20111013 Ver 2_Public Comments_20130415

North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
MEMORANDUM
TO: Tom Belnick
NC Division of Water Quality — NPDES
FROM: Shannon L. Deaton, Habitat Conservation Program Manager
Division of Inland Fisheries
DATE: April 12, 2013
SUBJECT: NPDES Public Notice for Martin Marietta Materials, Inc. Vanceboro Quarry, Beaufort
and Craven Counties, North Carolina.
NPDES Permit NCO089168
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the
NPDES public notice and draft permit with regard to impacts on fish and wildlife resources. The project
site is located approximately seven miles east of US Hwy 17 on the Beaufort- Craven County border
between the communities of Wilmar, NC and Blounts Creek, NC. The site is located on the drainage
basin divide between the Neuse River and Tar - Pamlico River basins. Our comments are provided in
accordance with provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16
U.S.C. 661 et seq.), Sections 401 and 404 of the Clean Water Act (as amended), and Coastal Area
Management Act (G.S. 113A -100 through 113A -128), as amended.
The applicant, Martin Marietta Materials, Inc. proposes to develop a 649 acre open pit aggregate
mine within a 1,664 acre project area. The site is currently owned and managed by the Weyerhaeuser
Corporation for the silviculture of loblolly pine. Impacts associated with the direct mining of the land
include permanent impacts to 6.69 acres of wetlands and 58,671 linear feet of jurisdictional ditches. To
facilitate the open pit mining, Martin Marietta Materials has applied to the NC Division of Water
Resources ( NCDWR) to withdraw up to 12 MGD of water from the Castle Hayne aquifer. This NC
Division of Water Quality (NCDWQ) NPDES public notice addresses the request to discharge up to 9
MGD of water into the headwaters of Blounts Creek. The discharge locations will be located at outfall
001 and outfall 002 into an unnamed tributary (non - jurisdictional ditch) of Blounts Creek. The waters of
Blounts Creek are classified C, Sw, NSW by the Environmental Management Commission, are subject to
the Tar- Pamlico Basin Buffer Rules, and are designated an anadromous fish spawning area (AFSA) by
the NCWRC.
We have reviewed previous documents from the applicant regarding this mine proposal and
submitted comments during the US Army Corps of Engineers 404 public notice and the NCDWQ 401
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

NPDES Martin Marietta Materials, Inc April 12, 2013
Vanceboro Quarry, Beaufort and Craven Counties
permitting process (18 January 2012, Cox). Our primary concern with this project continues to be the
proposed discharge into Blounts Creek. We do not feel that our concerns expressed in our previous
correspondence have been adequately addressed. Discharging 9 MGD of water into the headwaters of
Blounts Creek has the potential for significant adverse impacts to fish and wildlife resources and their
habitat. We request that alternative discharge options be considered in the project proposal that minimize
the impacts to Blounts Creek.
Resources of Blounts Creek
Blounts Creek is a deep water creek with hardwood riparian wetlands characteristic of a black,
swamp water drainage. The headwaters of the system are generally acidic and exhibit extremely low
flows that can vary seasonally from no flow to less than 18 cfs. There are no point source discharges into
Blounts Creek and the riparian areas are, for the most part, undisturbed and naturally vegetated except
downstream of the confluence with Herring Run where some residential development occurs along the
upland shoreline. The absence of discharges and intact riparian buffers greatly reduce sedimentation and
erosion in the upper reaches of the system. The mouth of the creek opens into Blounts Bay and the
Pamlico River. Salinity levels in the creek vary seasonally providing habitat for freshwater, estuarine,
and marine aquatic species.
Blounts Creek supports numerous and varied fish species including Striped Bass (Morone
saxatilis), Alewife (Alosa pseudoharengus), Blueback Herring (Alosa aestivalis), American and Hickory
Shad, Largemouth Bass (Micropterus salmoides), Yellow Perch ( Perca flavescens),White Perch (Morone
americana), Black Crappie (Pomoxis nigromaculatus), Chain Pickerel (Esox niger), Redfin Pickerel
(Esox americanus), American Eel (Anguilla rostrata), and occasionally Red Drum (Sciaenops ocellatus),
Southern Flounder (Paralichthys lethostigma), and Spotted Seatrout (Cynoscion nebulosus). These fish
inhabit Blounts Creek seasonally depending on water temperatures and salinity. Blounts Creek is fished
heavily by recreational anglers because of the rich diversity of fish species. NCWRC recently completed
Blounts Creek boating access area to enhance access to this system for anglers and other outdoor
recreational users.
