HomeMy WebLinkAbout20111013 Ver 2_Public Comments_20130403 (3)Strickland, Bev
From:
Karoly, Cyndi
Sent:
Wednesday, April 03, 2013 10:36 AM
To:
Strickland, Bev
Subject:
Fwd: Martin Marietta Materials, Inc. - Vanceboro Quarry NPDES and 401 certification
comments
Sent from my iPad
Begin forwarded message:
From: Al Johnston <alvinjohnston@centurylink.net>
Date: April 2, 2013, 10:24:14 AM MDT
To: <chuck.wakild@ncdenr.gov >, <tom.belnick@ncdenr.gov>
Cc: <karen.higgins@ncdenr.gov >, <cyndi.karoly_@ncdenr.gov >, <william.hart@ncdenr.gov>
<david.w.cox@ncdenr.gov>
Subject: FW: Martin Marietta Materials, Inc. - Vanceboro Quarry NPDES and 401
certification comments
Re: Martin Marietta Materials, Inc. - Vanceboro Quarry NPDES and 401 certification
comments
Martin Marietta Materials, Inc has applied for state and federal permits to develop a new 50 -year open
pit marine limestone mine in southern Beaufort County, east of Vanceboro, within the Blounts Creek
watershed. The company will impact 6.69 acres of wetlands and 11 miles of jurisdictional waters.
Martin Marietta was issued a mining permit from the Division of Land Resources. Permits are still
pending from the NC Division of Water Quality for water and wetland impacts and for the wastewater
discharge. A water withdrawal permit is also pending from the NC Division of Water Resources.
As a resident, and concerned citizen, please accept the following considerations regarding Martin
Marietta Materials, Inc (MMM) draft NPDES permit and Clean Water Act Section 401 certification
permit request to operate a 649 acre open -pit mine in Beaufort County:
Source Water Impact
• Up to 12 million gallons per day of Castle Hayne aquifer groundwater and stormwater
will be pumped from the open mine pit and discharged into 2 locations in upper Blounts
Creek.
• The mine is located within the cone of depression of the Potash Aurora phosphate mine
and the estimated drawdown (or cone of depression) of the Castle Hayne aquifer is at least
5 feet for up to 6 -7 miles.
• Drawdown impact will affect Beaufort County Water District supply as well as up to 195
wells belonging to local families and landowners as well as area.
Water Discharge Effect
• Blounts Creek is an important recreational resource for Beaufort County and is a brackish creek
(mix of salt and fresh water) system. As an important aquatic nursery area for numerous fish
species, as noted by the NC Division of Marine Fisheries, Blounts Creek supports dense
submerged aquatic vegetation (SAV) beds, critical habitat for fish and other aquatic life.
• The federal Clean Water Act requires that only the Least Environmentally Damaging
Practical Alternative may be permitted (for the 401/404 permit). MMM has a burden of proof to
state that other alternatives that eliminate or reduce the discharge to Blounts Creek and the
associated negative impacts are impracticable. They have not done that.
• The approval of a NPDES Discharge permit is in violation of state law. The discharge,
which constitutes large volumes of groundwater, would significantly raise the pH of the stream
system, a change that is not allowable under NC water quality regulations. Such a change in the
water chemistry would result in a change in aquatic species (e.g. fish and aquatic insects) that
could survive in those waters. State law is clear that it does not allow a discharge of waste to
change the species composition of a stream from its natural state.
• The proposed discharge will change the nature of the upper creek by changing water flow,
salinity, pH and the stability of the stream bank. These changes will impact all life stages of fish
as well as change the prey for these fish.
• The mine will not be consistently discharging the same amount of water thereby causing the pH
levels to swing up and down depending on their mining activity, and the demand for their product.
This constant changing pH level and flow will not provide a good habitat for fish and other
aquatic species.
• For its application, Martin Marietta conducted only 1 day of fish sampling during the wrong
time of year, then stated that no anadramous juvenile fish species (like herring, striped bass, etc)
were found. Sampling should have been conducted seasonally or at a minimum sampled in June or
July when these species are most likely to be present in the Creek.
• The land is being leased from Weyerhaeuser. Reclamation plans indicate that a large lake will be
left at the end of the life of mine. However, there is no information or analysis on impacts to
Blounts Creek once the wastewater discharge has ceased.
Sincerely,