20080868 Ver 2_PCS Response to DWR Comments_20171213

Scarbrauyh, Anthon
From: Jeff Furness <[e-mail]>
Sent: Wednesday, December 13, 2017 10:32 AM
To: Scarbraugh, Anthony
Cc: Julia Berger, [e-mail]; Steffens, Thomas A SAW
Subject: [External] RE: [EXT SENDER] S33 Broomfield Swamp Creek Monitoring Sites Study
proposal
Attachments: PCS-CZR study proposal 9-17 response 12 5 17.pdf
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Anthony:
We are finalizing the Broomfield Swamp Creek study plan, but wanted to provide you with the attached PCS/CZR
responses to the comments and questions posed by Jason Green. Please forward to Jason if you wish, and also let him
know that we can provide him with a CD of the 2017 (2016 data year) Annual Creek Monitoring Report, if he is
interested.
Sincerely,
Jeff
Jeffrey C. Furness
Senior Scientist, Environmental Affairs
PCS Phosphate Company, Inc.
1530 NC Hwy 306 S.
Aurora, NC 27806
T: [phone]
C: [phone]
[e-mail]
www.Dotashcoro.com
ft PotashCorp
From: Scarbraugh, Anthony [mailto:[e-mail]]
Sent: Wednesday, September 20, 2017 3:25 PM
To: Jeff Furness <[e-mail]>
Cc: Julia Berger <[e-mail]>; [e-mail]; Steffens, Thomas A SAW
<[e-mail]>
Subject: [EXT SENDER] S33 Broomfield Swamp Creek Monitoring Sites Study proposal
Jeff,
Per our discussion, please find attached comments and questions provided by Jason Green of Division of Water
Resources Water Science Section. Please take these into consideration when finalizing our study plan.
Regards,
Anthony Scarbraugh
Environmental Senior Specialist

Division of Water Resources — Water Quality Regional Operations
Department of Environmental Quality
252 948 3924 office
anthonv.scarbraugh(Mricdenr.gov
943 Washington Square Mall
Washington, NC 27889
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

NC Division of Water Resources Comments on "Broomfield Swamp Creek Reconnaissance"
Memorandum provided by CZR Incorporated.
Provided by Jason Green
NC Division of Water Resources
Water Sciences Section, Intensive Survey Branch
PCS/CZR responses in italics after each NCDWR bullet below. Overall, Broomfield Swamp Run has been
added to the list of the creeks that are currently being monitored as required in the 2009 4041401
permits, and the Broomfield Swamp Creek monitoring plan was drafted to be consistent with the
approved monitoring occurring in those creeks.
• What rationale were used to identify Broomfield Swamp Creek as the monitoring drainage area
rather than Cypress Run? Please provide documentation of this decision -making process.
Broomfield Swamp Creek was selected for several reasons, with the three most important ones as
follows:
1. based on projected impacts to the Cypress Run basin, mine activities in the S33 Tract would
occur for —10 years in the northern portion of the tract before the five years of baseline pre -
impact data collection in Cypress Run would begin;
1. the mouth of Cypress Run cannot be trawled for fish as a boat cannot get under the Bateman
Road bridge across South Creek and there is no boat launch upstream of that bridge; and
3. there is no mapped bottomland hardwood community to monitor in Cypress Run.
• If the entire range of physical water quality conditions are to be monitored and evaluated during
this effort, the individual parameters should be provided (ie. water temp, pH, conductivity etc.).
This is not fully identified in the reconnaissance proposal. Please indicate this by site and
frequency along with all other measured parameters in a proposed study design.
See attached Table 1 (Table I-A2 from the annual creeks reports) for monitored parameters for creeks
in the PCS study. Agency -approved original 1998 study per 1996 USACE permit/401 WQC conditions;
per the 2009 USACE permit/401WQC conditions, the original study was revised, expanded, and re-
approved in 1012.
• Gathering all physical water quality information will allow more accurate determination of flux
that might be observed in biological components of the monitoring plan such as fish community.
See attached table.
At least one site should be considered on South Creek. The proposed study area is subject to
bidirectional flow. Water quality conditions that are geographically downstream may become
upstream as flow from South Creek enters the project area.
See attached Figure 1 for monitored creeks. Per the approved plan, some creeks are monitored for
the full suite of parameters and others are not. One station each on South Creek, Pamlico River, and
PCS Phosphate Company, Inc. Page 1 5 December 2017
Broomfield Swamp Creek Plan Response to NCDWR comments

