20111013 Ver 2_Public Comments_20130325 (2)

Strickland, Bev
From: Karoly, Cyndi
Sent: Monday, March 25, 2013 9:05 PM
To: Strickland, Bev
Subject: Fwd: Vanceboro Quarry Scanned Comment
Attachments: 201303251813.pdf; ATT00001.htm
Sent from my iPad
Begin forwarded message:
From: "Belnick, Tom" <[e-mail]>
Date: March 25, 2013, 6:28:53 PM EDT
To: "Karoly, Cyndi" <[e-mail]>
Cc: "Rawls, Paul" <[e-mail] >, "Stecker, Kathy" <[e-mail] >,
"Adams, Amy" <[e-mail]>
Subject: FW: Vanceboro Quarry Scanned Comment
Cyndi- another comment letter I received and scanned for upload to database.
Paul/Kathy /Amy- fyi.
Tom Belnick
Supervisor, NPDES Complex Permitting Unit
NCDENR/Division of Water Quality
919- 807 -6390
E -mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties
- - - -- Original Message---- -
From: Tom Belnick [mailto:[e-mail]]
Sent: Monday, March 25, 2013 6:13 PM
To: Belnick, Tom
Subject: Message from "RNP0026733F34F1"
This E -mail was sent from "RNP0026733F34F1" (Aficio MP C4502).
Scan Date: 03.25.2013 18:13:11 ( -0400)
Queries to: [e-mail]

March 18, 2013
NC Division of Water Quality
Division of Environmental Health and Natural Resources
NCDENR -DWQ -NPDES
1617 Mail Service Center
Raleigh, NC 27699
Greetings:
RE: Martin - Marietta Materials Vanceboro Quarry
Herewith a few notes from my thoughts on comparing the 401 Water Quality Certification and the NPDES
wastewater discharge permit applications from Martin - Marietta for their proposed limestone quarry near
Vanceboro with the regulations and requirements for such processes:
"An evaluation of alternatives to discharge is required of all new or expanding facilities. The Engineering
Alternatives Analysis (EAA) guidance is available in the Permit Applications section of the site. Applications that
do not contain a thorough EAA will be returned."
The intent of the NPDES regulations and the associated permitting process is to minimize pollution of surface
water systems by the addition of foreign materials from discharged wastes. This creates the requirement for "an
evaluation of alternatives to discharge" as part of the permitting process.
The purpose of the evaluation of alternatives to the discharge being considered is to minimize damage to existing
surface waters, not to minimize the costs to the would -be polluters. However, that latter question is the entire
substance of the "Engineering Alternatives Analysis" provided by Martin Marietta, prepared by Groundwater
Management Associates, dated September 14, 2012. There is no mention of any variation in the pollution
produced by the various disposal mechanisms — only the relative costs. All of the options considered are declared
"feasible" alternatives to the polluting discharge into Blount's Creek in the AEE. It's only that the option of
destroying Blount's Creek is the least expensive.
Their EEA might be considered "thorough" with respect to that single peripheral question of the costs to be
incurred by Martin - Marietta to execute the respective options. It cannot be considered adequate to the pollution -
preventing purposes of the regulations. This clearly makes their application eligible for being 'returned'. Given the
availability of several feasible non - polluting alternatives to the proposed discharge, the discharge of mine
wastewater into Blount's Creek cannot be permitted.
The "Technical Memorandum" prepared by CZR Inc, dated October 30, 2012 purports to explain that the Blount's
Creek surface water system will not be degraded by the discharge of 12 million gallons per day of limestone mining
wastewater. They proceed to describe a number of major changes that will, if permitted, result in a completely
different surface water system. Everything about Blount's Creek will be different if they have their way. Their
refrain of "No adverse effect likely" is either totally disingenuous or a cynical "big lie" [The Big Lie is a 88- year -old
propaganda technique, given its name by Adolf Hitler, during the dictation of his book Mein Kampf, about using a
lie so overwhelming that no one could believe anyone could be so cynical or impudent as to distort the truth so
outrageously.]
Dramatic increase in pH and flow rate will, with no reason to doubt it, completer
upper reaches of the Creek... in the words of CZI, to "provide more habitat for an
assemblage of freshwater fish species." In other words, they propose to make th
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whole different list of fish species. I cannot find anyone who wants to change the membership of our present
"assemblage" of species in the direction proposed by CZR for MMM.
"Low pH conditions in NC swamp streams naturally reduce fauna richness and diversity." Pay special attention here
to the word "naturally" ...the way it is, is natural. Everywhere you look, "natural" swamp drainage is acidic. One
will also usually find such water to be brown — from tannic and humic acids. Naturally. The list of resident species,
the existing level of diversity, is entirely natural for that circumstance. "reduce ... richness and diversity" compared
to what ?! Acidic water running out of the swamps at the upper reaches of Blount's Creek is a totally natural state
of affairs. MMM will not improve it by adding a great excess of mining wastewater.
At various points in the document, CZR makes much of the fact that "increased pH reduces the solubility of
aluminum and therefore the toxic effects of aluminum." No reason is offered that we should have any reason to
believe that Blount's Creek presently has a problem with the toxicity of dissolved aluminum having untoward
effects on the existing fauna. No evidence is offered that Blount's Creek has any measureable aluminum dissolved
in it under normal conditions. The "scientific" background offered for these conclusions, in the form of papers
from Baker &'Schofield (Water Air and Soil Pollution 1982 v. 18:289 -309) and Hall et al. (Ecology 1980 61(4):976-
989), is irrelevant big lie double -talk that has nothing to do with the present state of Blount's Creek or anything
remotely like it. Hall et al: for example experimentally acidified a New Hampshire mountain stream running down
granite hills, with a mineral acid, and recorded loss of quality of the environment for a couple of fish species that
have never been seen in Blount's Creek. The headwaters of Blount's Creek are perhaps a hundred miles from any
granite. As discussed above, the water draining from the swampland in the upper reaches of Blount's Creek is
naturally acidic, with organic acids, not artificially acidified with a mineral acid, and the diversity observed is not
"reduced" relative to any comparable situations, but is entirely appropriate to that natural circumstance.
"Increased and more regular flow will ... alter community structure as functional feeding groups in intermittent
sections shift to those more characteristic of perennial streams." Translated from flimflam to plain talk, that means
that, if we let them change the upper reaches of Blount's Creek from intermittent (and sometimes negligible) flow
to a steady high rate of flow, the little critters that live there will go away and other kinds will come. ...again,
making things all better — for a whole different list of species to inhabit a whole different kind of creek.
Farther downstream, in the more consistently estuarine part of the Creek ... again "No adverse effects likely."
Because "effects of the project are predicted [ ! ?! — freely asserted; freely denied — I predict the suckiest team in
MLB this year will win the Series next year; now we're even.] to be within the range of existing natural conditions."
Same for all the fish species and all the invertebrates (the critters, like crabs and clams, but mostly smaller, like
copepods, that don't have backbones.)
The range of 'existing natural conditions' for the speedometer on my car runs from say, five mph to 90. And there
is a range of existing natural flow rates of Blount's Creek, from almost no flow to a visible current even here at its
widest point. Suppose we set the cruise control on my car at 85, or give Blount's Creek a flow rate somewhere on
the other side of 12 million gallons per day, all day every day, and leave it there for the next fifty years. Either
change is within the range of existing natural conditions, but there is nothing natural about pegging the system at
or near the end of the range of natural conditions. It will absolutely and dramatically change the creek and
everything that lives in it. This is not within the range of the intentions of the relevant law and is not to be
permitted.
As for the flow rate, just so for the salinity. Yes, it is variable, more or less constantly changing, depending on a
fair -sized number of variables. No doubt, each day, certainly an important one of those variables, and arguably the

