumptions in de-
sign and cost calculations are listed.

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                          APPENDIX A

           EVALUATION OF ALTERNATIVE SLUDGE HANDLING
                     AND DISPOSAL SYSTEMS
INTRODUCTION

     In the course of its efforts to improve its sewage sludge manage-
ment practices, Metropolitan Denver Sewage Disposal District  No.  1 re-
tained an engineering consultant (CH2M Hill) to study alternative
sludge processing and disposal systems and to recommend the best  alter-
native.  The results of the consultant's work are contained in a  four-
volume report, Volume II of which is entitled "Alternative Systems"
(Reference 6).

     Part of the present study involves an independent evaluation of
the alternatives considered by the consultant, together with  others,
prior to assessment of the environmental impacts associated with  the
more promising alternatives.  The material contained in this  section
summarizes the results of this independent evaluation.   A more de-
tailed description of the alternatives, with flow process diagrams,
and their associated costs is included at the end of this appendix.

SYNTHESIS OF ALTERNATIVES

     In order to compare alternatives in an equitable manner,  the basic
principle that each system must be complete in itself was adhered to.
Thus, the complete system must take as its starting point the raw and
digested sludges at the Central Plant, and as its end a disposal  mode
that is truly final; that is, a disposal mode requiring no further ac-
tion to process or transport the sludge.

ALTERNATIVE SYSTEMS

     Sixteen alternative systems were considered, eight of them similar
to those evaluated and reported by CH2M-Hill.  For convenience, the
numbering system used in the consultant's report has been retained.
Thus, Alternatives 1A through 8 are those evaluated by CH2M-Hill.

     Alternative 1A       Existing system, waste-activated and other
                            sludges trucked to Lowry Bombing  Range for
                            landspreading
                               A-l

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 Alternative IB

 Alternative  2



 Alternative  3


 Alternative  4


 Alternative  5

 Alternative  6


 Alternative  7



 Alternative  8



 Alternative  9



 Alternative 10




 Alternative 11


 Alternative 12
Alternative 13
Alternative 14
Alternative 15
Alternative 16
 Existing system with anaerobic  digestion

 Anaerobic digestion,  pipeline transport,
   air drying and beneficial  reuse  (prod-
   uct:  100 percent  air-dried sludge)

 Filter presses,  incineration, landfill
   of ash

 Heat treatment,  vacuum filtration,  land-
   fill

 Heat treatment,  air drying,  landfill

 Heat treatment,  vacuum filtration,  in-
   cineration, landfill of ash

 Anaerobic digestion,  filter  presses,
   compost (product:   100 percent nutrient-
   enriched composted  sludge)

 Filter presses,  compost (product:   100
   percent nutrient-enriched  composted
   sludge)

 Anaerobic digestion,  centrifugation, com-
   post (product:  100 percent nutrient-
   enriched composted  sludge)

 Anaerobic digestion,  pipeline transport,
   air  drying, compost (product:  50 per-
   cent air-dried  sludge; 50  percent
   nutrient-enriched composted sludge)

 Anaerobic  digestion,  centrifugation,
   landfill

 Anaerobic  digestion,  pipeline transport,
   air  drying, landfill,  compost (product:
   33 percent air-dried sludge; 33 percent
   nutrient-enriched composted sludge; re-
  mainder  to landfill)

Anaerobic  digestion, vacuum  filtration,
   compost  (product:  100 percent nutrient-
   enriched composted sludge)

Vacuum filtration, compost (product:  100
  percent  nutrient-enriched  composted
   sludge)

Anaerobic digestion, vacuum  filtration,
  pipeline transport to  solid waste re-
  cycling plant

Vacuum filtration, pipeline  transport to
  solid waste recycling  plant
                          A-2

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     Reviewing the alternatives briefly, alternatives 1A and IB  are
variations of the existing system of processing at the Central Plant,
with truck-haul to Lowry Bombing Range for incorporation into the soil.
Alternative 2 is the sytem recommended by CH2M HILL,  slightly modified.
As evaluated by CH2M-H111, the final product of this  system was  a
stored stockpile of air-dried sludge, the presumption being that users
of the sludge would haul the product from the stockpile to the final
reuse sites.  As evaluated here, the truck-haul to the use site  is in-
cluded as part of the total system.  Alternatives 3,  4, 5, 6 and 11
are options for processing prior to landfill.  Alternatives 7, 8, 9,
13 and 14 are options for processing prior to composting and sale.
Alternatives 10 and 12 are variations on Alternative  2, but with a dif-
ferent product mix.

     Alternatives 15 and 16 are options for processing prior to  trans-
port to a regional solid waste processing plant.  The feasibility of
these alternatives is currently being studied by Ralph M. Parson, Inc.
for the Denver Regional Council of Governments.  The  alternatives con-
sidered here are based on the assumption that the solid waste process-
ing plant would be located 5 km [3 miles] distant from the District's
plant and that digested sludge, at 25 percent solids  content, would be
accepted at the processing plant at no charge to the  District (Refer-
ence 7).

COST OF ALTERNATIVE SYSTEMS

     Economic evaluation of alternative sytems which  incur future
costs and accrue future benefits, always difficult, has become increas-
ingly so in a time of severe price inflation and doubt concerning fu-
ture resource costs and availability.  In view of these difficulties,
it is not surprising that differences of opinion exist in the engineer-
ing profession vis-a-vis the costs of certain processing and disposal
activities.

     The approach adopted in reevaluating the alternatives was to ac-
cept previous cost assumptions unless it appeared that an error  of judg-
ment had been made which might have a significant effect on the  compar-
ative costs of alternatives.  After thorough review,  the earlier assump-
tions were found to be generally acceptable, an exception being  the
omission of salvage values from the cost calculations.  This omission
has been rectified in order to conform with EPA cost-effectiveness
guidelines.  A more detailed discussion of cost assumptions is included
elsewhere in this appendix.

     The presentation of system costs is prefaced by  a brief discussion
of several factors that influence the economic evaluation.
                                  A-3

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 Revenue

      All systems considered that involve beneficial reuse have a poten-
 tial for revenue generation.  However,  the market  for sewage-sludge-
 derived products is somewhat uncertain;  demand  is  low and competitive
 products are still relatively cheap and  abundant.  The potential reve-
 nues from beneficial reuse to be accrued in  the Denver area have been
 estimated conservatively on the basis of experiences in other locations.
 Because of the doubts about the marketability of the products, the cost
 of each alternative assuming no revenue  is presented in the cost tabu-
 lation together with a cost adjusted for revenue.

 Inflation

      Cost-effectiveness analysis guidelines  published by the U.S. Envi-
 ronmental Protection Agency dictate that the effect of inflation should
 be neglected in cost comparisons of alternatives.  The basis for this
 is the belief that,  although future costs will  escalate, the ability
 of the users to pay these costs  will also escalate at the same rate.
 In addition,  the discount rate used in the present-worth calculations
 is intended to take account of the  declining value of money, the cost of
 borrowed  funds and  the  opportunity  cost  of money.  Because the alterna-
 tive sludge management  systems range from those with a high initial capi-
 tal cost  and  low operating expenses to those with low initial capital
 costs  and high operating  expenses,  the role  of  inflation in the cost com-
 parison is  crucial.   For  this  reason, comparative costs are presented
 first  without  an inflationary  factor and a second time with an inflation-
 ary factor  of  8  percent.

 Sunk Costs

     A further difficulty was  encountered in establishing a basis for
 equitably comparing  the alternatives.  Recently, the District began
 implementation of a  plan  to  construct new anaerobic digesters.  How-
 ever,  some  of  the alternatives being considered do not include anaero-
 ic  digestion as  a necessary  step in the  total system.   The question
arises  whether the cost of the digesters should be regarded as a sunk
cost,  to be ignored  in the evaluation,  or (since the funds are com-
itted and construction is about  to  begin) be included  in all alterna-
ives, irrespective of the need for  this  system component.   Adopting
either  of these approaches penalizes alterantives that do  not include
anaerobic digestion.  Because of this problem,  the cost comparison was
made in two ways:  first, and most  logically, the total costs of each
system were compared, including a cost  for digestion only  where tech-
nically necessary; second, recognizing  the realities of the situation,
a comparison was made treating the digestion cost as a sunk cost.
                                  A-4

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Comparative Cost of Alternatives

     Table 1 shows the present-worth cost of ten years of operation of
each of the alternative systems.  Similar information is presented in
Table 2, but in this case the capital cost of the new anaerobic diges-
tion system is treated as a sunk cost.  A notable feature of the cost
comparisons is the apparent economic attractiveness of alternatives 15
and 16, those that involve delivery of sludge to a regional solid waste
processing facility.  It should be remembered that at this stage these
alternatives are poorly defined; the corresponding cost estimates are
inevitably lacking in precision.  Of course, the viability of these
alternatives is predicated upon the existence of a facility of this
type in the future.  Because of the uncertainty, these alternatives are
not strictly comparable with the other alternatives considered and are
neglected in the following discussion.  However, alternatives 15 and
16 are worthy of serious evaluation; further remarks on this subject
are contained in the discussion that concludes this section.

     A review of Table A-l indicates that if inflation and revenue-
generation potential are ignored then Alternative 2, the recommended
plan, is one of a group of less costly alternatives, although by no
means the least costly.  If selection were to be based on this cri-
terion alone, then Alternative 2 offers no notable economic advantages.

     Considering the uninflated cost with revenue taken as a credit,
Alternative 2 is again one of a group of less costly alternatives, but
again not the cheapest.  However, it should be noted that those alter-
natives that become significantly less expensive than Alternative 2
rely heavily upon revenue generated from sales; and, of course, doubts
exist regarding the saleability of the product.

     Turning to the cost comparison adjusted for an 8 percent inflation
rate, the advantages offered by Alternative 2 become more apparent.
Even if no revenue is accrued, Alternative 2 is the least expensive.
If in fact sludge users collect dried sludge from the processing as
assumed in the original evaluation, then the total cost of Alternative
2 will be reduced still further.

     Table A-2 shows the cost of alternative systems treating the capital
cost of anaerobic digestion as a sunk cost.  As noted previously, this
reduces the apparent cost of all alternatives that include anaerobic
digestion.  Thus the economic advantages of Alternative 2 are empha-
sized in the cost comparison.

ENVIRONMENTAL IMPACT OF ALTERNATIVE SYSTEMS

     The environmental effects of the alternative systems fall into
two general categories:  the on-site effects—that is, the effects re-
                                   A-5

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                                      Table A-l.   COST OF ALTERNATIVE SYSTEMS


                                                  (million dollars)
i
en

Present-worth cost of
Unadjusted
Alternative
1A
IB
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
without revenue
24.1
24.7
24.0
24.2
22.5
33.3
23.6
30.3
34.0
33.8
28.8
26.4
28.9
28.4
27.0
16.8
10.1
with revenue
24.1
24.7
19.3
24.2
22.5
33.3
23.7
19.6
17.0
25.9
20.5
26.4
20.7
20.5
14.5
16.8
10.1
ten years of operation

Adjusted for 8% inflation
without revenue
34.3
30.1
17.7
26.8
25.9
30.2
23.6
35.1
45.1
40.1
24.4
30.8
24.5
33.8
36.4
17.8
13.3
with revenue
34.3
30.1
10.8
26.8
25.9
30.2
23.6
19.3
20.1
28.5
12.3
30.8
12.4
22.2
18.0
17.8
13.3

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i
--J
                        Table A-2.  COST OF ALTERNATIVE SYSTEMS TREATING THE CAPITAL COST

                                       OF ANAEROBIC DIGESTION AS A SUNK COST


                                                  (million dollars)

Present-worth cost of
Unadjusted
Alternative
1A
IB
2
3
A
5
6
7
8
9
10
11
12
13
14
15
16
without revenue
24.1
18.6
17.8
24.2
22.5
33.3
23.7
24.2
33.9
27.6
22.7
20.2
22.8
22.2
30.0
10.6
10.1
with revenue
24.1
18.6
13.1
24.2
22.4
33.3
23.7
13.5
17.0
19.8
14.4
20.1
14.5
14.4
14.5
10.6
10.1
ten years of operation

Adjusted for 8% inflation
without revenue
34.3
26.4
14.0
26.8
26.0
30.2
23.6
31.4
45.1
36.3
20.7
27.1
20.9
30.1
36.4
14.1
13.3
with revenue
34.3
26.4
7.1
26.8
26.0
30.2
23.6
15.6
20.1
24.8
8.6
27.1
8.7
18.5
18.0
14.1
13.3

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 suiting directly from and at the site  of  the project components; and
 off-site effects.   Off-site effects  are the effects of the ultimate
 sludge disposal method used on the receiving environment.

      Volume IV of  the Sludge Management report to the District  (Refer-
 ence 8 in Section  IV of the main text) is an environmental assessment
 of the alternative systems.  The analysis emphasizes on-site impacts and
 concludes that Alternative 2 is the  best  option from an environmental
 standpoint.  Off-site impacts are the  subject of detailed analysis in
 subsequent sections of this report.

      An independent review of the earlier assessment of on-site impacts
 led to general concurrence with the  major conclusions presented.  The
 more significant points emerging from  the review are discussed below.

 Process Options

      Many of  the alternatives are different only in that they employ
 different methods  for stabilizing and dewatering sludge.  The direct
 environmental implications of these  different processing options are
 relatively insignificant  when compared to the environmental consequences
 of different  transportation and  ultimate disposal methods.  One excep-
 ion to this is the relative resource economy of the processing options.
 All alternatives that include vacuum filters, filter presses, incinera-
 tors or heat  treatment  systems require chemicals and fuel for success-
 ful operation.   Alternative 2, which employs anaerobic digestion, re-
 quires neither.  In  a time of doubt  concerning future energy and mater-
 ials costs  and availability,  the  processing element of Alternative 2
 offers a  significant  advantage.

 Transportation

      Alternatives  2,  10 and  12 involve pipeline transport of digested
 sludge to a remote location, while the remaining alternatives involve
 trucking  of dewatered sludge  or ash  to an ultimate disposal site.
 Pipeline  transport is superior because it consumes less energy, does
 not  involve vehicular air-pollutant emissions and does not involve
 long-term impacts upon the  community arising from traffic and noise.

 PERFORMANCE OF ALTERNATIVE  SYSTEMS

      In this context, the performance of  a sludge management system is
used as an index of  its effectiveness as  a method of residual solids
disposal.  A number of elements contribute to system performance; they
 include process reliability, susceptibility to  random physical and cul-
tural disruption (due to earthquakes, labor disputes,  etc.), suscepti-
bility to resource shortages, and permanence.
                                  A-8

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Process Reliability

     Some of the process components of the alternatives are inherently
more reliable than others in making the required changes in sludge
quality.  Anaerobic digestion and air drying, the processes employed
in Alternative 2, are well understood and widely applied.   Properly de-
signed and operated, they  are proven to be reliable.   Vacuum filtra-
tion (employed in alternatives 1A, IB, 4, 6, 13 and 14) is probably the
most reliable of the mechanical dewatering methods, followed by centrif-
ugation (employed in alternatives 9 and 11) and filter presses (used in
alternatives 3, 7 and 8).  Incineration is a reliable  process but  is
inherently more hazardous than are the mechanical processes.  Heat
treatment systems are not widely applied and have incurred some problems
in continuous operation.

Susceptibility to Disruption

     All alternatives involve processing activities at the main plant
which would be disrupted during a labor dispute; the more complex  pro-
cessing options are more vulnerable, however, due to the need for  con-
tinuous operation by skilled personnel.  Pipeline transport would  be
less likely to be subject to disruption during a labor dispute than
would trucking because it is not a labor-intensive operation.  With
respect to disruption of ultimate disposal operations, Alternative 2
would be less vulnerable than would other alternatives by virtue of its
considerable storage capacity.

     Alternatives involving pipeline transport are more vulnerable to
disruption due to physical phenomena such as earthquakes and accidental
damage during other, unrelated human activities.  However, the Denver
region is not particularly earthquake-prone, as discussed in the section
on environmental setting.

Susceptibility to Resource Shortages

     An alternative's susceptibility to resource shortages is directly
related to its requirements for energy and chemicals.   All alternatives
that employ truck haul are relatively high energy consumers.  All  alter-
natives that involve mechanical dewatering are relatively high chemical
consumers.  By virtue of its processing method  (anaerobic digestion),
its transportation method (pipeline transport) and its use of free solar
energy for dewatering, Alternative 2 emerges clearly as the best option
with respect to this evaluation factor.

Permanence

     Assuming that no unforeseen regulatory or physical constraints
emerge, all alternatives considered can represent permanent solutions
                                  A-9

-------
 to the sewage sludge disposal problem.   Permanent,  in  this context,
 means having a life in excess of  100 years.

 THE APPARENT BEST ALTERNATIVE

      An independent evaluation of the alternative sludge management
 systems led to a general concurrence with  the results  of the earlier
 evaluation, indicating that Alternative  2, anaerobic digestion, pipe-
 line transport, air drying and beneficial  reuse, is the apparent best
 alternative.  This conclusion is  drawn on  the basis of the following:

      1.  It is economically attractive,  particularly when inflation
          is taken into account.

      2.  Its economic appeal does not depend heavily upon revenue
          from sales that may not,  in fact, occur.

      3.  It is flexible:  the product mix  can be adapted to the
          needs of the ultimate user;  even  under the worst circum-
          stances, air-dried sludge in excess of need could be
          landfilled without seriously increasing costs.

      4.  It is conservative of energy and materials.

      5.  Its on-site environmental  impacts are generally less
          serious  than those resulting from the other alternatives.

      Disadvantages of  Alternative  2  are  some doubt regarding long-term
 off-site  effects  (discussed in detail in a later section) and high ini-
 tial  cost.   A cost-benefit  analysis  of Alternative 2 is included as
 Appendix  G.

      Because of the present funding  arrangements for water pollution
 control facilities,  projects  with  a  high capital cost and low operating
 cost  attract a larger  proportion of  Federal and State funds than do
 projects  with low capital cost and high operating cost.  Thus it is in
 the interest of local  agencies responsible for sewerage service to
 select  capital-intensive projects  in order to maximize financing by
 outside agencies  and minimize  local  user charges.   On the other hand,
 it may  be in the  interest of  the outside funding agencies to adopt an
 opposite approach in order  to maximize the local share and distribute
 the available  grant funds to a larger number of individual projects.

      Basically, high initial capital cost can be regarded as a disad-
vantage only  if its investment does not bring a return in terms of
 significantly  reduced  total costs.   In the case of  this project, and
accepting that inflation  should be accounted for in the cost calcula-
tions,  it appears that the  initial capital investment does in fact
result  in significantly reduced costs.

     The cost  estimates for alternatives 15 and 16  (processing and
                                 A-10

-------
transport to a regional solid waste processing plant),  admittedly some-
what lacking in precision at this stage, do indicate tnat economically
these options and Alternative 2 are equally attractive.  This is par-
ticularly true if sludge can be delivered to the plant  undigested in
order to retain a higher heat value.  Although Alternative 2 is pres-
ently the apparent best alternative, it is recommended  that a detailed
environmental analysis of alternatives 15 and 16 be undertaken if there
is a decision to implement a regional solid waste processing facility.

DETAILED DESCRIPTION OF ALTERNATIVES AND
PROCESS FLOW DESIGNS

Alternative 1A

     Alternative 1A will involve the continuation of existing modes of
sewage sludge disposal.  The Denver Northside Plant will, in 1985, de-
liver 20 metric tons [approximately 20 short tons] of dry sewage sludge
to the Central Plant to be put into storage tanks.  From the storage or
holding facilities, sludge would be withdrawn and receive polymer con-
ditioning, here estimated at 4 kg/inetric ton [10 pounds per short ton]
of sludge solids.  The conditioned sludge would be dewatered on coil
vacuum filters and trucked to the Lowry Bombing range,  where smaller
appropriate vehicles would apply the sludge to the land.

     It is envisioned that the present vacuum filter capacity would
need expansion to accommodate future flows, and chemical conditioning
facilities would be added with the new coil vacuum filters.  Expanded
dewatered sludge hauling needs would necessitate the use of additional
trucks.  Existing coil filters would need repairs and renovation, as
will the filtration building.

     It is believed that the existing waste-activated sludge thickener
can be used to thicken future design flows.

Alternative IB

     This alternative, similar to Alternative 1A, represents continua-
tion of the existing system but with anaerobic digestion as an early
processing step.  This results in a marked reduction in dry solids to
be handled in subsequent processing and disposal steps.

Alternative 2

     Alternative 2 embodies the basic concept of beneficial sludge
reuse through soil conditioning.  All waste sludges would be anaerobi-
cally digested and then pumped, unthickened, to a drying and distribu-
tion center.  The drying and distribution center, which is discussed  in
detail in Metro Denver District Sludge Management, Volume III, Agricul-
tural Reuse Predesign, would air dry the sludge and stockpile it for
                                 A-ll

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                                                                  -
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                                                                                          (159)

                                                                                   FILTRATE  RETURN
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distribution.  The center would include demonstration facilities showing
the benefits of applying sludges to farmlands and would also have some
subsurface disposal capacity to be used as an interim measure until a
market for dried sludge develops.  The subsurface storage would be ac-
complished by injecting liquid sludge several feet into the eoil.

     New anaerobic digesters, some of which are under construction,
would be needed for the Central Plant sludge  as would a new pumping
and pipeline system.  The drying and distribution center location, ap-
proximately 40 km [25 miles] east of Denver, has not been finalized and
is one of three under consideration.

Alternative 3

     In this alternative plan, raw sludge from the Central Plant and
digested sludge from the Denver Northside Plant would be conditioned
with lime and ferric chloride, estimated at 230 kg [500 pounds] of lime
and 54 kg [120 pounds] of ferric chloride per ton of sludge solids.
This conditioning would permit a filter press to dewater the sludge to
35 percent solids content.  This level of dryness is desirable for the
subsequent step of sludge incineration.  It has been assumed that a
multiple-hearth furnace would oxidize the sludge to carbon dioxide and
water, leaving 35 percent of the original solids as ash.  The ash would
be trucked to a sanitary landfill or land application site within 40 km
[25 miles] of Metropolitan Denver.

     New chemical feed systems would be needed along with a completely
new sludge filtration system.  It has been assumed that all alterna-
tives involving filtration would need an expansion of the present
building and improvements to the ventilating systems.  Trucking system
improvements would include three new trucks for hauling incinerator ash
to the disposal site.  A multiple-hearth incinerator was chosen in
preference to a fluidized-bed incinerator because we feel that the lat-
ter has lower reliability due to feed mechanism difficulties and to
high corrosion and erosion from sludge and bed material, particularly
upon the subsequent air pollution control equipment.

Alternative 4

     Concern with the increasing costs of conditioning chemicals re-
quired prior to any sludge dewatering operation led to this alternative
using heat treatment of sludge to break down the gel structure of the
sludge particles and make them more amenable to settling and filtration.
Raw Central and digested Northside sludges would be heated in a Zimpro
Heat Treatment Unit and then cooled and decanted in a gravity separator.
The thickened sludge, of approximately nine percent solids content,
would be vacuum filtered through a cloth fabric on a belt or drum fil-
ter.  The thickened sludge, of approximately 25 percent solids content,
would be trucked to a sanitary landfill or a land disposal site.
                                 A-21

-------
      The decant from the thickener would contain almost 10 percent of
 the original sludge solids and pollutants.  This material would need
 treatment and represents a sizeable load upon any wastewater treatment
 facility.  Published results of the Porteous heat treatment unit opera-
 tion at Colorado Springs indicate that the decant liquor has contained
 8,470 mg/1 of COD and 3,800 mg/1 of BOD.

      New facilities needed for implementation of this alternative in-
 clude a heat treatment unit, thickeners, expanded and renovated cloth
 filters and expanded trucking facilities.   Additional treatment capaci-
 ty may need to be added for the heat-treated decant  liquor.

 Alternative 5

      Alternative 5 is similar to Alternative 4 in the treatment and dis-
 posal of sewage sludge except that the dewatering by vacuum filtration
 would be replaced by dex«7atering on drying  basins with an underdrain re-
 turn system.   Since the drying beds would  be removed from the  Central
 Plant location and it would be difficult to pump sludges of  9  to 10 per-
 cent solids content,  the heat-treated  sludge would not be thickened,
 only cooled after dewatering.   It  is felt  that pumping is to be pre-
 ferred  over the daily trucking of  large quantities of  thickened but
 watery  sludge.   It would be necessary  to treat the leachate  from the
 drying  beds either at  the Central  Plant or  at a new  facility near the
 drying  beds.   Dewatered sludge would be trucked to a landfill  or land
 disposal site.

      New components needed  for this  alternative include a heat treat-
 ment  unit,  cooling tank,  pumping and piping facilities,  drying beds
 with under  drains,  leachate collection and  treatment  and a new truck-
 ing  system.

 Alternative 6

     Alternative  6  is  similar  to alternative  4 in that  raw Central
 Plant sludge and  digested Denver Northside  Plant  sludge  would  be heat
 treated, cooled and decanted,  and  then  filtered  through  a  cloth,  belt
 or drum, vacuum filter.  However,  instead of  directly  trucking the
 sludge to a landfill,  in Alternative 6  an incinerator would be employed
 to reduce the sludge solids by  70  percent and  the sludge water  by 100
percent  to  lessen  the  trucking  and land disposal costs.

     The following new  items of process  equipment would  be needed to
implement this alternative:  a  heat-treatment  unit, assumed to  be manu-
factured by Zimpro; cooling and decant  tanks,  fabric media vacuum fil-
ters, along with conversion of  existing coil  filters to  fabric  filters;
a multiple-hearth incinerator;  and trucking facilities.
                                A-22

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      The decant and filtrate from heat-treated sludges contain substan-
 tial  loads of pollutants that must be properly treated.  This can re-
 quire expansion of existing wastewater treatment units to accommodate
 the new load.

