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2013-02-04_REVISION - C1981008 (3)
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2013-02-04_REVISION - C1981008 (3)
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Last modified
8/24/2016 5:12:49 PM
Creation date
2/4/2013 1:43:11 PM
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DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
2/4/2013
Doc Name
Borch Rebuttal (Faxed)
From
JoEllen Turner
To
DRMS
Type & Sequence
PR7
Email Name
DAB
MLT
SB1
Media Type
D
Archive
No
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JoEHen Turner <br />Borth Envirorrmental Pollution Consulting LLC October 2, 2012 <br />highly saline pit water for dust control. In fact it appears that large quantities of pit water have <br />been applied to the Morgan property since 2004. David Dearstyne (NRCS) reported in his letter <br />(Nov. 16, 2010) that he also observed that the stockpiles had "undetermined salt crystals of some <br />kind ". <br />7.5 Soil Chemistry Conclusion <br />I believe that many of the inaccuracies attributed to me are minor and/or inconsequential. <br />Further. I believe that some of Mr. Dejoia's analysis is misleading and/or inaccurate. <br />1) I agree with Mr. Dejoia that it is not correct to calculate a straight numerical average of <br />the pH. But in this case it does not change the conclusions. <br />2) Mr. Dejoia is wrong with respect to his statistical analysis (see comments above). His <br />analytical /methodological approach is also inaccurate as seen in form of the large confidence <br />interval for the substitute soil. The reason that I put the soils in the order that I did for <br />comparison was based on a quick evaluation of both the confidence intervals and the mean <br />values. The pH could be the same or lower - only by taking more samples and the same number <br />of samples for all soils will we be able to apply a "reliable" statistical method for comparison of <br />the mean values. <br />3) See comments above. <br />4) I reject the contention that I have exhibited bias in favor of the Morgans. I believe my <br />conclusions and methods, as outlined above are analytically sound. <br />7.6 Soil Chemistry Opinions <br />I stand by analysis, as stated above. <br />970 - 864 -7682 p.19 <br />8.0 Soil Depth <br />After further investigation of the Morgan property including a recent conversation with Mr. <br />Morgan I have come to the conclusion that the property did historically not have a high water <br />table. The statement about the high water table in my preliminary report was based on me <br />misinterpreting a statement from Mr. Morgan (I apologize for that). However, if the reclaimed <br />soil is more compacted than the native soils that could lead to poor drainage in the future - I <br />suggest that bulk density measurements should be conducted as soon as possible (before seeding <br />alfalfa) on the reclaimed soil to quantify the soil strength since that may allow for correction of <br />the soils strength before it's too late. David Dearstyne (NRCS) reported in his letter (Nov. 16, <br />2010) that the clay content was very high (Clay -heavy Clay loam greater than 35% clay) in the <br />stockpiled OB 1 soil and that it was likely to impact the permeability of this soil, especially if <br />compacted, and that this would result in lower permeability rates than acceptable for prime <br />farmland. <br />18lPage <br />PLTF 002492 <br />
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