20111013 Ver 2_Public Comments_20130326

Strickland, Bev
From: Karoly, Cyndi
Sent: Wednesday, March 27, 2013 8:42 AM
To: Strickland, Bev
Subject: FW: NPDES and 401 comments Vanceboro Mine
Attachments: 03_14_13 NPDES and 401 MMM comments _PTRF FINAL.pdf; Appendix A_DRAFT
Monitoring report.pdf; Blounts Creek Monitoring 201206- 201301_20130312_Appendix_B.pdf
From: Belnick, Tom
Sent: Tuesday, March 26, 2013 5:42 PM
To: Karoly, Cyndi; Adams, Amy
Cc: Rawls, Paul; Stecker, Kathy
Subject: FW: NPDES and 401 comments Vanceboro Mine
Cyndi- comments from Riverkeeper Heather Deck received 3/14. We might have received hardcopy at public hearing on
same day. Nevertheless, please add to comment database.
Paul /Kathy- fyi
•Ir WI
NCDENR/Division of Quality
019-807-6390
From: Heather [ma i Ito: riverkeeper ptrf.org]
Sent: Thursday, March 14, 2013 4:53 PM
To: Belnick, Tom
Cc: Higgins, Karen; Hart, Kevin; Cox, David R.
Subject: NPDES and 401 comments Vanceboro Mine
Please find the attached comments for the proposed Martin Marietta Materials limestone mine ( Vanceboro mine) for
Beaufort /Craven Counties. The comments include 2 appendices.
Thank you,
Heather Jacobs Deck
Pamlico -Tar RIVERKEEPER
Pamlico -Tar River Foundation
P.O. Box 1854
Washington, NC 27889
(252) 946 -7211 (office)
(252) 946 -9492 (fax)
(252) 402 -5644 (cell)
www.ptrf.org
Follow us on Facebook: http : / /www.facebook.com /pamlicotar

Follow us at Twitter: www .twitter.com /ptrfriverkeeper"
Operation Medicine Drop: www.omd- nc.org

Via Electronic Mail
March 14, 2013
Tom Belnick
NCDENR -DWQ -NPDES
1617 Mail Service Center
Raleigh, NC 27699 -1617
Re: Martin Marietta Materials, Inc. - Vanceboro Quarry NPDES and 401 certification comments
Dear Mr. Belnick,
Please accept the following comments regarding Martin Marietta Materials, Inc draft NPDES permit and
Clean Water Act Section 401 certification permit request to operate a 649 acre open -pit mine in
Beaufort County.
The Pamlico -Tar River Foundation (PTRF), founded in 1981, is a grassroots environmental organization
representing greater than 2000 members and is a licensed member of Waterkeeper Alliance, Inc. Our
mission is to monitor, protect, and enhance the Tar - Pamlico River and watershed while promoting
environmental justice.
PTRF has closely reviewed all materials related to the NPDES permit and 401 water quality certification
(WQC) applications by Martin Marietta Materials, Inc (MMM) for a 649 acre open -pit mine to be located
along the Beaufort - Craven County line. As described in detail below, we have numerous concerns
regarding their environmental analysis, alternatives analysis, and resulting impact to Blounts Creek, the
proposed receiving stream of the mine dewatering wastewater discharge.
PTRF recommends that the Division deny the NPDES permit based on the fact the discharge would
violate the pH water quality standard for swamp waters. Furthermore, we argue that the company has
failed to demonstrate that alternatives to a direct discharge that would avoid or minimize impacts to
Blounts Creek and the area's groundwater resource are not practicable, therefore the Division cannot
approve the 401 WQC.
Pursuant to Section 40 CFR 230.11(h) of the Clean Water Act (CWA) and 15 A NCAC 02H.0506 PTRF
focuses its comments on the impacts to Blounts Creek, the receiving stream for the mine dewatering
discharge.
Blounts Creek Physical Characterization
Blounts Creek is a third -order stream located in Beaufort County in eastern North Carolina. It flows
north approximately 14 miles, where it meets Blounts Bay, which is located 11 miles downstream of the
US 17 Pamlico River bridge. Three transportation crossings over Blounts Creek are the Norfolk Southern
Railway, immediately upstream of the confluence with Poundpole Swamp Branch, Tripp Road, a half
mile downstream of the railroad crossing, and NC 33, another 0.8 miles downstream.

The Blounts Creek watershed is approximately 89 square miles and is nearly entirely within Beaufort
County, except for about 0.7 square miles within Craven County. The watershed is delineated by two
12 -digit hydrologic units, referred to as Headwaters Blounts Creek (030201040106; —65 mi) and Outlet
Blounts Creek ((030201040107; —24 mi) by the US Geological Survey and shown in Figure 1.
Blounts Creek is fed by several first and second order tributaries including (upstream to downstream)
Herring Run, Nancy Run, Sheppard Run, and Yeats Creek. While the main branch of Blounts Creek drains
the south - central quarter of the watershed, multiple tributaries contribute to Blounts Creek along its
flow path. Herring Run drains most of the eastern areas of the watershed and joins Blounts Creek just
north of NC 33. Nancy Run drains the western most areas of the watershed and converges with Blounts
Creek less than a mile downstream of Herring Run. Between Herring Run and Nancy Run, Blounts Creek
widens from approximately 40 ft. just upstream of Herring Run to about 150 ft. downstream of Nancy
Run.
The watershed has remained largely undeveloped, with most residential housing located near the Creek,
downstream of Herring Run (Figure 2), including the community of Cotton Patch. Agriculture is the
largest developed land use within the watershed. The headwaters are Area residents have noted diurnal
tidal fluctuations of one to two feet each day downstream of Herring Run. However, the most extreme
tide driven water levels result from winds out of the south or west (falling water levels) and out of the
north and east (rising water levels).
The watershed is dominated by pine forest, scrub, and cropland. Development is primarily limited to
residential water front homes along the most downstream reach of Blounts Creek. Cotton Patch Landing
is a privately owned boat launch facility that anglers commonly use for accessing the water. The
uppermost headwaters of Blounts Creek have been ditched and drained for pine forest silviculture. The
most western parts of the watershed are former wetlands, drained for pine plantations.
Water Quality Classification
Blounts Creek is characterized as a coastal, blackwater stream. The pH of coastal blackwater streams
tends to also be more acidic, with values around the range of 5.0 to 6.0. These systems have also been
shown to be sensitive to nutrient inputs resulting in algal blooms under certain conditions.'
Assessments of nearby Palmetto Swamp and Durham Creek were determined not to be impaired.
Blounts Creek and its tributaries have yet to be assessed for impairment by the NC Division of Water
Quality (NCDWQ). However, all waters within the Pamlico River basin, including Blounts Creek are
designated as Nutrient Sensitive Waters by NCDWQ. The nutrient sensitive waters (NSW) designation is
a supplemental designation reserved for water bodies that require additional nutrient management
since they are subject to excessive growth of micro- or macroscopic vegetation.
Herring Run is recognized as the transition location on Blounts Creek between upstream freshwater to
the downstream tidal saltwater. Above Herring Run, Blounts Creek is classified as Class C, swamp and
' Mallin, M.A., J.M. Burkholder, M.R. McIver, G.C. Shank, H.B. Glasgow, Jr., B.W. Touchette and J. Springer. 1997.
Comparative effects of poultry and swine waste lagoon spills on the quality of receiving streamwaters. Journal of
Environmental Quality. 26: 1622 -1631.

