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Home My WebLink About20111013 Ver 2_Public Comments_20130328 (2)Strickland, Bev From: Karoly, Cyndi Sent: Thursday, March 28, 2013 3:38 PM To: Strickland, Bev Subject: FW: Written Comments - Vanceboro Quarry Project Attachments: Written Comments - Vanceboro Quarry.docx; BCCC Presentation.docx; P1010284.JPG; Picture 025.jpg; Hightide.jpg From: Bob Boulden [mailto:bbncltdCa)yahoo.com] Sent: Thursday, March 28, 2013 2:00 PM To: Adams, Amy; Belnick, Tom; Karoly, Cyndi Cc: aiattinaJim epa.aov; mitchell.michael(a)epa.Qov Subject: Written Comments - Vanceboro Quarry Project Hello Amy: This email and attachments are my written comments concerning the Vanceboro Quarry project. Regards - Bob March 28, 2013 TO: Amy Adams, Regional Office Supervisor, Surface Water Protection Section FROM: Captain Bob Boulden SUBJECT: Vanceboro Quarry Project Hello Amy: The comments (copy attached) I made at the Public Hearing are summarized below: • Local knowledge and common sense not used • Inadequate fish sampling data • Lack of definitive statements • No Environmental Impact Statement /bond posted • Change in wetlands /stream pH and flow • Discharge of aluminum to wetlands /creek • No data /discussion concerning temperature changes in the wetlands /creek • Not against the quarry, just direct discharge to Blounts Creek Please allow me to elaborate further on several of the topics as three minutes of speaking time did not allow me to address them fully. Also, I have a question — is the discharge to be 9,000,000 gpd or 12,000,000? I've seen both numbers mentioned and many of my comments are based on a flow of 9,000,000 gpd. FLOW Blounts Creek at the Tripp Road bridge (downstream side) is approximately 70 feet wide and 4.5 feet deep (see attached picture). If we take a 1 foot slice of the creek — this equals 2356 gallons of water. 9,000,000 gpd equals 6250 gpm. So, that 1 foot thick slice of creek is diluted /changed 2.65 times per minute with quarry discharge water. I do not understand how the data presented by Martin Marietta Materials, Inc. (MMM) supports minimal changes in flow characteristics of the creek. Additionally, Blounts Creek is significantly impacted by wind (see attached pictures of dock with no water near it and a boat dock nearly flooded — approximately 5 miles from quarry discharge outfalls). Winds blowing from the west remove large amounts of water from the creek, while easterly winds cause the creek to "flood ". These are not infrequent events! From the NOAA QCLCD data collected at Warren Field in Washington, NC for the first six months of 2012, there were 40 days of winds blowing from westerly quadrants that would have caused the water in the creek to be lower, and sometimes much lower than usual. Conversely, there were 12 days when the wind blew from easterly quadrants causing the level of the creek to rise above normal. In either case the discharge from the quarry impacts the creek more than usual. Less water in the creek — more flow velocity from the discharge carrying sediment further down the creek and potentially changing streambed contours, covering normally SAV and displacing fish and other wildlife. "Flooding" will float additional debris from normally "dry" areas near the wetlands /creek into the creek which can cover SAV as it settles to the creek bottom and increase turbidity. Also, as it decays it will use up dissolved oxygen in the creek. CHEMICAL DISCHARGES TO THE CREEK In addition to the 7 pounds of aluminum discharged to the creek daily, MMM data indicates we can also expect 2 pounds of vanadium, 2.2 pounds of manganese, 1 pound of zinc, 1.9 pounds of barium and 43 pounds of iron. That's a total loading of over 10 tons per year! I can't believe that this would be beneficial to the wetlands /creek. The pH of the "Quarry Discharge" from the TriTest Laboratory Report is reported as 7.4, but with a disclaimer "Exceeds holding time ". Do we really know what the pH is for the quarry discharge? TEMPERATURE I'm assuming (using one of their non - definitive phrases) that the extensive ditching system and holding ponds will ensure the temperature of the discharge water does not exceed the 5.04 degree F increase allowed for the creek? I do not agree with this scenario if that is their intent. When out on the boat in the winter, it is not uncommon to see surface to 1 foot down water temperatures in the low 40s F. Groundwater is approximately 55 degree F. Conversely, in the summer surface to 1 foot down water temperatures are routinely in the mid -80s F. Studies, if ever completed, need to be expanded to prove definitively that temperature changes will remain within the allowable limit and not adversely impact the wetlands /creek. In summary, as a retired environmental engineer the issues I've raised above and in my comments at the Public Hearing trouble me. Inadequate, incomplete or just totally missing data must be reviewed, expanded upon and /or generated to ensure that Blounts Creek is not adversely impacted by the MMM Vanceboro Quarry project. To restate from my comments at the Public Hearing "While I'm not against the quarry, let's ensure that MMM looks at the bigger picture, not just corporate profit, and chooses a plan to protect Blounts Creek now and for future generations. To me, direct discharge to Blounts Creek is not the best plan." Based on the data presented to date, I strongly urge you to deny the 401 certification and the NPDES permit. Please contact me at bbncltd @vahoo.com, or by phone at 252 - 402 -5564 with answers to my questions and if you wish to further discuss or require clarification of the issues I've brought to your attention. Respectfully, Bob Boulden 511 Long Point Road Chocowinity, NC 27817 Martin Marietta Materials, Inc. and their consultants have made assumptions based on computer models, data they have gathered and reference documents from around the US and elsewhere. What I don't see being used is local knowledge and common sense. Common sense suggests that you would sample the fish population and species at different times of the year; however, only one sample was taken. In all the reports I've reviewed, far too often I see phrases such as "we do not expect ", "it is assumed ", and "no adverse effect likely ". What if they are wrong? If the creek becomes polluted will they shut down the quarry? Shouldn't they be required to post a bond for cleanup of the creek if their assumptions are wrong? And beyond the scope of this meeting, why haven't they submitted an Environmental Impact Statement? One of their reports states that the pH of the creek will be increased from a range of 4.0 -5.5 to 6.3 -6.9. My understanding is that the pH of the creek cannot be changed. From another report, and I quote "increase in pH and perennial flow above Herring Run may provide more habitat for and less stress to a more diverse assemblage of freshwater fish species and increased egg survival" and "increased pH reduces the solubility of aluminum and therefore the toxic effects of aluminum." Aluminum is toxic to fish. So two wrongs make it right? Dump aluminum into the creek, but raise the pH so it's not so bad! Based on their lab analysis, with a discharge of 9 million gallons per day, we can expect 7 pounds of aluminum to be discharged to the creek that's nearly 1 % tons per year! Furthermore, if it is less soluble will it just settle to the bottom of the creek? I've seen no data describing how the temperature of the discharge water will affect the temperature of the creek. Only a 5.04 degree F increase is allowed. While I'm not against the quarry, let's ensure that Martin Marietta Materials, Inc. looks at the bigger picture, not just corporate profit, and chooses a plan to protect Blounts Creek now and for future generations. To me, direct discharge to Blounts Creek is not the best plan. Please contact our elected officials, and the Division of Water Quality expressing your concerns. This is the first day of the 30 day public comment period. It is not too late to make your voice heard! Thank you. �c 3 �-a � I'Ak v�. Jyt r�r iep k t V k ` } l , 'ILI NMI.�� .mil 'r :r`��..�'.. 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