 Alternative 7

      Composting of sludge for beneficial reuse is the principal feature
 of Alternative 7.  Central Plant sludges would be anaerobically digested,
 combined with Denver Northside Plant sludges and thickened in a gravity
 thickener.  The thickened sludge, of approximately 5 to 7 percent solids,
 would be conditioned with lime and ferric chloride prior to dewatering
 in a  filter press.  Dewatered sludge would be trucked to a 200-hectare
 [500-acre] composting and storage area.  Approximately 70 percent of the
 composted sludge would be sold in bulk, and 30 percent would receive nu-
 trient enrichment to a fertilizer level of 6-6-6 and be bagged for urban
 sale.

      New facilities necessary for implementation of this alternative
 include anaerobic digester, gravity thickeners, chemical conditioning
 systems, filter presses and trucking.  A new composting facility would
 also  be developed.

      It is felt that the addition of lime to the sludge on the order of
 25 percent by weight makes the sludge generally unacceptable as compost.
 For this reason Alternative 13 was developed to allow for a different
 conditioning system.

 Alternative 8

     Alternative 8 is very similar to Alternative 7 except that no
 digesters would be constructed at the Central Plant, and most of the
 sludges undergoing composting would be previously unstabilized.  Again,
 the addition of lime to the sludge makes it a poor choice for general
 use as compost material, and Alternative 14 was developed to overcome
 this difficulty.

Alternative 9

     Alternative 9 would also produce composted sludge as a final prod-
uct with a variation in the sludge treatment system.  Anaerobically di-
 gested sludges from both plants would be thickened and then chemically
 conditioned with polymers on the order of 4 kg [10 pounds] of polymer
 per ton of sludge solids.  The conditioned sludges would be cer.trifuged
 to remove water and it is estimated that a sludge cake with 80 percent
moisture could be achieved.  The dewatered sludge would be trucked to
a new 200-hectare [500-acre] composting and storage facility.  From
 there, 70 percent of the composted sludge would be sold in bulk, and
 30 percent would be nutrient enriched and sold as a bagged fertilizer.
                                 A-23

-------
       New facilities  required  for  this alternative include anaerobic
  digesters,  gravity thickeners, chemical conditioning systems, centri-
  fuges,  trucking  and  composting.   The use of polymers for sludge condi-
  tioning would make the  sludge perfectly acceptable as compost,

 Alternative 10

      Alternative 10 is almost identical to Alternative 2 in that the
 sludge  treatment processes and the final drying and  distribution center
 would be the same.  However,  it is felt that the complete disposal sys-
 tem of distribution to farmers of bulk dried,  stabilized sludge may not
 necessarily be sufficiently encompassing of beneficial uses.   In particu-
 lar, a substantial market need may exist for composted and enriched
 sludge for urban homeowners and landscapers.  Alternative 10 adds to the
 process train of Alternative 2 the provision for composting,  enriching
 and bagging a portion of the drying sludge.  At this time it is diffi-
 cult to specify the size of the market  for composted and enriched sludge,
 and this disposal system could be reserved as  a contingency measure for
 excess sludge disposal.   An estimate of  tonnage demand for costing pur-
 poses could be made after a market analysis for composted sludge.   In
 the interim, the additional composting  facilities are not reflected in
 any costs of alternatives.

 Alternative 11

      Alternative 11 is similar to Alternative  4 because  it  would provide
 a dewatered sludge for land disposal.  Alternative 11 adds  anaerobic
 digestion for  Central Plant sludges in  order to stabilize them and make
 them less noxious.  The  best treatment  system,  and attendant  strong de-
 cant liquor,  of  Alternative 4  would be replaced by polymer  treatment of
 the digested sludge,  followed  by  centrifuge dewatering  to produce a
 sludge cake  containing 20 percent  dry solids.   This  material  would then
 be trucked  to a  sanitary landfill  or other  land disposal site.

      New facilities needed  for this alternative include  anaerobic  diges-
 ters,  gravity  thickeners, polymer  feed systems,  centrifuges and  expanded
 trucking capability.

 Alternative  12

     Alternative  12 is basically  identical  to Alternatives  2  and  10 in
producing anaerobically digested sludges for drying and  distribution
for beneficial reuse.   This alternative includes a contingency plan  to
produce some composted and nutrient-enriched sludge for  the urban mar-
ket.  Additionally, if due to unforeseen circumstances a market for
dried or composted sludges is not adequately developed or is delayed in
expansion, provisions  would be made for trucking the  dried sludges  to a
landfill site.
                                 A-24

-------
     New components of Alternative 12 which would be in addition to
those of Alternative 2 include composting pads, nutrient storage and
addition facilities, a bagging machine and trucks for hauling sludge to
a landfill.  These additional facilities have not been included in the
costs of Alternative 12 because the proportion of the sludge production
duction likely to go to each disposal system has not been determined.

Alternative 13

     Alternative 13 was developed to alleviate the concerns about lime
content of composted sludge in Alternative 7.  In Alternative 13, di-
gested sludges would be thickened and treated with polymers.  The condi-
tioned sludge would be dex^atered to approximately 25 to 30 percent dry
solids content on a cloth vacuum drum or belt filter.  Trucks would
transport the dewatered sludges to a 200-hectare [500-acre] composting
facility, from where it is estimated approximately 70 percent would be
sold in bulk as compost.  Approximately 30 percent of the compost would
be enriched with nutrients to a 6-6-6 fertilizer level and sold to urban
users.  The fertilizer value of the compost could be adjusted to the
specifications of large-quantity purchasers.

     New facilities necessary for the implementation of this Alternative
include anaerobic digesters, polymer mixing systems, trucking and a com-
posting facility.  It was calculated that the existing coil vacuum fil-
ters, if converted to fabric media with a loading rate of 17 kg/m2/hour
[3.5 lb/(ft2)(hr)], could readily handle the expected load of digested
sludge due to the solids reduction that occurs in an anaerobic digester.

Alternative 14

     Alternative 14 is intended to provide a replacement for Alternative
8, which employs lime and ferric chloride conditioning of undigested
sludges prior to dewatering in a filter press and composting.  In Alter-
native 14, the sludges would be conditioned with a harmless and accept-
able polymer and then dewatered on cloth vacuum filters.  The use of
filter presses can give drier sludge cakes, but with polymer condition-
ing could result in poor performance with rapid filter blending.  The
dewatered sludges would be trucked to a composting and distribution fa-
cility.

Alternative 15

     Alternative 15 involves anaerobic digestion and thickening,  followed
by pipeline transport to a regional soliu waste processing center assumed
to be located 5 km [3 miles] from the District's Central Plant.  At the
processing center site, the sludge will be chemically conditioned and
vacuum filtered to approximately 25 percent solids content.  This prod-
uct material will be accepted by the operators of the solid waste pro-
cessing center at no charge.
                                 A-25

-------
 Alternative 16

      This alternative is similar to Alternative 15 except that anaerobic
 digestion is omitted in order to retain higher heat values in the final
 product material delivered to the solid waste processing center.

 Assumptions Used in Costing Alternatives

      1.  Process cost curves and other costing assumptions used by CH2M-
 Hill were used in the cost analysis after review and verification.
 Changes in basic assumptions were made only where it was determined that
 the assumptions were clearly in error or were unacceptable for some
 other reason.

      2.  Sources for cost and performance data were as  follows.
          a.   "Metro Denver District Sludge Management Report,  Volume II,"
 by CH2M-Hill,  1975,  together with back-up calculations  supplied by  CH2M-
 Hill.

          b.   "An Analysis of the Sewage Sludge Disposal Problem in
 Southern California," by Engineering-Science,  Inc.  and  J.  B. Gilbert and
 Associates for EPA,  1974.

          c.   Composting  cost and performance  data were  based upon  esti-
 mates  prepared by Dr.  Gar  Forsht of  the Economic Research  Service,  USDA
 and  supplied  by CH2M-H111.

          d.   Estimates of  revenue from sale of  composted  sludge were
 based  on  information supplied  by Mr. 'Kellogg  of Kellogg Sales  Company,
 Carson, California,  the  distributor  of Los Angeles  County's composted
 sludge.
          e.  Engineering-Science,  Inc.  in-house files on  sludge process-
 ing  performance  and  chemical dose rates.

     3.   All costs are related  to an Engineering News-Record construc-
 tion cost  index  of 2128, applicable to  the Denver area  in  December  1974.

     4.  Alternative  facilities  are sized  for 1985  sludge  production
projections.

     5.  Annual  operation and maintenance  costs derived for 1985 design
flows were assumed to apply  uniformly  to  the period 1975 through 1985.

     6.  Alternatives 1A and IB  involve continued use of existing coil
filters and addition of new  and  similar filters to handle  the  increased
quantities of sludge.  Needed capacity of new filters (at  a solids  load-
ing rate of 17 kg/m2/hr  [3.5 Ib/ft2/hr]) was calculated on  the basis  of
the demonstrated capacity of the  old filters at 14.6 to 17  kg/m2/hr  [3
to 3.5 Ib/ft2/hr].  The earlier  estimates were  in error on  this point;
                                  A-26

-------
the existing filter capacity was calculated too low by a factor  of  five.
Alternative IB would result in substantially lower tonnage of  sludge
solids fed to the filters because of reductions in the digestion process
and would need only a renovation of existing filters.

     7.  Vacuum filters were assumed to be belt or drum type.  Perform-
ance and chemical dosage rates were assumed to be similar to those  pub-
lished by Los Angeles County Sanitation District.

     8.  Composting costs were recalculated on the basis of information
contained in Dr. Gar Forsht's paper entitled "Estimated Processing  Cost
for Composting Sludge."  The earlier estimates were in error in  that  a
purchase of 400 hectares [1,000 acres] of land for composting was treated
as an annual expenditure rather than a one-time-only initial cost.

     9.  It was assumed that for composting alternatives 30 percent of
the sludge would be nutrient-enriched to a 6-6-6 fertilizer value.

Estimated Costs

     Cost breakdowns for each alternative are shown in Tables A-3 and
A-4.  All costs are expressed in 1974 dollars.  Salvage values were de-
termined by straight-line depreciation on the basis of the estimated
useful life of system components.
                                  A-27

-------
                         Table A-3.   COST SUMMARIES USING  10 PERCENT DISCOUNT  - NO INFLATION

                                                (thousands  of dollars)
r\3
co
Alter-
native
1A
IB
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
I
capital
2,186
9,893
25,759
14,236
12,636
29,060
20,636
15,503
8,538
15,675
26,616
12,913
26,746
12,705
5,830
10,813
2,763
t salvage
value (P.W.)
193
2,390
7,913
3,045
1,664
7,437
3,720
3,309
1,249
3,358
7,913
2,782
7,913
2,893
846
2,714
485
Differ-
ence
1,993
7,503
17,846
11,191
10,972
21,623
16,916
12,194
7,289
12,317
18,703
10,131
18,833
9,812
4,984
8,099
2,278
10 year
0 and M
(P.W.)
22,102
17,229
6,157
13,014
11,484
11,693
7,484
18,175
26,655
21,481
10,108
16,228
10,108
18,557
21.97C
8,744
7,841
With digesters .
Revenue
0
0
4,710
0
0
0
0
10,748
16,947
7,846
8,238
0
8,238
7,846
12,474
0
0
Sub-total
w/o revenue
24,095
24,732
24,003
24,205
22,456
33,316
23,680
30,369
33,944
33,798
28,811
26,359
28,941
:3,369
26,963
16,843
10,119
Total with
revenue
24,095
24,732
19,292
24,205
22,456
33,316
23,680
19,621
16,997
25,952
20,573
26,359
20,703
20,523
14,489
16,843
10,119
Without digesters
Sub-total
w/o revenue
24,095
18,568
17,839
24,205
22,456
33,316
23,680
24,205
33,944
27,634
22,692
20,195
22,822
22,205
26,963
10,679
10,119
Total with
revenue*
24,095
18,568
13,129
24,205
22,456
33,316
23,680
13,457
16,997
19,788
14,409
20,195
14,539
14,359
14,489
10,679
10,119
        *0ver a ten-year period.

-------
                     Table A-4.  COST  SUMMARIES
1=
ro
USING 10 PERCENT DISCOUNT AND 8 PERCENT  INFLATION
(thousands  of  dollars)
Alter-
native
1A
IB
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
I
capital
2,186
9,893
25,759
14,236
12,636
29,060
20,636
15,503
8,538
15,675
26,616
12,913
26,746
12,705
5,830
10,813
2,763
£ salvage
value (P.W.)
416
5,160
17,084
6,573
3,592
16,054
8,031
7,144
2,696
7,248
17,084
6,005
17,084
6,245
1,826
5,859
1,046
Differ-
ence
1,770
4,733
8,675
7,663
9,044
13,006
12,605
8,359
5,842
8,427
9,532
6,908
9,662
6,460
4,004
4,954
1,717
10 year
0 and M
(P.W.)
32,562
25,383
9,071
19,173
16,919
17,227
11,026
26,777
39,270
31,647
14,891
23,908
14,891
27,339
32,38'.
12,881
11,551
With digesters
Revenue
0
0
6,939
0
0
0
0
15,835
24,967
11,559
12,137
0
12,137
11,559
18,377
0
0
Sub-total
w/o revenue
34,332
30,116
17,746
26,836
25,963
30,233
23,631
35,136
45,112
40,074
24,423
30,816
24,553
33,799
36,385
17,835
13,268
Total with
revenue
34,332
30,116
10,807
26,836
25,963
30,233
23,631
19,301
20,145
28,515
12,286
30,816
12,416
22,240
18,008
17,835
13,268
Without digesters
Sub-total
u/o revenue
34,332
26,424
14,054
26,836
25,963
30,233
23,631
31,444
45,112
36,382
20,731
27,124
20,861
30,107
36,385
14,143
13,268
Total with
revenue*
34,332
26,424
7,115
26,836
25,963
30,233
23,631
15,609
20,145
24,823
8,594
27,124
8,724
18,548
18,008
14,143
13,268
         "over a ten-year period.

-------

-------
     This Appendix contains descriptions of soils,
by county, within areas which may receive sludge
under the proposed recycling scheme.

-------
                     Table B-l.  SOIL ASSOCIATIONS IN THE VICINITY OF DENVER
   Soil association
                     Description
Map code*
ADAMS COUNTY

   Weld-Adena-Colby


   Samsil-Shingle



   Ascalon-Vona-Truckton



   Nunn-Satanta



   Alluvial land


   Terry-Renohill-Tassel



   Blakeland-Valent-Terry


   Arvada-Heldt-Nunn


   Platner-Ulm-Renohill
Nearly level to steep, well-drained, loamy soils formed        27
in wind-laid deposits; on uplands

Sloping to steep, excessively drained, clayey and loamy        72
soils formed in materials from soft shale and sandstone;
on uplands

Nearly level to strongly sloping, well-drained and some-       71
what excessively drained, loamy and sandy soils formed
in wind-laid deposits; on uplands

Nearly level, well-drained, loamy soils formed in alluvial     23
materials that are underlain by gravel in some places; on
terraces and fans
Nearly level, poorly drained to well-drained, loamy and        30
sandy soils formed in stream and river deposits; on flood
plains
Gently sloping to steep, well-drained and somewhat ex-          6
cessively drained, loamy soils formed in materials from
soft sandstone and shale; on uplands
Undulating to hilly, somewhat excessively drained,              5
dominantly sandy soils; on uplands

Nearly level, well-drained, loamy and clayey soils              8
formed in alluvium; on terraces and fans
Nearly level to strongly sloping, well-drained, loamy          73
soils formed in old alluvium on interbedded shale and
sandstone; on uplands
           en
           O
'Tl
^
w
!Z
O
M
X
ta

-------
                      Table B-l (continued).  SOIL ASSOCIATIONS IN THE VICINITY OF DENVER
         Soil  association
                                                    Description
                                                           Map  code*
bd
I
ho
ARAPAHOE COUNTY

   Alluvial Land-Nunn


   Weld-Adena-Colby



   Renohill-Buick-Litle



   Nunn-Bresser-Ascalon



   Truckton-Bresser


   Stapleton-Bresser



   Fondis-Weld



 OTHER AREAS

    Fluvaquents-Fluvents



   Valent-Vona
Deep, nearly level, mainly loamy and sandy soils;  on
flood plains and terraces

Deep, nearly level to sloping, loamy soils that have a
clayey to loamy subsoil; formed in silty, wind-deposited
material; on high-lying divides between creeks
Sloping to steep, loamy soils that have a loamy to clayey
subsoil; moderately deep and deep over shale or sand-
stone; on uplands

Deep, nearly level and undulating, loamy soils that have a
clayey to loamy subsoil; developed in outwash; on uplands
and  terraces
Deep, rolling, loamy and sandy soils that have a loamy
subsoil; on uplands
Moderately steep soils that are loamy throughout;
moderately deep and deep over arkosic sandstone; on
foothills
Deep, nearly level and gently sloping, loamy soils that
have a clayey layer in the subsoil; formed mainly in
silty, wind-deposited material; on foothills


Deep,  somewhat  poorly  drained,  nearly  level,  coarse-
 textured soils;  on flood plains and  low  terraces; commonly
 flooded

Deep, excessively  drained  to well-drained gently sloping
to moderately steep sandy  soils;  on uplands
                                                                                                   23


                                                                                                    3
42



24

43


27
                                                                                                    18
                                                                                                   148

-------
                       Table B-l  (continued).   SOIL  ASSOCIATIONS  IN THE VICINITY OF DENVER
           Soil  association
                     Description
Map code*
        OTHER AREAS (continued)

           Ascalon-Olney-Vona


           Nunn-Dacono-Altvan
Deep, well-drained, nearly level loamy soils;  on
terraces with high water table

Deep, well-drained, nearly level soils; on terraces and
flood plains
  173
  174
         Map code numbers refer to Figure 7  in  Section III
        Source:   Denver Region Water Quality Management Program
td
Co

-------

-------
     This Appendix contains tabular listings
of plant species observed during the field re-
connaissance phase of the EIS process,  at the
Lowry Bombing Range and at the sludge applica-
tion portion of the Range.  It also contains
lists of common plants, birds and mammals in
the Denver region.

-------
                             APPENDIX C
                              BIOLOGY
Table C-l.  LIST OF PLANT SPECIES OBSERVED DURING FIELD RECONNAISSANCE,
                            AUGUST 7, 1975






Common name Scientific name £P
P*-> *H
J-i ,i"*
s e
0 0
iJ M





rt
QJ
ao
C
s
(U
co
-a
d
^
CD
?*,

§
o

c
o
•H
4J
u
•Hw
rH
p,
&






Q
cd
0)
03
Tree
   Plains cottonwood
Shrub
   Broom snakeweed
   Rabbitbrush
   Willow
Herbs
   Alfalfa
   Aster
   Buffalobur
   Bull thistle
   Cocklebur
   Common burdock
   Common sunflower
   Coneflower
   Dandelion
   Fanweed
   Fetid marigold
   Golden aster
   Goosefoot
   Gumweed
   Mikvetch
   Narrow-leaved
     umbrella-wort
   Plantain
   Prickly lettuce
   Prickly pear
   Prickly poppy
   Prostrate knotweed
   Prostrate pigweed
   Redroot pigweed
   Rocky Mountain beeplant
   Russian thistle
   Sand verbena
   Scarlet falsemallow
   Sedge
   Skeleton weed
Populus sargent!i               x
Gutierrizia sarothrae           x
Chrysothamnus nauseosus         x
Salix sp.                       x
Medicago sativa                 x
Aster sp.                       x
Solanum rostratum
Cirsium vulgare                 x
Xanthium i tali cum               x
Arctium minus                   x
Helianthus annuus               x
Ratibida columnifera            x
Taraxacum officinalis           x
Thlaspi arvense                 x
Dyssodia papposa                x
Chrysopsis sp.                  x
Chenopodium leptophyllum        x
Grindelia sguarrosa             x
^stragraJus sp.                  x
Oxybaphus linearis

Plantago spinulosa              x
Lactuca scariola                x
Opuntia polyacantha             x
Argemone polyanthemos           x
Polygonum aviculare             x
Amaranthus graecizans  -  -      x
Amaranthus retroflexus
Cleome serrulata                x
Salsola kali var. tenuifolia    x
Abronia fragrans                x
Sphaeralcea coccinea            x
Carex sp.                       x
Lygodesmia juncea
x
X
X
                                 C-l

-------
   Table C-l (continued).   LIST OF SPECIES  OBSERVED  DURING FIELD RECON-
                        NAISSANCE, AUGUST 7,  1975





Common name






Snow-on- the-mountain
Stinging nettle





Scientific name






Euphorbia marginata
Urtica dioica ssp. gr,





00
Crt
>> -H OJ
M J2 CO
3 ^ c
o o nj
nJ PQ 03
X
acilis x
Q)
00 C
-a o
3 -rl
rH 4-*
03 <3
O
t^T-tn
U H id
3 O. 0)
O D. >-i
_i ca ca


    Summer cypress
    Tansy  mustard
    Tumble pigweed
    Umbrella  plant
    Vervain
    Yucca
 Grass
    Beardless wheatgrass
    Blue  grama
    Buffalo grass
    Cheat grass
    Downy brome
    Fescue
    Junegrass
    Little bluestem
    Milo
    Needle-and-thread
    Oat
    Red three-awn
    Saltgrass
    Sand dropseed
    Sorghum sudangrass

    Squirreltail
    Sudan
    Three-awn
   Western wheatgrass
   Wheat
 Kochla  scoparia
 Descurainia pinnata
 Amaranthus albus
 Eriogonum effusum
 Verbena bracteata
 Yucca glauca
Agropyron inerme
Bouteloua gracilis
Buchloe dactyloides
Bromus japonicus
Bromus tectorum
Festuca sp.
Koeleria gracilis
Andropogon scoparius
Sorghum vulgare
Stipa comata
Avena sativa
Aristida longiseta
Distichlis stricta
Sporobolus cryptandrus
Sorghum bicolor X
  S. sudanense
Sitanion hystrix
Sorghum sudanense
Aristida sp.
Agropyron smithii
Triticum sativa
x

x
X
X
X
X
X
X
X
X
X
X
X
X
X
        X
X
X
X
X
 Portion of Site A not amended with sludge, shown in Figure 12.

