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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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Template:
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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JoEllen Turner <br />970 - 864 -7682 p.8 <br />Borth Environmental Pollution Consulting, LW October 2, 2012 <br />Comments to "disturbed" soils, handling of the A and B lifts, statistical approach, and <br />selection of data: <br />X concede that it is appropriate to change the reference in my report from "dirt piles" to <br />"disturbed soils ". However, my point is that soils stored in stockpiles are not per definition a soil <br />according to e.g., the Soil Taxonomy, 2" Edition (see my initial report). For instance, a soil is <br />characterized by one or both of the following: horizons, or layers, that are distinguishable from <br />the initial material as a result of additions, losses, transfers, and transformations of energy and <br />matter or the ability to support rooted plants in a natural environment. In my opinion disturbed <br />soils are in no way comparable to well established agricultural soil. <br />Just to clarify, I did not mean to say that the A and B lifts should be placed in the same <br />geographical location. I meant to say that the B lift should be placed below the A lift and not <br />mixed together. <br />I agree with Mr. Dunker that the term "significant" is a term to denote the results of statistical <br />data analysis. The major problem with the obtained data for the substitute soil is that the number <br />of replicates (n =3) is so low that no statistical test can be used with confidence to compare the <br />different soils. However, Aaron Dejoia claimed that, for instance, the salinity is <br />STATISTICALLY HIGHER (at the 95% confidence interval) in the substitute soil as compared <br />to Lift A, Lift B, Barx Profile2, Barx Lift A3, and Barx Lift B4. Please refer to figure 4 in Mr. <br />Aaron Dejoia's report (however the mean values calculated for each soil can not be compared by <br />simply calculating the confidence interval in fact a t- test/ANOVA test will not even work for this <br />dataset for reasons given below). In addition, to prove that the Darvey -Barx Subsoil has <br />statistically fewer coarse (rock) fragments than the Bench I substitute subsoil please refer to the <br />previous analysis of these soils which showed that the average percent coarse fragments in the <br />Darvey -Barx subsoil was 0% but 6.37% in the Bench 1 substitute subsoil based on the dataset <br />presented in the Walsh report on Subsoil suitability, February 2008 (revised July 2008). <br />With respect to pH no statistical test can be used for the given data sets to compare the mean <br />values (see comments below). However, all but the Lift B soil had numerical pH values lower <br />than the substitute soil (since no statistical test can be reliably applied to these data sets we can <br />only rely on measured (empirical) data points. To prove that the organic matter content of the <br />Substitute Soil is STATISTICALLY lower than any of the other soils i.e., Lift A, Lift B, Barx <br />Profile2, Barx Lift A3, and Barx Lift B4 please refer to figure 5 in Mr. Aaron Dejoia's report <br />(though I do not concede the validity of Mr. Dejoia's statistical approach). <br />The Key Ag Services data set is not easy to interpret for the simple reason that some data are <br />presented in cm (e.g., sample TPO4) others in inches (e.g., sample TP05) and some even in feet <br />(e.g., sample TP06). During my site visit I was told by Aaron Dejoia that they "always" use SI <br />units, though this is contradicted by the data sets. This represent a good example of an analytical <br />lab that may not pay attention to important details and that does not have a good QA /QC in <br />place. Another example of lacking QA/QC was when Key Ag had to retract a dataset due to <br />problems with their pH meter. With good QA/QC in place the dataset would never have been <br />send to the client. <br />7 1 Page <br />PLTF 002481 <br />
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