Durham Creek is monitored for salinity and depth.
• To identify bidirectional flow conditions, their frequency and impact to the study area, flow
measurements need to be collected at one location within the study area. This information will
help identify changes to water level and salinity as it fluctuates due to wind driven tides present
in the Pamlico River estuary.
Text copied below from Section 11. A of annual creeks reportfor context; italics and red text for
emphasis:
A.
Flow: Monitoring since 1998 has shown that the upper systems (unidirectional stream portion) of
the study creeks are driven primarily by local precipitation and baseflow. The lower estuarine portions of
the systems (bidirectional creek portion) are wind -tide driven and subject to region -wide precipitation and
Tar River discharge.
Monitoring of flow via weirs in Jacks Creek, Tooley Creek, and Huddles Cut by Skaggs et al. from
1999-2010 (in various combinations of years for each creek) showed that within the unidirectional portion
of the systems where the weirs were located, approximately 1 to 3 percent of modeled flow to the
downstream bidirectional portion is delivered from the upstream basins. Never having been quantified
before, this percent was lower than many may have predicted or expected.
Some of the weir locations were within the 2009 permit boundary and/or the drainage basin was
so reduced at some other weir locations that they were abandoned. In order to continue to monitor flow
via weirs, new locations would have been placed further downstream within the bidirectional portion of
the systems in some instances. With these restrictions and understanding of the low percent contribution
of upstream flow to the primary nursery areas, the Science Panel agreed that flow monitoring was not
needed.
The very shallow and intermittent nature of the upper systems of these creeks does not allow use
of traditional stream gauges. PCS then elected to try a new product in beta development, a low flow
gauge, to monitor the unidirectional portions of the systems. Low flow units were installed in the upper
portions of two creeks in 2011 (Duck Creek and Porter Creek). Shortly after that the product development
was stalled and delivery and deployment of additional units was uncertain. Additionally, the accuracy of
the data became questionable and so monitoring of the installed units ceased in 2013. Like the earlier
flow monitoring done by Skaggs in the unidirectional reaches of Jacks Creek, Tooley Creek, and Huddles
Cut, flow events recorded by the low -flow gauges in previous years in Duck Creek and Porter Creek
appeared to be related to precipitation and baseflow.
Beginning in March 2012, during visits to other equipment located at or near the low -flow gauge
locations and intended gauge locations, biologists made qualitative observations of flow (none, low,
medium, or high) and noted water depths. For the creeks added in 2011 and 2012, there are no earlier
flow data for comparison, but flow observation information will continue to be collected in lieu of low -flow
gauges and observations will be compared pre- and post -Mod Alt L where possible. Pre- and post -Mod Alt
L comparisons to the weir records of flow will not be possible because the locations of most of the weirs
were well upstream of the current flow observation locations. Following the August 2015 Science Panel
meeting, flow observations were begun in Huddles Cut at the three salinity monitoring locations (HS1, HS2,
PCS Phosphate Company, Inc. Page 2 5 December 2017
Broomfield Swamp Creek Plan Response to NCDWR comments