Blounts Creek is also designated as an anadromous fish spawning area, providing environmental
conditions and favorable spawning habitat for anadromous fish such as Striped Bass and River Herring
(Blueback Herring and Alewife). While adult Striped Bass clearly use Blounts Creek for spawning, it is
more difficult to demonstrate spawning in this system by River Herring. River Herring populations are
severely depressed and both the NC Division of Marine Fisheries and NCWRC currently prohibit the take
of River Herring in an effort to increase population numbers. Further, River Herring are under
consideration for inclusion on the endangered species list by the National Oceanic and Atmospheric
Administration. Historical "runs" of River Herring are locally known in the Herring Run tributary as well
as in Blounts Creek upstream and downstream of the NC Hwy 33 bridge. Sampling conducted from June
1974 through June 1976 in the Tar - Pamlico system demonstrated spawning activity in Herring Run from
about 200 yards downstream of the confluence with Blounts Creek to the NC SR 1110 bridge near Cox's
Crossroads. This area also produced the highest catch -per- unit -effort (CPUE) of River Herring eggs in the
Tar- Pamlico system with 163 eggs in a five minute tow (Marshall, 1976).
Recent NCWRC Sampling of Blounts Creek
On April 1, 2013 NCWRC staff electroshocked four locations in Blounts Creek upstream of the
NCWRC Blounts Creek Landing Boating Access Area. River Herring were collected in the Herring Run
tributary as well as within the mainstem of Blounts Creek, upstream of the confluence with Herring Run.
Access to the upper most sample site was limited due to the size of the electrofishing boat. Thirty nine
fish were collected; the sample was comprised mostly of Blueback Herring males and one gravid female
Alewife was captured ( NCWRC personal communication). This sample resulted in the highest CPUE of
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NPDES Martin Marietta Materials, Inc April 12, 2013
Vanceboro Quarry, Beaufort and Craven Counties
River Herring in years from the Tar- Pamlico system, and demonstrated the importance of Blounts Creek
as potential spawning habitat. (see attached map)
Wildlife resource comments and concerns presented below are provided in response to system changes
projected in technical documents prepared by Martin Marietta.
1) Change in Flow System
NCWRC is concerned that significant changes in flow can adversely impact River Herring
spawning success. Technical documents provided by Martin Marietta Materials, Inc. state that the upper
reaches of the system will change from essentially a low flow system to a moderate flow system.
Projected discharges will more than double water flow and volumes into Blounts Creek, thus altering the
creeks response to large rain events. Dramatic, sustained increases in flow to a riverine system will cause
a stream system to alter by adjusting its banks and bankfull height, which increases the sediment load in a
system. River Herring require a low flow system in order for eggs to settle on vegetation near the bank.
The moderate freshwater flow system resulting from this project proposal would cause eggs to be flushed
further downstream to water conditions unsuitable for hatching. Additionally, the success of River
Herring eggs depends on a low sediment load to minimize the potential for eggs being covered.
2) Water quality conditions
We are concerned that any significant changes to the water chemistry in Blounts Creek can also
affect River Herring's ability to spawn successfully. The infusion of water from the Castle Hayne aquifer
is projected to change pH, salinity, DO, iron, manganese, and other elements at the discharge location and
downstream. Many fish species use olfactory cues to locate their biological spawning grounds. River
Herring are known to spawn in their natal systems and, olfactory cues play an important role in their
spawning behavior. Any chemical alteration of these cues could impair herrings' ability to find their
historic spawning grounds.
3) Collection of baseline data
We recommend increased sampling over a broader period of time that represents seasonal and
annual water quality data prior to performing any project models that predict the influence of the mine
discharge on water chemistry. Accurate projections of project impacts rely heavily on collecting
representative baseline data of sufficient scope. Based on NCWRC's recent sampling results, we do not
concur that the freshwater input will improve conditions in Blounts Creek from its current swamp water
conditions. Current water quality conditions in Blounts Creek support spawning for River Herring and
numerous other fish species.. Baseline data collected by Kimley -Horn and Associates, Inc. (Kimley -Horn)
for Martin Marietta Materials, Inc. and projections in the project proposal shows the pH in the system
upstream of the confluence of Herring Run will increase from a current range of 4.0 -5.5 to 6.3 -6.9. This
change in pH would be a marked difference from the current conditions and may no longer sustain the
current resource use.