nutrient sensitive waters. The class C designation is for waters that are protected for secondary
recreation uses, such as wading, and boating, which result in infrequent or incidental human contact, as
well as fishing and fish consumption, wildlife, aquatic life, and agriculture. The swamp waters
designation is used to indicate water bodies with low velocities and other natural characteristics that are
different from adjacent streams, such as significantly lower pH and dissolved oxygen concentrations.
Class C waters are protected for secondary recreation (wading, boating, or infrequent human body
contact), wildlife habitat, biological integrity, and agriculture. Swamp waters are characterized by low
velocities and may have lower dissolved oxygen concentrations and pH values may be as low as 4.3.
Below Herring Run, the NC Division of Water Quality classifies Blounts Creek as Class SB, nutrient
sensitive waters. The SB designation refers to tidal salt waters that are protected for primary recreation
activities that result in human contact frequently occur, such as diving, and water skiing. Below Herring
Run, Blounts Creek is classified as class SB waters. Class SB waters are tidal salt waters protected for
primary recreation (swimming, diving, or frequent human body contact), wildlife habitat, biological
integrity, and agriculture. (Turbidity threshold: 25 NTU) Middle and lower reaches of Blounts Creek are
frequently used by fisherman.
Aquatic Habitat
Blounts Creek (Lower SB, NSW, upper —C, Sw, NSW) is a brackish creek system and an important aquatic
nursery area for numerous species. As noted by the NC Division of Marine Fisheries (DMF), Blounts
Creek supports dense submerged aquatic vegetation (SAV) bed s2. The DMF also confirms that the
system is used by anadromous fish for spawning migrations and nursery areas, and resident species . 3
As noted in a letter from the National Marine Fisheries Service to the Corps of Engineers (January, 2012)
"...Essential Fish Habitat (EFH) species (e.g. bluefish, flounder) have been documented in the creek. In
addition Blounts Creek has been designated an Anadromous Fish Spawning Area by the NC Wildlife
Resources Commission and anadromous fishes of interest to NMFS have been documented using the
creek for spawning as well for as a nursery area . ,A
An email communication from Maria Dunn, NC WRC, noted that eels were present in a March 2011
survey (shocking) of Blounts Creek from Cotton Patch Landing to the confluence of Herring Run.
American eel is a Federal species of concern. 5
Recreational Resource
Blounts Creek is also an important recreational resource for Beaufort County. Two public boat ramps
(one is fee based) are located on Blounts Creek. Beaufort County government recently purchased land
to expand and improve an existing access point. Recreational fishermen utilize Blounts Creek year
2 DMF Letter from Kevin Hart to William Wescott, January 3, 2012. Martin Marietta Materials Mine - Vanceboro
Site (Beaufort /Craven County)
3 I
4 NMFS letter to William Wescott, January 4, 2012 Martin Marietta Materials Mine — Vanceboro Site (SAW -2011
02235)
5 US FWS Endangered Species, Threatened Species, Federal Species of Concern, and Candidate Species, Beaufort
County, North Carolina

round. The creek and Blounts Bay are also an important economic resource for some commercial
crabbers and local fishing guides. One local guide estimates that 50% of his Pamlico River fishing trips
(that target species such as striped bass, juvenile red drum, speckled trout and flounder) utilize the
Blounts Creek fishery resource. 6
Water Quality Monitoring
PTRF in collaboration with Dr. Eban Bean, East Carolina University, initiated water quality monitoring at
two locations on Blounts Creek in June, 2012. The upstream site was located approximately one half
mile east of Norman Road, immediately upstream of the Norfolk Southern (NS) Railway crossing. The
Downstream monitoring site was located approximately 4,400 feet downstream of Herring Run and
approximately 300 feet upstream of Nancy Run on Blounts Creek. An YSI 6920 -V2 -1 Sonde (Upstream
sonde) was programmed to record data measurements at 30- minute intervals. An Onset Hobo U20
Water Level Data Logger (referred to as pressure logger here after) was deployed along with the
Upstream sonde. An YSI 6920 -V2 -2 Sonde (Downstream sonde) was installed at this site and
programmed to record data measurements at 30- minute intervals. Data collected included: water
depth, temperature, conductivity, salinity, dissolved oxygen, and turbidity.
Grab samples were also taken approximately twice per month and analyzed by Environment 1, located
in Greenville, NC. The grab samples were analyzed for turbidity, conductivity and total suspended
residue.
Three water quality surveys were also conducted by attaching one of the Sonde's to a boat, taking
measurements every 1 minute. The sonde was submerged alongside a boat and towed over a length of
the creek.
Although water quality values measured by MMM's consultants were typically within expected ranges
for the respective NC DWQ classifications, collected data points could not be validated from any existing
historical water quality records for Blounts Creek. A record of water quality on Blounts Creek would
have provided context as to whether values were representative of year round or seasonal fluctuations.
In addition, a water quality record could offer validation to assumptions made in evaluating the impacts
of stream discharge.
The overall goal of this study was to evaluate Blounts Creek existing water quality. To achieve this goal,
the following objectives were identified:
Objectives:
1. Establish a record of water quality over monitored duration.
2. Due to a lack of data, characterize water quality of Blounts Creek under existing conditions.
3. Estimate potential impacts to water quality from changes in flow patterns and or quality, if
possible
A preliminary report of data collected from June, 2012 through January, 2013 is currently being drafted
and likely to be completed by the first week of April. A partial draft of the report is included here
6 Personal communication with Cpt. Richard Andrews, Tar -Pam Guide Service.

(appendices A and B) for DWQ's consideration. Appendix A includes the methods and Appendix B is the
raw data graphs. Gaps in the data occurred for multiple reasons. The most common and unavoidable
reason was for extractions for calibration of the sensors and downloading data or water quality surveys
(downstream only).
Table 1. Upstream and Downstream sonde extraction dates and durations.
Upstream Sonde
Downstream Sonde
Extraction Date
Duration (Days)
Extraction Date
Duration (Days)
14 -Jun
7
13 -Jun
< 1
12 -Jul
< 1
21 -Jun
4
6 -Aug
< 1
12 -Jul
< 1
27 -Aug
3
18 -Jul
< 1*
25 -Sep
2
6 -Aug
< 1
27 -Aug
3
25 -Sep
2
9 -Oct
< 1*
24 -Oct
6#
15 -Nov
< 1*
*Extracted for water quality surveys; all other extractions for calibration and downloading.
Summary of water monitoring results
Key observations of the monitoring data include:
• In general, grab samples values were typically within 24 hr fluctuations.
• Blounts creek water quality parameters are within ranges for their DWQ classifications.
• The stream behaves generally as would be expected for a coastal blackwater, tidally influenced
stream.
• Lunar tides typically cause a 1 foot fluctuation of water levels at the downstream location each
day. No diurnal signal was observed in Upstream water levels.
• Upstream of the RR tracks, water level and DO data tend to indicate that this water is nearly
stagnant unless during a rainfall event or following large events.
• Upstream and downstream turbidities were typically less than 10 NTU, except following rainfall
events.
• Turbidity data at both locations indicate that turbidity is most strongly dependent on
photosynthetic microorganisms, rather than sediment transport.
• Downstream DO values and specific conductivities fluctuated opposite to each other.
Downstream DO concentrations were commonly less than 2.0 mg /I between July and
December, and commonly declined to near 0 mg /I.
• Upstream DO concentrations tended to be 3.0 mg /I or higher throughout the summer.
Impacts from Mine Dewatering Activities
Section 40 CFR 230.11(h) of the CWA and 15 A NCAC 02H.0506 requires that secondary impacts and
effects on the aquatic ecosystem be analyzed, including water quality standards and existing uses.
Therefore, MMM is required to fully and adequately assess the downstream impacts due to mine

