cfrw.us Blog

• The proposed project, based on information provided in the PN, describes the proposed impacts to surface waters and wetlands.  The proposed quarrying action will impact an estimated 600 acres of wetlands.  Of that total, 214 acres of CAMA jurisdictional wetlands will be impacted.  These wetlands reside in a unique and highly sensitive ecological environment home to a diverse array of flora and fauna.  Specifically, the area surrounding Island Creek is of important ecological value for its pristine condition and remote location.  Destruction of these important wetlands will impede the capability of this habitat to perform its primary function to provide refuge for faunal species and to act as a natural filter from contaminant-laden runoff. 

• CFRW has serious concerns regarding the impact this proposed project will have on the water quality of the Northeast Cape Fear River and the Cape Fear River near Wilmington, only several miles downstream.  The PN states that hydrogeologic investigations have been or will be conducted to assess the amount of water discharged from the proposed quarry pits.  There is concern as to the nature of the constituents of the effluent released from this facility.  Aquatic organisms are extremely sensitive to alterations to their physical environment and could be negatively impacted by contaminants or pollutants entering the wetlands and river.  Historical water quality data collected by the Aquatic Ecology Laboratory at the University of North Carolina at Wilmington should be utilized to determine baseline water quality conditions.  Any anticipated deviation from these baseline conditions may result in fundamental changes to the local biota adjacent to and downstream of the Northeast Cape Fear River.

• The potential impacts of dewatering on groundwater resource areas are also of concern to the CFRW.  The Castle Hayne and the Pee Dee aquifers provide the primary source of drinking water supply for many citizens of both New Hanover and Pender Counties. The proposed mining operation may threaten the integrity of the water quality within these two aquifers and thereby may threaten the source of drinking water for thousands of private citizens.  CFRW respectfully asks the applicant to describe in great detail within the EIS how the mining operations at the Carolinas Cement quarry will be done to ensure that the quality and quantity of the water resource within these aquifers will not be impacted by the proposed activities stated in the PN.

• The applicant will address air quality within the EIS, as stated in the PN.  Measures to reduce emissions of mercury, chromium VI and other dangerous contaminants need to be discussed in great detail in the EIS.  Contaminants such as these are highly toxic and detrimental to the fauna found in the aquatic environment.  Furthermore, the unique environmental conditions found within the estuarine and riverine benthic habitats promote the conversion of mercury to the transferable and highly toxic form of methyl-mercury.  The short-nose sturgeon is a federally endangered species which historically utilized the Cape Fear River as a conduit to its spawning grounds upstream.  Any additional pollutant and contaminant input to the system will impact the recovery of this important species.  Humans may also be significantly impacted by the deposition of mercury into the waterways which poses a significant health risk to humans who ingest fish containing methyl-mercury.

• Atmospheric deposition of mercury is a nonpoint source of water pollution and must be controlled to protect existing and designated uses of state waterways. The Environmental Protection Administration (EPA) also recognizes atmospheric deposition of mercury as a Clean Water Act nonpoint source of pollution. In response to fish consumption advisories due to elevated findings of methyl mercury, a Total Maximum Daily Load (TMDL) process was initiated to determine the measures necessary to protect human health. In order to establish adequate TMDLs, the EPA looked to the mercury concentration in fish tissue and both the point source and nonpoint source loads of mercury to the environment. Noting that the majority of mercury in the environment is derived from coal-fired power plants and air pollution, the EPA determined that most reductions to achieve water quality standards would need to be implemented through Clean Air Act regulations. Where just 1/70th of a teaspoon, or a single gram, of mercury can contaminate a 25-acre lake, the emission of potentially hundreds of pounds of mercury per year as proposed by the applicant will have an increasing impact on already burdened waterways. Clearly, the North Carolina antidegradation regulations do not allow for addition sources of mercury, either from direct point sources or nonpoint sources such as atmospheric deposition, where uses of waterways are not maintained and Water Quality Standards are not being met. 

The Northeast Cape Fear River is classified as being mercury impaired on the Federal 303D list. In fact, the boundary of the mercury impaired waters range from Highway 210 to Prince George Creek. The site of the old cement plant is almost exactly in the center of these contaminated waters. This leads one to suspect strongly the source of the mercury may have been from the previous cement plant. It is our opinion that a TDML must be developed for the Northeast and Cape Fear River basin before any additional mercury can be introduced into these waters by the applicant. A plan to develop the TMDL along with a timeline must be clearly defined in the EIS.

• During and after hurricanes and flood conditions Island Creek floods the surrounding wetlands to depths well above 10 to 15 feet above flood stage. Over a period of time potentially spanning weeks, these flood waters are slowly released into the Northeast Cape Fear River. The pristine wetlands in this area naturally buffer, filter, and help control flooding of inhabited and other areas downstream. How the loss of this buffer as a natural means to control downstream flooding will be mitigated to protect the personal loss of property or the life of humans, fauna, or downstream riparian ecosystems must be clearly described in the EIS.