 Sludge-amended portion of Site A, shown in Figure 12.
Q
 Planted by Metro Denver Sewage Disposal District No.  1.
                                 C-2

-------
    Table C-2.  COMMONLY OCCURRING RANGE SPECIES  IN THE DENVER AREA
            Common name
                                           Scientific  name
Native, climax grass species
   Big bluestern
   Blue grama
   Buffalograss
   Indiangrass
   Junegrass
   Kentucky bluegrass
   Little bluestem
   Mountain muhly
   Needle-and-thread
   Needlegrass
   Prairie dropseed
   Red three-awn
   Sideoats grama
   Sloughgrass
   Squirreltail
   Switchgrass
   Western wheatgrass
Associated woody plants, forbs
   and legumes - noxious weeds
   Canada thistle
   Field bindweed
   Halogeton
   Horsenettle, Caroline
   Horsenettle, white
   Povertyweed, silver-leaf
   Povertyweed, woolly-leaf
   Russian knapweed
   Saint Johnswort
   Sorghum almum
   Sowthistle, perennial
   Spurge, leafy
   Toadflax, Dalmation
             yellow
             common
Toadflax,
Whitetop,
Whitetop, hairy
Whitetop, tall
Associated woody plants, forbs
   and legumes - poisonous to
   livestock
   Arrowgrass
   Brake fern
   Chokecherry
                                 Andropogon gerardi
                                 Bouteloua gracilis
                                 Buchlbe dactyloides
                                 Sorghastrum nutans
                                 Koeleria cristata
                                 Poa pratensis
                                 Andropogon scoparius
                                 Muhlenbergia montana
                                 Stipa comata
                                 Stipa spartea
                                 Sporobolus heterolepis
                                 Aristida longiseta
                                 Bouteloua curtipendula
                                 Spartina pectinata
                                 Sitanion hystrix
                                 Panicum virgatum
                                 Agropyron smithii
Cirsium arvense
Convolvulus arvensis
Halogeton glomeratus
Solanum carolinense
Solanum elaeagnifolium
Franseria discolor
Franseria tomentosa
Centaurea repens
Hypericum perforatum
Sorghum almum
Sonchus arvensis
Euphorbia esula
Linaria dalmatica
Linaria vulgaris
Cardaria draba
Cardaria pubescens
Lepidium latifolium
                                 Triglochin spp.
                                 Pteridium aquilinum
                                 Prunus virginiana
                                  C-3

-------
   Table C-2  (continued).  COMMONLY OCCURRING RANGE SPECIES IN THE
                              DENVER AREA

	Common name	Scientific name	
   Deathcamas                       Zygadenus spp.
   Larkspur                         Delphinium spp.
   Locoweed                         Oxytropis spp.
   Water hemlock                    Cicuta occidentalis

Associated woody plants, forbs
   and legumes - others
   Black-eyed Susan                 Rudbeckia hirta
   Elderberry                       Sambucus racemosa
   Goldenrod, stiff                 Solidago altissima
   Horseweed                        Erigeron canadensis
   Prickly pear                     Opuntia rafinesquii
   Rose                             Rosa acicularis
   Russian thistle                  Salsola kali  var. tenuifolia
   Sunflower                        Helianthus spp.
   Yucca                            yucca grlauca

Source:  Denver Regional Council of Governments Water Quality Management
        Plan.
                                 C-4

-------
   Table C-3.  NATIVE TREES AND ASSOCIATED SHRUBS  IN  THE DENVER AREA
            Common name
          Scientific name
Overstory and climax trees
   Alder
   American elma
   Box elder
   Douglas fir
   Hackberry
   Narrow leaf cottonwood
   Pinyon pine
   Plains cottonwood
   Ponderosa pine
   Rocky Mountain juniper
   Russian olive
   Siberian elma
   White fir
   Willow

Associated shrubs
   American plum
   Bitterbrush
   Buffaloberry
   Chokecherry
   Creeping mahonia
   Gambel oak
   Hawthorn
   Indigobush
   Leadplant
   Mountain mahogany
   Ninebark
   Rabbitbrush
   Redosier dogwood
   Sagebrush
   Sandcherry
   Serviceberry
   Skunkbrush
   Smooth sumac
   Snowberry
Alnus tenuifolia
Ulmus americana
Acer negundo
Pseudotsuga menziesii
Celtis accidental is
Populus angustifolia
Pinus edulis
Populus sargentii
Pinus ponderosa
Juniperus scopulorum
Elaegnus angustifolia
Ulmus pumila
.Abies concolor
Salix spp.
Prunus americana
Purshia tridentata
Shepherdia argentea
Prunus virginiana
Mahonia repens
Quercus gambeli
Crataegus spp.
Amorpha fruticosa
Amorpha canescens
Cercocarpus montanus
Physocarpus monogynus
Chrysothamnus spp.
Cornus stolonifera
Artemisia spp.
Prunus besseyi
Amelanchier spp.
PJius  trilobata
Rhus  glabra
Symphoricarpos spp.
 Species is not native but has volunteered from established plantings.
Source:  Denver Regional Council of Governments Water Quality Manage-
         ment Plan.
                                  C-5

-------
             Table C-4.   COMMON  BIRDS OF THE DENVER REGION
             Common name
            Scientific  name
 Aquatic birds

    Canada goose
    Whistling  swan
    Lesser snow goose
    Mallard
    Gadwall
    American widgeon
    Pintail
    Green-winged teal
    Blue-winged teal
    Cinnamon teal
    Shoveler
    Redhead
    Canvasback
    Ring-necked duck
    Lesser  scaup
    Common goldeneye
    Barrow's goldeneye
    Bufflehead
    Common  merganser
    Ruddy duck
    Red-breasted merganser
    Hooded  merganser
    Greater scaup
    Wood duck
    Pied-billed  grebe
    Eared grebe
    Western grebe
Hawks and  falcons

    Turkey  vulture
    Sharp-shinned hawk
   Marsh hawk
   Rough-legged hawk
    Ferruginous  hawk
    Red-tailed hawk
    Swainson's hawk
   Golden  eagle
    Bald eagle
   Prairie falcon
   Sparrow hawk

Grouse, quail and pheasant

   Sharp-tailed grouse
   Bobwhite quail
   Ring-necked pheasant
 Branta canadensis
 Cygnus columbianus
 Chen hyperboea
 Anas platyrhynchos
 Anas stepera
 Marceca americana
 Anas acuta
 Anas carolinensis
 Anas discors
 Anas cyanoptera
 Spatula clypeata
 Aythya americana
 Aytha valisineria
 Aytha collaris
 Aytha affinis
 Bucephala  clangula
 Bucephala  islandica
 Bucephala  albeola
 Mergus merganser
 Oxyura jamaicensis
 Mergus serrator
 Lophodytes cucullatus
 Aytha marila
 Aix  sponsa
 Podilymbus podiceps
 Podiceps caspicus
 Aechmophorus occidentalis
Cathartes aura
Accipiter velox velox
Circus hudsonius
Buteo lagopus
Buteo regalis
Buteo borealis
Buteo swainsoni
Aguila chrysaetos canadensis
Haliaeetus leucocephalus
Falco mexicanus
Faico sparverius
Pedioecetes phasianellus
Colinus virgianus
Phasianus colchicus
                                C-6

-------
       Table C-4 (continued).  COMMON BIRDS OF THE DENVER REGION
              Common name
           Scientific name
Shorebirds

   Great blue heron
   Black-crowned night heron
   American bittern
   Sandhill cranes
   Virginia rail
   Sora rail
   American coot
   American avocet
   Killdeer
   Spotted sandpiper
   Willet
   Lesser yellowlegs
   Long-billed dowitcher
   Wilson's phalarope
   Common snipe
   Franklin's gull
   Black tern

Pigeons and cuckoos

   Band-tailed pigeon
   Rock dove
   Yellow-billed cuckoo

Owls and goatsuckers

   Screech owl
   Great-horned owl
   Short-eared owl
   Barn owl
   Burrowing owl
   Poor-will
   Common nighthawk

Terrestrial birds

   Ruby-throated hummingbird
   Belted kingfisher
   Red-shafted flicker
   Common redpoll
   Red-headed woodpecker
   Hairy woodpecker
   Downy woodpecker
   Eastern kingbird
   Western kingbird
   Say's phoebe
Ardea herodias
Nycticorax nycticorax
Botaurus lentiginosus
Grus canadensis tabida
Rallus limicola limicola
Porzana Carolina
Fulica americana americana
Recurvirostra americana
Charadrius vociferus
Actitis macularia
Catoptrophorus semipalmatus
Totanus flavipes
Limnodromus griseus scolopaceus
Steganopus tricolor
Capella delicata
Larus pipixcan
Chlidonias nigra surinamensis
Columba fasciata
Columba livia
Coccyzus americanus
Otus asio
Bubo virginianus
Asio flairsmeus flammeus
Tyto alba pratincola
Speotyto cunicularia
Phalaenoptilus nuttalli
Chordeiles minor
Archilochus coluoris
Megaceryle alcyon
Colaptes cafer
Acanthis linaria linaria
Melanerpes erythrocephalus
Dryobates villosus
Dryobates pubescens
Tyrannus tyrannus
Tyrannus verticalis
Sayornis saya
                                 C-7

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   Table C-4 (continued).   COMMON BIRDS OF THE  DENVER REGION
          Common name
          Scientific  name
 Traill's flycatcher
 Horned lark
 Barn swallow
 Cliff swallow
 Bank swallow
 Black-billed magpie
 Common crow
 Black-capped chickadee
 Common bushtit
 Dipper
 Red-breasted nuthatch
 House wren
 Mockingbird
 Catbird
 Brown thrasher
 Robin
 Hermit thrush
 Veery
 Golden-crowned  kinglet
 Ruby-crowned kinglet
 Water pipit
 Bohemian waxwing
 Cedar waxwing
 Loggerhead  shrike
 Starling
 Warbling vireo
 Orange-crowned  warbler
 Yellow warbler
 Ovenbird
 Yellowthroat
 Yellow-breasted chat
 American redstart
 House sparrow
 Western meadowlark
 Yellow-headed blackbird
 Red-wing blackbird
 Brewer's blackbird
 Common grackle
 Brown-headed  cowbird
 Bullock's oriole
 Lazuli bunting
 House  finch
American goldfinch
Dickcissel
Emphidonax traillii
Otocoris alpestris
Hirundo erythrogaster
Petrochelidon albifrons
Riparia riparia riparia
Pica Pica hudsonia
Corvus brachyrhynchos
Penthestes atricapillus
Psaltriparus minimus
Cinclus mexicanus unicolor
Sitta canadensis
Troglodytes aedon
Mimus polyglottos
Dumetella carolinensis
Toxostoma rufum
Turdus migratorius
Hylocichla guttata
Hylocichla fuscencens fuscescens
Regulus satrapa
Corthylio calendula
Anthus spinoletta
Bombycilla garrula pallidiceps
Bombycilla cedrorum
Lanius ludovicianus
Sturnus vulgaris vulgaris
Vireo gilvus
Vermivora celata celata
Dendroica petechia
Seiurus aurocapillus
Geothlypis trichas
Icteria virens
Setophaga ruticilla
Passer domesticus domesticus
Sturnella neglecta
Xanthocephalus xanthocephalus
Agelaius phoeniceus
Euphagus cyanocephalus
Quiscaleus guiscula
Molothrus ater
Icterus bullocki
Passerina amoena
Carpodacus mexicanus frontalis
Spinus tristis
Spiza americana
                             C-8

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    Table C-4 (continued).  COMMON BIRDS OF THE DENVER REGION
           Common name
          Scientific name
Rufous-sided towhee
Grasshopper sparrow
Lark bunting
Vesper sparrow
Lark sparrow
Tree sparrow
Chipping sparrow
Field sparrow
Lincoln's sparrow
Song sparrow
McCown's longspur
Chestnut-collared longspur
Townsend's solitaire
Pipilo erythrophthalmus
Armodramus savannarum australis
Calamospiza melanocorys
Pooecetes gramineus confinis
Chondestes granwacus strigatus
Spizella arborea ochracea
Spizella passerina arizonae
Spizella pusilla arenacea
Melospiza lincolni lincolni
Melospiza melodia
Rhynchophanes mccownii
Calcarius o mat us
Myadestes townsendi
                               C-9

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            Table  C-5.   COMMON MAMMALS OF THE DENVER REGION
            Common  name
             Scientific name
 Big game

    Antelope
    Mule  deer
 Small  game

    Blacktail jackrabbit
    Whitetail jackrabbit
    Fox squirrel
    Desert cottontail
    Eastern cottontail  rabbit

 Furbearers

    Coyote
    Opossum
    River Otter3
    Bobcat
    Striped skunk
    Shortail weasel
    Longtail weasel
    Black-footed ferret
    Raccoon
    Spotted skunk
    Gray  fox
    Red fox
    Swift fox
Rodents, shrews, and bats
    Spotted ground squirrel
   Thirteen-lined ground
     squirrel
   Whitetail prairie dog
   Blacktail prairie dog
   Ord kangaroo rat
   Big brown bat

Rodents

   Porcupine
   Least chipmunk
   Colorado  chipmunk
   Plains pocket gopher
   Silver-haired bat
   Red bat
   Hoary bat
   Prairie vole
Antilocapra americana
Odocoileus hemionus
Lepus  californicus
Lepus  townsendi
Sciurus niger
Sylvilagus audubonii
Sylvilagus floridanus
Canis latrans
Didelphis marsupialis
Lutra canadensis
Lynx rufus
Mephitis mephitis
Mustela erminea
Mustela frenata
Mustela nigripes
Procyon lotor
Spilogale putorius
Urocyon cinereoargenteus
Vulpes fulva
Vulpes velox
Citellus spilosoma

Citellus tridecemlineatus
Cynomys gunnisoni
Cynomys ludovicianus
Dipodomys ordi
Eptesicus fuscus
Erethizon dorsatum
Eutamias minimus
Eutamias quadrivittatus
Geomys bursarius
Lasionycteris noctivagans
Lasiurus borealis
Lesiurus borealis
Microtus ochrogaster
                                  C-10

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       Table C-5  (continued).  COMMON MAMMALS OF THE DENVER REGION
             Common name
             Scientific name
   Meadow vole
   California myotis bat
   Long-eared myotis bat
   Brown myotis bat
   Small-footed myotis bat
   Fringed myotis bat
   Long-legged myotis bat
   Eastern woodrat
   Northern grasshopper mouse
   Plains pocket mouse
   Silky pocket mouse
   Hispid pocket mouse
   Deer mouse
   Western big-eared bat
   Western harvest mouse
   Plains harvest mouse
   Masked shrew
   Merriam shrew
   Dusky shrew
   Mexican freetail bat
   Big freetail bat
   Northern pocket gopher
   Meadow jumping mouse
   Western jumping mouse
Microtus pennsyIvanicus
Myotis californicus
Myotis evotis
Myotis lucifugus
Myotis subulatus
Myotis thysanodes
Myotis volans
Neotoma floridana
Onychomys leucogaster
Perognathus flavescens
Perognathus flavus
Perognathus hispidus
Peromyscus maniculatus
Plecotus townsendi
Reithrodontomys megalotis
Reithrodontomys montanus
Sorex cinereus
Sorex merriam
Sorex obscurus
Tadarida braziliensis
Tadarida molossa
Thomomys talpoides
Zapus hudsonius
Zapus princeps
 Classed rare to near extinct due to constriction of habitat.
Source:  Reference
                                  C-ll

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    Table C-6.   COMMON AMPHIBIANS AND REPTILES  OF THE  DENVER REGION
             Common name
               Scientific name
 Salamanders

   Barred tiger
 Toads

   Great plains
   Woodhouse's
   Plains spadefoot

 Frogs

   Boreal chorous
   Bull
   Leopard
 Turtles

   Snapping
   Painted
   Yellow western box
   Western spiny softshell

 Lizards
   Lesser earless
   Eastern short-horned
   Northern  sagebrush

 Skinks
   Six-lined racerunner

 Snakes

   Eastern yellow-bellied racer
   Prairie rattlesnake
   Plains  hognose
   Central Plains milk
   Smooth  green
   Bullsnake
  Plains black-headed
  Wandering garter
  Plains garter
  Red-sided garter
Ambystoma  tigrinum mavortium
Bufo  cognatus
Bufo  woodhousei woodhousei
Scaphiopus bombifrons
Pseudacris  triseriata maculata
Rana catesbeiana
Rana pipiens
Chelydra serpentina
Chrysemys pi eta
Terrapene ornata luteola
Trionyx spiniferus hartwegi
Holbrookia maculata
Phrynosoma douglassi brevirostre
Sceloporus graciosus graciosus
Cnemidophorus sexlineatus
Coluber constrictor flaviventris
Crotalus viridis viridis
Diadophis punctatus nasicus
Lampropeltis triangulum gentilis
Opheodrys vernalis
Pituophis melanoleucus sayi
Tantilla nigriceps
Thamnophis elegans vagrans
Thamnophis radix
Thamnophis sirtalis parietalis
Source:   Reference
                                C-12

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Table C-7.  COMMON FISHES IN STREAMS AND LAKES OF THE DENVER REGION
            Common name
              Scientific name
Brown trout
Carp
Tench
Creek chub
Fathead minnow
Red shiner
Carp sucker
White sucker
Channel catfish
Black bullhead
Killifish
White bass
Largemouth bass
Smallmouth bass
White crappie
Black crappie
Green sunfish
Blue gill
Pumpkinseed
Yellow perch
Log perch
Darters
Salmo trutta
Cyprinus carpio
Tinea tinea
Semotilus atromaculatus
Pimephales promelas
Notropis lutrensis
Carpiodes carpio
Catostomus commersonnii
Ictalurus lacustris
Ictalurus melaf
Fundulas sp.
Lepibema chrysops
Micropterus salmoides
Micropterus dolomieu
Pomoxis annularis
Pomoxis nigromaculatis
Lepomis cyanellus
Leponiis macrochirus
Lepomis gibbosus
Pesca flaves cans
Percina caprodes
Percidae sp.
Source:  Reference
                                 C-13

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     This Appendix presents an overall discussion
of the feasibility of applying municipal sludge
to land, as evaluated by Engineering-Science, Inc.

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                             APPENDIX D
                     SLUDGE APPLICATION TO LAND
                         TABLE OF CONTENTS
INTRODUCTION                                                 D-l

PLANT NUTRIENT REQUIREMENTS                                  D-3

SOILS AS SLUDGE ASSIMILATORS                                 D-4

    Soil Suitability for Sludge Application                  D~4
    Allowable Sludge Application Rates                       D-4
    Chemical Reactions in Soil                               B-5
    Physical Effects of Sludge Addition to Soils             D-5

ENVIRONMENTAL CONSIDERATIONS AND CONSTRAINTS                 D-6

    Surface Runoff                                           D-6
    Groundwater                                              D-6
    Aesthetics                                               D-7
    Odor                                                     D-7
    Food Chain                                               D-7
    Nitrogen                                                 D-9
    Heavy Metals                                            D-ll
    Pathogens                                               D-12
    Salts                                                   D-14

AGRICULTURAL CONSIDERATIONS                                 D-15

    Fertilizer Value                                        D-15
    Fertilizer Market                                       D-15
    Crop Selection                                          D-16
    Germination                                             D-l8
    Weeds                                                   D-21
    Application Rates                                       D-21
    General Conclusions                                     D-22

CHEMICAL PROPERTIES OF METRO DENVER SLUDGE          -       D-24

LAND USE OPTIONS FOR SLUDGE APPLICATION                     D-24

    City Parks                                              D-24
    Sod Farms                                               D-28
    Irrigation and Dryland Farms                            D-28

REFERENCES                                                  D-30

                                 D-l

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                              APPENDIX D


                      SLUDGE APPLICATION TO LAND

 INTRODUCTION

     The agricultural  reuse of materials generated in the processing of
 municipal wastes is a contemporary issue that has as its philosophical
 base  the belief that  sewage wastes should be considered not as refuse
 but  as useful resources.  Past practices of sewage disposal have placed
 a burden on the environment in the form of air and water pollution and
 have  essentially involved the elimination of a significant amount of
 nutrient resources from the ecosystems.  Many communities in America are
 involved in programs  of recycling municipal sludges and effluents on the
 land; many universities and public agencies are conducting long-term
 research projects on  the effects of waste recycling on the environment.
 Preliminary results are appearing in increasing numbers in scientific
 and  technical journals and other publications.

    The intent of this appendix to the  Metro  Sludge  EIS is  to  provide
 general information concerning the land application of sludge, with
 specific consideration to the chemical composition of Metro Denver sludge
 as it relates to agricultural reuse.   Sources for more detailed or more
 situation specific information are given in the reference section.

    The Metropolitan Denver Sewage Disposal District No. 1 proposes the
 transfer of anaerobically digested liquid sludge from the central plant
 to a drying and distribution site,  where the sludge would be air dried
and stockpiled for distribution for agricultural reuse purposes.  The
 land application of sludge can be grouped into  three general categories
according to application rates;  these are presented below and summarized
in Table  D-l.

        "The reuse  of waste  sludges for fertilization as shown in
         Table D-l  utilizes  low loading rates (less  than 45 tons
         per hectare  per year [20 tons/acre/year]),  depending on
         sludge  characteristics,  soil,  and the  crop  grown.   The
         objective  is  the  maximization  of crop  production by full
         use of  the nutrients present.   Almost  any soil suitable
         for high  rate agricultural production  is  suitable for this
         type  of operation.   The  key  feature  of this system is that
         a  balance  between the nutrients  added  and the  nutrients
         removed with  the  crops should  be maintained.   Only the
         amount  of  organic material required  to maximize crop
         production is applied.

         The  'high  rate  fertilizer' system uses  higher  loading rates
         (up  to  170 metric tons per hectare per year [75 tons  per
         acre  per year]).  The objective  is  to  maximize the amount
                                D-2

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                           Table D-l.   THREE MAIN  CATEGORIES FOR WASTE ORGANICS APPLICATION TO  LAND
i
UJ

Method
Fertilization








High rate
fertilizer









Loading rates,
Annual
<2 to 45
depending
on waste
organica
character-
istic, soil
and crop
grown.

<11 to >168










, metric ton.s/haa
Maximum
accumulation
224 to 2240 to
prevent excess
accumulation of
heavy metals or
other pollutants
in soil.



900 to 2240 to
prevent toxic
accumulations
of pollutants
in the soil.









Impact on quality
Objective
Maximize crop
production by
use of ferti-
lizer to sup-
ply part or
all of pri-
mary anu/or
micro nutri-
ents.
Apply organics
to cropped
soil. Main-
tain crop while
maximizing or-
ganics appli-
cations .



Suitable soils
Any soil which
is suitable for
high agricultural
production.





Generally fine
textured soils
with a high capa-
city to adsojrb or
precipitate
large quantities
of heavy metals
or other pollu-
tants.

Soil
Improves soil
fertility and
organics improve
soil structure.
No detrimental
effects.



May reduce soil
usefulness for
some crops or uses.
Soil would prob-
ably be improved
at lighter load-
ings. Accumula-
tion of pollutants
in soil must be
monitored.
Water
With a well managed
system there would
be no harmful effect
on groundwater or
surface water.




Possibly would result
in excess nitrogen
which could be
leached to ground-
water. Proper man-
agement of surface
runoff would protect
surface waters.


           Disposal
             (landfill)
11 to
several
hundred
Several hun-
dred to 2240
or more
To dispose of
organics by in-
corporation in
soil.  A crop
may or may not
be grown be-
tween applica-
tions.
Generally fine
textured  soils
with a high  capa-
city to adsorb or
precipitate
large quantities
of heavy  metals
or other  pollu-
tants.
Soil usefulness
will likely  be
greatly reduced.
Accumulation of
pollutants in
soil should  be
monitored.
Excess nitrogen could
be leached  to ground-
water.  Proper man-
agement would mini-
mize potential for
pollution from other
materials.
           al metric  ton/hectare - 0.446 English tons/acre
           Source:  Agricultural Reuse Program  (Reference D-l).

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          of sludge applied, with crop production secondary in
          importance.  Solids suitable for this type of operation
          should be fine textured with a high capacity to absorb
          or precipitate large quantities of heavy metals.   Even-
          tually, continued unbalanced applications of waste
          organic materials may reduce the soil's usefulness to
          grow certain crops because of accumulations of heavy
          metals or salts.   The application of the nitrogen con-
          tained in the waste organic materials would not be
          balanced by crop  removal or natural denitrification,
          and accumulation  of nitrogen in the soil would probably
          occur.  Nitrogen  compounds could eventually reach the
          ground water or surface system if proper precautions
          were not taken.

          The third general method of operation involves 'dis-
          posal'  at very high loading rates (up to several hun-
          dred tons of waste sludge applied per hectare per year).
          The objective is  to dispose of as much sludge as  possible
          by incorporation  into the soil with little or no emphasis
          on crop production.   Fine textured soils will precipitate
          large quantities  of heavy metals  or other pollutants and
          are suitable for  this  type of operation.   The end result
          of continued operation using the  'disposal'  method is the
          potential impairment of the soil  due to accumulation of
          salts,  heavy metals,  and nitrates in the soil.   Leaching
          of nitrates,  salts,  and heavy metals from the soil into
          the ground water  or carrying of these materials  into the
          surface water regime  is  a potential hazard that  must be
          considered in design."  (Reference D-l)

     The method characterized  as  "fertilization"  is  the one proposed by
Metro Denver and is the  one  that  will be focussed upon in  this appendix
as well as  in  the  body of  the  environmental impact statement.
PLANT NUTRIENT REQUIREMENTS

    Sixteen elements are known to be essential for plants to be able to
complete their life cycle.  Ten of these elements are required in rela-
tively large amounts for plant growth.  These macronutrients are: carbon,
oxygen, hydrogen, nitrogen, phosphorus, potassium, sulfur, calcium, mag-
nesium and iron.  The remaining six micronutrients which are essential
in trace amounts are: manganese, zinc, copper, boron, molybdenum and
chlorine.  Certain plants may not require one or more of the sixteen
elements.  Certain others require still other elements, or they must be
able to substitute to a degree some elements for others.  Some of the
elements required by specific plants are sodium, selenium, cobalt and
silicon.  All of these nutrients with the exception of carbon are drawn
by land plants mainly from the soil.  Municipal sludge contains all of
                                  D-4

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 the  essential plant nutrients in varying amounts.
 SOILS  AS  SLUDGE ASSIMILATORS

     Soil  is primarily made up of mineral matter, organic matter, micro-
 organisms, solutions and air.  The assimilative potential of a soil depends
 upon its  ability  to filter, buffer, adsorb and absorb sludge constituents.
 Soils  chemically  and biologically transform sludge component and support
 plants which  utilize the nutrients in them (Reference D-2).

 Soil Suitability  for Sludge Application

     Physical  properties that affect a soil's ability to assimilate sludge
 include:  porosity, structure, texture (grain-size distribution) and
 mineralogy.   Soil filterability is a property that determines how
 efficiently a soil can act as a physical filter of suspended particles
 and  pathogenic organisms. Permeable soils of intermediate texture with
 enough colloidal  content to trap particulates are generally the best
 filters.  Soils that are least suitable for land application include
 those  that are: 1) extremely fine-textures; 2) extremely coarse-textured,
 such as sands  and gravels; 3) very shallow; 4) wet or undrained; 5) frozen;
 and  6) solonetz and others that are sodium saturated (Reference D-3).

    Aspects of soil chemistry that are of importance to sludge assimilation
include:   1)  ion exchange capacity,  2) chemical alteration,  and 3)  soil
pH and calcium reserve.

     Ion exchange  capacity refers  to the total amount of cations and
 anions that are sorbable per unit of soil weight (expressed as milli-
 equivalents per 100 grains of soil) .  Most soils have moderate to large
 cation-exchange capacities but only limited anion exchange capacities.

 Allowable Sludge  Application Rates

     The cation exchange capacity  is the sum of both the capacities of
 organic and inorganic soil components.  The ability of a soil to retain
 heavy  metals  from sludge applications - and to keep them out of the
 ground and surface water and unavailable to plant tissues - is  largely
 a function of its  cation exchange capacity (Reference D-3).  Equation D-l
 shows  the maximum permissible sludge  loading rate as determined by the
 cation exchange capacity of a soil and the heavy metals content of the
 sludge, where CEC equals the cation exchange capacity of the unsludged
 soil in meq/100 g. and ppm equals mg/kg dry weight  of sludge  (Reference
 D-4).  The constant-200 adjusts for the addition to the soil of some ex-
 change capacity in the sludge (Reference D-5).

     Total Sludge  (dry wt. metric  tons/hectare)=

                     	73,000   (CEC)	
                     ppm Zn + 2(ppin Cu) +  4(ppni Ni) -200
                                  D-5

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     This equation limits the heavy metal additions  calculated as  zinc
 equivalent to 10 percent of the cation exchange  capacity.   The zinc
 equivalent takes into account the greater plant  toxicities  of copper and
 nickel.  This equation applies only to soil that can be  adjusted  and
 held at a pH of 6.5 or greater for a period of at least  two years  after
 sludge application (Reference D-10).