dewatering activities and DWQ must take those impacts into consideration. The mine as proposed
cannot function independently from the dewatering wastewater discharge.
Predicted pH changes
Submitted technical memos by the applicant demonstrate how the proposed discharge will change the
aquatic environment and species present, especially in upper Blounts Creek. 7,8 The pH will change from
the current upstream range of 4.0 -5.5 to a predicted 6.3 -6.9.
Furthermore, the additional discharge of groundwater would be expected to dilute organic acids, which
could be expected to effectively inhibiting the acidification process (further affecting the pH beyond just
mixing). It is plausible that the resulting pH may be even higher than predicted.
The draft permit proposes to allow a discharge that is in direct violation of water quality standards.
As noted in 15A NCAC 0213.0211 (g) pH: shall be normal for the waters in the area, which generally shall
range between 6.0 and 9.0 except that swamp waters may have a pH as low as 4.3 if it is the result of
natural conditions.
The "best usage of waters" narrative "maintenance of biological integrity" standard 15A NCAC
213.0211(1) requires maintenance of "a balanced and indigenous community of organisms having species
composition, diversity, population densities and functional organization similar to that of reference
conditions." 15A NCAC 2B.0202(11).
DWQ cannot approve a permit that changes the species composition of a water that is not similar to
that of reference conditions. Therefore DWQ must deny the NPDES permit.
Aquatic Habitat Assessment
In order to determine downstream impacts to Blounts Creek aquatic habitat and water quality
standards, MMM hired Coastal Zone Resources, Inc. (CZR) to conduct a habitat assessment.9 Based on
this assessment, MMM stated in the 404 application that, "... no anadromous fish were observed during
the study.i10 They also concluded that the analysis "showed that the abundance and diversity of fish and
macrobenthic invertebrates was lower than expected, and that Blount's Creek was typical of an upper
drainage segment of a lower Coastal Plain freshwater system.""
PTRF demonstrates below that the habitat assessment was flawed in several ways.
- Regarding the methodology of the study, what is largely missing is the context of these findings
when compared to other, similar streams. This is particularly true for the fish assessment. The
macro invertebrate data is compared to some state standards, but the Biotic Integrity measures
are often designed for a single system and broadly applied. 12
Technical Memorandum. September 6, 2012. Stability, Flood, and Water Quality Analyses. Vanceboro Site, Martin
Marietta Materials, Craven and Beaufort Counties, North Carolina. Kimley -Horn and Associates, Inc.
8 Technical Memorandum to address potential direct and indirect effects on identified fish populations from
predicted changes in Blounts creek water quality. October 30, 2012. CZR Incorporated.
9 Appendix D of MMM 404 permit application: Aquatic habitat assessment of the upper headwaters of Blounts
Creek in the vicinity of the potential quarry site near Vanceboro, Beaufort County, NC. CZR, Inc. August, 2011.
10 See page 15 of the Section4041ndividual Permit application supporting document.
11 Id.
12 Email communication with Dr. David Kimmel, Assistant Professor, Dept. of Biology, East Carolina University.

Regarding the Jaccard index and the Morisita Horn indices: both are fairly standard techniques
to measure similarity. It would be useful to measure a stream that is similar to provide more
information on what the differences outside of the system might be. For example, these
systems may already be degraded in some way or may be exceptional habitat. 13
The data demonstrates a lower pH and it is common that a lower natural pH for coastal streams
will often predispose the taxa towards lower diversity. 14 Therefore MMM cannot correlate this
data with the statement that abundance of fish and macroinvertbrates does not indicate a high
quality system."
With regards to this statement found in the analysis, "The Jaccard index indicated that although
UT2 had the most species in common with Blounts Creek ( 0 75) the Morisita Horn index
indicated that UT2 was more similar to UT1 in terms of community overlap (0 79) (Table 4) on
page 8 ": these comparisons are probably meaningless unless compared to some known
distribution or diversity of these streams. 16
Regarding statement in 4.2 fish on page 14: "Overall both species richness and total abundance
were relatively low for both impact and control monitoring locations. ": This statement lacks
meaning as this data is not compared to a standard or other stream control site. It is unclear
here what is meant by low, it has to be qualified by comparison to some standard or other
stream. These numbers may appear low, but may be natural for these systems. Also, the fish
numbers reported are absolute numbers and do not incorporate the effort it took to collect
them. 17
The study was conducted on only one day in April 2011. With the methods used for collection,
young of year of anadromous species should be sampled in June or July. The sampling took
place too early in the year to provide meaningful data as to the presence of these species. 18
In order to more clearly capture the actual fish communities inhabiting the creek, at a minimum
seasonal sampling should have occurred (3 -4 times over the period of one year) and over a 2-
day period /monitoring trip. 19
Hydraulic assessment of receiving streams
MMM's consultant Kimley -Horn and Associates, Inc. conducted a hydraulic assessment of the proposed
receiving streams in Upper Blounts Creek.20The assessment provided data for a proposed build -out
discharge of 12 MGD on the structural stability of the downstream receiving waters. The assessment
noted that for 3 of the 4 channels analyzed, the addition of the 12 MGD or 18.6 cfs would produce flows
that equal or exceed the bankfull discharge. Bankfull flows normally experienced by these streams may
occur several times each year, but only for a few days in duration, not continuously throughout the
13 id
14 id
15 See page 15 of the Section4041ndividual Permit application supporting document.
16 id
17 id
18 Personal communication with Dr. Anthony Overton, Assistant Professor, Dept. of Biology, ECU. December 20,
2011.
19 id
20 Appendix C of 404 application. Technical Memorandum: Geomorphic and hydraulic analysis for the proposed
built -out dewatering discharge. July 2010. Kimley -Horn and Associates, Inc.

year. 21 It is plausible that the UT segments may respond to this large increase in continual discharge by
widening and deepening, even if flow is less than bankfull. 221f the deepening occurs then the slope will
increase and a knickpoint will develop that would result in erosion that occurs and the knickpoint would
migrate upstream. 23 Furthermore, any deepening or channelization that occurs due to discharge of
mine wastewater will lower the functioning of the floodplain and may result in greater flooding
downstream. 241f channels are channelized they may have steeper banks than is normal and if greater
discharge is added those banks may have a tendency to slump and the bank material may add sediment
to downstream segments . 25
While the difference between current and expected shears may appear small, the shear would more
than double in magnitude. This will likely lead to stream channel erosion in the upper headwaters.
Channel erosion may not be limited only to the discharged channel. If down cutting of the main channel
occurs, then head cuts may form where tributaries join, leading to down cutting within tributaries.
One inaccuracy noted in the report is that bankfull flooding is estimated to occur every 1.1 -1.3 years.
However, the numbers used are for streams in Piedmont and Mountain settings and are too high for the
Coastal Plain .26 A paper by Sweet and Geratz 27 notes that bankfull flooding for similar NC Coastal Plain
streams occurs several times a year.
This change in stream velocity and flow will likely result in significant deposition of eroded material to
occur immediately upstream of the NS railway (PTRF /ECU Upstream monitoring station). Sedimentation
will cover up habitats while scour will displace and destroy habitat.
Wastewater Discharge Variability
The Division of Water Resources has groundwater pumping amounts for several other Martin Marietta
Mines in eastern North Carolina available on their website. 28 Looking at data for the Clarks Quarry in
New Bern, the Onslow Quarry in Richlands and the Belgrade Quarry near Maysville, one will note that
pumping amounts and the number of days pumping may be highly variable. Such variability may result
in pH values that shift up and down, thereby impacting aquatic species present. Furthermore, steady or
variable discharge could significantly alter the hydrologic regime of the headwaters, which appears to be
stagnant for much of the time, outside of significant rainfall events.
Salinity Changes
For a discharge rate of 12 mgd, upstream migration of brackish water in the Herring Run area that
results from low rainfall or wind tides would likely become less frequent. As observed in our monitoring,
21 Email communication with Dr. Michael O'Driscoll, Assistant Professor, Geology Dept. ECU and Dr. Scott Lecce,
Professor, Dept. of Geography, ECU.
22 id
23 Id.
24 Email communication with Dr. Michael O'Driscoll, Assistant Professor, Geology Dept. ECU
25 id
26 Id
27 Sweet, W.V. and J.W. Geratz. 2003. BANKFULL HYDRAULIC GEOMETRY RELATIONSHIPS AND RECURRENCE
INTERVALS FOR NORTH CAROLINA'S COASTAL PLAIN. Journal of the American Water Resources Association
39(4):861 -871.
28 http: / /www.ncwater.org/ Permits_ and_ Registration/ Capacity_ Use /Central_Coastal_Plain /ccpcualist.php