• Anadromous fish in the Cape Fear River basin are threatened due to the loss of habitat, access to their spawning grounds and nursery areas, pollution, siltation and other pressures. The dynamics of the river are changing due to such things as the intrusion of saltwater and climate change. This has caused the migration, feeding and spawning behavior of anadromous fish include Stripped Bass, shad, herring and the Short Nosed Sturgeon to change as they attempt to adapt. National Marine Fisheries estimates that the restoration of this fishery will yield over five (5) million dollars per year in revenues to North Carolina. Island Creek is unique in its geography and habitat. This resource must be evaluated and assessed so that we understand the criticality of the potential destruction of and the diminishment of its water quality or any component of the ecosystem it provides currently or may play in the restoration of the fishery as a whole. Fish stocks and all components to supporting their existence, ability to spawn and reproduce must be extensively studied and reported upon. This may require a multiple year study to not only establish a baseline of what exist today, but a clear understanding of the dynamics of the ecosystem as a whole and its role in the potential restoration of the Cape Fear River anadromous fishery.

• The Northeast Cape Fear River provides excellent recreational fishing opportunities.  The applicant must describe in the EIS the impact to this economic activity within the region. Additionally, the Northeast Cape Fear River provides a living to those who have invested into the development of ecotourism businesses. The future development of this industry must be considered in any evaluation for its potential impact to North Carolina and the local economy. The public uses the river for fishing, swimming, birding, and hunting. Some just like to breathe its clean air or enjoy its natural state. The introduction of a cement kiln, strip mine, and the destruction of miles of wetlands bordering the Northeast Cape Fear River and Island Creek must be evaluated in the EIS as to its current and even more so future impact to restricting its use to an industrial area that is not suitable or safe for public use.

• The applicant has indicated that they may use the river to transport both fly ash, coal, and other toxic hazardous materials by barge to and from the proposed site.   The impacts of a potential accident involving a barge carrying these materials should be studied and included in the EIS.  The area for study should include the Northeast Cape Fear River in proximity to the proposed cement facility, the main stem of the Cape Fear River from the mouth to the confluence of the Northeast Cape Fear River, and the Northwest branch of the Cape Fear River to the Sutton Power plant. Special consideration should be given to areas of dense population as exist such as in the downtown Wilmington area, endangered species of fish, fauna and mammals and other sensitive ecosystems on and bordering the river.

• Island Creek provides habitat for a varity of migratory birds. It is well known for its population of wood ducks, osprey and owls. Bald eagles have been observed feeding and remaining in the area for extended periods of time in their migrations. Island Creek primary habitat classification is bottomland hardwood forest. Bottomland hardwood forests are primary nesting grounds for a variety of Neo-tropical migrant birds.  Neo-tropical birds migrate long distances from the tropical latitudes in winter to temperate latitudes in summer to facilitate their breeding biology. Most notably, the prothonary warbler is one out of 32 species of warbler that only nests in cavities of trees.  prothonotary warbler has been deemed by U.S. Fish and wildlife as a species of concern due to its breeding specialization. Our senior naturalist with CFRW has concerns about the lack of bird survey work that has been performed in proximity to the proposed cement factory site.  During a preliminary bird count conducted by CFRW, 8 prothonotary warbler breeding males were observed on a mile stretch of island creek site.  Any change in the forest matrix could negatively impact the abundance and breeding success of warbler and other bird species.  In addition, avian research has proven a direct relationship between forest fragmentation and a decline in neo-tropical species. Development at the proposed level would create an edge effect.  These edge effects will concentrate song bird breeding into smaller areas making them more vulnerable to predators and kleptoparasites. We recommend that a full year comprehensive bird survey should be conducted to truly understand the bird diversity inhabiting the Island creek complex. The applicant is requested to provide an inventory and assessment of all migratory birds that inhabit Island Creek and the associated areas of the Northeast Cape Fear River and quantify the impact to them through the destruction of habitat, reduction in air or water quality. Particular sensitivity must be provide for the need to provide the appropriate buffer size for habitat functions dependent upon the resident species, the life-history characteristics of the species, the condition of the wetland and the wetland buffer, the intensity of the surrounding land use, and the function the buffer is to provide.

• Cement Plants are typically lighted in a manner that introduces an extremely high amount of light pollution. We a concerned as to how this will adversely impact the feeding, breeding and survival of nocturnal mammals, birds and reptiles. American Alligator and specific bats that are on the endangered species list that reside on the applicant’s property or reside within close proximity to the area should be given special consideration in the applicant’s review.

• The historical significance of the property needs to be extensively investigated. As an example the Civil War encampment of J. W. Johnson was located on this property. Early maps also show the earliest of bridges crossing Island Creek on the Gilmer maps of 1818 (University of North Carolina at Chapel Hill. Library. Southern Historical Collection.  

Thank you for your time and consideration of these comments.  CFRW appreciates the opportunity to continue to participate in the discussions and developments of this project.  Please feel free to contact me anytime regarding these comments or any other issue pertaining to the proposed Carolina Cement Company’s (Titan America) proposal to construct a cement manufacturing facility and quarry.
Sincerely,

Doug Springer