 Chemical Reactions in Soil

     The soil may chemically alter many of the materials  which have been
 introduced into the profile through  the addition of sludge.   These alter-
 ations may lessen or increase the environmental  impact of sludge applica-
 tion.   For example,  through the conversion of organic nitrogen to nitrate,
 a  potential threat to groundwater quality and public health (Reference D-6)
 is introduced.

     Soil pH and calcium reserve are  very important  properties that de-
 termine to what degree a soil can inhibit the solubility of heavy metals
 compounds.   Contrasting properties of  alkaline (calcareous) and acid
 soils  are given below (Reference D-7) :

     Alkaline  (Calcareous)  Soils                 Acid Soils


   High in calcium                     Low in calcium
   High in pH  and carbonate             Low in pH;  no  carbonate
   Rich in nutrients                    Poor in nutrients
   Low  solubility of  heavy metal       High solubility of heavy  metal
     ions                                 ions
   High activity  of nitrogen  fixing     Low activity of nitrogen  fixing
     and nitrifying bacteria              and nitrifying bacteria
Physical Effects of Sludge Addition to Soils

    Sludge can act as a soil conditioner by the provision of those
organic compounds that eventually become valuable humus in the soil.
Sludge humus performs all the beneficial functions in the soil that any
other kind of humus does: it holds large quantities of water, it improves
soil structure and water absorption capacity  (Reference D-8). It also
improves root penetration and proliferation in the soil.

    Sludge as a soil conditioner promotes desirable physical properties
in soils such as friability (loose and crumbly rather than hard and
cemented)  and improved drainage (Reference D-9).   Sludge residue decreases
the bulk density of the soil (Reference D-10).  In clay soil, sludge
alleviates unfavorable characteristics by providing large pore spaces
among soil aggregates.  In sandy soil, it creates chemical reaction sites
for nutrient exchanges, improves soil aggregation, and makes a good
                                 D-6

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binder to hold the sand from blowing away (Reference D-ll).   It reduces
the erodibility of all soils through enhancement of more resistant soil
structure.

    Adding sewage sludge initially increases the hydraulic conductivity
of a soil, but the conductivity later decreases.  Organic matter,  through
the activity of microorganisms, increases soil aggregation thereby
increasing permeability.  The subsequent decrease in hydraulic conductiv-
ity appears to be due to clogging of soil pores by microbial decompo-
sition products.

    Incorporation of sludge markedly influences the soil atmosphere.   The
low oxygen and high carbon dioxide contents initially result from high
rates of liquid sludge application which can reduce root growth, nutrient
uptake and plant growth.  Other gas products of decomposition, such as
methane and ethylene, can be detrimental to plants under high sludge
application rates (Reference D-12).  However, anaerobically digested
air-dried sludge is stable enough so that decomposition reactions take
place over a rather extended period of time and do not deplete soil
oxygen (Reference D-32).
ENVIRONMENTAL CONSIDERATIONS AND CONSTRAINTS

    The application of sewage sludge to the land can have effects on
many functional components of the ecosystem.  These effects, along with
the major constraints to sludge application, are discussed in this
section.

Surface Runoff

    The area east of the Metropolitan Denver area is subject to heavy
runoff during the spring thaw and during the summer when relatively
short duration, high intensity thunderstorm activity occurs.  Application
of sludge during the spring and summer months could, if not handled
correctly, contaminate surface runoff with elevated levels of nitrate,
salts and suspended organic materials.  Heavy tnetals contained in the
organic materials are bound physically and chemically in the soil (when
sludge is incorporated into the soil), and as long as the soil stays in
place, little movement of heavy metals is expected.  Special attention
should be given to methods of containing surface runoff in order to pre-
vent contamination of surrounding surface water supplies (Reference D-l) .

Groundwater

    If the application of sludge on irrigated farmlands is implemented
by the private farms in the area, certain precautions concerning nitrogen
loading must be observed so that a balance between the amount of nitrogen
applied and the amount removed by the crops can be obtained.  This should
prevent excess nitrates from percolating into the groundwater table.
                                  D-7

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 For dry land farm applications, the percolation problem is much less
 severe.  Downward leaching of nitrates into the groundwater table  would
 occur rather slowly, estimated by Pratt (Reference D-30)  to average about
 0.15 to 0.75 m/yr (0.5 to 2.5 ft/yr) through unsaturated  strata in an
 area with characteristics similar to those of Adams County.  The possi-
 bility of groundwater contamination from excess nitrates  under excess
 sludge application regimes cannot be overemphasized.

 Aesthetics

     Land application of sludge can be managed so that no  more of an
 aesthetic impact would result than with general agricultural field
 practices.  Certain precautions can reduce any major aesthetic problems.
 Surface application of dry or liquid sludge should be followed shortly
 by incorporation into the soil either by discing or plowing.   The  time
 of the year when this is done should be controlled to prevent dust con-
 ditions from occurring.   Farm practices in the Denver area are fairly
 well defined and a great deal of experience on the part of the farmers
 has been accumulated to prevent dust problems.   Sludge should be applied
 only during the times of the year when proper dust prevention techniques
 can be observed (Reference D-l) .

 Odor
     Since the Metro Denver sludge would be anaerobically  stabilized,  the
 odor potential would be quite low.   The odor conditions are  closely  re-
 lated to anaerobic bacterial action on volatile  organic matter  in both
 the liquid and solid portions of the sludge.   Either  a high  degree of
 reduction of volatile matter, or chemical treatment  to inhibit  bacterial
 action,  is necessary to prevent nuisance odors.   The  degree  of  volatile
 reduction achieved by anaerobic digestion is  generally not less than  40
 percent  to achieve a stabilized sludge (Reference D-4).

     The  application of organic materials to  the  soil,  followed  by plowing
 in  shortly thereafter, should be no more objectionable than  the use of
 barnyard manure. With proper attention to application techniques,  odors
 should not be detectable outside of the immediate vicinity of application.
 Those odors which  are detectable when standing within the application
 area can best be characterized as faint tarry  odors with  a slight trace
 of  ammonia.   These odors will dissipate rapidly  after application to
 the  land.

 Food Chain

     The  application of sludge to agricultural  land on which  crops  enter-
 ing  the  human food chain are grown  is  a matter of some concern,  although
 there are  no  documented cases of disease resulting from the  use of sludge,
EPA guidelines require that  the application of sludge  to  lands on which
crops entering the human food chain will or may be grown must be examined
closely in terms of hazards  to human health and future  land productivity.
(Reference D-4)

                                   D-8

-------
     The principle of food chain concentration (biological magnifi-
cation) involves the accumulation and concentration of some sub-
stances as energy is passed in the form of food along the food chain.
Thus, a substance which is contained in minute amounts in individual
plants can become highly concentrated in certain organs in an animal
which eats a large number of those plants.

     Heavy Metals in Sludge—

     Elements in sludge that are potential hazards to plants or higher
species in the food chain are:  boron, cadmium, cobalt, chromium cop-
per, mercury, nickel, lead and zinc.  The elements that are a signifi-
cant potential hazard to the food chain through plant accumulation
are cadmium, copper and zinc.  Molybdenum has on rare occasions caused
animal toxicities when they have pastured on soils naturally rich in
this element.  Sludge from Metro Denver District is not expected to
contain toxic levels of molybdenum.  Toxic metals added to soils are
not a hazard to the food chain until they have entered an edible part
of a plant, such as the leaf, grain, fruit, or edible root or tuber.
Copper will cause severe plant injury before the content is high enough
to be toxic to most animals.  Cadmium and zinc, when added to the soil
in sludge, can lead to increased food chain cadmium and zinc (Refer-
ence D-13).

     Cadmium and Zinc—The Food and Drug Administration expects to
specify the permissible level of cadmium in foods in the marketplace,
possibly to be established at the current natural background levels
(Reference D-13).  Cadmium accumulates in the kidney and liver over
many years.  Kidney damage and hypertension have been related to in-
creased cadmium levels in these organs.  "Itai-Itai" disease was caused
in Japan by increased dietary cadmium; cadmium suppressed calcium
absorption and led to weak bones in older persons (Reference D-5).

     The only apparent way proposed so far to ensure that the cadmium
level in a food crop grown on a sludge-treated soil will not be a
food-chain hazard, is to reduce the cadmium content of sludges to 0.5
percent of the zinc content, and as near as possible to 0.1 percent
of the zinc content.  In this way, zinc excess (at about 500 ppm Zn
in leaves) would injure the crop before the zinc or cadmium content
of the crop became a health hazard.  Zinc appears to compete with
cadmium at the sites of uptake and injury in animals, and the high
zinc in crops grown on sludge-treated soil should serve to reduce
cadmium uptake and accumulation.  Grain, fruit, and edible roots have
a lower zinc content than the leaves of the same plants.  Cadmium is
excluded even more strongly, so that the cadmium/zinc ratio of grain,
fruit, and edible roots are one-half to one-tenth that of leaves.  The
choice of these types of crops in preference to leaf crops would mini-
mize cadmium movement into the food chain.  Further research is needed

                                   D-9

-------
 to determine what levels of cadmium and  zinc  are  safe  for  the human
 food chain (Reference D-13).

      Copper, Mercury and Lead—Copper, mercury, lead and some of  the
 other elements in amounts normally found in sludges will not cause
 appreciable plant and food chain injury  unless they are sorbed onto
 vegetative material by direct contamination and then ingested by
 animals in large amounts (Reference D-14).

      Direct Ingestion of Sludge by Pasturing  Domestic  Animals—

      Animals,  notably cattle,  are known  to  eat considerable quantities
 of soil as part  of their daily diet.  Sludge-applied soils, eaten by
 domestic animals,  would short-circuit the capacity of  the  soil in
 screening contaminants from the food chain.   Metro Denver  District is
 now engaged in a research project aimed  at  determining accumulations
 of heavy metal elements in various tissues  of animals  fed  controlled
 quantities of  sludge.

 Nitrogen

      Nitrogen  contained in digested  sludge  is the most immediate  limit-
 ing factor to  annual rates of  application on  a given tract of land.
 This is  due to the fact that  addition of excess nitrogen to the soil
 involves the risk  of polluting  the groundwater with nitrates.  The
 threat  of methemoglobinemia,  caused  by nitrates and nitrites in water
 supplies,  are  discussed under  public health impacts.   The  processes
 which affect the form  of  nitrogen in soils  (mineralization, nitrifi-
 cation,  denitrification,  immobilization, fixation, adsorption by  cation
 exchange,  volatilization,  convection, dispersion, and  plant uptake) may
 take place concurrently.   The  reates of  these processes are determined
 largely  by soil  type and  climate.  The nitrogen content of the anaer-
 obically digested  liquid  sludge at Metro Denver will consist of approxi-
 mately 40  percent  ammonia  nitrogen and 60 percent organic  nitrogen
 (Reference D-l).   During  drying,  most of the  ammonia and about half
 of  the organic nitrogen are lost  tn volatilization.

      Nitrogen  is available  to plants mainly as nitrates and ammonium.
 The  ammonium form  is rapidly converted by soil nitrifying  bacteria
 to  the nitrate form.  Organic nitrogen is also mineralized to the nit-
 rate  form  abailable  to  plants.  Excess nitrates not taken  up by plants
 can be leached into  the groundwater reservoirs.  Nitrogen  is lost
 through denitrification and volatilization of ammonia  and  nitrogen gas
 to  the atmosphere.   Volatilization can account for at  least a 25  per-
 cent loss  of ammonia nitrogen, with this percentage increasing the
 longer the  sludge  is subject to air-drying.   Approximately 30 percent
of  the remaining nitrogen in applied sludge becomes available for plant
uptake in  the first year, 15 percent in the second year,  10 percent in

                             D-10

-------
the third year and 5 percent in the fourth and succeeding  years.

     Nitrogen pollution problems can be controlled  with  correct management
which involves the formulation of a nitrogen balance for the  sludge
application program that prevents excessive nitrate leaching.  The com-
ponents of a nitrogen balance which must be known or estimated include:

   1)  Total nitrogen concentration of the applied sludge as  percent
       of solids (N);
   2)  The amount of sludge applied in metric tons  per hectare (R):
   3)  The amount of residual available nitrogen in the  soil  in metric
       tons per hectare (p);
   4)  The percent of nitrogen which is mineralized in a given year  (c );
   5)  Nitrogen losses through denitrification and volatilization;
   6)  Potential annual uptake of nitrogen by each crop  in Kg/ha/yr  (U);
   7)  Proportion of the nitrogen in the crop removed from the land  at
       harvest (c^);
   8)  The amount of leaching to be allowed;
   9)  A timing pattern to retain the balance sufficiently close  to  an
       equilibrium.

The major elements of this balance are expressed in Equation  D-2:

                            C]_ U
                     R = 1,000 c2 N  ~ P         (Equation D-2)

The variable p is assumed to be zero for the first year, and  for  success-
ive years is calculated according to the decay of residual available
nitrogen (30 percent in the first year, etc.)

     Nitrogen losses through denitrification and volatilization during
air-drying should be estimated and subtracted from the total  before  N
is computed.  The amount of leaching allowed is determined by the initial
groundwater quality, the size and rate of flow in the groundwater
reservoir, and the size of the sludge application site.   A certain amount
of leaching is required in order to restrict the buildup of soluble  salts
in the soil root zone below tolerable limits.  This leaching  water will
inevitably carry available nitrate forms to the groundwater.   As  a
rule of thumb, sludge application rates should be such that no more  than
one half of the nitrogen in the applied sludge can be carried by  the
leaching fraction of irrigation water.  Timing of sludge application
depends on the site and the specific situation.  It depends on 1) the
rate of nitrification and, 2) assuming that nitrate ion  movement  occurs
only with percolate movement, the moisture content properties of  the
soil, and 3) the amount of water added to the area.  If  sludge nitrogen
is nitrified and moves below the root zone before it is  absorbed  by
plants, it will percolate on to the groundwater.  If leachate nitrate
concentration is low during most of the year, high levels for a short
period of time are more tolerable.  Monitoring of the leachate must be
included with the management program to compensate for unknown factors
                                D-ll

-------
 (Reference D-15).

 Heavy Metals

    Heavy metals are  found in  digested sludge and usually occur in the
 soils as well.  Toxic conditions  are  not  caused merely by a high metal
 content in soil or sludge,  but  rather by  the presence of heavy metals
 in soluble form.   Heavy metals  are  adsorbed on the cation exchange sites
 of soil clays.  Metals may  also be  precipitated, chelated, or complexed
 with organic matter  in a form that  is unavailable to plants (Reference
 D-16).   The major  heavy metals  that are potentially hazardous to plants
 because of their amounts in sludge, availability in soils, and toxicities
 to plants or animals are zinc,  copper, nickel and cadmium (Reference
 D-15).   Successful treatment  of sludge heavy metals by the soil occurs
 when they are adsorbed or otherwise held  by the soil matrix so that
 they cannot be taken up by  plants or  leached into the groundwater.

    The  availability  of heavy  metals in sludge to crops is largely a
 function of soil pH  and cation  exchange capacity, phosphorus, calcium,
 organic  matter, and  crop variety, species, organ and age.  The following
 summary  presents methods of minimizing metal uptake by crops (Reference
 D-14):

               Factors for  Reducing Availability of
           Sludge Trace Elements and Their Uptake by Plants

       Sludge:   Low concentration  of  trace elements
                 Low Cd to  Zn ratio
                 High  Phosphorus
                 High  organic matter
                 High  lime

       Soil:     Neutral to high pH
                 High  cation exchange capacity
                 High  organic matter
                 Calcareous soils

       Crop:     Trace  element  tolerant variety and species
                 Fruit  and seeds compared with vegetative tissue
                 Younger compared with older vegetative tissue

Plants vary greatly  in  tolerance to heavy metal toxicity and the relative
tolerance of some plants is shown below (Reference D-14):
                               D-12

-------
                Relative Tolerance to Metal Toxicity

     Very        Beet crops (chard, sugarbeet,  redbeet),  kale,  mustard,
   Sensitive:    turnip, tomato
   Sensitive:    Beans, cabbage, collards,  other vegetable crops

  Moderately     Many farm crops, i.e., corn,  small grains,  soybeans
   Tolerant:
   Tolerant:     Most grasses, i.e., fescue, lovegrass,  Bermudagrass,
                 perennial ryegrass
     Very        Ecotypes of grasses
   Tolerant:

    EPA guidelines for sludge application rates are based on the soil
cation exchange capacity and the concentrations of zinc, copper and
nickel, as shown above in Equation 1.  The limits imposed by this
equation are designed to keep down the level of heavy metals being
absorbed by plants and to protect the fertility of agricultural lands
(Reference D-4) .

Pathogens

    The control of pathogens is of importance because of possible direct
exposure to sludge in the handling and application steps and in the
food chain.  Although anaerobic digestion reduces the pathogen content
of sludge, a significant number of pathogens may survive the process
(Reference D-2).  There is no documented evidence of disease caused by
the use of digested sludge on agricultural land, yet some pathogenic
organisms have been reported to survive in soils for long periods of
time.

    Four major groups of pathogenic organisms that are found in munici-
pal wastewater are:  1) Salmonella, Shigella and Mycobacterium bacteria;
2) the protozoa, Entamoeba hystolytica and Naegleria; 3) Helminth
parasites, As caris, Ancyclostoma, Necator, Taenia, and Tricahuris; and
4) viruses.  Of the 150 viruses isolated from sewage, only two, the
causative agents for poliomyelitis and infectious hepatitis, have been
found to be epidemiologically significant (Reference D-15).  The sur-
vival and movement of viruses through the soil is the subject of much
research (Reference D-16).  Fecal and total coliform bacteria, although
not pathogenic, are used for pathogen determinations because of their
large numbers and the ease of measurement as an indication of the
presence of other enteric bacteria and pathogens (Reference D-15).
                                D-13

-------
     Additional pathogen reduction beyond that attained by stabilization
 can be achieved by the following methods:

     1) Pasteurization for 30 minutes at 70°C (158°F);
     2) High pH treatment, typically with lime,  at a pH greater than 12
        for 3 hours;
     3) Long-term storage of liquid digested sludge for 60 days at 20°C
        (68°F) or 120 days at 4°C (40°F);
     4) Complete composting at temperatures above 55°C  (131°F)  for at
        least 30 days;
     5) Use of chlorine or other chemicals  to stabilize and disinfect
        sludge (Reference D-4, D-2).

 Current research shows preliminary  promise in the use  of high  energy
 electrons for disinfection of sludge passing in a thin stream  in a
 specifically adapted process (Reference D-31).

     The viability of pathogens is extremely variable and may be from a
 few hours to several months.   Among the factors influencing the survival
 of pathogens in the soil and on vegetation are:

     1)  Type  of organism;
     2)  Temperature -  lower temperature  increases  viability;
     3)  Moisture - longevity is greater  in  moist soils  than in  dry soils;
     4)  Type  of soil - neutral, high  moisture holding soils favor sur-
        vival;  and
     5)  Organic matter -  the type and amount of  organic matter  present
        may serve  as  a food or energy source to  sustain the microorgan-
        isms  (Reference D-2).

     The potential for groundwater contamination by pathogens is depend-
 ent  on  the ability  of pathogens  to survive  and  move through the soil
 system.   Fine  clay solids  are  more effective  than sandy  soils  for  the
 removal of pathogens.  A soil  system is  generally efficient in removing
 pathogens  unless  rapid movement  of sludge  (or later, irrigation water)
 occurs  through  large  cracks in the soil  profile. Generally, surface
water contamination constitutes  a greater hazard  through surface
 erosion or surface water runoff  during periods  of snowtnelt or  thunder-
storm precipitation (Reference D-2).

    EPA guidelines state that  sludge-treated  land should not be used
for human  food  crops  to be eaten  raw  until  three years  after sludge
application.   Sludge  applied to  crops which  are cooked  or processed  be
before consumption, to pastures,  or  to crops used for  forage,  should
test negative for pathogens by normally  applied analytical procedures.
EPA suggests  the use  of Salmonella and Ascaris  as pathogens of  choice
for a monitoring program (Reference D-4).
                                 D-14

-------
 Salts

     The soluble ions  calcium,  magnesium, sodium, potassium, chlorine
 and carbonate are the principle  inorganic ions added to soil in sludge
 and mineralized from  sludge  organic materials in large concentrations.
 These highly soluble  salts are involved in exchange reactions in the
 soil and,  depending upon the composition of the adsorbed phase, will
 be temporarily retained and  slowed in  their passage through the soil.
 In the Denver area, normally there is  sufficient excess irrigation or
 rain water available  to flush  these ions through the soil and into the
 groundwater table.  In arid  and  semi-arid parts of the country, water
 is relatively expensive and  thus scantily used, and rainfall is infre-
 quent, resulting in an accumulation of salts in the upper soil layers.
 This accumulation can, in time,  prove  deleterious to crops.  Frequently,
 in the case of high sodium concentrations, soil permeability is drasti-
 cally decreased before sodium  directly affects plant growth.  This
 occurs with too high  a percentage of sodium ions on the exchange sites
 when sodium replaces  calcium and magnesium ions on clay particles, dis-
 persing the soil particles and decreasing soil permeability.

     The salt content  of soils  is determined by the electrical conductiv-
 ity (millimhos per cm) or percent of  the  soil mass  in  more  severe  con-
ditions.  Generally, when the conductivity  rises  to  above  4.0  minhos/cm,
the salt content is considered high  and.will  affect  yields of  all  except
salt-tolerant plants  (Reference D-19).

     Crops  commonly grown in  the  Denver region will suffer 50 percent
 reduction  in yield at a soil salt concentration of 0.25 percent (with
 50 percent water saturation).  Assuming a 1.2 m [4 ft]- root zone  and
 a background salt level of 0.05  percent, 200 metric tons  [200 tons] of
 dry solids would add  the maximum limit of 0.20 percent more salt to the
 root zone  (Reference  D-l).

     Low-rate application of  sludge probably will not cause salt accumu-
lation in amounts that would  affect  plant  growth.   For  irrigated land,
the leaching provided by the  irrigation water should prevent a harmful
buildup of salts.  Crop yield would  be reduced on dry land farms by
lower  salt concentrations that were not flushed by leaching.  At load-
ing rates of less than 1 m ton per year [1 ton/yr],  over 100 years would
be required  to reach potentially harmful salt concentrations of 0.15 per-
cent in the  soil  (Reference D-l).  Salt accumulation in soils is easily
monitored and can be controlled with proper management.

    Boron  is  a potentially hazardous element, commonly viewed with
alarm  in irrigation waters.  The  most  boron-sensitive crops are adverse-
ly affected  at  levels  above  0.3  mg/1 in the irrigation water.  No
limits have  been  established on  the tolerable levels of boron in
sludges; however, it  is possible  to compare boron loadings resulting
from typical irrigation applications with equivalent applications of
                                D-15

-------
 sludge.   About 100 mg/kg  of  boron concentration in sludge, applied with
 recommended  limits, can be considered a safe limit.  Historical data on
 the boron concentration of sewage sludges in Denver do not exist.  A
 recent grab  sample analysis  of  the three Denver sludges produced the fol-
 lowing boron concentrations:

       Denver Central Plant  Primary Sludge:             60 mg/kg
       Denver Central Plant  Waste Activated Sludge:     62 mg/kg
       Denver North Side Digested Primary Sludge:       31 mg/kg
 AGRICULTURAL  CONSIDERATIONS

 Fertilizer  Value

     Anaerobically  digested sludge contains all of the essential plant
 nutrients and has  valuable soil  conditioning properties.  The literature
 contains many references  to increased plant growth resulting from the
 application of sludge.  The major fertilizing elements, nitrogen, phos-
 phorus  and  potassium, are present in varying proportions depending upon
 the  nature  of the  sludge and other factors such as the length of time
 which the sludge has been dried  or stored.  Essentially, the solids
 portion of  the sludge contains most of the nitrogen and phosphorus,
 while the liquid portion contains most of the potassium (Reference D-20).
 In calcareous soils, such as those found in the Denver area, potassium
 is more available  to plants than in non-calcareous soils, and thus the
 low  potassium content of dried sludge would probably not need to be
 supplemented  by commercial fertilizer.

     Total nitrogen content of air-dried sludge is approximately 6 to 8
 percent of  the dry weight, with  about one-half of that present as
 ammonium nitrogen.  It is assumed that approximately 30 percent of the
 total nitrogen in applied sludge is made available for plant use in
 the  first year, 15 percent in the second year, 10 percent in the third
 year, and 5 percent in the fourth and succeeding years.  Since nitrogen
 is usually  considered to be the  limiting factor in annual sludge
 application rates, sludge as a commercial fertilizer substitute can
 supply  the needed amount of nitrogen for a particular site and crop.
 Other nutrients,  such as potassium,  may be deficient and require supple-
mental  fertilization.  Phosphorus (at 3 percent of the dry solids) is
 abundantly supplied in an application which is computed to balance
nitrogen with uptake by plants.   The possibility of applying excess
phosphorus exists in non-calcareous  soils.

Fertilizer Market

    In 1972, 36,000 metric tons   [40,000 tons]  of fertilizer were sold
in the Denver area, a large part of  which was  used for urban lawns,
gardens  and other non-farm purposes  (Reference D-l).   The 1970 farm
fertilizer use percentage by crop and the total land area are shown
                                D-16

-------
 in  Table  D-2. The main source of organic fertilizer in Colorado is
 livestock manure  (88 percent), with about 10 percent of organic fertiliz-
 er  sales  consisting of sewage sludge  (Reference D-l).  Commercial
 sales  of  natural  organic  fertilizers  have dropped off considerably in
 Colorado, but the amount  of manure that is used for fertilizer far
 exceeds the  amount which  is sold commercially (Reference D-l).

