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HomeMy WebLinkAbout20210710_E-Portman_ADI3From: Miller. David To: Kastrinsky, Josh Subject: FW: [External] FW: Important concerns on applicant reply to ADI3 questions - and suggested follow up questions to consider Date: Monday, January 10, 2022 1:40:09 PM Attachments: Sound study comments to Wake Stone ADI 3 reply submitted April 30 2021.pdf April 30 Wake Stone reply to DEO ADI 3 - comments on sound and sunset clause.odf.docx From: Ervin Portman[mailto:eportman@weststarprecision.com] Sent: Saturday, July 10, 2021 11:31 PM To: Miller, David <david.miller@ncdenr.gov>; Wrenn, Brian L <brian.wrenn@ncdenr.gov> Cc: Wilson, Reid <Reid.Wilson@ncdcr.gov>; Michael, Jeff <jeff.michael@ncdcr.gov>; Patterson, Dwayne <dwayne.patterson@ncparks.gov>; elzabeth.biser@osbm.com; Masemore, Sushma <sushma.masemore@ncdenr.gov> Subject: [External] FW: Important concerns on applicant reply to ADI3 questions - and suggested follow up questions to consider CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. I have added a word document to make the comments easier to read. Ervin Portman From: Ervin Portman Sent: Saturday, July 10, 20215:47 PM To: Miller, David <david.miller(@ncdenr.gov>; brian.wrenn(@ncdenr.gov Cc: reid.wilson(@ncdcr.gov; jeff.michael(@ncdcr.gov; dwayne.patterson(@ncparks.gov; elizabeth.biser(@osbm.nc.gov; sushma.masemore(@ncdenr.gov Subject: Important concerns on applicant reply to ADI3 questions - and suggested follow up questions to consider The attached file includes my concerns and comments related to answers supplied by Wake Stone on April 30, 2021, regarding the noise impacts on the park, and on the key importance of reinstating the 50 year sunset clause. The Mining Act of 1971 is only as effective as its enforcement, the last 40 years of this permit raises serious questions about how DEQ has applied the law in this case. To make the comments easier to review they have been added to the attached pdf, so each comment can be reviewed in the context of the applicants response it is related to. I ask DEQ to consider these comments and to request from Wake Stone important information not disclosed by them in their response to DEQ. 1. The L1 data measured in the study was not disclosed. This will reflect the loudest sounds measured and expose the intensity of sound intrusions understated by the L10 metric, please ask the applicant to add it to the report. 2. The applicant shows Lmax and L10 data but asks DEQ not to consider it, because it is different from Leq hourly data; but why is the hourly average a better reflection of sound intrusions on the purpose of a park? What measure best reflects the sounds a park visitor will hear? 3. The isopleths for the concurrent operation of both Pitt and Pit 2, were not provided, but concurrent operations would be allowed by the site plan submitted. This combined operation is not reflected in the sound study as the applicant only disclosed the sound data assuming Pit 1 sounds stop and Pit 2 sounds start. In reality the site plan submitted allows concurrent operations which have not been modeled. The combined effects of two concurrent pits will have louder impacts over a greater area than the individual operation of only one pit, so the study results presented to DEQ understate the real sound impacts of a concurrent operation. 4. How many blasts were monitored and on what dates and times to determine the blast loaded into the model, and how do these blast(s) differ from the historical actual blasts conducted? S. What was the distance between the blast site and depth and what was the buffer between the blast and the monitoring location, and how was this larger forested buffer and deeper depth of blast reflected in the "back calculation" used to reflect future blast impacts in the model. 6. The sound study and the isopleths document that the existing quarry operations already have a significant adverse impact on the entire park, and that the expansion will only increase the intensity of the impacts and the area of the park effected by them. Why would DEQ allow this to continue beyond the 50 year limit of the 1981-2017 permit. 7. The buffers and sunset condition were key to reducing the impact on the park, yet the buffers have been violated and the sunset condition removed after 37 years, 8. DEQ has received numerous complaints of permit violations at the quarry, but has never issued a notice of violation or conducted a hearing on any of the complaints, why has this provision of the Mining act not been respected? a. Buffer Violation in 1981 when the applicant cleared to the east of the pit, too close to the park b. Buffer violation in 1986 when the applicant violated the area north of the 10 year line to the north of the pit c. Buffer violation in 1992 when the applicant blasted too close to Crabtree creek, destroying the buffer and filling the creek with material blocking 90% of the creek. d. Buffer violation after 2010 expansion of the material stock area that resulted in flooding of the eastern buffer and killing of trees in the buffer and the state park. (ongoing) e. Permit violation for depositing sediment into the streams that feed to Crabtree Creek, (ongoing) 9. DEQ has been provided extensive additional information that the Sunset clause included in the 1981 permit was not a "typographical error" as asserted by Wake Stone after 37 years of accepting the sunset condition, yet DEQ has taken no action to reinstate the Sunset clause they removed in 2018, as a permit modification and later in 2019 re - characterized as a ministerial correction. Does DEQ intend to correct the 2018 error and reinstate the 50 year sunset condition the applicant accepted for 37 years, or is DEQ content to allow the quarry unlimited time to continue to impact the park with no limit? 