salinities increased over extended periods, from a several days (early July) to several weeks (October —
December). Diffusion and diurnal fluctuation of flows are likely significant processes that control
salinities near Herring Run. The salinity modeling did not take diffusion and tidally controlled flows, and
used data from two days for validation. Our downstream monitoring station is approximately 0.5 miles
downstream of Herring Run. The measured and predicted salinities produced by MMM show a range of
approximately 1.5 (surface) to 4.0 (10 ft. depth). At a depth 2 -3 ft. below the surface, monitored
salinities typically ranged from 4 to 11 ppt between June 2012 and January 2013.
The evaluation of salinity impacts downstream also do not take into account fluctuating salinities of the
Pamlico River, the salinity source for Blounts Creek. Historical records of this are available from NCDWQ.
Impact to SAVs
The increase in flow will most likely result in additional nutrient export downstream. This may yield
more phytoplankton production in the receiving waters, which affects the light field for the seagrasses.
Combined with the likely increase in sediment delivery, suitable habitat for Submerged Aquatic
Vegetation (SAV), documented in Blounts Creek, will be negatively impacted. These plausible increases
in turbidity and chlorophyll a combine to severely reduce seagrass habitat, thereby negatively impacting
fishery habitat.29
Future Impact of Mine Closure
Various aspects of how the stream ecology will respond to the proposed discharge in Blounts Creek
were evaluated. However, the future impacts when the mine ceases to operate (20 -30 years in the
future) were not addressed or discussed. If freshwater replaces brackish water (or high pH replaces low
pH), organisms and vegetation will be expected to adapt over several decades. However, the conditions
would be expected to return to their current state, which could lead to loss of vegetation and habitat as
organisms adjust to what are characterized as harsher conditions.
Alternatives
MMM has not demonstrated that no practicable alternatives exist or that the proposed impacts will not
lead to water quality standard violations or remove or degrade existing uses. 15 A NCAC 02H.0506
requires that avoidance and minimization of impacts must include consideration of the downstream
impacts due to the mine dewatering discharge. In light of this, PTRF believes that possible other
alternatives relating to the mine dewatering discharge should have been analyzed. Such alternatives
may include:
- Depressurization wells that could then re- inject all or a portion of the groundwater to avoid or
minimize impacts via wastewater discharge and groundwater withdrawal and drawdown. Such an
alternative would require re- injection of only groundwater, as injection of wastewater (i.e. from the
open mine pit) is not allowable under North Carolina rules and statutes.
29 Biber, P.D., Gallegos, C.L. and W.J. Kenworthy. 2008. Calibration of a Bio- optical Model in the North River,
North Carolina (Albemarle — Pamlico Sound): A Tool to Evaluate Water Quality Impacts on Seagrasses. Estuaries and
Coasts: J CERF (2008) 31:177 -191

Connection to local water supply for all or a portion of the groundwater.
Other alternatives that would avoid or minimize the discharge of wastewater to Blounts Creek (or
other creek systems).
Mitigation
Mitigation ratios are established in order to provide a margin of error due to the fact that restoration
efforts are not 100% successful and functional replacement requires a significant amount of lag time.
Furthermore, the Corps and EPA have noted that certain types of wetlands, especially hardwood forest
wetlands, require a much higher mitigation ratio than 1:1. The information included in the application
notes that some historic man -made alteration of soils and hydrology has occurred to the depressional
hardwood wetlands proposed to be impacted by the mine. None the less, hardwood wetlands typically
require a mitigation ratio greater than 1:1 and if permitted, PTRF proposes that a 2:1 ratio would be a
more appropriate mitigation ratio for hardwood wetland impacts based on the reasons cited above.
Monitoring
As noted above, PTRF believes that the NPDES permit cannot be approved since it is a clear violation of
water quality standards. However, should the project ultimately be permitted, PTRF recommends the
following monitoring requirements beyond what DWQ has incorporated in the draft NPDES permit for
benthic monitoring:
- Erosion pins placed at several locations downstream of the discharge location and at a control site.
The control site, pin locations, and number to be determined in consultation with DWQ and the
Corps. If erosion exceeding the control site occurs, we request the Corps to re -open the permit and
require additional measures to minimize further impacts to the downstream area as well as
additional compensatory mitigation for stream impacts.
- Water Quality sampling including but not limited to the following parameters: nitrate /nitrite, total
phosphorus, ammonia, TKN, TON and TIN, pH, salinity, dissolved oxygen, TSS, and turbidity.
Monitoring should occur on a monthly basis for a period of 2 years to establish baseline data, then
quarterly. Monthly monitoring would again be required once MMM has reached its maximum
discharge (approximated to be 9 MGD) for a period of 2 years, then quarterly until the discharge is
ceased permanently.
In summary, PTRF requests the denial of the NPDES permit and 401 water quality certification based on
the fact the proposed discharge violates water quality standards. We also argue that MMM has not met
the requirement for a Section 401 Certification and therefore ask that DWQ deny the certification
request.
We appreciate the opportunity to comment in the proposed project.
Sincerely,
9" �� Ux._

Heather Deck
Pamlico -Tar Riverkeeper
Pamlico -Tar River Foundation
Cc: Karen Higgins, NC Division of Water Quality
Kevin Hart, NC Division of Marine Fisheries
David Cox, NC Wildlife Resource Commission

Appendix A
BLOUNTS CREEK MONITORING
PRELIMINARY DRAFT REPORT
METHODS
Monitoring Sites
Monitoring on Blounts Creek was conducted at two sites, referred to as Upstream and Downstream
(Figure 1). Sites were monitored from June 7, 2012 to January 18, 2013. Monitoring equipment at each
location was protected by a polyvinyl chloride (PVC) housing that allowed water to freely flow around
sensors.
Figure 1. Locations of monitoring sites on Blounts Creek.

Upstream Site
The upstream site was located approximately one half mile east of Norman Road, immediately upstream
of the Norfolk Southern (NS) Railway crossing. At this location, Blounts Creek is divided into two
channels that intersect downstream of the bridge. This location is approximately 8 miles upstream from
the mouth and is located near CZR's WQ1 water quality sampling location. It was selected since it should
be minimally affected by backwater from downstream flow conditions. Thus, measured values should be
influenced greatest by nearby upstream water quality. The site was also the furthest upstream location
on Blounts Creek, accessible without using private roadways. The site was accessible by foot via the NS
Railway.
An YSI 6920 -V2 -1 Sonde (Upstream sonde) was programmed to record data measurements at 30- minute
intervals. An Onset Hobo U20 Water Level Data Logger (referred to as pressure logger here after) was
deployed along with the Upstream sonde. The sonde and pressure logger were housed in a PVC housing
that was secured to the streambed with rebar and heavy gauge wire. Another pressure logger was
suspended from a nearby tree branch to record atmospheric pressure. The pressure loggers were
programmed to collect data every 15 minutes.
Downstream Site
The Downstream monitoring site was located approximately 4,400 feet downstream of Herring Run and
approximately 300 feet upstream of Nancy Run on Blounts Creek. The PVC housing was mounted to a
pylon support of a private dock (permission granted for monitoring). This site was selected due to its
downstream proximity to Blounts Creek's confluence with Herring Run, while being located upstream of
the Nancy Run confluence. Due to the access agreement, this site was only accessible for monitoring via
Blounts Creek.
An YSI 6920 -V2 -2 Sonde (Downstream sonde) was installed at this site and programmed to record data
measurements at 30- minute intervals. The sonde installation was approximately 4.5 to 5 feet above the
streambed. A pressure logger was attached to the PVC housing cap to record atmospheric pressure and
programmed to record data at 15- minute intervals.
Water Depth
The Hobo U20 Water Level Data Loggers do not directly measure water levels. Instead it measures and
records absolute pressure and temperature of the surrounding environment, which can be used to
calculate water depth.
The absolute pressure below a water surface (P) is the sum of the atmospheric pressure (Po) and the
hydraulic pressure of the water, atmospheric pressure must be subtracted from absolute pressure to
determine the hydraulic pressure. The hydraulic pressure is directly proportional to water depth (D),
which can be calculated by:
D _ (P—Po)
P9