     The overall commercial fertilizer market adds perspective to the
 use of sludge in  place of chemical fertilizers.  Increased demands are
 being  made on the fertilizer industry as a result of various factors,
 including the energy crisis, the need for heavier applications in old
 farming areas, and increases in newly added farming areas.  Domestic
 supplies  are predicted to fall short  of the demand, and the increasing
 prices of commercial fertilizer may induce more farmers to view the use
 of  sludge favorably.

     The ability of sludge to compete  with fertilizers in the marketplace
 is  an  issue  that will certainly emerge in the near future.  For example,
 at  a trucking cost of $0.08 per cubic meter-kilometer [$0.10/cu yd-mile], a
 distance  of  about 100 km  [60 mi] would represent the limit at which the
 transportation cost of air-dried sludge (with 5 percent nitrogen on a
 dry weight basis  and 50 percent solids) equals the current price of
 equivalent commercial chemical fertilizer nitrogen ($0.55 per kilogram
 [$0.25/lb])  alone.  A general formula for computing the break-even
 distance  for trucking sludge is given simply by:

                           D =  F NYWS	            (Equation D-3)

 where  D is distance from  the distribution center to the ultimate appli-
 cation area, F is unit commercial fertilizer cost, N is fraction of
 nitrogen  in  the dry solids, W is the  fraction of solids in the slude, S
 is  specific weight of sludge and Y is cost of trucking a unit volume of
 sludge (including Water)  over a unit  distance, all parameters being in com-
patible (metric or English) units.  Application cost is assumed equal for
 sludge and chemical fertilizer.

Crop Selection

     Selection of  crops suitable for growth on sludge-enriched soils
 should be done in consultation with the local extension service of the
 U.  S.  Department  of Agriculture.  Plants vary widely in their reactions
 to  sludge application, and these reactions are site-dependent.  Under
 most conditions,  some crop species take up and accumulate certain trace
 elements, reducing crop yield and inhibiting use in the food chain.  The
 major  factors governing crop response on sludge amended soils are soil
 type,  pH, moisture content, climate,  and crop species.  Soils that
 have a neutral or higher  pH, a high cation exchange capacity and a
 high amount  of organic matter reduce  the availability of trace elements
 and their uptake by plants.

     Crops that are grown  for their seeds or fruits rather than vegetative
                                 D-17

-------
                          Table  D-2.  ON-FARM FERTILIZER USED IN DENVER AREA, 1970
i
M
00

Crop
Corn
Wheat
Sugar beets
Potatoes
Barley
Oats
Dry beans
Sorghum
Alfalfa

Total tons sold
and surface
area
Percentage of
N
51
7
23
1
10
2
0
1
5
100
4,003, metric

[A, 413, short]
total element
P
12
1
50
3
19
2
I
I
11
100
1,187, metric

[1,308, short]
applied
K
__ .
-
28
16
-
-
7
11
38
100
110,

[121,
Hectares
planted
32,684
123,525
8,829
830
33,453
14,418
4,617
3,657
37,058a

metric 259,070

short ]
Acres
planted
80,700
305,000
21,800
2,050
82,600
35,600
11,400
9,030
91,500a

639,680


       Harvested.

      Source:   Agricultural Reuse Program (Reference D-l).

-------
 tissue and crops whose younger rather than older vegetative tissue is
 utilized are more desirable in terms of trace element accumulation.
 Some  crop species and varieties are more tolerant to trace elements
 than  others.  Field crops such as corn, small grains, and soybeans are
 moderately tolerant.  Most grasses (fescue, lovegrass, Bermudagrass,
 orchard grass, perennial ryegrass) are tolerant to high amounts of
 metals.  Unusually metal-tolerant ecotypes of the grasses are found on
 ore outcrops containing extremely high amounts of metals (Reference
 D-5).  The leafy vegetables such as beets, mint, vine, lettuce, swiss
 chard, tend to accumulate cadmium and other heavy metals in their
 le aves.

    The nutrient uptake potential of different crops is essential
 information for determining nitrogen loading rates, as discussed above
 under Nitrogen.  Table D-3 presents nitrogen uptake by certain forage,
 field and forest crops.  The varying capacities of different crop
 species to use water through evapotranspiration relate to the water
 regime of the area and possible salt accumulations in the soil. Daily
 consumptive water use of three crops, grown near Denver is shown in
 Figure D-l.

    The selection of vegetative cover can also influence the potential
 for contamination of surface waters, since certain plants stabilize the
 soils and control erosion and runoff more efficiently than others.  For
 example, most grasses would be superior to crops such as soybeans or
 corn  in the control of runoff (Reference D-20).

 Germination

    The inhibition of germination following the application of liquid
 digested sludge on soils has been occasionally reported.  The results
 of two research efforts in this field are briefly presented below.

    Molina, Braids, Hinesly and Cropper conducted experiments with  corn
 and soybeans (Reference D-22).  Seeds did not germinate in the liquid
 phase of fresh digested sludge.  This inhibition was not due to ammon-
 ium nor solely due to a salt effect, an oxygen deficiency, or a low
 oxidation-reduction potential of the medium, they concluded.  Seeds
 did germinate in digested sludge which had been aged in contact with
 the air for one week.

    Sabey and Hart worked with sorghum sudangrass, millet and wheat,
 using Metro Denver sewage sludge (Reference D-19).  They found that
 increasing amounts of sewage sludge caused increased inhibition of
 germination and emergence of sorghum sudangrass and millet when planted
 shortly after the sludge was incorporated into the soil.  Wheat was
 planted five months later and did not show any inhibitory effects,  even
with high rates of application.  A later greenhouse study (the results
 of which have not been completely analysed) shows that with low applica-
 tion  rates (22 to 45 metric tons/hectare  [10 to 20 tons/acre]), two
                                 D-19

-------
           Table D-3.   REPORTED NUTRIENT REMOVAL  BY  CROPS

Crop
Forage
Coastal Bermuda grass
Reed canary grass
Fescue
Alfalfa
Sweet clover
Red clover
Lespedeza hay
Field
Corn
Soy beans
Irish potatoes
Cotton
Milo maize
Wheat
Sweet potatoes
Sugar beets
Barley
Oats
Forest
Young deciduous (up to 5 years)
Young evergreen (up to 5 years)
Medium and mature deciduous
Medium and mature evergreen
Nitrogen
(kg/ha/yr)

538-672
253-402
308
174-246
177
86-141
146

174
105-127
121
74-112
91
56-85
84
82
71
59
112
67
34-56
22-34
uptake
(Ibs/ac/yr)

480-600
226-359
275
155-220a
158a
77-1263
130

155
94-1133
108
66-100
81
50-76
75
73
63
53
ioob
60b
30-50b
20-3 Ob
legumes obtain a substantial part of their nitrogen requirements
 from the air.
tv  •
 Estimated.
Source:   Design Seminar for Land Treatment of Municipal Waste-
         water Effluents (Reference D-21).

                               D-20

-------
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                                                       \
                                                           0.05
     MAR.   APRIL    MAY   JUNE   JULY    AUG.    SEPT.   OCT.   NOV.

                            MONTH




   SOURCE : AGRICULTURAL REUSE PROGRAM  ( REFERENCE D-l )
                         FIGURE  D-l

          DAILY CONSUMPTIVE WATER USE OF CROPS

              GROWN NEAR DENVER,COLORADO
                           0-21

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 weeks  to one  month  is  sufficient  to eliminate the inhibitive effects
 on wheat.   The  time period  increases with higher rates of application.
 The germination of  corn  and sorghum sudangrass hybrid was somewhat more
 affected by the sewage sludge  than the wheat, although this result was
 thought  to  be adversely  affected  by greenhouse conditions.

     Sabey and Hart  conducted a preliminary study to determine whether
 inorganic salts or  organic  compounds caused the germination inhibition
 (Reference  D-19).   The authors concluded that the salt content of the
 sludge did  not  cause the inhibition, and that the inhibitive factor is
 associated  x^ith the organic compounds since destroying or volatilizing
 the organic compounds  eliminates  the inhibition.

 Weeds

     Weed control may be  a major problem when sludge is applied to agri-
 cultural land,  although  the literature contains few references to this
 problem.  A cause of weeds  associated with sludge applications is the
 viability of  seeds  of  many  food crops through the human digestive
 system and  the  wastewater and  sludge treatment processes.  Application
 of sludge may necessitate the  use of herbicides for effective weed
 control.  The concentration of herbicides in runoff and drainage water
 should be monitored.

 Application Rates

     Application rates depend  on  sludge composition, soil characteris-
 tics, climate,  vegetation,  and cropping practices.  Applying cludge at
 an annual rate  to support the  nitrogen needs of a crop avoids problems
 associated  with pollution of water supplies.  Almost all ill-effects  a-
 rise from too heavy or too  frequent applications of sludge  (Reference D-3).
 Total sludge  application limitation is imposed by heavy metals content
 of  the sludge and is defined by Equation D-l on page D-5.  Annual applica-
 tion rate,  on the other  hand,  is  constrained by the available nitrogen
 content  of  the  sludge  and is expressed in Equation D-2 on page D-ll above.

 General  Conclusions

     The  application of  liquid digested sludge has been shown by research
 and by practical experience  to have beneficial effects on agricultural
 lands if proper rates  of  application (as determined by the properties of
 the sludge,  the nature of the site and the characteristics of the crops
 grown)  are adhered  to.   These beneficial effects are generally the re-
 sult of  the enhancement of soil properties and the addition of plant
nutrients that lead  to increased crop yields.   There are many references
 that document increases in plant growth as a direct result of the applica-
 tion of sludge.   Some studies even show that yields are higher on sludge
enriched  soils than on soils which have received commercial fertilizer.
 (Reference D-23).

-------
    Although the application of sludge to a given area  is  extremely
site dependent,  some general conclusions  which may be of  use  are pre-
sented below (Reference D-10,  D-15,  D-19):

    1)  Salt buildup in the soil can create a short  term  hazard to
        plant growth,  but will not  cause  long-term problems if proper
        irrigation and drainage practices are followed.

    2)  Pathogenic dangers, as indicated  by fecal coliforms,  will not
        extend more than 120 to 150  cm (50  to 60  in.) into the soil
        profile, nor last more than  2.5 months near  the soil  surface.

    3)  Heavy metal contamination of the  groundwater is not a problem
        even at  high sludge loadings because of the  soil's ability  to
        adsorb and retain them.   Cadmium  may be the  first metal to
        present  such a problem (Reference D-15).

    4)  Heavy metal uptake by  plants grown  on sludge amended  soil is
        not expected to be excessive and  should cause no  plant toxicity
        or human dangers as long as  the ultimate  application  rate limit
        is not exceeded.

    5)  Nitrate  leaching to the groundwater can be substantial, increas-
        ing directly with sludge application rates,  and will  be the
        first limiting factor  for sludge  application on a yearly basis.

    6)  Nitrate  leaching can be controlled  with management techniques
        involving balancing nitrogen applications with  crop uptake.

    7)  Potential hazards to the groundwater can  be  more  accurately
        monitored by measuring leachate quality and  quantity  than
        through  direct groundwater sampling.

    8)  Direct ingestion of sludge-applied  soil by domestic animals
        can be a potential danger to the  human food  chain through direct
        accumulation of heavy  metals in edible tissues.

    9)  Seed germination can be inhibited if sludge  is  added  just prior
        to planting.  If planting is conducted two weeks  to one month
        after sludge application, seed germination is uninhibited.

   10)  Properly digested sludge will produce no  offensive odors  after
        application and incorporation into the soil.

   11)  A sound  agronomic and  environmental principle is  to apply  the
        least amount of sludge that  will  supply sufficient nutrients
        for plant growth.
                                  D-23

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    12)  Monitoring is necessary for sludge application programs  to
         ensure against creating environmental hazards.
 CHEMICAL PROPERTIES OF METRO DENVER SLUDGE

     The organic material generated by the Metro Denver Sewage  Disposal
 District No.  1 will be anaerobically digested,  and will contain organic
 and inorganic nutrients, humus,  and residual levels of various metallic
 compounds.   The digested sludge  will contain 6  to 8 percent  total
 nitrogen (expressed as a percentage of the dry  weight of the organic
 materials),  of which 3 to 4 percent (of the total dry solids)  will be
 ammonia nitrogen.   The sludge will contain approximately 3 percent
 total phosphorus.

     The most  recent heavy metals concentrations of primary and waste-
 activated sludges  from the Northside and  Central treatment plants are
 presented in  Table D-4.   A flow-weighted  average concentration is also
 computed and  presented for the mixture that would result from  blending
 these sludges.   A  comparison of  the quality of  this mixture with  that
 of a "good" sludge is  presented  in Table  D-5.

     It can be seen that  nickel and copper exceed the suggested limits.
 Excessive levels of these two heavy metals  can  adversely affect plant
 growth.   The  cadmium/zinc ratio, which is perhaps  the most important
 indicator of  heavy metal toxicity,  is  higher than the suggested limits.
 However,  with the  conservative application  rate recommendations and the
 calcareous nature  of soils  in the  study area, it  probably will not
 cause a significant problem.

     Metro Denver sludge  contains all of the essential plant nutrients
 and  possesses  soil conditioning  properties.   The  nitrogen content is
 satisfactory  for fertilization purposes.  The longer sludge is  dried,
 the  more  ammonium  nitrogen  is  lost  through  volatilization.
LAND USE OPTIONS FOR SLUDGE APPLICATION

    Four specific land use areas are being considered by Metro Denver
for the application of sludge.  These are: 1) city parks, 2) mine
spoil sites, 3) sod farms, and 4) irrigation and dryland farms.  In
this section, specific parameters will be discussed as they relate to
each land use.

City Parks

    The literature contains general references to the application of
sludge on city parks, lawns and golf courses, but no definitive studies
have been reported.   In New York City, sludge has been used as a soil
conditioner to produce artificial topsoil on proposed park sites (Ref-
                                  D-24

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Table D-4.  SLUDGE HEAVY METALS CONTENT COMPUTED  FROM SAMPLES OBTAINED
       AND ANALYZED OVER A PERIOD OF FOUR MONTHS  IN  EARLY  1975



Parameter
Zinc
Copper
Nickel
Chromium
Lead
Cadmium
,. d
Manganese
Mercury6
Cd/Zn ratio


Pri-
mary
sludgesa
927
587
268
301
275
9
131
17.8
0.0065

Heavy metals content ,
ing/kg dry sludge
Concentrated
waste-activated
sludges'3
1,252
916
289
545
383
24
97.5
4.2
0.019


Flow-
weighted
average0
1,145
808
282
465
347
19
109
8.7
0.017
 Arithmetic averages computed for 18 samples except for manganese and
 mercury (see footnotes d and e, below).

 Arithmetic averages computed for 17 samples except for manganese and
 mercury (see footnotes d and e, below).
Q
 It was assumed that the mixture contains 33 percent primary and 67
 percent concentrated waste-activated sludge.

 Arithmetic averages computed for two samples.
g
 Arithmetic averages computed for three samples.

Source:  Raw data obtained from Metropolitan Denver Sewage Disposal
         District No. 1.
                                  D-25

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  Table D-5.  COMPARISON OF METRO DENVER SLUDGE HEAVY METAL CONTENT
                        WITH SUGGESTED LIMITS

                         (mg/kg dry solids)


Element
Zinc
Copper
Nickel
Chromium
Lead
Cadmium
Manganese
Mercury
Boron

Existing
concentrations
1,145
808
282
465
347
19
109
8.7
51a

Suggested
(Reference D-24)
1,500
750
150
500
500
50
-
-
-

limits
(Reference
2,000
800
100
-
1,000
< 0.5 % of
-
15
100


D-13)





zinc



Cadmium/zinc
  ratio
0.017
0.001 - 0.005b
0.005
 Obtained by computing a sludge solids flow-weighted average of grab
 samples described on page D-15.  Grab samples were collected on 30
 October 1975.
 Reference D-13.
                                 D-26

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 erence D-ll).   Composted sludge and leaf mold are  being  used  to
 renovate the soil at the newly created Constitution  Gardens in Washing-
 ton, D.C.  (Reference D-25).   Liquid and possibly dewatered sludge  can
 be applied to the surface of turf grass, but  odor  might  be a  problem
 and time would be required before traffic could be allowed to return
 (Reference D-14).  The timing of sludge application  could control  the
 odor problem.   If sludge is applied in the winter, the snow and  moisture
 will carry the nitrogen value to the root zone, will eliminate any
 perceptive odor,  and will accelerate lawn growth in  the  spring (Reference
 D-26).

     In general,  grass is a good crop for sludge fertilization because
 it is tolerant of heavy metals, has a high rate of nitrogen uptake,
 and minimizes problems from runoff.  Furthermore,  with each cutting
 appreciable quantities of salts and nutrients are  removed from the
 land, if only to be placed in landfills.

 Mine Spoil Sites

     The literature contains many references to the use of sewage sludge
 for revegetation programs on mine spoil sites.  Most of  these sites
 have been coal mine spoils, although the extreme environmental conditions
 associated with coal mine spoil sites are generelly  similar to those  of
 other large scale mining operations.  In general,  problems  result  from
 extremely acid soil conditions, high rates of erosion and runoff,  acidic
 runoff, toxic levels of certain metals in the soil,  low  soil  fertility,
 low soil moisture content,  and high summer surface temperatures.  Be-
 cause of the nature of mining operations, spoil sites necessarily  do
 not possess a substrate favorable to plant growth.  Most soils evolve
 over long periods of time as a result of x^eathering  of parent material
 and the accumulation of organic matter.

     Experiments with revegetation of spoil sites have confirmed  the
difficulty of establishing vegetative cover on such harsh conditions.
There is frequently 100 percent mortality of plants on spoil sites  with
no amendment.  On sites treated with sludge, plants germinate  and
survive.

     The potential toxicity of a mine spoils site is  best characterized
by the pH,  Although there is a difference in plant tolerance  to  acidity,
a spoil material with pH below 4.0 is toxic to most plants.   The  pH of
most spoil sites is between 2.0 and 3.0.  At these  values the  high
solubility of certain metals such as iron, aluminum and manganese
severely inhibits plant growth.  Evans and Sopper  report  that  on  an
experimental plot, the untreated control boxes had  complete  mortality
of trees, grasses and legumes.  They also had the  lowest  average  values
for phosphorus and nitrate-nitrogen and  the highest values of  iron,
manganese and aluminum.  Plots  treated with effluent and sludge,  had
the highest values for phosphorus and nitrate-nitrogen and the lowest
for iron, manganese and aluminum.  Since benign spoil materials  are also
                                 D-27

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 low in soluble phosphorus and nitrate-nitrogen,  they concluded that
 iron, manganese and aluminum are more  directly  related to  revegetation
 failures.  The higher concentrations  of these and other heavy  metals
 appear to be the results of solubilization  of the native rock  by  the
 high acidity.   Irrigation with effluent and sludge leached and diluted
 the native salts (Reference D-27).  The addition of sludge also
 increased both phosphorus and potassium levels  in the treated  spoil
 (Reference D-28) .

     The establishment of a complete ground  cover of vegetation is highly
 desirable since it can result in (1) earlier stabilization and reduction
 of erosion;  (2)  earlier mitigation  of  acid  drainage by diminishing net
 recharge through increased evapotranspiration losses;  (3)  the
 acceleration of accumulation of organic residues  which will chelate
 and otherwise  make unavailable the  soluble  iron,  manganese and
 aluminum (Reference D-27).   Organic residues also provide  the  necessary
 seed bed for plant germination.

      The major effects of the application of digested sludge to mine
 the spoil sites  include the  improvement of  spoil  pH,  increased
 infiltration of  precipitation,  the  germination and establishment  of
 vegetation,  and  the reduction of acidity and concentrations  of some of
 the chemicals  in the runoff  issuing from the site (Reference D-29).

 Sod Farms

      The  use of  digested sludge  on  sod  farms has  been  proposed by
 Metro Denver and some of the  sod growers in the  Denver Area.   Sludge
 contains  all of  the essential plant nutrients and enhances  soil
 properties through the addition  of  organic  residues.   Sod  farming
 involves  the periodic removal of the topmost plant and soil  layers,
 thus  the  importance of the ability  of sludge to provide  continuing
 soil-building  material becomes apparent.  Site conditions  regulate the
 application  rate of sludge,  depending on specific soil and  crop
 characteristics.   Grass is a  good crop  for  sludge fertilization because
 it  is  tolerant of  heavy metals,  is  not  used as feed or food, has  a
high  rate of nitrogen  uptake,  and minimizes  problems  from  runoff  and
erosion.  If sludge is  applied in the winter, the  snow and moisture
will  carry nitrogen to  the roots, will  eliminate  any perceptive odor,
 and will  accelerate  vegetative growth in the spring  (Reference D-26).

Irrigation and Dryland  Farms

Digested sludge has been  used widely in agriculture  throughout the
United States and in other parts of the world.   Most of  the material
discussed in this appendix relates  to  the agricultural  use of  sludge
and need not be repeated.  In general,   dry  farmland will sustain  a
lower application rate  of sludge because the rate  of nitrogen  uptake
of dryland crops is much  lower than that of  irrigated  crops.  Most
irrigated and non-irrigated crops grown in  the  study area are either
                                D-28

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not consumed by humans or are processed to such a degree that sludge
contaminations are removed.

     Irrigated crops include many plants intended for direct human
consumption with minimal processing.   Even though it is not recommended
to apply sludge on fields growing such crops,  proximity of  the various
fields, rotation patterns and loss of records  may lead to inadvertent
sludge contact with these plants.  Therefore,  a greater degree of  im-
portance should be attached to control and management recommendations
to mitigate adverse impacts on the food chain.
                                  D-29

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                       REFERENCES FOR APPENDIX D
  D-l.   CH2M HILL,  Agricultural Reuse  Program, Denver, Colorado,
        March 1973.

  D-2.   U.S. Environmental  Protection  Agency,  Process Design Manual for
        Sludge Treatment and Disposal,  EPA  625/1-74-006, October 1974.

  D-3.   Evans, James  0., "Soils as  Sludge Assimilators," Compost Science,
        Vol. 14,  No.  6  (Nov.-Dec. 1973).

  D-4.   U.S. Environmental  Protection  Agency, Municipal Sludge Manage-
        ment:  Environmental  Factors, Technical Bulletin, EPA 430/9-75-
        XXX, Preliminary Draft.

  D-5.   Chaney, Rufus L.  "Recommendations  for Management of Potentially
        Toxic  Elements  in Agricultural  and  Municipal Wastes," in "Fac-
        tors Involved in Land Application of Agricultural and Municipal
        Waste," USDA, ARS,  Beltsville, Maryland, 1974.

  D-6.   Ellis,  Boyd G.,  "The Soil as a Chemical Filter," in Recycling
        Treated Municipal Wastewater and Sludge Through Forest and Crop-
        land,  Edited by  William  E.  Sopper and Louis T. Kardos, The Penn-
        sylvania  State University Press, University Park, 1973.

  D-7.   Epstein,  Emanuel, Mineral Nutrition of Plants: Principles and
        Perspectives, John Wiley and Sons, New York, 1972.

  D-8.   Anonymous,  "Waste Water  Expert Answers Indignant Old Lady,"
        Compost Science, Autumn, 1969.

  D-9.   Lisk, Donald J.  "Trace Metals in Soils, Plants, and Animals,"
        Advances in Agronomy, Vol.  24,  1972.

D-10.   Hinesly, T. D., 0. C. Braids, and J. E. Molina, Agricultural
        Benefits and Environmental Changes Resulting from the Use of
       Digested Sewage Sludge on Field Crops, U.  S. Environmental Pro-
        tection Agency, SW-30d, 1971.

D-ll.  Kirkharn, M.  B., "Disposal of Sludge on Land: Effect on Soils,
       Plants, and Ground Water," Compost Science, Vol. 15, No. 2
        (March-April 1974).
                                 D-30

-------
D-12.  Epstein, Eliot, "The Physical Processes in the  Soil  as Related to
       Sewage Sludge Application," in Proceedings of the Joint Confer-
       ence on Recycling Municipal Sludges and Effluents on Land, U.S.
       Environmental Protection Agency,  U.S.  Dept.  of  Agriculture, and
       the National Association of State Universities  and Land Grant
       Colleges, Champaign, Illinois, July 9-13,  1973.

D-13.  Chaney, Rufus L. "Crop and Food Chain  Effects of Toxic Elements
       in Sludges and Effluents," in Proceedings  of the Joint Confer-
       ence on Recycling Municipal Sludges and Effluents on Land, U.S.
       Environmental Protection Agency,  U.S.  Dept.  of  Agriculture, and
       the National Association of State Universities  and Land Grant
       Colleges, Champaign, Illinois, July 9-13,  1973.

D-14.  Walker, John M., "Sewage Sludges  — Management  Aspects for Land
       Application," Compost Science, Vol. 16, No.  2 (March-April 1975).

D-15.  Trout, T. J., J. L. Smith and D.  B. McWhorter,  Environmental
       Effects of Land Application of Digested Municipal Sewage  Sludge,
       Interim Report, Department of Agricultural Engineering, Colorado
       State University, Fort Collins, Colorado,  1975.

D-16.  Office of Research and Monitoring, Task Force Report on Sludge
       Disposal, U.S. Environmental Protection Agency, April 1972.

D-17.  Malina, Joseph F., Jr., and Bernard P. Sagik, Eds.,  Virus Sur-
       vival in Water and Wastewater Systems, Water Resources Symposium
       No. 7, Center for Research in Water Resources,  the University of
       Texas at Austin, 1974.

