20111013 Ver 2_Public Notice Comments_20130314

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Memorandnm on Proposed Vaneeboro Qmrry of Martin Marietta Materials
(MMM)
To: NC Division of Water Quality !
From: James Coke, PhD in Chemistry, retired j
Date: March 12, 2013 i
Subject: The inadequacy and flawed nature of CZR TechnicalMemorandum dated I
October 30, 2012 and the unjustified conclusions reached in this
memorandum �
General Comments:
Many of the CZR comments and conclusions are based on "f eshwater fish" but the ]most
important fish in Blounts Creek for the recreational fishing community are diadrom0us
saltwater species including flounder, speckled trout, and striped bass. These are the Tones
which will be most severely impacted by the large amount of freshwater injected info
Blounts Creek. In addition to this distortion, there are a number of species that are totally
missing from the impact discussion in the CZR report. Also, there are a number of 1
unjustifiable extrapolations of scientific studies which purport to support the permitting
of the MMM mine discharge when in fact they do not Several studies actually contradict
the conclusions of CZR. Each of these will be discussed separately.
Speckled Trout:
One of the more sought out and prized game fish in Blounts Creek is the speckled trout
(Cynosdon nebalosus). Although CZR mentions these in the lists of regulated fish 4nd
fish present in Blounts Creek, there is absolutely no mention of them in the discussion of
the environmental effect from mine discharge of large amounts of fresh water into
Blounts Creek.
Effects of pH Change:
The report indicates a change in the natural pH of 4.0 -5.5 up to pH of 6.3 -6.9 f om ghe
mine discharge. This may not seem like much, but pH numbers are log or exponential
numbers. So a change of pH 4.0 to pH 7.0 represents a thousand fold decrease in acidity.
Even CZR admits pH levels are very important in regulating fish biochemical Pros.
CZR tries to mitigate this effect by claiming the organic acids in the creek bed will Duffer
the mine discharge pH down from the higher levels. This is very doubtful in a rapidly
moving stream of fresh water. There are a number of articles one can easily find in the
H terature that point out that speckled trout tolerate a pH as low as 4.0 although they`may
pze&r slightly bigher PH-
In any event, look at the attached pictures of healthy fish from Blounts Creek at pH 4.0-
5.5. They seem to be thriving. They represent reality, not conjecture (there are many
other pictures). I
The CZR report concludes that raising the pH from 4.0 -5.5 to pH 6.3 -6.9 will provide a
more diverse realm of freshwater species ", ignoring the fact that it
destroy the more important saltwater species.
ro F,MAR 1 4 2093 U
WA U AL rY
_�

Aluminum Levels and Fish Toxicity
Aluminum toxicity is an extremely complex subject What is generally agreed on is that
many waters that have low pH also have high aluminum ion content Exactly how toxic
this is to eggs, larvae, adult fish by species and other factors is hotly debated and studied.
There are even articles that claim high aluminum levels are beneficial to egg survival but
harmful to larvae and post-larvae stages.
One of the articles cited in the CZR report (Hall et al., Ecology, 61 976 -989 (1980)
showed increased aluminum levels as acidification was increased (pH lowered).
InteesdWy, they found no gill damage in brook trout samples.
The fourth paragraph on page 4 of the CZR report discusses this study and contains some
gross inaccuracies. CZR states "Acidic pH levels found in upper coastal plain waters such
as Blounts Creek naturally have greater concentrations of inorganic aluminum (Hall et
al., 1990). The article quoted refers to a study by Hall in which a rocky stream in the
woods in New Hampshire was artificially acidified down to pH 4 for six months by the
addition of sulfuric acid. They found that this lowering of pH caused an increase in metal
ions, including aluminum. As noted above, they found no gill damage in brook trout
The CZR report has very obviously extrapolated from this study to claim that Blounts
Creek has high aluminum levels. Blounts Creek is a slow moving brackish water stream
moving through marshland. Thus, they are trying to lead the reader to believe that
Blounts Creek will be better for fish if massive amounts of fresh water at pH 6.3 -6.9 is
injected into the creek, thus raising the pH level so as to reduce the aluminum levels. Hall
made no such claim, and the analogy between their stream and Blounts Creek is zero.
This is a blatantly false and misleading mention on the part of CZR and is without
factual basis.
CZR also makes the statement (same paragraph) "that the more sensitive a fish species is
to acidic levels of pH, the greater the toxic response to aluminum concentrations will be
with decreasing levels of pH (Baker and Schofield, 1982)." Baker and Hall were both
referring to brook trout Note, speckled trout are one species that seem to be most tolerant
of acidic conditions.
I could not find literature on the exact aluminum levels in Blount Creek water. It may
well be that acidic water flowing over rocks and leaching out aluminum is not analogous
to acid water flowing through marshy organic rich soil. Thus, Blounts Creek cannot be
assumed to have high aluminum levels. It may also be that the fish simply aren't as
sensitive to aluminum in Blounts Creek because of their migratory habit as compared to
brook trout
In any event, look at the attached pictures of fish caught in Blounts Creek. The speckled
trout do not look like they are suffering from aluminum poisoning (reality versus
speculation). Thus there seems to be no need to pump mine water into Blounts Creek to
"save the fish from aluminum poisioning".
2