10. Is DEQ satisfied with its enforcement of permit violations over the 40 years of this permit? 11. Why has DEQ agreed to every permit change requested by the applicant over the same 40 year period, including buffer reductions and the elimination of the sunset clause. These were key protections for the park that have not been enforced by DEQ why? If you would like to discuss I am always free to discuss this important subject with either of you. Please review these comment and add them to the public record on this expansion request. Thanks for all you are doing for our state, I trust these comments will help you enforce the Mining Act of 1971 in a way that respects the law and protects the state park, and the applicant. Ery Portman 101 Fern Bluff Way Cary, NC 27518 Cell 919 924 6025 Wake Stone Corporation www.wakestonecorp.com Quarry Phone Numbers: Locations: 919/266-9266 - Knightdale 6811 Knightdale Blvd., Knightdale, N.C. 919/677-0050 - Triangle 222 Star Lane, Cary, N.C. 919/775-7349 - Moncure 9725 Stone Quarry Rd., Moncure, N.C. 252/985-4411 - Nash County 7379 North Halifax Rd., Battleboro, N.C. 843/756-3400 - N. Myrtle Beach 3990 Hwy 9 Business East, Loris, S.C. April 30, 2021 By Hand Delivery David Miller, State Mining Engineer NCDEQ— Division of Energy Mineral and Land Resources 512 North Salisbury Street Raleigh, North Carolina 27699 RE: Wake Stone Corporation Triangle Quarry Mining Permit No. 92-10 Wake County, North Carolina Neuse River Basin Mr. Miller: Business Office Address: P.O. Box 190 6821 Knightdale Blvd. Knightdale, N.C. 27545 919/266-1100 Fax: 919/266-1149 Enclosed are duplicate copies of Wake Stone Corporation's responses to the six (6) comments contained within your letter of April 14, 2021 ("3`d ADI Letter"). In providing these responses we have attempted to be as thorough and concise as possible, providing you with the information you need to move forward to permit issuance. As requested, our response to Item #1 provides a tabulated listing of all equipment (present and future) incorporated in the acoustical study modeling. Additionally, we have included graphics that illustrate the locations of each of these potential noise sources as they were included in the Cadna-A model runs. Our response to Item #2 includes a narrative discussion of how the "final" acoustical study report addressed the specific questions that had been raised in your letter of February 25, 2021. We have also included a PDF version of the final report in which we have highlighted the changes between this and the previously submitted draft report. These items should clarify any questions you have concerning the acoustical study methodologies and results. We have included in this response a set of revised Erosion and Sediment Control Plan drawings that include placement of a concrete wash -out location on the existing quarry site should such be required during bridge construction. 4. In responding to Item #4 concerning placement of the proposed security fence within areas subject to the Neuse River Riparian Buffer rule, we maintain that the General Statutes related to the buffer rules (15A NCAC 02B .0714 and 15A NCAC 028.0610) clearly state that fencing is deemed allowable within buffer areas subject to limitations on tree removal. Our previously submitted explanation of how we intend to construct the proposed security fencing incorporates plans for avoiding removal of trees within Zone 1 of the buffer. We have made numerous attempts to obtain NC Division of Water Resources concurrence on our understanding of the buffer rule's provisions for fencing, but as of this date, have received no response from NCDWR. 5. The recommendation for upsizing of the riser pipe structure for Basin 4 has been addressed in the revised Erosion and Sediment Control Plan and supporting calculations prepared by PLD, LLC. 6. In addressing Item #6 we have included the information we have available to us, including copies of past email correspondences in which we requested correction of the "sooner" versus "later" language error. We have also included an affidavit from former Wake Stone Corporation CEO John R. Bratton in which he provides his recollection of the origin of Reclamation Condition No. 5. In addition to the two (2) printed copies of these response items as requested in your letter of April 14, 2021, we are also providing a USB memory device containing a digital (PDF) version of these materials. We believe these additional data will provide you the final information you need to move forward to permit issuance. Should you have additional questions, we are available by phone, email, or MS Teams to provide responses. Sincerely, Wake Stone Corporation David F. Lee Environmental Supervisor Wake Stone Corporation Triangle Quarry Mining Permit No. 92-10 Narrative response to ADI Letter #3, item #1: 1. Please supply a list of all equipment that was modeled and its location for the "Wake Stone Triangle Quarry Expansion Acoustical Study". WSC Response Per DEMLR's item #1 request, following are a tabulated listing of all noise sources modeled during compilation of the "Wake Stone Triangle Quarry Expansion Acoustical Study". 