D-18.  Kellogg, Clay, "The Business of Processing and  Marketing  Wastes
       as Fertilizer and Soil Conditioner," Compost Science, Vol. 16,
       No. 3 (May-June 1975).

D-19.  Sabey, B. R. and W. E. Hart, Land Application of Metro Denver
       Municipal Sewage Sludge, Final Report, Colorado State University,
       Agricultural Experiment Station,  1972.

D-20.  Carroll, Thomas E., David L. Maase, Joseph M. Genco, and  Chris-
       topher N. Ifeadi, Review of Landspreading of Liquid  Municipal
       Sewage Sludge, National Environmental  Research_Center, Office of
       Research and Development, U.S. Environmental Protection Agency,
       EPA 670/2-75-049, June 1975.

D-21.  Powell, G. Morgan, Design Seminar for  Land Treatment of Munici-
       pal Wastewater Effluents, prepared for U.S. Environmental Pro-
       tection Agency, Technology Transfer Program, CH2M HILL, Denver,
       Colorado, May 1975.
                                 D-31

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 D-22.  Molina, J. A.  E.,  0.  C.  Braids,  T.  D. Hinesly, and J. B. Cropper,
        "Aeration-Induced  Changes in Liquid Digested  Sewage Sludge,"
        Soil Science Society  of  America  Proceedings,  35: 60-63, 1971.

 D-23.  Struble, Robert G.,  "Sewage Sludge  Aids Farm  Crops in West Ches-
        ter, Pennsylvania," Compost Science, Vol. 15, No. 2 (March-April,
        1974).

 D-24.  Shipp,  Raymond F.  and Dale E.  Baker, "Pennsylvania's Sewage
        Sludge  Research and Extension Program," Compost Science, Vol. 16,
        No.  2 (March-April 1975).

 D-25.  Patterson, James C.,  "Enrichment of Urban Soil with Composted
        Sludge  and Leaf Mold  —  Constitution Gardens," Compost Science,
        Vol.  16, No.  3 (May-June 1975).

 D-26.  Olds, Jerome,  "How Cities  Distribute Sludge as a Soil Condition-
        er,"  Compost Science, Autumn,  1960.

 D-27.  Evans,  James 0.  and William E. Sopper, "Forest Areas for Dis-
        posal of Municipal, Agricultural, and Industrial Wastes," Paper
        presented at the Seventh World Forestry Congress, Buenos Aires,
        Argentina,  October 4-18, 1972.

 D-28.   Sutton,  P.  and  J. P. Vimmerstedt, "Treat Stripmine Spoils with
        Sewage  Sludge,"  Compost  Science, Vol. 15, No. 1, (January-Feb-
        ruary 1974).

 D-29.   Lejcher,  Terrence R. and Samuel H.  Kunkle, "Restoration of Acid
        Spoil Banks with Treated Sewage Sludge," in Recycling Treated
        Municipal  Wastewater and Sludge through Forest and Cropland,
        edited by  William E. Sopper  and Louis T. Kardos, The Pennsyl-
        vania State University Press, University Park, 1973.

 D-30.   Pratt, 0.  F. "Effects of Sewage Sludge or Effluent Application
        to Soil  on the Movement of Nitrogen, Phosphorus, Soluble Salts
        and Heavy Metals to Groundwaters,"  presented at 2nd National
        Conference on Municipal Sludge Management and Disposal, Anaheim,
        California, August 18-20, 1975.

D-31.   Farrell, Joseph, "High Energy Radiation in Sludge Treatments —
        Status and Prospects," presented at 2nd National Conference on
       Municipal Sludge Management and Disposal, Anaheim,  California,
       August 18-20, 1975.

D-32.  Miller,  R. H., "Factors Affecting Decomposition of  an Anaerobi-
       cally Digested Sewage Sludge in Soil,"  Journal of Environmental
       Quality, Vol. 3, No.  4,  1974.
                                 D-32

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-------
     The discussion of environmental setting,
presented in Section III is supplemented in this
Appendix with a detailed study of site-specific
environmental characteristics.  The sites dis-
cussed here include the drying and distribution
site, the representative sludge reuse sites
(city parks, sod farms, mine spoil sites, irri-
gated farms and dryland farms), and the site of
the existing operations at the Lowry Bombing
Range.

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                            APPENDIX E

      ENVIRONMENTAL SETTINGS OF DRYING AND DISTRIBUTION SITE AND
        SPECIFIC LAND APPLICATION SITES FOR METRO DENVER SLUDGE
DRYING AND DISTRIBUTION SITE

     The proposed drying and distribution center,  Site B-2,  is located
about 32 km [20 miles] east of the District's Central Plant.   As  shown
on Figure 2, it is 18 km [11 miles] southeast, of Barr Lake and is bordered
on the south by Irondale Road.  The site is rectangular,  extending about
2.4 km [1.5 miles] in an east-west direction and 3.2 km [2 miles]  in a
north-south direction.  The description of the environmental setting of
the drying and distribution site is taken from "Metro Denver Sludge Man-
agement, Volume IV, Environmental Assessment," by CH2M-H111 (February
1975).

Topography

     The topography of the project area is slight to moderately rolling
slopes.  Elevation of the terrain ranges from approximately 1,570 m to
16,40 m [5,150 ft to 5,390 ft] above sea level.  There is a slight ridge
running north-south through the center of the site.   The view to the
north from Irondale Road is generally unobstructed by topographic fea-
tures up to the ridge in the midpoint of the site.  A pronounced drain-
ageway occupies the southeastern corner of the site.

Soils

     The soils at the site are in general a tight, silty clay material
and have a low permeability rate compared to many soils in the area.
Soil depths have not been determined in the area of  the site.  These
soils have sufficient organic materials, with satisfactory nutrient lev-
els, for most crop production.  Low crop yields in the area can generally
be attributed to low rainfall.

Surface Water

     The project site has no perennial streams or other water bodies.
The site is on high ground and receives runoff only from within the site.
A natural drainage area in the southeastern corner of the site subjects
a small off-site area to surface inflow and possible flooding.
                                  E-l

-------
      Part of the site is subject to severe water erosion problems as a
 result of high-intensity, sudden thundershowers and snowmelt  on unpro-
 tected soils.  The runoff is high in sediment and suspended solids.

 Groundwater and Geology

      The project area is underlain by the Denver-Arapahoe-Dawson forma-
 tion and the Laramie-Fox Hills formation.  Each of  these formations
 yields a small to moderate supply of water to wells for  domestic and
 livestock uses.  The uppermost bedrock is the Denver or  Arapahoe forma-
 tion.  Both formations are composed of layers of shale,  sandstone
 with some clay, and silt stone.   The aquifers in these formations are
 more or less confined, and vertical permeability between water-bearing
 zones does not occur readily.   The Laramie-Fox Hills formation  under-
 lies the site at an estimated  depth of 270 to 400 m [900 to 1,300 ft]
 and is considered the boundary between fresh  water  and brackish water.
 Available resource information indicates  that the water  above the Laranie
 formation is of good quality.

      The depth to groundwater  on the site is  typically 15 m [50 ft]  or
 more, with upland wells having a water depth  of  30  m [100 ft] or  more.
 No  groundwater was encountered in the top 3 to  4 m  [10 to 12 ft]  during
 exploratory investigations with  a backhoe.  The  exact size  and  yield of
 aquifers  underlying the site is  not  known.

 Biology

      Vegetation—

      Wheat  crops  are  rotated on  the  project site, leaving 50 percent  of
 the crop  area  fallow  each  year.   Within the southeastern corner,  the site
 has a 1.6-hectare [4-acre] area  of overgrazed prairie.   The site  has  no
 trees or  shrubs.  Vegetation consists  of  short grasses (blue grama,  west-
 ern wheat and  buffalo),  yucca, Russian thistle,  wild lettuce, sunflower
 and prickly  pear  cactus.   No rare or unique species  of vegetation  consid-
 ered  essential  to the  ecology  of  the region are  present  on  the  site.

      Wildlife--

      Wildlife  studies  did  not  identify any wildlife  habitats essential
 to  the  site's ecology.   In the general vicinity  of  the site, there are
varying species of rabbit, mouse, owl, hawk and  coyote.    Except for  the
coyotes, which are territorial animals, these species do well in dis-
turbed areas.  There is  sufficient area surrounding  the  site to provide
new habitats for animals displaced by construction.

Air Quality

     Air quality  in the vicinity of the project area is  relatively good.
                                  E-2

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The site is sufficiently removed from the Metropolitan Denver area  to  be
unaffected by the urban pollution problem.  The only significant deterio-
ration of air quality in the area occurs during dust storms.   The sever-
ity of these depends on conditions of wind, precipitation and soil  dis-
turbance such as plowing.  Even at its worst,  however, wind-blown dust
does not constitute a major problem in the area.

CITY PARKS

     The City of Denver has developed an elaborate park system.   More
than 100 named parks, and many interconnecting landscaped parkways,
cover more than 1,100 hectares [2,800 acres] within the city  limits.
The topography of Denver is relatively flat, with an elevation ranging
from about 1,570 to 1,670 m [5,150 to 5,480 ft].  Two perennial water-
courses, the South Platte River and Cherry Creek, flow through the  city.
Many lakes have been created,  most of which are included within the
City park system and are utilized for recreation.  The lakes  are dis-
cussed under General Environmental Setting, above.  They are  signifi-
cant with respect to runoff hazards from sludge applied to park areas
surrounding them.

Soils

     The soils in the City and County of Denver have not been surveyed
for agronomic purposes because of the predominantly nonagricultural
land use in the metropolitan area.  Therefore, detailed information
about these soils is unavailable.  The information presented  is thus
surmised from the general surface geology and  soil conditions of the
surrounding counties, augmented with limited site observations.

     It is assumed that soils  in the City parks are generally low in
clay content (loams, silt loams, sandy loams and possibly some dry
loams), with correspondingly low cation exchange capacity. Most of the
soils are probably calcareous, beginning at some depth below  the sur-
face, if not found throughout  the profile.  Because of the necessary
grading and leveling activities, most of the profiles are probably  sub-
stantially altered, and most of the topsoil has been moved from one
place to another.  Of the more than 100 established parks in  Denver,
most are on subsoils of heavy  clay "plated" with a thin layer (7.5  to
10 cm [3 to 4 in.]) of imported topsoil.  Some 15 to 20 parks are
planted on old landfills with a fine cover of  topsoil.

Biology

     Vegetation—

     The vegetacion of the City parks can be characterized generally
as urban landscaping and has been described above, under Urban/Residen-
tial Unit.  With the exception of the two stream courses traversing the
                                   E-3

-------
 cicy, the site of Denver was originally part of the mixed prairie,  but
 a variety of nonnative trees has been planted along the streets and in
 the parks.  Chief among these trees are soft maple, elta,  weeping willow,
 Carolina poplar, Lombardy poplar, ash, sycamore,  Norway pine,  Russian
 olive and several varieties of fruit trees.   The City park system is
 entirely artificial, with extensive lawns,  gardens, shrubs and trees
 having been planted on graded, leveled and  filled areas.   Many of the
 parks include golf courses with extensive areas of grass.

      Some nearby urban communities with extensive park sites,  such  as
 Northglenn,  Commerce City and Aurora,  have  expressed interest  in apply-
 ing sludge to their City parks,  also.

      Wildlife--

      The urban and residential environs of  the Denver Metropolitan  area
 represent a  unique,  though unnatural,  environment.   The introduction of
 nonnative shrubs,  herbs,  grasses and trees  has incidentally selected
 and attracted many animal species that normally would not  occur in  this
 area.

      Chief examples of such introductions are the red-eyed vireo,
 bronzed  grackle,  robin and house sparrow.   Some species are typically
 introduced with urbanization and become established as  pests which  de-
 stroy  food and property or endanger  public health.   These  "undesirables"
 include  the  starling,  house mouse, Norway rat and,  in some cases, the
 pocket gopher.

     A woodland—type atmosphere  has  been created  by planted groves  of
 trees within many  of the  City parks.   Native  species  which can  adapt to
 human presence  include the black-capped  chickadee,  house finch  and
 chipping  sparrow.  Occasionally  several  bat species may also be  found
 within the trees.  The large expanses  of  grass  within the  City  park
 system and golf courses particularly attracts robins  and starlings.

 Noise

     The  Denver Metropolitan area has many noise  sources and attendant
 noise pollution similar to  that  found  in all  large  cities.  In  the  resi-
 dential areas, transportation  systems are the most noticeable sources of
 noise.  Generally, the  extensive City parks are bounded and traversed by
multi-laned  streets and expressways.  Steady automobile traffic  produces
 ambient noise levels of 60  to  95 decibels.  Particularly abrasive noises
 greater than 85 decibels are  generated by trailer trucks, motorcycles and
 sports cars  (Reference  89).

     Within the urban and residential areas, noise sources are regulated
by speed limits and designation of traffic corridors.  Thus, residences
                                  E-4

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and community facilities are somewhat screened from extreme noises.
Trees and shrubs in the residential areas, particularly in the patchwork
City park system of Denver, reduce sound levels to some degree.  The
presence of decorative plantings, although they do not significantly
reduce noise levels, often have the effect of reducing the incidence of
complaint about noise (Reference 89).

Odor

     At the present time, odors in City parks are determined by particu-
lar local neighborhood activities (industrial emissions in certain parts,
poorly controlled exhaust from stationary and mobile sources in other
parts and temporary odors caused by applications of chemicals to lawns
and trees, etc.).  City park and public works crexra attend to the
cleanliness and maintenance of the park areas.  Overall, under most con-
ditions, there are no noticeable disturbing odors present at City parks
where large numbers of people spend a great deal of time walking, sit-
ting, lying on the grass, eating lunch and engaging in sports activi-
ties.

SOD FARMS

     Sod farms represent a special type of irrigated farm.  Many hec-
tares in Adams and Weld counties, as well as in other areas south of
Denver, are used for this grass culture.  Sod farms yield one of the
major nonconsumptive crops in the area.  The sod is used solely for
landscaping and decorative plantings.  Sod farms typically require warm,
sunny weather, frequent irrigation and heavy fertilization.

     A representative sod farm was examined in Adams County and is
shown in Figure E-l.  The farm is located near Brighton, east of Barr
Lake.  It is owned by Bill Mathews and includes areas in Sections 25
and 26, T.l.S, R.65W.  Elevations vary gradually.

Soils

     The soil in the Mathews sod farm is nearly uniformly Trackton
loamy sand, on nearly level to moderately sloping land, as shown on Fig-
ure E-2.  The soil texture is rather uniform to a depth greater than
150 cm [60 in.].  It is a noncalcareous soil with neutral pH and rather
low cation exchange capacity.  The soil absorbs water rapidly and does
not allow runoff except at very high precipitation rates; thus, water
erosion hazard is very low.  However, the soil is subject to severe
x^ind erosion if it is not stabilized with vegetation.

Water

     Groundwater is the only source of water for irrigation of the sod
farm studied.  Groundwater table is at a depth of about 20 m [60 ft].
                                   E-5

-------
                                               FIGURE E-l
                      BOOT LAKE RES. 3km (2miles)
E 8km (5mil
             !JRRIGATED\

 39km (24miles]
                                       SOD FARM
                                          AND
                                  DRYLAND WHEAT FARM
                      E-6

-------
NC
                                                        f\/\
                                NOTE : FOR A DESCRIPTION OF SOILS AND
                                     CORRELATION OF MAP SYMBOLS SEE
                                     TABLE


                                 SOILS ON THE SOD FARM AND

                                ADJOINING DRYLAND  FARMS IN

                                       ADAMS COUNTY

-------
 However, deep reservoirs are pretreated for irrigation water supply.
 The Laramie-Fox Hills aquifer, at this point,  is at a depth of approxi-
 mately 370 m [1,200 ft] from the land surface and is well protected by
 a great thickness of intervening aquitards, as described under Geology,
 above.

      Surface drainage is provided by Box Elder Creek,  which traverses
 the Mathews farm in a north-south direction.   The streambed is dry
 nearly year-round and is used for a cow pasture.  (The owner of the
 farm proposes to apply sludge to this part of  his farmland as well  as
 to the sod farm and adjacent dryland wheat fields.)   Frequency of oc-
 currence of flow in Box Elder Creek, by the estimate of the owner,  is
 once every five years.

 Biology

      Vegetation—

      Kentucky bluegrass is the basic crop  of the sod  farm.   Thick sod
 mats formed by this grass constitute a stable  community,  effectively
 excluding  other competitive plant species.  The  crop  period varies  from
 nine to 18 months and follows the procedure described  below:

      1.  Seed bed preparation—The fields  are  plowed and  graded where
 necessary.   Chemical fertilizers with a  nitrogen-phosphorus-potassium
 (N-P-K)  percentage of 16-16-8 or 18-46-0 are applied  to the prepared
 surface at  up to 110 kg/ha [100 Ib/acre].

      2.  Seeding—Several varieties  of Kentucky  bluegrass may be used.
 Particular  strains may  be chosen for their  hardiness,  ability to with-
 stand cold  and  adaptability to  local conditions.  Common  blends include
 raerion, Windsor,  pennstar,  fylking,  baron,  nugget and  newport.

     3.  Cultivation and  maintenance—The newly  planted beds  are irri-
 gated frequently for the  first  three to  four weeks until  the  plants are
 set and a sod layer  begins  to form.   At  this stage, the crop  undergoes
 a. regimen of  spray irrigation as  often as once per day, weekly  mowing
 and monthly fertilization.   Chemical fertilizers most  commonly  used
 have an N-P-K percentage  of  20-20-10 or  16-16-8, such  as ammonium sul-
 fate, and are applied typically at 335 kg/ha [300 Ib/acre].   Compara-
 tive fertilizer usage is  shown  in Table  E-l.

     4.  Crop harvest—Prior to harvesting, the  sod may be  treated with
 a high-nitrogen fertilizer  such as 46-0-0 and irrigated every one to
 two days to prepare  it for  transporting.  The upper sod layer is har-
vested with special machines, which  cut an approximately 5-cm  [2-in.]
 thick sod and soil mat of 45-cm  [18-in.] width.  The sod strips are
rolled up into large rounds and immediately shipped to the customer.
                                 E-8

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                 Table E-l.  COMPARATIVE FERTILIZER USAGE AT SELECTED SOD FARMS IN THE DENVER REGION
I
to

Farm
A
B

C

Dd


Ee
Fertilizer
type,a
N-P-K
20-20-10
16-16-8
46-0-0
18-46-0
33-0-0
5-3-3
5-3-3
32-0-0
20-20-10
Application
rate,
kg/hac
225
335
450
110
225
1,900
1,455
450
335
Application
frequency,
times per year
7 to 8
7 to 8
1 to 2
1
4
1
7 to 8
1
4
Maximum nitrogen Crop
application rate,° cycle,
kg/ha months
335 12
705 9 to 12

315 18

450
t0 14
840 ^

270 18
          fertilizer composition expressed as percentage of nitrogen, phosphorus and potassium (N-P-K)  in
           the total mixture.
           Nitrogen is calculated as N, assuming maximum amount and number of applications per year.
          Cl kg/ha = 0.893 Ib/acre.
           Farm D utilizes dried poultry wastes as primary fertilizer.
          eMathews farm used as representative sod farm.

          Source:  References 90,91,92,93,94,

-------
 As the cue sod does not store well, it is usually cut the day prior  to
 shipping.  The harvest period varies from 9 to 18 months.   Vegetative
 growth is most active during the spring and summer and slows  consider-
 ably as the weather becomes colder.  During the winter months,  the
 grass enters a period of dormancy requiring little irrigation or  fer-
 tilization.  This resting period is necessary for future grass  growth.
 The type of grass species and length of winter dormancy determine, to
 a great degree, the cropping period.  Sod crops can also be regrown
 from the trimmed sod.  When the demand is low, the sod crop—unlike
 consumptive products—can remain on the ground to be harvested  at a
 later date without deterioration of quality.

      Wildlife—

      A sod farm represents a greatly simplified ecosystem of  short
 grass and sod.   Wildlife is generally dominated by a few species, which
 are seasonal in occurrence.  In the planting  stage,  seed-eating birds
 such as Brewer's blackbird and  the western vesper sparrow are common.
 As the crop growth progresses,  earthworms,  grasshoppers and their preda-
 tor, the western meadowlark, proliferate.  Small grass-eating and burrow-
 ing animals are less common in  a sod farm compared to  other cultivated
 fields.   This is due to the constant mowing and maintenance,  which dis-
 turb the animal habitat.   Mammal species  which may be  found in  the vi-
 cinity of sod farms are the pocket gopher,  meadow vole  and  jackrabbit.

 Noise

      The  countryside is generally  noted for its quietude.   The vastness
 of the plains area  and  generally open conditions  allow  for  rapid noise
 dispersal.   The main sources of  noise pollution are  trucks  and automo-
 biles  travelling  on the roadways crossing  the  plains region as well as
 farm  equipment  and  machinery.  Farm equipment  is  generally  heavy duty
 and  can generate  noise  levels equivalent  to a  truck-trailer.  However,
 the relatively  low  density of farms and their  remoteness make this
 noise  source  insignificant in the  overall context.

 Odor

     There are  usually  no  noticeable  odors on  a  sod farm except imme-
 diately after mowings.  These are  pleasant and  temporary smells con-
 fined to the  immediate  area  of the  mowed  fields.

 MINE SPOIL SITES

     The Climax molybdenum mine, used as an example of  mine reclamation,
 is situated in  the Colorado  Front Range approximately 80 km [50 miles]
 west of Denver.  The location of the mine and  tailings pond is shown in
 Figure E-3.  The mine site is reached via U.S. Highway  40 and is approxi-
mately 6 km [3.7 miles] southwest of Berthoud Pass and  3.4 km [1.9 miles]
                                 E-10

-------
south of the Continental Divide.  The terrain is rugged and mountainous
and is transected by deep canyons.  The Urad mine and spoils site is
located in the narrow canyon of Woods Creek, which is a tributary to
Clear Creek.  The Henderson mine and spoils site is located in the upper
section of the west fork of Clear Creek.  Elevation at the site is ap-
proximately 3,100 m [10,400 ft] above sea level.

     The mining operations are conducted by Climax Molybdenum.   The
molybdenum-rich ore is mined from 900 m [3,000 ft] below the surface.
The ore is crushed and washed in an acid solution to extract the metal,
which is further refined.  The residual rock material is finally depos-
ited in the large tailings near the foot of Woods Creek Canyon and
Upper Clear Creek Canyon.  Leachates from the tailings are further col-
lected downstream in a settling pond before entering Clear Creek.

     The mine spoils areas are wedge shaped and cover approximately 60
ha [140 acres] to a depth of 75 m [250 ft].  The rock material on the
site is coarse monzonite, only 16 percent of which passes through a 2  mm
sieve.  The final surface of the spoils site has been leveled to pre-
pare for reclamation with sludge and wood chips and for plantings. At
the present time, 6 ha [15 acres] have undergone initial reclamation
and another 50 ha [125 acres] await reclamation.

     Climax Molybdenum anticipates reaching full capacity at the Woods
Creek Canyon spoils site by 1980.  At that time, a new site will be
used for tailings, and the old site will be available for full reclama-
tion.  By the year 2030, the ore at this particular site will probably
be depleted, and the operations will be transferred to a site near
Leadville, 190 km [120 miles] from Denver.

Climate

     Located near the crest of the Continental Divide, the mine site
experiences some extremes in climate, as shown in Table E-2.  The mean
annual temperature is less than 0°C [32°F], and mean temperatures are
below freezing for six months per year.  The growing season is relative-
ly short, extending from one to two months in duration.  Precipitation
is heavy.  A great deal of the precipitation occurs as snowfall.  Snow-
fall amounts to more than one meter [3.3 ft] for at least six months per
year, with the period from June to September being the most clement.

Geology

     The mine spoil site is located on landslide deposits from the pre-
Cambrian Silver Plume Granite and the Tertiary Porphyritic Rhyolite.
Samples from the spoil site show that the tailings themselves are from
the Silver Plume Granite.  Most of the tailings are composed of porphyri-
tic quartz monzonite veined with molybdenite and pyrite.  Some pegmatite
with large grains of molybdenite also make up part of the tailings.
                                  E-ll

-------
                                                 FIGURE  E-3
                         BERTHOUfr PASS  5 km (3_mi
^
                                  fVi.ir • .

                        \  \'"o   \ '   , ^BM.  '• ^

                                       ^-^
                                        •^DENVER 80 k^m (50 miles)
                                   REPRESENTATIVE
                                          MINE
                                      SPOIL SITE
                  E-12

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         Table E-2. TEMPERATURE, PRECIPITATION,  SNOW AND FREEZE DATA, BERTHOUD PASS


^emperaturjB
•c
[«F]
Precipitation.
mm
[in.]
Snowfall
cm
[in.]


-11.4 -11.4
11.5 11.4

72.9 73.2
2.87 2.88
110.2 112.5
43.4 44.3


-8.4 -4.4
16.8 24.1

91.7 108.5
3.61 4.27
134.6 144.5
53.0 56.9
Freeze threshold temperature



i


°C
0
-2.2
-4.4
-6.7
-8.9
[ °P 1
32
28
24
20
16


1.6 5.
34.8 42.

84.6 73.
3.33 2.
80.8 41.
31.8 16.
Mean
spring







7 10.4 9.1
3 50.8 48.3

4 72.9 63.0
89 2.87 2.48
7 0 0.8
4 0 0.3
Nov Dec

5.3 0.6 -6.2 -9.1
41.6 33.0 20.8 15.6

58.2 55.1 73.7 94.5
2.29 2.17 2.90 3.72
23.9 65.0 112.3 125.5
9.4 25.6 44.2 49.4
Annual

-1.5
29.3

921.5
36.28
951.7
374.7
number of days between date of last
occurrence and first fall occurrence
41
64
90
118
137










Source:  Decennial Census of United States Climate;  Climatological Data for the U.S.:   Colorado.

