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wells are required to be located on the site so that the <br />impact of the sludge application process on groundwater can <br />be readily determined. <br />As with other DEN permitted systems, monitoring of sludge <br />sites is often inconsistent and sporadic. DEM does review <br />the monitoring reports from the on -site groundwater <br />monitoring wells. They also review lab analyses of sludges <br />applied to sites. DEM does not visit sites more than one <br />time per year, if that often. Sludge application is a self - <br />policing treatment process. <br />15 <br />