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Please supply a copy of the March 12, 2021 "Wake Stone Triangle Quarry Expansion Acoustical Study' that provides tracked changes from the February 11, 2021 draft version. WSC Response Wake Stone has provided both the draft and final versions of the "Wake Stone Triangle Quarry Expansion Acoustical Study" in paper and PDF form to prevent unauthorized changes to the document. However, to satisfy this request we have provided the March 12, 2021 PDF with all changes highlighted in Adobe and "comments" that can be viewed in Adobe or summarized and printed after each page. These additional comments not only describe the changes, but also indicate the reasons for the edits, including which items are addressed from the Noise Study specific ADI letter dated February 25, 2021. Although incorporated into the final study, and not separately requested by DEMLR, we offer the following responses to those comments: General Comments: A 10d8A increase/decrease seems to be course measure of significant impact. The Division understands that this standard is used by NCDOT and other agencies evaluating noise impacts. However, considering a state park is adjacent to the proposed quarry, the Division believes a more conservative standard should be considered. Please provide further justification for a use of this standard. After DEMLR raised this issue, Wake Stone and WSP had much discussion about defining "significant adverse effect" as it relates to noise impacts. As indicated on page 6 of the report, "humans can barely perceive a change in noise level of+/-1 decibel, can likely perceive a change of +/- 3 decibels, and can easily perceive a change of +/- 5 decibels...". Based on this description, we concede that a 5 dBA increase, as easily perceived, may constitute a negative or adverse impact. However, to rise to the level of "significant," we agreed that the use of + 10 dBA was justified. Although not included in the original draft report, as was stated above, NCDOT and others have used the 10 decibel increase as a criteria for requiring mitigation. Furthermore, it should be noted that although potential quarry noise has been called into question as a potential "significant adverse effect on the purposes of a publicly owned park, forest or recreation area," there is nothing in the North Carolina Division of Parks and Recreation mission or purpose that has any reference to noise or the expectation of the absence of noise. See pages 2-3 of the William B. Umstead State Park General Management Plan (attached). Considering that the noise impacts of RDU Airport, US Interstate 40, and US Highway 70 (which is currently proposed to be widened and expanded) all far exceed the noise impacts associated with the expansion of the quarry, and considering that the area of Umstead Park that is nearest the expansion area is closer to RDU Airport and does not have any established trails, campgrounds, or other facilities, there is nothing to suggest that a more stringent standard should be considered for defining "significant adverse effect." • During our discussion, Wake Stone described several conservative assumptions that were included in the model. Please provide a comprehensive list of these assumptions. This list is highlighted on page 17 of the attached Wake Stone Triangle Quarry Expansion Acoustical Study. Report Specific Comments: • Please include further discussion of the usage factors for equipment noise implemented in the modeling (p. 18). This discussion has been highlighted at the bottom of page 19 of the attached Wake Stone Triangle Quarry Expansion Acoustical Study. • On p. 17, a ground factor of G=0.5 was used for the quarry. Please provide a discussion explaining why this is appropriate. The use of "Less -absorptive ground factors" is one of the conservative assumptions described above. The photo of the processing plant and stockpile area added on page 17 of the Wake Stone Triangle Quarry Expansion Acoustical study was also intended to support the use of a ground factor of G=0.5. • Table 4, p. 20 — Please provide a detailed explanation of how the "existing 1-40 traffic" was modeled. The description of Table 4 on pages 20-21 of the Wake Stone Triangle Quarry Expansion Acoustical Study provides the detail requested. • Blasting noise discussion p. 22 — Please explain how the blasting noise ranges compare similarly between the existing and proposed pits. The maximum blasting noise from the proposed pit seems significantly higher than the existing pit. This is explained on page 23 of the Wake Stone Triangle Quarry Expansion Acoustical Study. Because most of the receptors requested are located closer to the expansion area than to the existing