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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 />