where P is the submerged absolute pressure, Po is the atmospheric absolute pressure, p is the density of
water, and g is the gravity constant. Densities were calculated from water temperature and salinity
measurements using standard equations (McCutcheon et al, 1993).
Only an atmospheric pressure logger was required for determining Downstream water levels, since the
Downstream sonde included a built in pressure sensor. However, the Upstream sonde did not include a
pressure sensor, and therefore two pressure loggers were required to record water level data.
Downstream data were initially (June 7 through 11) assumed to be suitable for estimating Upstream
atmospheric pressures and determining water depths. However, the pressure differences were found to
be significant and an Upstream atmospheric pressure logger was deployed on June 21. Subsequent
water depths referenced the Upstream atmospheric pressure data.
Upstream flows were intended to be estimated from a rating curve developed from multiple flow
surveys for the Upstream location. However, with depths up to X, all flow velocity measurements were
less than 0.3 feet per second. Downstream flow was not recorded during this study due to a lack of
appropriate monitoring equipment.
Temperature
Each sonde was equipped with an YSI Conductivity /Temperature probe (6560) for recording water
temperatures at 30- minute intervals. In addition, the U20 pressure loggers also recorded temperature
measurements at 15- minute intervals, providing atmospheric temperatures at both locations and a
secondary Upstream submerged temperature data record.
Conductivity and Salinity
The YSI Conductivity /Temperature (CT) probe measured water temperature and resistance which were
used by the sonde to calculate conductivities, specific conductivities, and salinities. The CT probe directly
measures resistance and temperature of the sampled water volume. The sonde calculates conductance
(mS /cm) as the inverse of resistance. Since conductance varies based on solution temperature, the
sonde calculates the solution's specific conductivity (µS /cm), or the equivalent conductance for the
solution at 25 °C. This allows for temperature independent measures of ion concentration. Salinity is a
metric used for classifying water bodies that quantifies the amount of salt in a solution (ppt). The sonde
calculates specific conductivity and salinity from conductance values and temperatures using standard
methods (Rice et al., 2012).
Dissolved Oxygen
Each sonde used an YSI Rapid Pulse Dissolved Oxygen (DO) Sensor (6562) for measuring dissolved
oxygen (mg 0/1). The DO sensor measures the electrical current required to reduce oxygen that has
diffused through a Teflon membrane into a potassium chloride solution. This electrical current is
proportional to the DO concentration of the solution outside of the membrane. The sonde auto
calculates the percent DO saturation from water temperature, salinity, and atmospheric pressure at
calibration.

Turbidity
Each sonde used an YSI Turbidity Sensor (6136) for measuring turbidity (NTUs). The optical turbidity
sensors measure the amount of light emitted by the sensor that reflects off suspended particles and
back to the sensor. Since the sampling volume for these sensors are very small, large particles can
occasionally produce non - representative values that can be orders of magnitude greater than previous
and subsequent values. Outlier values, those an order of magnitude or greater than adjacent values,
were replaced by the average of the previous ( -30 minute) and subsequent ( +30 minute) measured
turbidity values.
Sonde Maintenance
Data were downloaded from the sondes and pressure loggers approximately every three to four weeks.
All data were collected and stored and backed up on ECU network space. The sondes were extracted
from their housings at these times for cleaning and sensor recalibrations at ECU's Coastal Water
Resource Center. Calibrations were performed with standard solutions and following procedures
outlined in the YSI User Manual (YSI, 2011). To inhibit bio- fouling, an anti - microbial paste (Desitin ®) was
applied to the sonde guard after each calibration. In addition, sonde bodies were wrapped in plastic
wrapping, except around pressure sensor openings on the downstream V2 -2. Sondes were then
redeployed as soon as feasible, typically within one to three days.
Water Quality Grab Samples
Water quality grab samples were collected approximately twice per month at the Upstream and
Downstream sites (Table 1). Environment 1, Inc., an analytical laboratory in Greenville, NC, provided
sealed coolers and sealed containers for sample collection. Samples were collected near the surface of
the water column. Samples were placed in the cooler, iced, and delivered to Environment 1, where they
were released to the lab for analysis. All samples were delivered to Environment 1 on the same day as
collection, except for July 18 samples. Samples were collected on July 18, but could not be delivered to
Environment 1 before close of business. Samples remained on ice and in the possession of the ECU
student collector until the samples were delivered the following morning (July 19).
Samples were analyzed for Turbidity (NTU; NEMI: 2130B), and Conductivity (µS /cm; NEMI: 2510B) for
validation of monitoring data. Samples were analyzed for pH (unitless; NEMI: 4500 -H +B) and Total
Suspended Residue (mg /I; NEMI: 2540D) since these parameters are significant indicators of overall
water quality and were not continuously monitored. While values for pH were not to be used for
reporting, they are included as a reference in this report. To supplement Environment 1's data, ECU
began measuring pH using a Hanna Instruments pH meter during each site visit after September 19.
Beginning on November 8, a local volunteer also began measuring pH every one to two weeks at each
monitoring site.

Table 1. Dates of grab sample collections.
Month
Day
June
25
July
2, 12, 18
August
6
September
7, 30, 27
October
25
November
1, 27
December
13
Weather Data
Daily precipitation totals (Global Summary of the Day) during the monitoring period were retrieved from
the National Climatic Data Center website for two closest weather stations to the study area,
Washington, NC: 10.5 ESE (GHCND: USINCBF004) and New Bern, NC: Craven County Regional (GHCND:
USW00093719). The Washington station was approximately 8 miles northeast of the Downstream site,
while the New Bern station was approximately 24 miles south - southwest of the Upstream site.
Hourly wind data (velocity and direction) were also collected from the New Bern station (USAF WBAN
ID: 72309593719). Warren Field (Washington, NC; USAF WBAN ID: 74692503741), approximately 13
miles northwest of the Downstream site, also provided hourly wind data for the monitoring period.
Hourly wind speeds were averaged for each day to determine the daily average wind speed. Average
wind directions were calculated as the speed weighted average of the hourly wind directions values for
each day.
Water Quality Surveys
Three water quality surveys were performed during the monitoring period. For each survey, the
Downstream sonde was extracted from its housing, the data sampling interval was changed to one
minute, and the internal clock was synchronized with a Garmin hand -held Global Positioning System
(GPS) unit that logged the position each minute. The sonde was submerged alongside a boat and towed
over a length of the creek. Water quality data were then geo- located using the corresponding
coordinates and time stamps from the GPS unit.

