JoEllen Turner
<br />Borth Environmental Pollution Consulting, LLC
<br />sulfate/gypsum levels. I don't know if the coal dust could contain high enough sulfate
<br />concentration to cause this pollution.
<br />970 - 864 -7682 p.18
<br />October 2, 2012
<br />From Ayer and Westcot, 1985: http:// www. fao. org /docrep /003/T0
<br />Gypsum occurs naturally in many soils in arid climates [Colorado is semi -arid] and some soils
<br />will contain gypsum in sufficient quantity to affect interpretations of both soil salinity (ECe) and
<br />sodicity (exchangeable sodium), and require a correction both to the measured soil salinity (ECe)
<br />and to the reported SAR which is frequently used to estimate the soil exchangeable sodium
<br />percent (ESP). For example, a gypsiferous soil has a measured ECe of 6 dS /m, a soil salinity
<br />which is expected to reduce yields of many salt sensitive crops. Since 2 dSlm of the reported
<br />ECe can be attributed to the gypsum, the ECe safely can be discounted by 2 dS /m and the
<br />corrected ECe now becomes ECe = 4 dS /m, an amount much less hazardous to sensitive crops.
<br />As an example of the problem in interpretation, a strongly gypsiferous soil, but with high
<br />salinity, may have an ECe of 12 dStm, of which 2 dS /m can be attributed to the gypsum. If all
<br />the other salts are sodium, there should be, in the saturation extract, Na = 100 met and Ca not
<br />more than 30 melt, yielding a calculated SAR of 26. Such a. soil, having ECe = 12 dS /m and
<br />SAR of the saturation extract equal to 26, is normally classified as a saline- alkali soil which
<br />requires extensive reclamation by a massive gypsum application plus extensive leaching before
<br />cropping. This is an incorrect interpretation. The soil is moderately saline (ECe = 12 dS /m) but it
<br />is not sodic because the gypsum provides a steady supply of calcium.
<br />Since the reclaimed soil has to be equal or better than the native soil the substitute soil needs to
<br />have a measured EC lower than 2.6 dS /m.
<br />7.3 Organic Matter
<br />See my comment above about the problems (e.g., decreased crop yield, less soil aggregation, less
<br />water holding capacity, less nutrient retention, etc) related to low organic matter concentrations.
<br />In addition, figure 5 in Mr. Dejoia's report clearly shows that the organic matter content is
<br />- 300% higher in the undisturbed soil than the stockpiled Lift A. The Dejoia report does not
<br />provide evidence to establish that the organic matter content can be returned to — 2.5% within the
<br />10 year reclamation cycle mandated by the regulations.
<br />7.4 Additional Soil Physical and Chemistry Parameters
<br />It is clear that the salt levels in the stockpiles are higher than in those found in the native Barx
<br />soils, indicating that the stockpiles were contaminated with salt, most likely due to the use of
<br />17 Page
<br />PLTF 002491
<br />Undisturbed
<br />soil (n=49)
<br />Substitute soils
<br />(n =6)
<br />A lift
<br />(n =67)
<br />B lift
<br />(n =90)
<br />Mixed "C'
<br />(n =52)
<br />Average
<br />Gypsum
<br />(Ca504 * 2H
<br />m eq/100g
<br />3.0
<br />(258 mg /100g
<br />(or 025%))
<br />6.0
<br />(517 mg /100g
<br />(or 0.5%))
<br />5.9
<br />7.1
<br />5.9
<br />JoEllen Turner
<br />Borth Environmental Pollution Consulting, LLC
<br />sulfate/gypsum levels. I don't know if the coal dust could contain high enough sulfate
<br />concentration to cause this pollution.
<br />970 - 864 -7682 p.18
<br />October 2, 2012
<br />From Ayer and Westcot, 1985: http:// www. fao. org /docrep /003/T0
<br />Gypsum occurs naturally in many soils in arid climates [Colorado is semi -arid] and some soils
<br />will contain gypsum in sufficient quantity to affect interpretations of both soil salinity (ECe) and
<br />sodicity (exchangeable sodium), and require a correction both to the measured soil salinity (ECe)
<br />and to the reported SAR which is frequently used to estimate the soil exchangeable sodium
<br />percent (ESP). For example, a gypsiferous soil has a measured ECe of 6 dS /m, a soil salinity
<br />which is expected to reduce yields of many salt sensitive crops. Since 2 dSlm of the reported
<br />ECe can be attributed to the gypsum, the ECe safely can be discounted by 2 dS /m and the
<br />corrected ECe now becomes ECe = 4 dS /m, an amount much less hazardous to sensitive crops.
<br />As an example of the problem in interpretation, a strongly gypsiferous soil, but with high
<br />salinity, may have an ECe of 12 dStm, of which 2 dS /m can be attributed to the gypsum. If all
<br />the other salts are sodium, there should be, in the saturation extract, Na = 100 met and Ca not
<br />more than 30 melt, yielding a calculated SAR of 26. Such a. soil, having ECe = 12 dS /m and
<br />SAR of the saturation extract equal to 26, is normally classified as a saline- alkali soil which
<br />requires extensive reclamation by a massive gypsum application plus extensive leaching before
<br />cropping. This is an incorrect interpretation. The soil is moderately saline (ECe = 12 dS /m) but it
<br />is not sodic because the gypsum provides a steady supply of calcium.
<br />Since the reclaimed soil has to be equal or better than the native soil the substitute soil needs to
<br />have a measured EC lower than 2.6 dS /m.
<br />7.3 Organic Matter
<br />See my comment above about the problems (e.g., decreased crop yield, less soil aggregation, less
<br />water holding capacity, less nutrient retention, etc) related to low organic matter concentrations.
<br />In addition, figure 5 in Mr. Dejoia's report clearly shows that the organic matter content is
<br />- 300% higher in the undisturbed soil than the stockpiled Lift A. The Dejoia report does not
<br />provide evidence to establish that the organic matter content can be returned to — 2.5% within the
<br />10 year reclamation cycle mandated by the regulations.
<br />7.4 Additional Soil Physical and Chemistry Parameters
<br />It is clear that the salt levels in the stockpiles are higher than in those found in the native Barx
<br />soils, indicating that the stockpiles were contaminated with salt, most likely due to the use of
<br />17 Page
<br />PLTF 002491
<br />
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