In addition to the pH changes, the introduction of a 9MGD freshwater discharge would decrease
overall salinity levels in the upstream portion of the system and move the salt wedge further downstream.
During the April 1, 2013 NCWRC sampling event, surface salinity levels at the Herring Run confluence
were 5.1 ppt. In the project proposal, the salinity range gathered by Kimley -Horn was only 0.03 — 1.08
ppt. These data differences show the high variability of salinity that can occur in this system and
demonstrate the importance of designing a baseline monitoring plan that captures the variability of critical
water quality parameters such as pH and salinity annually as well as seasonally or during weather events.
The documents provided by Martin Marietta Materials, Inc. state that Blounts Creek downstream
of the confluence of Herring Run will see minimal changes. This area is especially important for
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NPDES Martin Marietta Materials, Inc April 12, 2013
Vanceboro Quarry, Beaufort and Craven Counties
anadromous fish spawning, and we are concerned that impacts and changes to this upper reach may be
more heavily affected and need to be adequately addressed in the project proposal.
4) Planning for future monitoring and mitigation needs
NCWRC requests that additional details be incorporated into the project proposal regarding
monitoring and mitigation to compensate for anticipated system changes during and after the life of the
mine operation. Specifically, we request the applicant collect baseline data and model the potential
impacts of a 9MPG discharge on stream morphology and hydrology.
5) Discharge alternatives
NCWRC requests that alternative methods of discharging 9MGD of freshwater be proposed to
avoid the potential significant effect on Blounts Creek. Several alternatives presented in this project
proposal could result in minimized impacts to Blounts Creek, but were not chosen primarily due to cost.
One alternative considered by the applicant included injection of 4.5 MGD into the aquifer and a
discharge of 4.5 MGD into Blounts Creek. Although this alternative was dismissed due to costs; however,
this or a similar alternative could significantly reduce fish and wildlife impacts. Water withdrawn from
the Castle Hayne aquifer could be injected back into the aquifer while water withdrawn from the surficial
aquifer could be discharged into Blounts Creek. This alternative would significantly reduce the volume
and velocity of water discharged in addition to minimizing water chemistry differences between aquifer
and surface waters. Injection could be done well away from the aquifer withdrawal to lessen any
influence on the needed cone of depression and minimize impacts to aquatic resources.
The applicant determined the discharge option mentioned above was a more expensive alternative
than a complete surface water discharge. However, costs presented in the application did not take into
account the value of fish and wildlife impacts, the cost of increased monitoring not currently proposed,
and the cost of stream mitigation post -mine closure. Total project costs should take all these factors into
account as well.
We believe that the project as proposed will have significant adverse impacts to the significant
aquatic resources in Blounts Creek. Potential impacts to water quality and aquatic habitat in Blounts
Creek could be reduced if an alternate method of water discharge such as the split alternative were
employed.
Thank you for the opportunity to provide comment on this permit. We look forward to reviewing
additional information as it becomes available. If we can be of further assistance, please contact me at
(919) 707 -0222.
Ec: Maria Dunn and David Cox, NC Wildlife Resources Commission
Literature Cited
Marshall, Michael D. 1976. Anadromous Fisheries Research Program - Tar River, Pamlico River and
Northern Pamlico Sound. Completion Report for Project AFCS — 10. North Carolina Division of Marine
Fisheries, Morehead City, 90p.
41Page

Map depicting recent NCWRC sampling of Blounts Creek

Strickland, Bev
From: Karoly, Cyndi
Sent: Monday, April 15, 2013 9:57 AM
To: Strickland, Bev
Subject: FW: WRC comments: Vanceboro Quarry, Martin Marietta Materials, Inc
Attachments: NPDES_MMMV_FINAL_041213.pdf
From: Belnick, Tom
Sent: Monday, April 15, 2013 9:57 AM
To: Karoly, Cyndi; Adams, Amy
Cc: Rawls, Paul
Subject: FW: WRC comments: Vanceboro Quarry, Martin Marietta Materials, Inc
I1' • -
• • ') • •
NCDENR/Division of Quality
#,,19-807-6390
E-mail correspondence to and from this address may be subject to the
From: Deaton, Shannon L.
Sent: Friday, April 12, 2013 5:21 PM
To: Belnick, Tom
Cc: Dunn, Maria T.; Cox, David R.; Curry, Robert L.
Subject: WRC comments: Vanceboro Quarry, Martin Marietta Materials, Inc
Please find attached WRC comments on the NPDES Public Notice for Martin Marietta, Inc. Vanceboro Quarry.