Appendix B: Monitoring Data
7.00
Depth: Observed
Depth. 24 h avg.
6.04
5.00
r
4.00
c�
E
ar
3.00
Q
MINIMUM ME,ASUREABLE WATER LEVEL: 1.4 fl.
1.00
0 00

TOO
6.00
gm
4.00
3,00
W■
Loo
0.00
Date (M/D/YY)

7.00
Depth: Observed
• Depth: 24 h avg.
6.00
...............
500
a
%
4.00
E
0 3.00
MINIMUM MEASUREABLE WATER LEVEL: 3.0ft.
2.00
............... ...............
1.00
0.00
7/1 7/6
7/11 7/16 7/21
7/26 7/31
ME
ME
5.00
4.00
E
100
04A
W70,
rim,
Date (M/D/YY)

7.00
Depth: Observed
® Depth: 24 h avg.
6.00
6
5.00
r
4.00
s
to revs
E
0 3.00
MINIMUM MEASUREABLE WATER LEVEL:'3.Oft.
2.00
1.00
0.00
8/1
8/6 8/11 8/16
8/21
8/26 8/31
Date (M /D /YY)
7.00
Depth: Observed
Depth: 24 h avg.
6.00
5.00
4.00
g
.00
�
2.00
s �
MINIMUM MEASUREABLE WATER LEVEL: 1.4 ft.
1.00
0.00

7.00
Depth: Observed
• Depth: 24 h avg.
6.00
5.00
4.00
E
CO 3.00
MINIMUM MEASUREABLE WATER LEVEL:
3. ft.
2.00
1.00
...............
........... .......................................................................................................
0.00
9/1 9/6
9/11
9/16
9/21
9/26
k9*141
6,00
5.00
4.00
E
3.00
P"o
Loo
0.00
Date (M/D/YY)

7.00
Depth: Observed
Depth: 24 h avg.
6.00
5.00
Y %
v
4.00
E
3.00
00
MINIMUM MEASUREABLE
WATER LEVEL: 3. ft.
2.00
1.00
0.00
.........................................................
10/1
10/6
10/11 10/16
10/21 10/26
7.00
. ill,
to
4.00
E
3.00
2.00
1,00
0.00
Date (M/D/YY)

7.00
Depth: Observed
. Depth: 24 h avg.
6.004
r
a
5.00 _A
a
• m
p`a
� �
sr � "E '•
4.00
.......
E
c
3
0 3.00
MINIMUM MEASURER
LE WATER LEVEL: 3. ft.
2.00
1.00
0.00
11/1
11/6
11/11
11/16 11/21
11/26
Date (M /D /YY)
7.00
Depth: Observed
Depth: 24 h avg
6.00
S,Oq
S4.00
e�
3.00
2.00
MINIMUM MEASUREABLE WATER LEVEL: 1.4 ft.
1.00
0.00

7.00
Depth. Observed
® Depth: 24 h avg.
6.00
.,
i
A
5.00
�
� a
a
.e °.
•
4.00
..
E
a to
�.c
0 3..00
MINIMUM
MEASUREABLE WATER LEVEL:'3.Oft.
2.00
1.00
0.00
12/1
12/6 12/11
12/16 12/21
12/26 12/31
Date (M /D /YY)

7,00
6,00
5.00
4.00
3.00
ez
2.00
LOO
0.00
7.0,0
6,04
5.00
a
4,04
E
c
it
00 3.00
2,04
1,0()
0J)o
1/1 1/6 1111 1116 1,121 1/26 1131
Date (MID/'YY)

130
120
110
100
Wo
a
Z3 80
as
a
E
9 70
E
a
50
50
40
30
20
130
120
110
100
90
80
r
°v 70
w
c
Q 60
50
40
30
20 1
6/1/12
6/6/12 6/11/12 6/16/12 6/21/12 6/26/12
Date (M /D /YY)

130
120
110
100
90
v
80
M
Q
a
70
E
v
0 60
50
40
30
20
130
120
110
100
LL
4v 90
Q 80
E
9
E
v 70
,n
C
3
CO 60
50
40
30
20
8/1/12
8/6/12 8/11/12 8/16/12 8/21/12 8/26/12 8/31/12
Date (M /D /YY)

130
Upstream Surface (Hobo)
Upstream Subsurface (Hobo)
120
Upstream Subsurface (Sonde)
110
100
94
v
s0
ro
Q
E
70
E
ro
v
0 60
_
54
ww t 'w
%mow
t r
.
,
40
30
u
20
130
Downstream Surface (Hobo)
Downstream Subsurface (Sonde)
124
114
140
v 90
v
a $0
a
__ P
t e
a
`
ro74
r ......... e....... .
......... ... .... °
q
t
0 64
;.. $ _.. ....
x ...... ..
54
®� s
a
t
44
1
.
34_.
20
11/1/12 11/6/12 11/11/12
11/16/12 11/21/12 11/26/12
Date (M /D /YY)

130
120
110
100
90
v
ro
80
a
E
F 70
E
v
0 60
50
40
30
20
130
120
110
100
v 90
ro
&0
E
E
w 70
3
0 60
50
40
30
20
12/1/12
12/6/12 12/11/12 12/16/12 12/21/12 12/26/12 12/31/12
Date (M /D /YY)

134
124
114
144
44
$4
u�
E
74
E
ro
as
64
54
44
30
24
130
Downstream Surface (Hobo)
Downstream Subsurface (Sonde)
120
114
100
v
90
Q g4 P
E _ r
r
ro74 ......................................................
no 60 1 ',� && ..._g
� as a AAA
^ as
i g
54 s`
44 _a
30 `i
'r
20
1/1/13 1/6/13 1/11/13 1/16/13 1/21/13 1/26/13 1/31/13
Date (M /D /W)

wwo,
ww,
0.16
0,14
E
0,12
0 0110
u
U
U
0.08
E
0.06
0,G4
0.02
0.00
20.00
18.00
16.00
14.00
E
12.00
u
0
U 10.00
U
8.00
ro
6.00
4.00
2.00
0.00
6/1/12 6/6/12 6/11/12 6/16/12 6/21/12 6/26/12
Date (M/D/YY)

rowil
0.18
lop,
E
0.14
u
zi.
E
0.12
L L 0.10 j
u
u
411
,0,08
Dn- 0.06
0.04
0.02
0.00
20.00
18.00
16.00
E
14.00
yr
E
> 12.00
10.00
V)
E 8-00
6.00
cl
4.00
2.00
0.00
7/1/12 7/6/12 7/11/12 7/16/12 7/21/12 7/26/12 7/31/12
Date (M/D/YY)

wwo,
ww,
0.16
0,14
E
0,12
/0110
u
0.08
E
0.06
mom
mm
LIM

0.20
mm
0.16
If 014
E
0.12
UO 0110
u
u
IV
0.08
E
dJ
0106
0.04
0,02
OM
20.00
18.00
16.00
E
u 14.00
-0�
E
12.00
u
_0
0
U 10.00
u
0)
vl
E 8.00
em
6.00
4.00
2.00
0.00
9/l/12
9/6/12 9/11/12 9/16/12 9/21/12 9/26/12
Date (M/D/YY)

0.20
Upstream Specific Conductivity (Grab Samples)
Upstream Specific Conductivity (Raw)
0.119
Upstream Specific Conductivity (24 h avg.)
0.115
E 0.14
U
E
Downstream Specific Conductivity (Raw)
0.12
c.
0 0.10
18.00
0.08
E
X0.45
NO MONITORING DATA COLLECTED:
LOW WATER LEVELS AND EQUIPMENT ERROR
0.04
0,02
0.00
MOD
Downstream Specific Conductivity (Grab Samples)
Downstream Specific Conductivity (Raw)
18.00
• Downstream Specific Conductivity (24 h avg.)
16M
E
14.00
E
Z�
1100
Q 10.00
E 8.00
dj
6.00
0
4.00
2.00
OM
10/1/12 10/6/12 10/11/12 10/16/12
10/21/12 10/26/12
10/31/12
Date (M/D/YY)