Salinity of Blounts Creek:
The salinity in Blounts Creek is absolutely going to be reduced by storm water and
ground water from the MMM mine. Page 7 of the CZR report speaks to this issue. It says
the constant rout of fresh water from the mine will push the "salt wedge" downstream
and create more habitat for freshwater fish species and nursery habitat for diadromous
fish. It doesn't say how for the fresh water will extend and says the fluctuation is like
normal events. The change caused by the mine dewatering is continuous and permanent
and is not a fluctuation. They are admitting that feshwater species will gain and saltwater
species will lose. See the Smithsonian Marine Station at Fort Pierce Report on spotted sea
trout (Qwwdon nebulosas) or speckled trout for salinity data. It is reported that adults
and juveniles have similar preferences for salinity but abrupt salinity changes have severe
adverse effects on spotted sea trout Their abundance peaks at salinities of 15 -35 ppt and
spawning peaks when salinity is high, typically 30-35 ppt (Literature references are
given.) Also there is I OOPA mn vival of eggs and larvae when salinity is 19-38 ppt.
Another source of salinity data is Press Register Delta Project I.C. Lb Finn Fish
Populations in the Mobile Delta which reports 20-45 ppt as optimal and similar survival
limits in salinity.
It is very clear from these references that injections of large amounts of storm water and
ground water into Blounts Creek will have adverse effects on the populations of speckled
trout in Blounts G4eek. Depending on where the salt water boundary is, it may even
emiminate speckled trout from Blounts Creek.
It is particuWY important to revisit a statement about pH on page 5 of the CZR report
because it contains a conclusion that "raising the pH to 6.3 -6.9 may create more suitable
habitat for spawning, egg and larval development, juvenile and adult stages for all
diadromous fish species". This conclusion is absolutely false because the mechanism for
raising the pH also involves lowering the salinity by injecting fi+esh water. It would be
absolutely fatal to the speckled trout population.
Turbitity and Whmie of Mine Water.
From estimates of rainfall, ground water, quantity of earth over - burden to be moved, and
amount of limestone to be mined and crashed, it is inconceivable that the water from the
mine will be injected into Blounts Creek as clean, sediment five, low turbitity water. For
MbAM to loll the creek and be fined is not an acceptable alternative to not allowing the
mine in the first place.
Quantity of Ground Water.
GaUdaY.mMK- Total gil in 50 years
12,000,000 219,000,000,000
91000,000 109,000,000,000
This shows the fresh ground water wasted in 50 years
C

Quantity of Rainfall on Mine Site — 659 acres:
Assume a hurricane that drops 12 inches of rain. `
659 acres x 43,560 square feet / acre x 18. x 7.48 galJ cubic foot = 214,834,000 gal.
This is approximately 20 times the daily amount that is to be pumped. How many of
these will occur in 50 years?
A 4-6 inch rain is not at all uncommon, producing many times the expected daily pumped
groundwater amount.
SUMMARY
The ROAM mine discharge is a tremendous waste of flesh water, a valuable natural
resource belonging to everyone, and will cause severe damage to Blounts Creek, one of
the best and most valuable fishing spots in the state. This will cause economic damage to
tourism and local residents.
The CZR report is not to be accepted as fact. The statement in the report on page 1 tiat
"Table 1 presents a summary of findings which demonstrate that no adverse effects are
likely to occur to fish species, macroinvertibrates, or Essential Fish Habitat (EFH) in
Blounts Creek due to predicted changes in pH, salinity, and flow velocity fiom the
proposed quarry discharge of 12M gallons/day" is, in my opinion, an outrageously *dse
statement. They talk about harmful effects in the report and then have the audacity tp say
that there are none. They leave out many severe adverse effects (for example to speckled
trout) and then claim that there will be no harm. In my opinion, the CZR report is a,
biased report containing distortions and omissions of scientific studies, and is simplb a set
of conclusions by CZR, paid for by WOL These conclusions tend to make WA M look
good and favor the approval of the mine discharge into Blounts Creek.
The permit for discharge of mine water into Blounts Creek should be denied
Please observe the next page of photos of Blounts Creek fish that demonstrates, as it
exists, it is a healthy thriving fish community for several saltwater fish species.
4

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