20111013 Ver 2_Public Comments_20130404 (2)

Strickland, Bev
From: Karoly, Cyndi
Sent: Monday, April 08, 2013 10:14 AM
To: Strickland, Bev
Subject: FW: Comments on Draft Permit#NC0089168
Attachments: CWFNC Vanceboro quarry comments.doc
From: Katie Hicks [mai Ito:katieCa)cwfnc.orq]
Sent: Thursday, April 04, 2013 7:52 AM
To: Karoly, Cyndi
Subject: Comments on Draft Permit #NC0089168
Ms. Karoly,
Please find attached the comments of Clean Water for North Carolina on Draft Permit 4NCO089168
for Martin Marietta Materials.
Best,
Katie Hicks
Clean Water for North Carolina
katie(o)cwfnc.org
[phone]
http://www.facebook.com/CWFNC
i

Clean Water for North Carolina
29 1/z Page Avenue
Asheville, NC 28801
[e-mail]
March 13, 2013
Cyndi Karoly
N.C. Division of Water Quality
Wetlands and Stormwater Branch
1650 Mail Service Center
Raleigh, NC, 27699-1650
[e-mail]
Comments on Draft Permit#NC0089168 for Martin Marietta Materials
Dear Ms. Karoly,
Clean Water for North Carolina(CWFNC) is a statewide environmental justice
organization promoting clean water and environments. We have over 400 members
spread across 56 of North Carolina's 100 counties, from mountains to coast. Please
accept the following comments regarding the proposed issuance of draft permit #
NC0089168 for the new Vanceboro quarry.
CWFNC opposes the issuance of the draft permit. Our research has determined that the
new discharge to Blounts Creek from the proposed limestone quarry represents a
significant threat to aquatic ecosystem health and water quality downstream, and the
permit as written would not protect the watershed, which is an important aquatic nursery
area. The NC Division of Marine Fisheries has written that Blounts Creek supports dense
submerged aquatic vegetation beds, which are critical habitat for multiple aquatic
organisms.
Since the discharge would consist mainly of groundwater, which has a very different pH
than the brackish waters of Blounts Creek, the discharge would significantly raise the pH
of the stream system. This is not allowable under current state water regulations, as it
would alter the diversity and types of aquatic species able to live downstream. Water
flow, salinity, and physical stream bank characteristics will also be altered.
The permit only requires pH monitoring downstream of the discharge once per month.
Since the volume of discharge will change from day to day, this is not adequate to
measure the fluctuation in pH levels. The constant fluctuation is likely to disturb the
chemistry and habitat for aquatic species. pH should be measured daily at Outfalls 001
and 002 to ensure compliance with daily maximum limits. Total suspended solids and
total iron must also have enforceable limits.
The protocols used by Martin Marietta Materials for fish sampling in preparing their
application to the Division of Water Quality were flawed. The company 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. The sampling should be
carried out again with multiple seasonal samples, or at a minimum sampled in June or
July when these species are most likely to be present in the Creek.
The Best Management Practices for preventative maintenance required in the permit are
not specific enough to ensure protection of nearby groundwater and Blounts Creek. The
permit states that "spilled fluids shall be cleaned up to the maximum extent practicable
and properly disposed." The company must comply with specific, strict guidelines for
managing spills, especially spills of any hazardous chemicals, and the permit should
address these.
Thank you for this opportunity to submit comments.
Sincerely,
Katie Hicks
Assistant Director
Clean Water for NC