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to accomplish that. Their one advantage is that they have this <br />waste heat. <br />Chairman Wheeler felt if it then is true that they can raise <br />the sludge to Class A in that fashion, the next question is do <br />they have the areas within the City limits to dispose of that <br />material. Mr. Munksgaard did not know if there is enough vacant <br />land area within the City limits for that purpose. <br />Commissioner Bird asked if the City has the option of hiring <br />a contractor to come in and haul the material away, and Mr. <br />Munksgaard noted they even could take it to another county. <br />There are multiple options available to the City. <br />Commissioner Scurlock noted that although the Ag interests <br />have been willing in some cases to accept this material in the <br />groves, they have a concern about the build-up of heavy metals <br />over a period of time. <br />Mr. Munksgaard confirmed that is where the federal regula- <br />tions are so stringent. They have studied this type disposal in <br />regard to impact on the food chains, and the federal 503 rules <br />basically would make land application not cost effective. The <br />way they are currently proposed, they have reduced them by an <br />order of magnitude of 10. DER, in their 17.6.04 rule, did not <br />adopt those strict land application requirements on heavy metals. <br />but if the federal rules go through in 1990 as written, the state <br />will have no choice but to meet the federal requirements. <br />Commissioner Scurlock asked if the Class A the City has <br />meets those requirements for land application, and Mr. Munksgaard <br />believed the way the DER rule is written, they would, and <br />possibly also under the federal rules, but at such a very low <br />rate. He explained that when you talk about an order of <br />magnitude of 10, instead of having a sod farm of 1,000 acres, you <br />now would be talking 10,000 acres, and this, of course, has a <br />great impact on cost effectiveness. Mr. Munksgaard noted that <br />his firm is a national consultant, and he believed they have a <br />good vision of the way things are headed. They, along with <br />DEC 21 1989 <br />T <br />BOOK 78 PAGE735 <br />