most important, is the amount of fresh water coming into the creek from its drainage area. (which, by the way, is
much more like distilled water than it is like the very metallic and hard water coming out of the aquifer through
the proposed mine). Just like the discussion above for the flow rate, so the salinity. Twelve MGD may not take the
flow rate OR the salinity all the way outside of the natural range of variability, but there is absolutely nothing
natural about lopping off most of the range of natural variability by pegging the flow rate near the upper end and
the salinity near the lower end of the natural range, forever. This is not within the range of the intentions of the
relevant law and is not to be permitted.
I could go on. Their classification of Blount's Creek as the lowest level of freshwater quality is wrong. In warm
weather, there are water skiers in the Creek every day, and I have never seen a single one get on and off their skis
without swimming in the deliciously soft water. These are nursery waters that also qualify for ORW or HOW. There
are SWLs. There are a number of other points in their argument for this permit, that they have handled much the
same as they have handled these points, and which equally cry for the same response —the permit must be
denied. Their DWR permit application is presented in the same attitude and needs the same response. I have an
interesting thought: I wonder if MMM has ever done anything quite like this before, and if so, if they could perhaps
demonstrate how they have done such with good outcomes for all concerned including the creeks nearby ?
I wish you well in doing your jobs. I have heard only one (well justified) NotlnMyBackYard comment. Most of us are
happy enough for them to have their mine, and they do seem like nice folks, but these laws, and your jobs
enforcing them, exist to keep them from destroying surface waters like Blount's Creek. They need to take their
mess elsewhere.
AI es wishes
(harles E Boklage, PhD
Blount's Creek resident
with almost 50 years of teaching biology
middle school to medical students
[e-mail]