operation, it was anticipated that blasting noise levels would increase at those locations, particularly during the "worst case" earliest stages of pit development. However, just as the current quarry pit has over the years, blasting noise is expected to diminish as the expansion pit gets deeper. • Footnote of Table 6, p. 22 — Please provide an explanation of how blast noise is not used for compliance purposes. Per our discussion, you indicated that the blast noise was included in the hourly averaging of the study. Please describe this. Footnotes on pages 22 and 23 of the Wake Stone Triangle Quarry Expansion Acoustical Study have been revised to clarify that blasting noise is included in the modeled Leq noise levels. The Lmax data shown on Table 6 is a different metric which should not be compared to Leq data. • Please describe why back-up alarms were not included in noise study. Backup alarms were included in the noise study and addressed extensively on page 24 of the Wake Stone Triangle Quarry Expansion Acoustical Study. Backup alarms were not included in the model, which is common practice in modeling industrial activities for two reasons: 1. Predicting the duration and location of backup alarms is challenging and subject to constant change. 2. Although easily identifiable because of their high frequency relative to other noises, the sporadic, short -duration sounds from backup alarms would not be expected to contribute significantly to Leq modeled noise. Wake Stone has also already committed to the use of the more attractive "white noise" backup alarms recommended by WSP USA, Inc. WSP USA, Inc. 100 Summer Street " Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Wake Stone Triangle Quarry Expansion Acoustical Study Prepared For: Wake Stone Corporation 222 Star Lane Cary, NC 27513 Prepared By: WSP USA, Inc. 100 Summer Street Boston, MA 02111 Revision Date: 12 March 2021 1/29 WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Table of Contents Executive Summary...............................................................................................................Page 3 ProjectDescription................................................................................................................Page 4 Acoustical Terminology.........................................................................................................Page 6 RegulatorySetting.................................................................................................................Page 8 Existing Noise Measurements.............................................................................................Page 10 Noise Prediction Model........................................................................................................Page 17 NoiseModel Results.............................................................................................................Page 20 BlastingNoise.......................................................................................................................Page 22 BackupAlarms.....................................................................................................................Page 24 Sound Isopleth Contours.....................................................................................................Page 24 Conclusions..........................................................................................................................Page 25 Professional Qualifications..................................................................................................Page 25 2/29 WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Executive Summary A comprehensive environmental acoustical study was performed to evaluate noise potentially generated by the expansion of the Wake Stone Triangle Quarry located at 222 Star Lane in Cary, North Carolina. The quarry has been in operation since 1982. With approaching depletion of reserves in their existing pit (Pit 1), Wake Stone plans to expand to the adjacent RDUAA Odd Fellows Tract for opening of a second pit (Pit 2). Concern has been expressed for the possible noise consequences associated with the new pit expansion with respect to noise levels propagating through the adjacent William B. Umstead State Park (Umstead State Park). In order to receive an expansion permit from the North Carolina Department of Environmental Quality (NCDEQ) Division of Energy Mineral and Land Resources (DEMLR), Wake Stone must demonstrate that noise from their new operations will not have a "significantly adverse effect on the purposes of a publicly owned park, forest or recreation area . To that end, this acoustical study was performed, taking into account the noise mitigation measures that Wake Stone has already publicly committed to install. The study was performed in accordance with the agreed and accepted methods described in Wake Stone Noise Study Protocol dated 9/2/20. Ambient and existing operational noise levels were measured throughout Umstead State Park, existing and future operational noise levels were modeled to compute the changes in noise level expected in the park, and the results were evaluated against commonly accepted definitions of significant noise impact, i.e. future