00
0. 18
[Intl
E 0.14
u
0.12
Uo 0.10
U
Q]
Q�
� OM
E
0
:0-0.06
0.04
LIM
0 Upstream Specific Conductivity (Grab Samples)
Upstream Specific Conductivity (Raw)
Upstream Specific Conductivity (24 h avg,)
NO MONITORING DATA COLLECTED:
LOW WATER LEVELS AND EQUIPMENT ERROR
0.00
20.00
4, Downstream Specific Conductivity (Grab Samples)
Downstream Specific Conductivity (Raw)
18.00
Downstream Specific Conductivity (24 h avg.)
16.00
U14.00 14.00
D7
12.00
0
iv
U 10.00
U
U
CL
E 8-00
6.00
4.00
2.00
0.00
11/1/12
11/6/12 11/11/12
11/16/12
11/21/12 11/26/12
Date (M/D/YY)

HE
IMM
016
E� 0, 14
E
0,12
UO 0110
U
tl
OM
E
ro
:CL 0,06
0,04
M
[Billie]
20.00
18.00
V
16.00
E
14.00
E Downstream Specific Conductivity (Grab Samples)
12.00 Downstream Specific Conductivity (Raw)
u
Downstream Specific Conductivity (24 h avg.)
0
10.00 ............... ...............
E 8-00
3: 6.00
0
4.00
ss
2.00
0.00
12/1/12 12/6/12 12/11/12 12/16/12 12/21/12 12/26/12 12/31/12
Date (M/D/YY)

U
Z�r
E
0120
0.18
0.16
0.14
0.12
UO OAO
E
0,06
0.04
0,02
Me
20.00
0 Downstream Specific Conductivity (Grab Samples)
18.00 Downstream Specific Conductivity (Raw)
Downstream Specific Conductivity (24 In avg.)
16.00
E
u 14.00
Jil
E
12.00
u
U 10.00
_U
U
N
E 8.00
M
�U
3 6.00
4.00
2.00 k ............
0.00 7
1/1/13 1/6/13 1/11/13 1/16/13 1/21/13 1/26/13 1/31/13
Date (M/D/YY)

ROTIEN
ace
m
7.00
cQj
6.00
0
5.00
0
E 4.00
3.00
2.00
LOO
(100
12.00
10.00
E txo
8.00
O
6.00
E
3: 4.00
0
cl
2.00
0.00
6/1/12
6/6/12 6/11/12 6/16/12 6/21/12 6/26/12
Date (M/D/YY)

10.00
ME
Ms
7.00
ca
E
E00
�2
0
5.00
o
E 4M
3.00
2.00
1.00
0.010
12M
10.00
al
0
&00
E
4,00
0
0
2.04
0.010
7/1112 716/12 7111Y12
Upstream Dissolved Oxygen (Raw)
Upstream Dissolved Oxygen (24 h avg.)
ry
Y f Jp
"A
7/16112 7121112 7126Y12 7131112
Date (M/D/YY)

10.00
Upstream Dissolved Oxygen (Raw)
Upstream Dissolved Oxygen (24 h avg.)
4.00
8.00
7.00
a
.....
m
v 6.00
a
a
ti
v 5.00
E 4.00
3.00
2.00
x
1.00
n
0.00
12.00
Downstream Dissolved Oxygen (Raw)
® Downstream Dissolved Oxygen (24 h avg.)
10.00
ti
E 8.00
X
O
v
6 6.00
v
C
it 4.00
q
m
s
2.00
..
0.00
r ..
8/1/12
8/6/12
8/11/12 8/16/12
8/21/12 8/26/12 8/31/12
Date (M /D /W)

o M
9.60
M
7.00
E
6.00
sin
a
5.0,0
6
a
E 4.00
100
2,00
Loo
0.007
U00
10.00
l
c
air
is
0
as
E.00
E
a
e
4,07
0
E
4,017
9/1/12
Upstream Dissolved Oxygen (Raw)
Uipstrearn Disso4ved Oxygen (24 h avg.)
s „ ,
77"\
a y .
m.a
9/5/12 9/11112 9116/12 9/2.1/12 9126/12.
[late (M /D /YY)

10.00
Upstream Dissolved Oxygen (Raw)
Upstream Dissolved Oxygen (24 h avg.)
9.00
8,03
7.00
bu
a 6.003
Q
NO MONITORING DATA COLLECTED:
'5" 00 LOW WATER LEVELS AND EQUIPMENT ERROR
E4.00
a
3,00
2.(J0
1,009
0,4'0

R-11ST61
w M,
mm
-TOO
E
6.00
0
7&A
0
E 4.00
3,00
2 M
Loo
OLD
12.00
i 01fif
al
0
&00
E
4,00
m M$o
roffics
12 Z :2 IIY6112 I2II112 I IY 16/12 IIY21112 1226/12
Date (M/D/YY)

10.00
Upstream Dissolved Oxygen (Raw)
Upstream Dissolved Oxygen (24 h avg.)
9.00
...............
8.00
...............
7.00
6.00
...............
0
> 5.00
24.00
A
............... . ...... .
J, N-k
Ar
3.00
2.00
1.00
0.00

10000
Fm
101
14
w
..
rr
z
ME
E
0.1
511/12 516/12 5/11112 6116112 6/21/12 6126/12
Date (M /p /YY)

10000
u
100
E
m
10
0.1
Date (M /D /W)

10000
mm
100
14
Lim
Date (M /D /YY)

10000
Upstream Turbidity (Grab Samples)
Upstream Turbidity (Raw)
Upstream Turbidity (24 h avg.)
1000
ff
100
o
E
10
v;

10000
oi,
100
E
B
10
o,1
Date (M /D /YY)

10000
ifulrox
Ic"
E
us
10
0.1
1000
*Downstream Turbidity (Grab Samples)
Downstream Turbidity (Raw)
Downstream Turbidity (24 h avg.)
100
F-
Z
,210
E
o
0.1
11/1/12 11/6/12 11/11/12 11/16/12 11/21/12 11/26/12
Date (M/D/YY)

1001
101
a
Zak
E
Q.1
12/l/12 12/6/12 12/11/12
12/16/12 12/21/12 12/26/12 12/31/12

10000
om
100
14
w
m
i
z
ME
0.1
1/1/13 1/6/13 1/11/13 1/16/13 1/21/13 1/26/13 1/31/13
Date (M/D /YY)

3.50
3.00
2.50
c
0
% 2.00
'i 1.50
a
m
1.00
0.50
0.00
6/1/12
Appendix 13: Nearby Daily Weather Data
6/6/12 6/11/12 6/16/12
Date (MM/D/Y'Y)
6/21/12 6/26/12
150 13
11MWashIngtan,
NC; 10.5 E 5 E G H C N D U 5 1 N C IF 00 4
New Bern, NC: Craven County Regional Airport (GHCND:US---]
8
3.041
2.50
r
0
2DO
M -L.5U
1,00
0,50
0.0',
7/1/12 7/6/12 7/11/12 7/16/12 7/21/12 7/26/12 7/31/12
Date (MM/D/YY)

3.5+0, -
�■Washington., NC: 10.5 ESE (GHCND USINCBF004)
El New Bern, NC. Craven County Regional airport (GHCND U5W00093719)
3.00
2.50
a
a
A 1.50 —
a
LOU
0.50
0.00
8/1/12 816112 8111/12 8116/12 8/21/12 8/26/12 8/3.1/12
Date (INi4 /D /YY)

3.50
■ Washington, NC: 10.5 ESE (GHCND:USINCBF004)
* New Bern, NC: Craven County RegsanaV Airport (GHCND:USWO00'93719)
3.00
2..50
E
c
g 2.00
2
R 1.50
d
m
1.00
0.50
OLD
10/1/12 10/5112 10/11/12 10/16/12 10/21/12 10/26/12 10/31/12
Date (MM /D/YY)
3.50
■ Washington, NC: 10.5 ESE (GHCND:USINCBF004)
0 New Bern, NC: Craven County RegsanaV Airport (GHCND:UStWO00'93719)
3.00
MO
0
c 2-00
2
a?
R 1.50
d I I
1.00
0.50
OLD
11/1/12 11/6/12 11/11/12 11116/12 11/21/12 11125/12
Date (M M /D/YY)