and HS3). However, since all three of these locations are subject to frequent bi-directional flow (particularly
HS3), wind direction is also noted. As the salinity monitors are downloaded every two weeks, the
opportunity for flow observation at the Huddles Cut locations is doubled compared to other creek flow
locations, which are visited once a month when hydrology monitors are downloaded. Videos of flow are
also taken at the flow observation points throughout the year, which are available upon request from
CZR.
Flow presence and water depth are recorded during each site visit but determination of the
primary influences upon observed flow is sometimes difficult due to proximity to open water or wind
effect at many stations. Therefore, these flow observations should not be construed as evidence of flow
derived only from the basin upstream of the observation point. The observation data have not been
scrutinized to determine if a wind event may have been solely responsible for water flowing into the basin
(and counted as flow) and then, possibly, upon a change in wind direction or speed, had begun to flow back
downslope out of the system and was then observed as flow (seiche-like effect).
Tar River discharge, rainfall, and wind speed/direction are part of the analysis in the annual report. you
will be added as a recipient of future PCS creeks study annual monitoring reports (July of each year for
previous year's data)
• Meteorological data should be collected, or determined to be available to provide watershed
specific rainfall and wind conditions. Please provide source of data if collected from existing
weather stations.
See attached table of parameters (most creeks have a dedicated rain gauge; PCS Aurora NOAA
Station 6N also used for wind and when necessaryfor precipitation).
• Site locations described in the reconnaissance proposal appear to be located in an appropriate
manner along the length of the waterbody described (Broomfield Swamp Creek) and should
provide information to identify salinity gradient and water level as required.
PCS Phosphate Company, Inc. Page 3 5 December 2017
Broomfield Swamp Creek Plan Response to NCDWR comments

Table 1. Monitored parameters, equipment, and frequency of data collection. Water quality samples are
collected and AquaTROLLs are downloaded every two weeks. Rain gauges and LevelTROLLs are
downloaded once a month (Table I-A2 from annual creeks reports).
water
Wetland hydrology - alluvial bottomland
LeveITROLLS
Every 1.5 hours/monthly field check
Estuarine/creek water levels
AquaTROLLS
Every 1.5 hours/2 week field check
Flow events
Observation'
Monthly field check
Water Quality
Salinity/conductivity/temperature
AquaTROLLS
Every 1.5 hours/2 week field check
Total dissolved phosphorus
Field to lab
Every 2 weeks
Dissolved orthosphosphate
Field to lab
Every 2 weeks
Ammonium nitrogen
Field to lab
Every 2 weeks
Nitrate nitrogen
Field to lab
Every 2 weeks
Dissolved Kjeldahl nitrogen
Field to lab
Every 2 weeks
Particulate nitrogen
Field to lab
Every 2 weeks
Particulate phosphorus
Field to lab
Every 2 weeks
Chlorophyll a
Field to lab
Every 2 weeks
Total organic carbon (TOC)
Field to lab
Every 2 weeks
Particulate organic carbon (POC)
Field to lab
Every 2 weeks
Total dissolved nitrogen (TEN)
Field to lab
Every 2 weeks
Metals in water
Field to lab
August
(Ag, As, Cd, Cr, Cu, Fe, Mo Se, Zn)
Metals in sediment
Field to lab
August
(Al. Ag, As, Cd, Cr, Cu, Fe, Mo, Be, Zn)
Rainfall by major basin
Ecotone rain gauge
1 Continuous; every 0.1 inch
Benthos - estuarine Ponar and sweep May
Fish - estuarine Otter trawVfyke net Weekly - April lhru June
Vegetation - alluvial bottomland Transacts (herb and shrub plots) Late growing season - Aug/Sept'
In sltu water duality Parameters I I
Monitored in conjunction with Weekly with fish collections
fish/benthos sampling, and/or Spring with benthos collections
water quality sample collections Every two weeks w/WQ collections
- water temperature
YSI handheld
- dissolved oxygen
YSI handheld
- conductivity
YSI handheld
- specific conductivity
YSI handheld
- salinity
YSI handheld
- pH
YSI handheld
- turbidity wANQ
Turbidimeter
- secchi depth w/fish/benthos
Secchi disc
- water depth w/fishibenthos
Tape measure
- percent SAVdsible w/fish/benthos
Visual
'Low flow gauges removed from Porter Creek and Duck Creek; production of additional units unlikely
2Not all creeks are monitored every year.
PCS Phosphate Company, Inc. Page 4 5 December 2017
Broomfield Swamp Creek Plan Response to NCDWR comments

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