noise levels should not increase by more thanq to 10 decibels above existing noise levels. The results of the acoustical study found that, under worst -case noise producing conditions, noise levels throughout Umstead State Park are expected to remain well below the g to 10- decibel relative increase limit definition. Thus, Wake Stone's expansion and operation of Pit 2 are not expected to cause a significantly adverse noise impact in the park. Some particular activities conducted in the new pit will be audible in portions of the park, just as they are today. However, future noise levels are expected to only increase by 0 to 3 decibels throughout the vast majority of the park. The following report details the methodology, assumptions, noise measurement and modeling results, relevant criteria, findings and conclusions of the acoustical study. 0 3/29 Summary of Comments on Microsoft Word - Wake Stone Triangle Quarry Expansion Acoustical Study (Final 3-18-21).docx Page: 3 iTINumber: 1 Author: catkins Subject: Highlight Date: 4/14/2021 3:54:51 PM — Number: 2 Author: catkins Subject: Sticky Note Date: 4/14/2021 4:08:03 PM The original draft report used only +10 dB language. We acknowledged that when analyzing standards for noise criteria, +5 dB is sometimes used or even +5 to +10 dB. TI Number: 3 Author: catkins Subject: Highlight Date: 4/14/2021 3:54:59 PM WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Project Description Wake Stone Triangle Quarry is located at 222 Star Lane in Cary, North Carolina. The quarry has been in operation since 1982. With the approaching depletion of reserves in their existing pit (Pit 1), Wake Stone plans to develop a second pit (Pit 2) on the adjoining RDUAA Odd Fellows Tract, as shown in Figure 1. Concern has been expressed for the possible noise consequences associated with expansion of the new pit with respect to noise levels propagating through the adjacent Umstead State Park. Once Pit 2 is approved for operation, the plan would include winding down and ceasing extraction operations in Pit 1 but to still make use of the surface equipment in its current location to process aggregate reserves excavated from Pit 2. Aggregate reserves in Pit 2 will be loosened using controlled blasting and then loaded in trucks for transport to the existing primary and secondary production plants. Thus in total, the only thing that's changing from a noise perspective is where the mobile noise sources will be located. Typical heavy earth moving equipment currently used in Pit 1 and the existing plant and stockpile yard areas include bulldozers, backhoes, excavators, front end loaders, rock drills, rock crushers, feeders, vibrating screens, conveyors, haul trucks, graders, water trucks, pumps and man -lifts. Similar equipment will be used in Pit 2 also, with the exception of stationary equipment. Blasting is anticipated to be performed a couple times a week to loosen new material for excavation. Work hours are generally from 7 AM to 5 PM. Figure 1. Wake Stone Triangle Quarry Existing and Proposed Excavation Pits Conceptual Mine Pion for Triangle Quarry Expansion RQU Mcuntcfn Bike Cenier IS01--r- f,( Umstecd 51cte Park Mu Pit 2 `.a � � � e� s Pit 1 ,•�J�>f � 44 `♦ F � w 4/29 WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US The Umstead State Park is a forest recreational area located immediately adjacent to the north and east of the Wake Stone Triangle Quarry. The area is a mature forest with approximately an even split between deciduous and conifer trees. Visitors have used the park since 1937 for hiking, bicycling, picnicking and seasonal camping. Various trails run through the park, with the majority of fixed sites (picnicking and camping) located relatively close to Wake Stone's existing facilities and operations in Pit 1. To that end, moving extraction operations to Pit 2 should be a noise benefit (i.e. reduction) for these picnic and camping sites. There is also one residence located along Old Reedy Creek Road immediately to the west of the new Pit 2 site at which noise levels would likely increase due to Pit 2 being located closer to the residence than exists today for Pit 1. '-highway I-40 runs along the southern boundary of the quarry and the park causing traffic noise to be audible in both properties. Lastly, it should be noted that the park is bordered on the northwest by Raleigh Durham International Airport. Use of Runway 32-14 routes aircraft directly over Umstead State Park. 0❑ 5/29 Page: 5 Number: 1 Author: catkins Subject: Sticky Note Date: 4/14/2021 4:15:52 PM This sentence was added as background information important to understanding that an increase in "Quarry -Only" noise does not necessarily mean that the current or future noise attributable to quarry activities is/will be the predominant noise at any location in or around the park. J Number: 2 Author: catkins Subject: Highlight Date: 4/14/2021 4:10:39 PM WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Acoustical Terminology As with any field of science, it is critical to understand and make proper use of technical terms and definitions that are used in the acoustical industry. Noise can be quantified in many different manners depending on its temporal/time, tonal/frequency, or