Let me know if you need a hard copy mailed of these comments.
JLA
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9i � 1
(o HOMEOWNERS ASSOCIATION o •
Comments /Concerns: Vanceboro Quarry Project
Public Hearing March 12, 2013
The Cypress Landing community, represented by the Cypress Landing Home Owner's Association
(CLHOA), is located on the south side of Chocowinity Bay. Cypress Landing is currently home to
approximately 600 families.
While it does not appear that the CLHOA is directly affected by the actual mining operations or
increased volume of water discharge into Blount's Creek, we still have concerns about the potential
impact of the Vanceboro Quarry project.
Like most people living in the area, Cypress Landing residents are dependent on the Castle Hayne
aquifer for our domestic water. Everything we hear about the aquifer indicates that level of the water
table continues to drop whether from increased demand or other environmental factors.
Additionally, Blount's Creek is a very short boat ride down the Pamlico River from Cypress Landing.
Many of our residents enjoy the boating and sport fishing activities the creek provides and we do not
want to see these activities adversely affected.
Access to Blount's Creek, along with the other waterways in the area, has played a significant part in the
success of our community. We believe a "healthy" Blount's Creek will help to continue this success.
The information presented at the Public Hearing predicted two very different outcomes.
The Martin- Marietta report, with data and analyses provided by their consultants, indicated a better
than best case scenario. Changes would be minimal and those changes would actually improve the river.
An increase of nine million gallons per day may not be a lot of water at the mouth of the river, but it is
difficult to believe that would not totally dominate conditions at the location where it will enter the river
and for some distance downstream. We would like to know what locations and flow volumes were used
in the analysis.
There were no comments regarding the impact of withdrawing of 9/12 million plus gallons per day on
the aquifer. (We are not sure whether it is 9 or 12 million gallons as both volumes were used
interchangeably during the discussions.)
On the other hand, the concerns expressed by those apposed to the project indicated worse than worst
case results. Everything about the river would be changed and or destroyed. These conclusions were
supported by little or no analysis. Also, they indicated current regulations do not allow for any changes,
good or bad, in sensitive swamp areas like those at the planned discharge site. Is this the case?
100 MARINA DRIVE, CHOCOWINITY, NC 27817 OFFICE 252.975,3255 FAX [phone]

Discharge Alternatives seem to have been evaluated on the basis of cost alone and not on the benefit of
their results. There was some mention of technical feasibilities in the evaluations but no information
was provided.
One of the rejected alternatives, "100% Ground Water Reinjection ", would totally eliminate any impact
on Blount's Creek and minimizes the impact on the aquifer. It was the mid -price alternative and
probably deserves further consideration.
No one addressed a "recovery plan" in the event any or all of the worst case concerns were to occur. It
seems unlikely that just stopping the discharge would correct all the damages.
At this time Cypress Landing is neither for nor against the project but rather very concerned that the
ultimate decision must be based on factual data, complete and accurate analyses and provides the
appropriate protection of our precious water resources, both Blount's Creek and the aquifer. To this
end we believe that more detailed, accurate and objective analysis is required.
Thank You
John Rebholz
President, Cypress Landing HOA

Mr.` Chuck Wakald` ' '' >� , �. 10 April 2013
NCDENR= DWQ -NPDES
1617 Mail'Service Center
Raleigh,'NC 27699 =1617
Dear Mr. Waklid tn`�
We are writing to you to protest the permitting of water discharge into
Blounts Creek by the proposed Martin Marietta Materials Mine. My wife and I built a
house on Blounts Creek in 2003 after several years of research throughout the southeast
to find conditions that filled our requirements. The delicate balance of the estuary
system here in Beaufort County was not a primary concern at the time. Over the ten
years that we have lived here we have learned a lot more about our environment and
how precious it is not only to us but to all of the country and our descendants. We do
not have scientific evidence to present attesting to the detrimental effects of dumping 12
million gallons of fresh water into the creek but we can offer many antidotes of the
occasions when there has been a major increase in fresh water due to heavy rain. The
marine -species that inhabit this creek are many and varied and their,ab4ndance attracts
all sorts of visiting wildlife both in the water and in the air. Changing that delicate
balance of the estuary will almost certainly have some impact that will be immediately
visible with the accumulative impact over time unimaginable.
Thank you for your attention to this matter,
Robert L and Teresa S Jenkins
95 Waters Edge Drive
Chocowinity,
c