3.50
■ Washington, NC: 10.5 ESE (GHCND:USINCBF004)
* New Bern, NC: Craven County RegsanaV Airport (GHCND:UStWO0093719)
3.4147
2.517
E
c
0
g 2.01Cb
2
a?
a
R 1.5(D
d
m
LGO
C3.5t3
OLD Jan t 11
12/1/12 12/5%12 12/11/12 12116/12 12/21/12 12/26112 12/31/12
Date (MM %D/YY)
3.50
■ Washington, NC: 10.5 ESE (GHCND:USINCBF004)
* New Bern, NC: Craven County RegsanaV Airport (GHCND:U51+J�tiQ93719}
3.4747
2.517
E
c
g 2.01Cb
2
a?
R 1.5(D
d
LGO
C3.5t3
am —
1/1/13 1/6/13 1111/13 1/15/13 1/21/13 1/25/13 1/31/13
Date (M M %D/YY)

AVERAGE DAILY WIND DIRECTION AND SPEED
a Speed (WBAN:03741) Fj Speed (WBAN:93719) ■ Direction (WBAN:03741)
4 Direction (WBAw 33719)
N 0
NE 45 4
4
E 9,0
■
C SE 135
t ■
a
5180 A
A A
■ 4 A 4
Q SW 225 A
a
W270
NW 315
N 360
20
'U
15
Qj
10
5
Ail
0
6/1./12 616/12 f,111112 (,/16/12 ("121112
612f"112
Date(M/D/YY)
■ Speed (WBAN:0374 1) 0 Speed (WBAN:93719) ■ Direction (WSANM741)
4, Direction (WBAN:93719)
NG --------------------- - -------------------------------------- ------------------------------------------------------ ---------------------------------------------------------------------------------------------
-
NE 45
E 90
C SE 135
2
A
t
S180 4
A
SW 225 A A
•
em
W270
NW 315
N 360
20
15
10
5
ni
0
1)1112 716112 7111,112 7/16/12 7121112
7/26/72 7131112
Date (M/D/YY)
*Data for Washington (WBAN:03741) and New Bern (WBAN: 93719) weather stations.

■ Speed (WBANM741)
0 Speed (WBAN:93719) A Direction (WBANM741)
A Direction (WBAN93719)
IN 0
NE 45
E 90
a
SE 135
.2 A
t
cr
S180 A
r
A
SW 225
W270
NW 315
N 360
20
15
10
5
lf�
Ll
ri
n, n
n
H
ri
n
ni
O
0
811/12 8/6/12
8111112 8116112 8121112
8126112 8131/12
Date (M/D/YY)

N Q,
---—-------------
NE 45
a
e E 90
e
cu
ea
SE 135
❑
n
a
.t
°
2
A 51801
C
°
SW 225
a e
A
GF
7
< w 270
T
NW 315
N 36®
A
20
aj
tll
C
G
15
1C
a'
5
d
_
c�
�7
911/1.2 916112
9/1.1112 9/16/7.2 9,121./12
9/26/12
Date (h f D/YY)
■Speed QWBAN:03741)
0Speed (WBAN:93719) A Direction (WBAN:93741)
e Direction (WBAW93719)
qy p
�
n
NE 45
a" E 9[i
SE 135
e
4
E
g S180
e1
SITU 225
d
W27(7
a
It
�S
NW 315
n
d
G
N 36©
20
C
6
c v
15
6
10
5
rl'd
d..,
0
1011.112 10116./12
101111/12 1011 ex,112 101121112
w/26/12 10/31/12
Date (M/D/YY)

Coate ( /D /1Y)
L_m Screed' (WBAN:03741)
❑Speed (WBAN:93719) ■ Direction (WBAN;03741)
d Direction (WBAN:93719)
NQ
— - --
- - -- - -..
_..— -- —
d
A.
NE 45
d
tl
E 90
d
SE 135
�
Q
t
A A
A
4
G
siso
C
QP SW225
° `
A as a
A
w 270
.F
A
d
A
d
A
NW 315
A
n
C
d
A
v N 360
A
d
24
aj
C
15
c
10
oil
5
C7.
Q
-
7.1.11.112 1.1 /6/12
1.111111.2. 1.1/16112 1.1121112
1112611.2
Crate ( /®/1'1)
■ Speed (WBANM741,)
❑Speed (WBAN:93719) A Direction (WBAN.Q3741)
d Direction (W3AN:93719)
N 1.7
.
NE 45
■
d
a
A
�
m E 90
L
'
A
d
c�
SE 135
s
A
A
a S180
A °
d
A
A
A
A A
A
y SW 225
_ A_ a
a A
w
s
W270
r
A
6
a
■ A
d
NW 315
�
d
N 360
®
20
171
d
15
C
10
5
d
—sit
o
Q
1111.112 12,16112'.
12/11112 12/16/12 11121111
12121112 12/31/12
Coate ( /D /1Y)

■ Speed (WBANM741) 0 Speed (WBAN:93719) A Direction (WBANM741) A Direction (WBAN93719)
IN 0
A A
NE 45
E 90 ► A
eq
SE 135
s
t
cr
S180
w SW 225 r A
4
W270
a A
NW 315
■
N 360 A 20
15
10
5
o 0
Date (M/D/YY)

Appendix C: Water Quality Surveys
Water Quality Survey: July 18, 2012
Kilometers Miles N
I 1 -1 1 1 i
0 O�2' 0.4 0 0 1 R.
Data Collected on OT1 8,2012 Using YS 16920 V2 Water Quality Sonde

Kilometers Mites
0 0-2 CIA 0 0-1 0-2
Data Collected on 071M2012 Using YSI 6920 V2 Water Quality Sonde

Kilometers Miles
0 0.2 0A 0 0.11 0.2
Data CoRected on O7/1812012 Using Y 16 20 V°2 Water Qualfty Sonde

Kilometers Miles
0 0,2 OA 0 0.1 0,2
Data Collected on OTII 812012 Using YSI 6920 V2 Water Quality Sonde

Kilometers Miles
0 0.2 OA 0 0.1 O2
Data Collected on OT18I2012 Using YS! 6920 V2 Water Quality Sonde

Water Quality Survey: October 9, 2012
Kilometers Miles IN
I I I I I I
0 1 2 0 0, 5
Data CoHected on 1 WOW2012 Uwg YSI 6920 V2 water Quahty Sonde

Kilometers Miles
0 1 2 0 0,5
Data Collected on 10109/2012 Using Y 6920 V2 Water Quality Sonde

Kilometers Miles
I I I I I
0 1 2 0 0.5
Data Collected on 101'09/2012 Using Y 6926 V2 Water Quality Sonde

Kilometers Miles
0 1 2 0 0,5
Data Collected on 10,t09/2012 Using YSI 6920 V2 Water Quality Sonde

Water Quality Survey: November 15, 2012
Kilometers Miles
0 1 2 0 O. 5
Data Collected on 1111512012 Using YSI 6920 V2 Water QuahtV Sonde

Kilometers Miles N
I I I I I I
0 1 2 0 0, 5
Data Conected on 10,0912012 Uwg YSI 6920 V2 water Quahty Sonde

Kilometers Miles
0 1 2 0 0.
Data Collected on 1111 12012 Using YSV 6920 V2Water Quality Sonde

Kilometers Miles
0 1 2 0 0.5
Data Collected on 11 /1 SM12. Us inn YSI 6920 V2 WnterOuafilv qonde

Kilometers Miles
0 1 2 0 0,5
Data Cotlected on 110512012 Using YSI 6920 V2 WaterQuahty Sonde