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Show f Kennecott John G. Catts V,c~ Pres,oenr Env1ronmen111 Atta ,rs Memorandum January 9, 1992 ROBERT LONERGAN SUBJECT: Review of Undated ERI-Logan, Inc. Report Entitled "Watershed Reclamation, Preliminary Assessment. surface Media Investigations" ("the Report"> Pursuant to your request, Preston Chiaro and I have undertaken Our a substantive technical _review of the referenced Report. comments, which follow, are separated into those which are general nature addressing issues prevelant throughout the text and specific comments directed to . specific pages. GENERAL COMMENTS The Report suffers from extensive quality control problems. Care was obviously not used in its preparation. The Report was not reviewed for accuracy, completeness, or internal consistency. This comment applies at all levels, from simple things like the lack of a date on the cover, numerous inaccurate figure references, and poor grammar to more serious problems such as figures that are illegible and "interpretations" of data that have no foundation in accepted scientific practices. Data from numerous references are used without an expla~ation of the accuracy or comparability of the data or the means used to collect them. A quality control review by ERI would have identified many of these problems before the Report was ever circulated. In many respects, the Report appears to be a preliminary draft rather than a ~inal document. 1. From di verse and sometimes sparse data, broad, sweeping 2. The Report is conclusions are drawn without critical analysis. largely a "house of cards", an illusion of scientific analysis without the underlying and necessary framework to support it . . Many of the .conclusions reached by the (unknown) authors are not substantiated by data presented in the Report. In fact, data presented in some cases directly contradict conclusions put forth in the text of the Report. The Report does not contain an adequate description of methods 3. of investigation or interpretation. Methods by which samples were collected and analyzed are not given. This information is |