19920039 Ver 1_Staff Comments_20100928

0 -M3?
NC Division of Water Quality
401 Oversight and Express Permitting Unit
September 28, 2010
Memorandum
To: Larry Eaton
From: Eric Kulz
Subject: PCS Phosphate
Whitehurst Creek West Prong - Monitoring Summary Report
Larry:
If you recall, we asked CZR, Inc. to send us a summary of the macrobenthos, fish, and water
quality monitoring data for the above-referenced site. The method of data presentation in the
previous reports (annual reports contained baseline and current-year data only) made it difficult to
observe trends in the data.
Whitehurst Creek pre-restoration was apparently an incised and straightened channel.
Comparing overall pre and post construction data, it is unfortunate that the number of tolerant
taxa increased. Their explanations of the unconfined channel and continuous beaver problems
make some sense. I guess the question is how do these data compare with relatively
undisturbed swamp streams in that part of the state.
It was good to see some increase in EPTs (increase in mayflies, but decrease in caddisflies,
although the caddis taxa numbers have been improving over the past two years) over the life of
the project.
I don't really know how to make sense of the fish data, as I don't have a lot of experience dealing
with them. I guess the increase in piscivorous species is good.
I am not sure of the value of the water quality data, especially since there is no pre-construction
data. We don't have WQ standards for most of the constituents, and the data appear to show
(assumed?) natural up-and-down fluctuations.
The $64,000 question is can they be released from the monitoring? Do we think we see enough
positive info in this data to say they successfully mitigated for impacts?
Take a look at the report and then let's talk to John
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
http://ncwaterquality.org/wetlands