-------
      Both molybdenite (MoS2) and pyrite (FeS2) are sulfides  whose oxida-
 tion leads to acidic mine drainage.  Without alterations and amendments,
 these rocks can be expected to provide an inhospitable substratum for
 plant growth.

 Soils

      There are no soils in the mine spoil site under  study;  nor
 would there be any developed soils at any other such  sites destined  for
 reclamation.   The material involved in reclamation is processed rock,
 extracted from great depths, largely unaffected by soil-forming factors.
 At the Urad and Henderson mine sites, the spoil materials are very
 coarse (from gravel to boulder-size primary particles),  are  angular  and
 are incapable of supporting plant life.   Due to the acid treatment for
 extraction of molybdenum,  these rocks can be expected to retain an aci-
 dic reaction for several years.  Any reclamation scheme  would necessari-
 ly require a  change in the texture of the surface material in addition
 to introduction of organic matter and fertilizer elements.

 Water

      Tributaries to Clear  Creek,  i.e., Woods Creek and the upper  sec-
 tion of  the west fork of Clear Creek,  flow along the  mine spoil sites
 studied.   Because of the exposed  bedrock  and occurrences of very  thick
 consolidated  rocks in the  area, groundwater is  of  minor  significance.
 Large holding basins in  the mining  areas  are used  to  settle  the fine
 particles suspended during processing of  the rocks.   Effluent from the
 ponds is  discharged directly to the streams draining  into Clear Creek.

 Biology

      Vegetation—

      The  vegetation on the mine spoil site  is quite sparse, mainly be-
 cause of  the  lack of  soil.   A  thin  layer of  sludge mixed  with wood chips
 and  bark  has  been applied, and  systematic planting  of spruce, pine, juni-
 per  and aspen seedlings  has  been conducted.   Some  grass  has also been
 seeded, and a  few other  native plants, such  as yarrow, big sagebrush,
 bear berry and buffalo berry, have  established themselves with  the germi-
 nation and growth of a few individuals.  All  of  the vegetation on  this
 site is growing very slowly, and some of it,  such as  the  buffalo berry,
 appears stunted.   Some of  the tree  seedlings  have died.

     Wildlife—

     The mine spoils site  is a severely disturbed area with very sparse
plant growth,  as described above.  The exposed strata of rock and gravel
provide a relatively sterile environment with no resident animal species.
Visitants from the neighboring lodgepole pine forests may include mule
                                E-14

-------
deer, coyote, striped skunk, mountain vole and snowshoe hare.   Probable
bird species passing over the area are Cooper's hawk,  turkey vulture,
gray jay and gray-headed junco.

Noise

     The nine spoils site is rural and fairly isolated.  Traffic along
Highway 40, which is 1.6 km [1 mile] away from the site,  represents a
small fraction of ambient noise.  The main source of noise is  from the
processing of the ore.  The rock-crushing and washing apparatus prob-
ably generate the most noise, while the small but steady truck traffic
to and from the site augments the background noise levels.  The rela-
tive isolation, heavy growth of trees adjacent to the site and steep
valleys effectively confine the noise from the mining operations.

Odor

     The molybdenum mine has few associated odors.  On the limited
tailing areas where reclamation has begun, some odors uncommon to the
area are generated.  The weathering of wood chips and sludge into the
upper rock material exudes a faint decomposition odor at close range.
However, the material deodorizes rapidly, and no odors are perceptible
30 m [100 ft] from the site.

IRRIGATED FARMS

     There were almost 17,000 hectares [42,000 acres]  of irrigated
farms in Adams County in 1973 (Reference 95), about five percent of
the whole county.  By contrast, only about 900 hectares [2,200 acres]
are irrigated in Arapahoe County (Reference 14), less than one percent
of the county.  Areas of irrigated crops and value of all crops grown
in Weld, Adams and Arapahoe counties are presented in Table E-3.  The
proportion of irrigated land increases from south to north due to in-
creased availability of surface and groundwater supplies.  In Adams
County, most of the irrigated farms are along the South Platte River
and its tributary creeks.  Water is directed from these watercourses,
and pumped from the groundwater reservoir, as well as from various
sources on the western slopes of the Rockies.

     The principal irrigated farm used for detailed study is located
in the southern part of Weld County, east of Platteville, as shown on
Figure E-4.  It is a 223-hectare [550-acre] field owned by Ray Olin of
Platteville and is, in part, in Sections 16 and 17, "T.3N., R.66W.  The
land has gentle, uniform slopes of about two percent draining into the
Platte Valley Canal.  It is, at its closest boundary, about one km
[0.6 mile] from the eastern edge of the town of Platteville.  U.S.
Highway 85 and the Union Pacific Railroad tracks are located about one
km [0.6 mile] to the west of the irrigated farms.  Road 32 connects the
farm to the town and to the major thoroughfares.
                                E-15

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    Table E-3.   VALUE  AND  AREA  OF CROPS  HARVESTED  IN WELD,  ADAMS AND  ARAPAHOE  COUNTIES  IN 1973

Crop
Winter wheat
Spring wheat
Grain corn
Silage corn
Barley
Grain sorghum
— i Dry beans
cr>
Sugar beets
Oats
All hay
Potatoes
Other crops
All crops

Value,
1,000
dollars
15,644
18
15,284
35,789
3,138
35
7,396

20,033
388
14,700
2,285
4,529
119,239
Weld County
Irri- Non-
gated irrigated
(hectares)"1
1,900 70,100
40 40
24,100 200
48,000b 	
9,500 4,200
40 200
7,400 80

14,300b 	
2,100 500
49,200b 	
1,400 	
.... ....
157,980° 75,320°
Adams County
Value,
1,000
dollars
14,073
179
1,442
1,560
921
86
122

474
54
2,644
...
2,624
24,179
Irri- Non-
gated irrigated
(hectares)3
1,600 53,000
400 500
2,200 100
2,500b 	
1,400 5,100
100 300
200 	

400b 	
300 300
7,900b 	
	
....
17,000° 59,300C
Arapahoe County
Value,
1,000
dollars
5,378
13
125
320
304
24
• • •

...
4
711
...
358
7,237
Irri"
gated
Non-
irrigated
(hectares)3
200
...
100
700b
40
80
• • *

...
...
3,200b
...
...
4,320C
23,000
100
200
....
2,600
100
• • * •

....
80
....
	
....
26,100C
Original  source data are  in acre:,:  1 hectare « 2.471  aTes.
 Total  area  (irrigated and nonirrigated,  if any).
°Total  areas of harvested  crops do not include "other crops" and vary considerably  from year to year.  Irrigated areas may include
 minor  amounts of nonirrigated areas.

Source: Colorado Department of Agriculture, 1973-1974  Colorado Agricultural Statistics

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                                         FIGURE E-4
PLATTEVILL
                           —  _          I
                  IRRIGATED
                            ROAD 32
                            ,
     HIGHWAY 85
                               REPRESENTATIVE
                                AGRICULTURAL
                                REUSE AREAS

-------
      The crops that have been grown on this irrigated farm in recent
 years include alfalfa, corn, wheat and some sugar beets.   Groundwater
 is used as the principal source of irrigation water  supply.   Depth to
 groundwater table is, at places, only one meter [3 to 4  ft]  from  the
 surface.  Intensive agronomic management practices,  typical  of high-
 yield irrigated agriculture, are followed using modern equipment  and
 the recomendations of agricultural extension services.   Thus,  a high
 degree of control over application of amendments to  the  soils  can be
 expected in this and most other irrigated farms.  Commercial fertilizer
 application rates commonly used in the irrigated farms in  the  area are
 87 kg/ha [78 Ib/acre] nitrogen (as N) and 100 kg/ha  [90  Ib/acre]  phos-
 phorus (as P)  on pinto beans and sugar beets.   Barnyard manure is used
 on sugar beets in the early growing stages.   Corn receives from 112 to
 225 kg/ha [100 to 200 Ib/acre] of nitrogen in anhydrous ammonia form,
 injected into  the irrigation water.

 Soils

      The most  widespread soils which are found  in the irrigated farms
 in southern Weld County and northern Adams County (nearest to  the sludge
 distribution center)  are presented in Table  E-4.   The pertinent charac-
 teristics of each soil are tabulated from data  furnished by  the U.S.
 Soil Conservation Service.   The suitability  and  limitations  of  each
 soil are also  presented,  on the basis of  the characteristics of the soil.
 These subjective ratings do not include  the  properties and implications
 of the crops grown upon these soils.   Crop implications are  covered under
 the discussion of impacts upon the food  chain and  in  Appendix  D.

      It  appears  that  most of the soils under  irrigation in the  study
 area possess the properties which would  potentially make them  suitable
 for sludge application.   There are,  however, a few soils (such as  Loup-
 Boel, Valent and  Tassel)  which may be patently unsuitable  for  reuse of
 sludge.

 Biology

     Vegetation—

     Large areas  of Weld  County and  smaller  sections  of Adams and
Arapahoe counties are  irrigated  farmland.  Primary crops are corn  for
 silage and grain, sugar beets,  winter wheat and hay.  Crops of  lesser
 importance in the study area are  barley, dry beans, sorghum, oats,  po-
 tatoes, fruits and vegetables.

     Crops are generally cultivated on a rotational basis that varies
with the soil,  terrain and available water.  Spring-planted crops are
seeded in the relatively dry, open-weather months, from early March
through June.  The ambient temperatures and type of crop  determine  the
                                 E-18

-------
Table E-4.  PERTINENT CHARACTERISTICS  OF SELECTED SOILS UNDER IRRIGATION IN WELD COUNTY

Soil tt.p
series, sym-
type" bol
Vona, 51,
fine 51B,
sandy 11B
loam
Dacono, 17M
clay
loam
Olney, 21B
loamy
sand
Altvan, 23
loam

Thedalund, 43
clay
loam
Loup-Boel, -9
sandy
loam
Otero, 53,
sandy 54
loam
Renohiil, 66B
clay
loam
Valent, 72
fine
sand
Depth Clay
to con-
rock, Slope, tent,
cmc * %
>150 0
to
12

>150 0
to
6
>150 1
to
10
>150 0
to
15
50 0
to to
100 15
(unavailable at


>150 0
to
10
>150 2
to
15
>150 0
to
25
low



35
to
50
18
to
35
17
to
35
18
to
35
the present


5
to
18
35
to
50
very
low

Cation
exchange
capacity,
meq per
100 g soil
very
low


60
to
80
12
to
20
„_


—


time)


—


70
to
100
very
low


6.6 to 7.3
7.4 to 8.4


6.6 to 7.8
7.4 to 8.4

6.6 to 7.8
7.9 to 8.4

6.1 to 7.3
7.4 to 9.0

7.9 to 8.4





7.4 to 8.4


6.6 to 7.8
7.9 to 9.0

6.6 to 7.8


Permea-
bility,
cma/hr
5
to
15

0.5
to
1.5
0.5
to
15
0.05
to
5
1.5
to
5



15
to
50
0.05
to
1.5
15
to
50
Sludge application/reuse
Suita- Limt- Management
bility tation needed
moderate low CEC liming,
and pH low rates


high low pH liming


moderate low pH liming


moderate surface
texture

high


low flooding


moderate low CEC, —
clay
content
high


low low clay liming
content,
low pH

-------
         Table E-4  (Continued).   PERTINENT  CHARACTERISTICS  OF  SELECTED  SOILS UNDER  IRRIGATION  IN WELD COUNTY
I
rv>
o


Soil
aeries,
typcb
Tassel,
fine
sandy
loam


Shingle,
clay
loam


M»p
sym-
bol
84





87B



Depth
to
rock,
cmc
25
to
50



>150





Slope,
%
3
to
25



0
to
25

Clay
con-
tent,
%
low





18
to
35
Cation
exchange
capacity,
meq per
100 g soil
very
low




low




Permea-
bility,
pHd cms/hr
7.4 to 8.4 5
to
50



7.4 to 9.0 1.5
to
5


Sludge
Suita-
bility
low





moderate






application/reuse
Limi-
tation
low clay
content,
depth to
bedrock,
high per-
meability
low clay
content

Management
needed
__





—


aBaaic soil characteristics were obtained  from soil survey descriptions and interpretations provided by the USSCS.

 Soil type refers  to the texture of the airface of the  typifying pedon.

cl cm - 0.3937 in.

 The first values  refer to soil characteristic in the upper layers  (top 15 to 50 cm) and the second values refer  to deeper layers.

-------
irrigation water need.  Spring and summer rainfall is generally inade-
quate for most crop production.  Harvest of spring grains begins in
August and is completed by mid-September.  Cutting of dry beans occurs
in early September, while corn and sorghum are harvested from late
September to mid-October.  Sugar beets are harvested from early October
to mid-November.

     Wildlife—

     Wildlife on cultivated lands is generally seasonal and often re-
flects the type of crop grown in an area.  On irrigated farmlands that
produce crops such as alfalfa, corn, vegetables and some grains, insec-
tivorous birds predominate.  Easily visible spring and summer birds in-
clude the western meadowlark, Brewer's blackbird,  robin, lark sparrow
and grasshopper sparrow.  Seed-eating and often crop-eating birds,
which are most abundant after planting and at harvest times, include
several species of blackbirds, sparrows, migratory waterfowl and, in
some areas, the introduced ring-necked pheasant.

     Small rodents, generally viewed as agricultural pests, are an im-
portant part of the food chain.  Burrowing and nest-making animals in-
clude pocket gophers, ground squirrels, jackrabbits, harvest nice and
meadow voles.  Predators which control the small animal populations are
the red-tailed hawk, Swainson's hawk, ferruginous hawk and, rarely, the
golden-eagle.

     The cultivation of former prairie lands has not only changed the
overall habitat but has also added a few ecological "niches."  Agricul-
tural remnants and surplus areas, such as streambanks, road edges,
fencerows, corners and woodland patches are important wildlife shelter
and wintering areas.  Unharvested strips, stubble and fallow areas pro-
vide a valuable food supply during the winter.

Noise
     Noise levels of an irrigated farm are similar to those discussed
in the section on noise under the heading Sod Farms, above.

Odor

     Background odors on irrigated farms are often pleasant and natural:
the scents of the freshly turned soil and cut hay and the subtle aroinas
of growing crops.  To some, even the animal manure odors on farms are
not particularly unpleasant because of their association with the seren-
ity of rural living.  Where chemicals are used (fertilizers, pesticides,
herbicides, etc.), temporary odors from their vapors, dusts and other
aerosol components spread to surrounding areas, downwind of application
areas.
                                 E-21

-------
 DRYLAND FARMS

      In Adams County there are 146,000 ha [360,000 acres]  of nonirri-
 gated farms, and in Arapahoe County nearly all farms are nonirrigated
 (Reference 95),  Areas of various crops under nonirrigated culture  are
 shown in Table 22 for Weld, Adams and Arapahoe counties.

      An estimated 97,000 ha [240,000 acres]  in Adams County is  unsuit-
 able for cultivation or is in native grasses used for grazing (Refer-
 ence 10).  These areas are also potential recipients of  sludge  for
 improved production of fodder and are treated collectively under  the
 heading Dryland Farms both in the discussion of general  environmental
 characteristics in the present section and in the section  on impacts,
 below.

      Wheat and barley are the principal crops grown under  dry farming.
 Generally, dryland farming involves a lower  degree of management  control
 than does irrigated farming because of the low relative value of  crops
 produced per unit area of land.   Occasional  droughts (sometimes lasting
 for two consecutive years) bring production  down to nearly zero.  Dry-
 land farming is typically characterized by very extensive  land holdings
 requiring highly mechanized harvesting procedures and equipment.  Soil
 conservation practices,  such as  rotation fallowing,  and water conserva-
 tion practices,  such as  scarring the soil surface for better  penetration
 of  rainfall and  improved water storage,  are  generally practiced.

      In dry-farming areas,  sources  of  water  supply are generally  at
 considerable  distances from the  farms  and  thus  are not threatened by
 pollution from runoff  from those farms.   However,  in certain  other areas
 (where  dry farms  are adjacent  to irrigated areas  or  dry river bottoms
 are used  for  pasture), the groundwater table may  be  close  to  the  surface,
 and intermittent  stream  courses  may be affected  by the operations.

      Two  example  sites used  for  detailed  study  are (1) east of the sod
 farm described earlier and  (2) near  the  irrigated  farm described  above.
 These sites are shown on Figures E-2 and  E-4, respectively.

 Topography

      Dry farms are  generally located on gently  sloping, rolling topogra-
 phy  with slopes up  to about 15 percent.  The noncultivated pasture areas,
 such  as dry strearabeds,  flood plains,  hillsides and  rocky areas, have
 less  regular  topography and have  steeper slopes.   None of  the dry-farmed
 areas are  graded.

 Soils

      Soils in the dryland farm areas in Adams County are shown in Fig-
ure E-4.  Some of their characteristics pertinent  to  sludge application
                                 E-22

-------
are presented in Table E-5.  These soils are deep,  almost  uniformly  non-
calcareous in the surface "plow" layer and highly calcareous below (with
the exception of Truckton, which is noncalcareous throughout).   This
pattern leads to low pH in the top layers and alkaline condition in  the
lower strata.  Clay content and cation exchange capacity are generally
very low, and the soils are subject to erosion by blowing  wind  and over-
land flow of water.

Biology

     Vegetation—

     Crops are generally cultivated on an annual cycle beginning in
the fall.  After the first fall rains, winter wheat and winter  barley
are seeded in September and October.  In some cases, erosion and crust-
ing of soils may necessitate a second seeding.  Favorable  climatic con-
ditions during November and December enable the crops to grow to a
strong stand before entering dormancy during January and February.
The wheat plants begin greening up by March but are subject to  dry,
windy conditions during April and May.  The amount of spring and summer
rain determines the success of the wheat and barley crops.  Under favor-
able conditions, the crops can be harvested during the summer.   The
higher elevations are often harvested late into the summer.  With the
fall rains, the dry-farming cycle begins again.  Water conservation  re-
quires fallowing and scarification of the land surface in  the fall.

     Wildlife—

     Dryland farm areas are generally less intensively cultivated com-
pared to irrigated farm areas.  This seasonal monoculture  of grain
crops leads to somewhat lower diversity of animals than is found in
the irrigated farm.  Easily visible spring and summer birds include
the western meadowlark, Brewer's blackbird, robin, lark sparrow and
grasshopper sparrow.  Seed-eating and often crop-eating birds,  which
are most abundant after planting and at harvest times, include several
species of blackbird, sparrow, migratory waterfowl and, in some areas,
the introduced ring-necked pheasant.

     Small rodents, generally viewed as agricultural pests, are an im-
portant part of the food chain.  Burrowing and nest-making animals in-
clude pocket gophers, ground squirrels, jackrabbits, harvest mice and
meadow voles.  Predators which control the small animal populations
are the red-tailed hawk, Swainson's hawk, ferruginous hawk and, rarely,
the golden-eagle.

     Dryland farming is generally practiced over large areas, with
minimal supervision.  The unharvested strips, stubble and  fallow from
these grainfields are an important winter food source for  wildlife.
                                 E-23

-------
     Table E-5.   PERTINENT  CHARACTERISTICS  OF  SELECTED  SOILS  IN DRYLAND  FARMING IN ADAMS COUNTY
~ " ~~" ~ " " • " • "-• - - - - - - 	 	 - - ----.-r-, .--i_. ,___!. _-L 	 J J ^— __-,-•-, I --L -~«JJ._— ^_ -.- .._..-
Depth
Soil Map to
series, sym- rock,
typeb bol cmc
Ascalon, As >150
sandy
loam
Platner, PI >150
loam

Stoneham, St >150
loam

Truckton, Tt >150
sandy
loam
Vona, V:. >150
loamy
sand
Slope,
3
to
5
0
to
3
3
to
9
1
to
3
3
to
9
Clay
con-
tent,
very
low

mod-
erate

low


very
low

very
low

Cation
exchange
capacity,
meq per
100 g soil
very
low

low


low


very
low

very
low

Permea- Sludge application/reuse

6.6
7.9

6.6
7.9

7.4
7.9

6.6


6.6


pHd
to 7.8
to 9.0

to 7.3
to 8.0

to 7.8
to 8.4

to 7.8


to 8.4


bility, Suita- Limi-
cms/hr bility tation
1.6 moderate low CEC
to
16
0.15 moderate low CEC
to
5.0
1.6 low low CEC
to
16
0.13 low low pH
to
0.3
16 moderate low CEC
to
>20
Management
needed
runoff
control




runoff
control

liming


runoff
control

aBasic  soil characteristics were obtained from soil survey descriptions and interpretations provided by the USSCS •
 Soil  type refers to  the texture of the surface of the typifying pedon.
cl cm  - 0.3937 in.
dThe first values refer to soil characteristic in the upper layers (top 15 to 50 cm) and the second values refer to deeper layers.

-------
Noise

     Noise levels of dryland farming are similar to  those  discussed
in the section on noise under the heading Sod Farms,  above.

Odor

     No particular odors are generally associated with dryland  farms.
Only during the harvest is the subtle scent of crushed chaff  barely
noticeable.

LOWRY BOMBING RANGE SLUDGE DISPOSAL
AREAS AND LANDFILL

     The Lowry Bombing Range is located 24 km [15 miles] east of  Denver
in Arapahoe County.  The Metropolitan Denver Sewage  Disposal  District
No. 1 and the City and County of Denver are currently engaging  in three
separate, although related, disposal operations on 810 hectares [2,000
acres] of the old bombing range, which is just to the west of the pres-
ent bombing range.  The site is bounded on the west  by State  Highway
30 and on the south by Airline Road, and falls within Sections  31 and
32, T.4S., R.65W. and Sections 4 and 6, T.5S., R.65W.  The locations
of the three operations are shown in Figure E-5.  Approximately 527  hec-
tares [1,300 acres] are currently being used for the land  appliction
of dewatered sludge.  The City and County of Denver  is utilizing  69
hectares [170 acres] in the western part of Section  6 as a solid  waste
disposal dump.  In the eastern part of Section 4, approximately 145
hectares [360 acres] are being used for landfill operations during the
winter.  These areas will be referred to as Sites A,  B and C, respec-
tively.

     Site C is the winter disposal area where sludge is dumped  when
the soil is frozen.  It is referred to as a deep incorporation  area
because trenches are excavated and the sludge is dumped and then cov-
ered up.  Upon completion of the operation, the site will  be  revege-
tated with native grasses.  The groundwater supply is being monitored
to detect groundwater pollution.

     Site D, located south of Site C in the northeast part of Section  9,
T.4S., R.65W., is a completed winter landfill area that is being revege-
tated with native grasses.

Topography

     The elevation of this area ranges from 1,720 m  to 1,785  m  [5,650
ft to 5,850 ft].  The relief is subdued, consisting  of gently rolling
hills and shallow valleys.  Murphy Creek and several of its tributaries
run from south to north through the western part of  Site  A.  Senac
Creek also runs from south to north, lying to the west of  Site  C and
                                E-25

-------
                                                    FIGURE E-5
DENVER 24km(l5miles

STATE HIGHWAY 3O
                                                 ITE  C
                                    SITE A - LAND APPLICATION
                                    SITE B - CITY AND COUNTY DUMP
                                    SITE C - LANDFILL
                                    SITE D - COMPLETED LANDFILL
                                             LOWRY
                                        BOMBING RANGE
                                        DISPOSAL  AREA
                      E-26

-------
to the east of Site A, and joins Coal Creek to the north of  the  prop-
erty.  Both creeks are dry most of the year,  flowing  only during per-
iods of stream runoff.  Associated with these watercourses are flat,
wide floodplains.

Soils

     Soil characteristics for this area are summarized in Table  E-6,
and occurrence of the soils is shown on Figure E-6.  The particular
occurrence of lime layering in the soil profile is the most  notable
property of these soils.  A layer of noncalcareous (acidic)  surface
soil to a depth of from 30 to 60 cm [12 to 23 in.] overlies  deeper,
highly calcareous (alkaline) materials.  This relatively uniform se-
quence has important implications for sludge  application because of
the differential solubility of heavy metal compounds  at various  soil
reactions.

     Surface layers (to a depth of about 15 to 25 cm  [6 to 10 in.] are
also coarser (i.e., contain less clay) than are the deeper layers of
most soils in the area.  This usually gives rise to a corresponding
stratification in the cation exchange capacity of the soils. Wind and
water erosion hazards are generally severe on the Bombing Range, with
great dust clouds generated by trucks and automobiles, even  in slow
winds.

     The Fondis and the Renohill soil series  are the  most extensive
soils in the study area, occurring on approximately 80 percent of the
total area, as shown in Figure 13.  The Fondis series, which includes
the Fondis silt loam and the Fondis-Colby silt loam soil types,  occu-
pies approximately 50 percent of Site A.  These are deep, well-drained
soils with a high water-holding capacity.  The surface layer of  soil  is
15 to 17 cm [6 to 7 in.] thick and rests abruptly on  the subsoil, which
consists of dense clay 46 to 51 cm [18 to 20 in.] thick.  The Fondis
soils are high in natural fertility but are moderately susceptible to
water and wind erosion.  These soils are suited to native grasses and
cultivated crops.  Smaller units occur on Sites B and C.

