20111013 Ver 2_Public Comments_20130416

Strickland, Bev
From: Karoly, Cyndi
Sent: Tuesday, April 16, 2013 12:56 PM
To: Strickland, Bev
Subject: FW: NPDESNanceboro Quarry Comments
Attachments: VanceboroQuarryBiologyComments .pdf
Bev— I'm not sure if this got scanned in, so I'm forwarding this just in case.
From: Belnick, Tom
Sent: Tuesday, April 16, 2013 10:34 AM
To: Fleek, Eric
Cc: Rawls, Paul; Poupart, Jeff; Adams, Amy; Sauber, Jay; Karoly, Cyndi
Subject: NPDES /Vanceboro Quarry Comments
Eric- can you take a look at natural resource comments submitted by NC WRC and NC DMF (attached, with blank page
separating the comment letters) for the proposed NPDES discharge from the Martin Marietta Vanceboro Quarry. Very
high profile- we had 150 people attend public hearing, with >100 written comments coming in. Local concerns raised
about impacts at the initial discharge location (pH change) as well as downstream impacts to fisheries in Blounts Creek.
Paul Rawls is Hearing Officer for the NPDES discharge, and we will get together at some point to discuss comments. I'd
like to have ESS involved in that discussion, as well as WARD. The comment period closed Friday 4/12, and Final Action
must be taken within 90 days.
PS -The hearing also included the 401 certification for wetland impacts, but most comments appear to be focused on the
proposed discharge of quarry dewater and potential downstream impacts in Blounts Creek.
Thanks
Tom Belnick
Supervisor, NPDES Complex Permitting Unit
NCDENR /Division of Water Quality
919 - 807 -6390
E -mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties

Ham.
0 North Carolina Wildlife Resources Commission 0
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 NC0089168
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]
F
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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 (Mot-one
saxatilis), Alewife (Alosa pseudoharengus), Blueback Herring (Alosa aestivalis), American and Hickory
Shad, Largemouth Bass (Micropterus salmoides), Yellow Perch (Perea 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.
4 Page

Map depicting recent NCWRC sampling of Blounts Creek