     The Renohill series, which includes the Renohill-Buick  loams and
the Renohill-Litle-Thedalund complex, occurs on approximately 30 percent
of Sites A and B, and on the majority of Site C.  These are  moderately
deep, well-drained, gently sloping to steep soils that have  moderately
slow to slow permeability and moderate water-holding  capacity.   The
Renohill soils are moderate in natural fertility, but are susceptible
to water and wind erosion.  These soils support native grass and are
unsuited to cultivation because of the shallowness of the rooting zone
and the severe hazard of erosion.
                                E-27

-------
Table E-6.  PERTINENT CHARACTERISTICS3 OF SOILS IN LOWRY BOMBING RANGE SLUDGE DISPOSAL SITES

Soil Map
series, s;tn-
typc bol
Buick, Bx
loam

Fondis, Fd
silt
loam
Fondis- Fo
Colby,
silc
loam
i 1 1
i
ro Renohill- Rh
00 Buick,
loam
Renohill- Rt
Litle-
Thedalund,
complex
Nunn, :!1
loam


Terry- Te
Olney-
Thedalund,
sandy
loams
Weld- Wr
Deertrail,
silt
1 nnm
Depth
to
rock,
cmc
120
to
180
>150


>150



50
to
100
50
to
100

>150



60
to
150


>150



Clay
con-
Slope, tent,
% %
3 low
to
9
1 low
to high
5
3 low
to high
5

3 moderate
to
9
9 moderate
to
30

0 moderate
to
3

5 very
to low
20


0 low
to
3

Cation
exchange
capacity,
meq per
100 g soil
low


low
moderate
high
low
moderate-
high

moderate


moderate



moderate



very
low



low



Permea-
bility,
pHd cms/hr
6.8 to 8.0 1.6
8.0 to 9.0 to
16
6.4 to 7.5 <1.6
7.5 to 9.0

6.4 to 7.5 <1.6
7.5 to 9.0


7.5 to 8.5 <1.6


7.5 to 8.5 <1.6



6.5 to 7.0 <1.6
7.5 to 8.5 1.6
to
16
6.8 to 7.5 1.6
to
16


6.5 to 9.0 <1.6
8.0 to 9.0 1.6
to
16
Sludge application/disposal
Suita- Limi- Management
bility tation needed
moderate low CEC runoff
control

high — aubsoiling


high — aubsoiling



moderate shallowness erosion
control

moderate ahallowness erosion
control


high — erosion
control


moderate — erosion
control



moderate low CEC erosion
control



-------
I
ro
                                  Table E-6  (continued).   PERTINENT CHARACTERISTICS* OF  SOILS
                                          IN  LOWRY  BOMBING RANGE SLUDGE  DISPOSAL SITES
         Basic soil characteristics were obtained  from soil survey descriptions and Interpretations provided by the USSCS.
         Soil type refers  to the texture of the surface of the typifying pedon.
        Cl  ca - 0.3937 In.
         The first values  refer to soil characteristic In the upper layers  (top 15 to 50 on) and the second values refer to deeper layers.

-------
       SOILS OF THE
  LOWRY  BOMBING RANGE
  SLUDGE  DISPOSAL AREAS

SOURCE-U.S. SOIL CONSERVATION SERVICE

-------
Water

     Coal Creek, Senac Creek and Murphy Creek are ephemeral  water
courses traversing the 850 ha [2,100 acre]  disposal area  at  the Lowry
Bombing Range toward the north and northwest.   Groundwater occurs  both
in the alluvial material and in the underlying bedrock, moving in  a
northwest direction, similarly to the surface waters.   Shallow ground-
water, lying at a depth of about 18 to 30 m [60 to 90  ft] is of ade-
quate extent and yield to be used for some  irrigation  and/or domestic
purposes.  Deeper groundwater levels of the Laramie-Fox Hills aquifer
lie at about 520 m [1,700 ft] from the ground surface  (Reference 87).
This is an important regional aquifer, used principally in the upstream
areas in eastern Arapahoe and Adams counties.   There are  a number  of
wells downstream, in Denver, tapping this aquifer.  In the immediate
vicinity of the Lowry Bombing Range disposal area, some 15 domestic
wells equipped with electrical or windmill-powered pumps  are in active
use.  About 30 other observation and monitoring wells  have been estab-
lished by the U.S. Geological Survey in cooperation with  the Metropoli-
tan Denver Sewage Disposal District No. 1 to study impacts upon ground-
water quality.  Furthermore, the District maintains surveillance on
runoff and surface water quality by sampling and analysis of waters in
six catch basins, two springs, two creek stations and  two wells.
Biology

     Vegetation—

     The vegetation of the bombing range can be described as  being
characteristic of the Uplands Vegetation type.   It is primarily pasture
and range land that has been subject to grazing for many years.  While
the original vegetation was probably a short-grass prairie, heavy graz-
ing has changed it to a weedy grass type that contains annual grasses
and annual and perennial weeds along with the original perennial bunch-
grasses.  Good range management practices are needed to prevent over-
grazing and to control erosion, particularly on the Renohill  soils.

     Site A has been subject to the land application of thousands of
tons of dewatered sludge since 1969.  The sludge is applied  in alter-
nating strips of varying widths along 1-m [3-ft] elevation contours,
plowed under and planted with wheat and/or grasses, and subsequently
used for the grazing of 300 to 500 beef cattle.  This site will be used
by the City and County of Denver for solid waste disposal as  soon as
current operations are completed on Site B.

     Most of the vegetation that has appeared on Site A can be charac-
terized as weedy species that are fast-growing colonizers of  bare soil.
                                E-31

-------
 Common stint lower, Russian thistle,  summer cypress and  tumble pigweed
 are almost ubiquitous, covering the belts of  application with a  swathe
 of greenery that provides little food value to livestock.   The practice
 of livestock grazing on this site has resulted in the  almost total  de-
 -truction of the planted crops (milo, oats, wheat and  sudan) since
 cattle eat the succulent young shoots as soon as they  reach a height
 of 10 to 20 cm [4 to 8 in.].  Some  grasses can be expected  to appear
 over time, although heavy grazing makes it difficult for them to  be-
 come established.

      Wildlife—

      Wildlife within the Lowry Bombing Range  is characteristic of the
 Uplands Vegetation unit.  The large expanses  of rolling  plains with low
 vegetative cover favor small mammal species such as the  prairie vole,
 Ord kangaroo rat, pocket mouse,  ground squirrel and jackrabbit.   These
 rodents occupy varying ecological niches and  occur sporadically through-
 out the range area.  The openness of the plains area and relatively low
 animal density contribute to several wide-ranging predator  species  such
 as the red-tailed hawk,  Swainson's  hawk and coyote.  The thin stands of
 cottonwood trees along the seasonal creek drainages in the  area are
 prime  roosting areas for the predatory birds  and  for occasional golden
 eagles.   Several reptiles may be  found throughout this arid region, in-
 cluding  the bullsnake, prairie rattlesnake and  central plains  milksnake,
 which  prey primarily upon rodents.   Other  reptiles, feeding upon  in-
 sects,  are the horned lizard and  sagebrush lizard.  Infrequent bluffs
 and cliffs over river bottoms and eroded  areas  provide a  specialized
 habitat  for the bank swallow and  kingfisher,  which utilize  overhangs
 ind vertical walls  for nesting and  feeding.

 Noise

     The  countryside  is  generally noted  for its vastness and  quietude.
 The main  sources  of  noise  pollution  at  the  Lowry  Bombing Range are  the
 roadways  traversing  the  plains, farm equipment,  solid waste  processing
 equipment  at the  landfill,  sludge handling  and  transport vehicles and
 aircraft.   Heavy  equipment  for solid  waste  and  sludge handling probably
 generates  the greatest daily  noise.   Military vehicles and  aircraft also
 cause disturbances, although  infrequently.  However,  the relatively low
 density of  the military  reservation  and  its remoteness make all these
 noise sources insignificant  in the overall  context.

 Odor

     There are currently no  significant odors originating at any of the
 sites on the Lowry Bombing Range  (Reference 88).  There have been no
complaints since 1972, when the contractor  had piled  quantities of
sludge without plowing it under.  After public hearings in June 1972,
                                E-32

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the Metropolitan Denver Sewage Disposal District  No.  1  revised  methods
of land application,  and current practices do  not generate significant
odors.  Freshly applied sludge can be smelled  only at very short  dis-
tances.
                                  E-33

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Him
l
   llll

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     This Appendix contains examples of letters
of support for the Metro sludge recycling pro-
posal.  The letters were solicited by the Metro
District in order to obtain a semi-quantitative
estimate of the potential market for the sludge.
Many of the writers indicate a desire to have
the sludge available for their own uses.  This
Appendix is not intended to present representa-
tive samplings of opinion vis-a-vis the sludge
reuse concept.  An assessment of the public re-
actions to this concept is presented in Section
VIII.

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                           APPENDIX F
    XAMKES OF APPROVAL  FOR OR INTEREST IN THE  PROPOSED PROJECT
   •«>o.o«..u.«     cm_nr^3/\Tr  r-nni •vr=inr=r^B irrs COMPANY
                        A DIVISION OP              INC.
                             HENDERSON MINE
                                  Box 68
                            Empire, Colorado 80438
                               (303) 569-3221

                               July 25, 1975
Mr. William J. Martin
Director of Resource Recovery and Reuse
Metropolitan Denver Sew.-ge Disposal District No. 1
3100 East 60th Avenue
Commerce City, Colorado 80022

Dear Bill:

     This letter is basically to inform you that this year's
planting has gone very well.  The 300 dry-weight tons of
sewage you supplied for mine reclamation revegetation at  the
Urad mine has been spread on the 15 acres slated for seeding
this year, and the grass and trees are beginning to look  pretty
good.  The test plots planted last year are looking very  good
also, even with 18 consecutive dry days in late June and  parly
July.

     Although the whole process is still somewhat in the  ex-
perimental stage, I can see no reason why-things shouldn't go
pretty well as planned in tl2 future.  The tentative schedule
for the future sewage needs is as follows:

          Spring 1975          300 tons
          Fall 1975            300 tons
          Spring 1976          300 tons
          Fall 1976            650 tons
          Fall 1977            750 tons
          Fall 1978            750 tons
          Fall 1979            450 tons
          Fall 1980            350 tons

               TOTAL         3,850 tons
                                  F-l

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 WJM                     July 25, 1975
     It Is the sewage that is making the difference.  The sewage
is pretty well the key to the whole operation of revegetating
the fragmented rock covering the mine tailing.  We appreciate
everything you are doing to help us in this endeavor.
                               Larry F.V Brown, Ph.D.
                               Environmental Control Engineer
LFB:mb
                             F-2

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                                        Michael Dulacki
                                        656 i.ilvauke- St.
                                        Denvsr, Colorado  80205
Metro Denver Sev/age Disposal Dist.  £1
3100 2. &0th Avenue
Commerce City, Colorado     S0022

Dear Sirs:

     I am v/riting this letter to  you  to tell you that  I  endorse
the recycling of r.uncipal vastes in general and that I endorse
your particular plan of recycling    Denver sev;age sludge as a
fertiliser and soil conditioner.  The possibilities of this plan
are many; for one, the Denver Parks jepartnent could use this
fertiliser for the city parks.   -mother example is the uso of
the fertilizer by • private citizens for their ovrn lav.ns and  gardens,
I hope you are successful in your efforts to implement this plan.
                                         Sincerely yours,
                                  f-3

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     5
                                                         o
TLANlA
ORT SMfTH
ORT WORTH
ITTLE ROCK
CW ORLEANS
HILADELPHIA
AVANNAH
AMPA
AMBURG. WEST GERMANY
AN JOSE. COSTA RICA
            INCOPPORATED
     IMPORTERS-EXPORTERS

ORGANIC AND CHEMICAL FERTILIZER MATERIALS
     ANIMAL FEEDING SUPPLEMENTS
         OILS, FATS AND MEALS

         36O LEXINGTON AVENUE

  INETVTYCXRK., JSIEW YORK 1O017


                   July  29, 1975
 1ILIPHONC
2I2-867-O2OO
CAVLC ADDWCS9
'BAKER8RO'
TCLCX t-2487
   42O944
   223482
      Metropolitan Denver  Sewage Disposal
      District No. 1
      Commerce City/ Colorado

      Gentlemen:

      We noticed in the July 28th issue of the publication Air/Water
      Pollution Report, that you have  been granted $76,029 to study
      the effect of feeding to  cattle,  crops grown on sludge amended
      soils.  From our letterhead, you will see that we are in the
      fertilizer and feeding materials business,  and for many, many,
      years, we have actively sold heat dried activated sewage sludge
      to the fertilizer industrye  Some of this sludge finds its way
      on to pasture lands  as part of a complete mixed fertilxzer0
      Consequently, we will be  keenly  interested in knowing the outcome
      of your study, if this information could be made available to us.
      As a matter of fact, we would like to know whether you are recovering
      and heat drying your sludge  and  whether you would be in a position
      to offer us tonnage.  We  are currently selling, nationally, the
      entire output of the Metropolitan Sanitary District of Chicago for
      the people who have the contract with them and can handle additional
      supply.

      We look forward to the pleasure  of hearing from you.

                                          Very truly yours,
                                         H
      JWR/nw
                      Wi Reisack
                        President
                                     F-4
              BAKERBPO CCNTROAMERICANA S.A . COSTA RICA • NUTRITION PRODUCTS DIVISIONS. NEW ORLEANS. PHILA-
              DELPHIA . THE KAINIT DIVISION. SAVANNAH •  POULTRY DY.PRODUCTS. INC.. HANCEVILLE. ALAOAMA . THE
              PRO-PAK CORPORATION. FERNANDINA DCACH, FLORIDA . H. J. DAKER & DRO. (CANADA) LTD. MONTREAL

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lie
CITY of
                                 10959 IRMA DRIVE
                                 NORTHGLENN, COLORADO 80233       (303) 452-1941
                Bill Martin
                C/0 Metro Denver Sewer
                3100 E. 60th Avenue
                Commerce City, CO  80022

                     We are extremely interested in obtaining anarobically
                digested stabilized sludge for use on our parks and green-
                ways.  We understand that this caterial will be made avail-
                able in the near future and would like to be contacted so
                ve can use this valuable resource.  We can use approximately
                200 to 500 tons annually.
                     Could you please send me the Chenical analysis c-f the
                material also, what method will be used in transporting to
                Northglenn.

                                            Thank you,
                                                 DeBell
                                           'Superintendent of Public Works
                                            City of Northglenn
                JDB/cw
                                                 F-5


   '• of the director of community works

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                    City of Commerce City
                           4407 East 60lh Avenue
                        Commerce City, Colorado 80022

                           TELEPHONE (303) 287-3485                      COMMUNITY
                                                             DEVELOPMENT
 August 11, 1975
 Mr.  William J.  Martin,  Director
 Resource Recovery & Reuse
 Metropolitan Denver Sewage Disposal District #1
 3100 East 60th  Avenue
 Commerce City,  CO   80022

 Dear Mr.  Martin:

 I am writing this letter pursuant to our conversation of Thursday,
 August  7,  1975.

 The  City of Commerce City has been strongly considering and hopes
 at some future  date using "sludge" as a fertilizer for both new park
 development and park maintenance.   The City has approximately 40-
 acres of  developed park and open space which we are fertilizing
 (commercial)  a minimum  of three times a year.  As well, we are
 planning  to construct between 10 and 15 additional acres each year
 for  the next four years in which we have been applying manure for
 topsoil development.

We would  like to  substitute your sludge in both these instances.

Since-fely,
Dale W. Gilbert
Director of Community Development

th
                              F-6

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                                      August, 1971*
     TOi     1KB METROPOLITAN DENVER SEWAGE DISPOSAL DISWICP NO. 1
             We, the undersigned, in the interests of minimizing environ-
     mental pollution and conserving cur resources, wish to affirm our
     support for the recycling of municipal wastes.  In particular, we
     strongly support efforts which would r.ake nuniciple wastes avail-
     able to the public for use as an organic fertilizer.
HAMS                               ADDRESS                          ZIP
         This petition was signed by 461 persons, primarily in the Metropolitan

         Denver area.
                                           F-7

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                     COLORRDO ORGRN1C GROUERS'fiNO fi3Ri£TER5'fl55QClffl]ON
                                   DEN»tR, COLORRDO £D2il
                                     477-6Z9!
)the Metropolitan Denver Sewage  Disposal District #1.

    V/e the undersigned individuals,  residents of  Metropolitan Denver com-
itted to the usage  of  natural fertilizers only and convinced that,  as
i^payers, v;e are  entitled to stabilized,dry or semi-dried activated sludge
id  concentrated anaerobic-produced  sludge,  semi-dry or dried.
     Name
Address
land area     1/4 ton  1/2 ton 1 ton  (+]
               This petition was signed by 15 persons who requested a total of 37 1/2

               tons of sludge.
                                        F-8

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mm

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     This Appendix comprises a reproduction of the
tabulation of the environmental evaluation ma-
trix used by the facilities planner (CH2M—HH1)
in selecting site B-2 from the three finalists
for a sludge drying and distribution site.  Even
though site B-2 has been selected by the plan-
ners as the most favorable location, nagging
problems remain with respect to neighborhood
acceptance and potential market proximity.  For
more information on the environmental, engineer-
ing and cost factors weighed in the process of
site selection refer to Reference 8 in Section IX
of the main body of the EIS.

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                                     CONSIDERATION                                                                  CRITERIA
                                                    Overall land reciuireinents                            Are 2000 acres available?
                                                   On sue Duffer
                                                   Current lana u
                                                                                                                                                         tt>e region wiin posted speeds of 55 MPH.            witn speeds of 55 MPH.



SOIL AND GEOLOGY                             Soil Characteristics                                 Soil Series                                          T.uckum Lu;

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                                                 CONSIDERATION
            CLIMATIC CONDITIONS
 I
ro


                                                                                                                                                                                                                                                    Same as Site A.
                                                                                                                                                                                                      Same as Site A.
Same as Siie A.



Same as Site A.



Same as Site A.

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                                                      CONSIDERATION
                 RELIABILITY
cn
                                                                                                                  eened?


                                                                                                                                                               $ J 1,948,000 Based on 197.
                                                                                                                                                                                                              tie approximately $675,000.
                                                                                                                                                                                                              $11,695.000 baieO on 1974 cc
approximately $688,000.
$12,899,000 baieU on 197.
Same ai Site A.

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   APPENDIX H
DISTRIBUTION LIST

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                     DISTRIBUTION LIST

Federal Agencies

     Council on Environmental  Quality
     Environmental Protection  Agency
          Office of Federal  Activities
          Office of Solid Waste Management Programs
          Office of Water Programs
          Office of Public  Affairs
          Office of Legislation
          Dr. Joseph Parrel!,  NERC Cincinnati
          G. Kenneth Dotson, NERC Cincinnati
          Environmental  Impact Coordinators,  Regions I-X
     U.S. Department of Agriculture
          Dr. Rufus Chaney,  Agricultural  Research Service
          Dr. Elliot Epstein,  Agricultural Research Service
          Forest Service, Region II
          Forest Service, James Evans, WO
          State Conservationist, Soil Conservation Service
     Food and Drug Administration, Dr. George Braude
     Department of Interior
     Department of Health, Education & Welfare, Regional Director
     Energy Research & Development Administration, Herb Pennington
     Army Corps of Engineers,  Omaha District
     National Commission on  Water Quality, Dr. Harold Allen
     National Technical  Information Service
     Department of Transportation
          Federal Highway Administration
     Department of Housing & Urban Development, Regional Director
     Department of Defense
          Commander, Rocky Mountain Arsenal
          Commander, Lowry Air Force Base
     Farmers Home Administration, State Director
     William Armstrong,  U.S. House of Representatives
     Pat Schroeder, U.S. House of Representatives
     Floyd Haskell, U.S. Senator
     Gary Hart, U.S. Senator
     Jim Johnson, U.S. House of Representatives
     Dr. Richard Hayes, Public Health Service, Ft. Collins

State Government

     State Clearing House, Office of Planning
     Executive Secretary, Colorado Water  Pollution
       Control  Commission
     Colorado Department of Health
     Colorado Water Pollution Control Division
     Colorado Air Pollution  Control Division
     Colorado Solid Waste Division
                         H-l

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      Colorado Department of Natural  Resources
      Colorado State Land Use Commission
      Colorado State Department of Highways
      Colorado Wildlife Division
      Colorado State Water Conservation Board
      Colorado State Soil  Conservation  Board
      Office  of the Governor
      State Historical  Society

 Regional , County and Local  Government

      Denver  Regional  Council  of Governments
      Adams County Commissioners
      Adams County Planning  Department
      Boulder County Planning Department
      City of Boulder,  Publics  Works  Department
      Arapahoe County Planning  Department
      Jefferson  County Planning  Department
      Tri-County Health  Department, Don Turk
      Larimer-Weld Planning  Department
      City &  County of Denver
          Planning Department
          Health  Department
      Adams County Agricultural  Extension Service
      Denver  Water Board
      City of Westminister
      City of Golden
      City of Commerce City,  Attn:  Mr. Dale Gilbert
      City of Bennett
      City of Brighton, Attn: Mr. Bill Sharp
      City of Englewood
      City of Littleton
      City of Lakewood-
      City of Prospect Valley
      Denver  City  Parks Department, Ron Maketric
      City of Aurora, Attn: Mr. Charles Wemlinger
      City of Arvada
      City of Thornton
      City of Northglen, Attn:  Mr. Jack Debill

Sanitation Districts

     Metropolitan Denver Sewage Disposal  District  #1
     City and County of Denver Wastewater Control Division
     Applewood Water & Sanitation District
     Berkeley Water & Sanitation District
     Crestview Water & Sanitation District
     North Pecos Water & Sanitation District
     North Table Mountain Water & Sanitation District
     North Washington Street Water &  Sanitation District
                         H-2

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     Northwest Lakev/ood Sanitation District
     Pleasant View Water & Sanitation District
     Westridge Sanitation District
     Wheatridge Sanitation District
     Alameda Water & Sanitation District
     Bancroft Water & Sanitation District
     Fruitdale Sanitation District
     Highland Park Sanitation District

Other Associations & Individuals

     Colorado Open Space Council
     Rocky Mountain Center on Environment (ROMCOE)
     ECO-Center, Environmental Clearinghouse
     Colorado Clean Water Action Project
     Sierra Club, Enos Mills Chapter, Jim Fowler
     Keep Colorado Beautiful, Beverly Fleming
     Environmental Action, Maury Wolfson
     League of Women Voters
     National Wildlife Federation
     Thorne Ecological Institute
     The Denver Post
     The Rocky Mountain News
     Straight Creek Journal

     Denver Public Library
     Adams County Regional Library
     University of Colorado Library
     Colorado State University Library
     Burlington Ditch Company
     Dr. Edward Bryan, Program Manager
      National Science Foundation

     Mr. Martin Sorensen
     Sierra Club Wilderness Coordinate
     Golden, Colorado

     Miss Katherine O'Keefe, Attorney at Law
     Berkeley, California

     Larry Brown
     Environmental Control Division
     Climax Molybdenum Company
     4704 Harlan
     Denver, CO

     Dr. Parviz Soltanpour
     Department of Soils/Laboratory
     Colorado State University
     Fort Collins, Colorado
                          H-3

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 John J. Brehaney
 RMP Company
 100 West Walnut Street
 Pasadena, California 91124

 Dr. Richard G.  Burau
 Associate Professor of Soil  Chemistry
 Department of Land, Air and
   Water Resources
 University of California
 Davis,  California  95616

 Mr. Eugene L.  Begg
 Soil  Scientist
 Department of Land, Air
   and Water Resources
 University of California
 Davis,  California  95616

 Mr.  Ronald W. Crites
 Metcalf and Eddy,  Inc., Engineers
 1029  Corporation Way
 Palo  Alto, California  94303

 Jack  Danford
 1450  South Havana  Street,  Suite 340
 Aurora,  Colorado 80012

 Dr. Wilfred G.  Iltis,  Entomologist
 Department of Biology
 California  State University
 San Jose,  California

 Mr. Bill Mathews
 229 Pierce
 Lakewood,  Colorado

 Mr. Ray 01 in
 No. 13487  Road 32
 Platteville, Colorado

 Dr. E. W. McCord
Northern Colorado Research Station
Greeley, Colorado

Dr. John Pourbaugh, Entomologist
California State Health Department
2151 Berkeley Way
Berkeley, California 94704
                          H-4

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Dr. Parker F. Pratt
Professor of Soil  Science
University of California
Riverside, California

Mr. S. W. Maphis
Briscoe-Maphis, Inc.
Deep Six Division
2336 Pearl Street
Boulder, Colorado

Dr. Berne R. Sabey
Department of Soils
Colorado State University
Fort Collins, Colorado

Dr. James Smith
Department of Civil Engineering
Colorado State University
Fort Collins, Colorado

Reynolds Turf Farms
Post Office Box 595
Brighton, Colorado 80601

Dr. Duane Westphal
Great Western Sugar Company
Longmont, Colorado

Mr. Calvin Tupps,  Adams County
Bob Ziegler, Adams County

Dr. Bernard Korbitz
Department of Medicine
Presbyterian Medical Center
Denver, Colorado

Jack Haines, Adams County
Robert Sandquist,  Adams County

Dr. Edwin Bennett
Department of Environmental Engineering
University of Colorado

Environmental Assessment Project

Environmental Defense Fund

John Schwing, Jerry Boyle
Cornell, Hayes, Howl and & Merryfield-Hill (CH2M-Hill)

Engineering Science, Inc.
Berkeley, California
                           H-5

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Benedetti,  Opperman & Martinez
1 Park Central
Donald Warner,  Bennett, CO
Catherine &  Leroy  Mundell, Bennett, CO
F.W. & Blanche  Meyer, Bennett, CO
Clarence Smith, Commerce City, CO
Edith Marlott,  Byers, CO
Brighton Adams  County Standard
The Brighton-Blade
Brighton Market-place
                          TIC             «U.S Government Printing Office: 1976-678-352

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