magnitude/loudness properties. Noise magnitude is expressed in units of decibels (dB) which is a logarithmic quantity comparing fluctuating air pressure to that of a standardized reference static air pressure of 20 micro -pascals (i.e. dB re: 20 µPa). For this reason the noise levels that humans hear are called sound pressure levels. Noise is expressed as a logarithmic quantity because humans are sensitive to relative changes in noise levels. To illustrate, humans can barely perceive a change in noise level of +/- 1 decibel, can likely perceive a change of +/- 3 decibels, can easily perceive a change of +/- 5 decibels, and will generally describe a change of +/- 10 decibels as a doubling or halving in level. With respect to tonal qualities (frequency), a frequency weighting adjustment has been standardized to account for the human auditory response over the audible frequency range of approximately 20 Hz to 20,000 Hz. Humans are less capable of hearing low frequency sounds, exhibit a maximum sensitivity to tones in mid -frequency ranges, and are slightly less sensitive to high frequency sound as well. This frequency weighted adjustment is referred to as "A - weighting", with results expressed as A -weighted decibels, or dBA. Examples of A -weighted decibel levels for common outdoor and indoor noise sources are provided in Figure 2. Another common practice is to separate a sample of noise into its spectral components by using frequency filters of known shape and bandwidth. This approach provides insights into the source and transmission characteristics of the noise and allows for identification of frequency ranges that contain the most acoustical energy. Octave band and third -octave band filters are typically used for this purpose because their bandwidths are a constant percentage of their center frequencies, and are better for mimicking how humans perceive discrete frequencies by providing finer resolution at lower frequencies. Numerous metrics and indices have been developed to quantify the temporal characteristics (changes over time) of community noise that include the following: The Equivalent Sound Level, or Leq, is the energy -averaged single noise level that represents the same acoustic energy that was contained in the fluctuating noise level over a defined period of time. The Leq is useful for describing the "average" sound level over a defined period of time, and is expressed in dBA. The Maximum and Minimum Sound Levels, or Lmax and Lmin, are the loudest and quietest instant sound levels occurring during a period of time. The Lmax is particularly useful for evaluating loud, impulsive noise events. Lmax and Lmin levels are expressed in dBA, however the root -mean -square (RMS) time constant of the sound level meter's detector has a significant effect on the measured levels. By International agreement, a sound level meter with an RMS response set to 'slow' (Lmaxs) has a rise time constant of 1 second, where a setting of 'fast' (Lmaxf) is about 8x faster with a rise time constant of only 0.125 seconds. The Day Night Sound Level, or Ldn, is a 24-hour community noise metric in which a 10 decibel adjustment has been added to the measured hourly Leq levels from 10 PM to 7 AM to account for people's greater sensitivity to noise intrusion at night. The Ldn metric is used in many federal noise guidelines to assess the long-term effects of transportation sources. The Sound Percentile Level, or Ln, expressed in dBA is a statistical representation of changing noise levels indicating that the fluctuating noise level was equal to, or greater than, the stated level for "n" percent of the time. For example, the L1, L10, L50, and L90 represent the noise 6/29 WSP USA, Inc. " 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US levels exceeded 1%, 10%, 50%, and 90% of the time. The L10 is often used to identify impacts of transportation or construction noise sources, while the L90 is considered to represent steady background noise. Figure 2. Common A -Weighted Decibel (dBA) Sound Levels Noise Scale: Common Sound Levels Common Outdoor Noise Level Common* Indoor Sound Levels dB (A) Sound Levels 110 110 RodrBand halide Subway 100 100 Trait 8-747-200Takeaff at 2 miles {New York) Gas Lawn Mower at 3 feet DwATrudt g0 90 foodMender 40— at ISo feet at 3 ket DC-9-30Takeoif Loud Voice iMSM at 2 miles Garbage LkspoW Maim Metropolis Da}tirne so go at 3 feet 13-757TakeoN at2 mllies High"TraffCat50Teet 70 70 Vacuum Clea eat10feet baCommerM Normal Speech Area 60 � 60 SuburbanDaymme Runt Urban Daytime SO - - r�l Lam Rusinessofte Dishwasher Next Room RuialDeylkrre Refrigerator quMurban SmallThater Nght4ne 40 40 Large Confer€nee Room gtdat4ubaubart Ind) Nighttina Library 30 30 udr omirtlilght quietRura6NigMtinre CarcartHall 20 20 Broadcast & Recording Studio 10 10 0 0 Ybresholdof Hearing --' The Sound Power Level (PWL) of a noise source is the strength or intensity of noise that the source produces/emits regardless of the environment in which it is placed. Sound power is a property of the source, and therefore is independent of distance. The radiating sound power then produces a Sound Pressure Level (SPL) at any given point of interest which human beings perceive as audible sound. The sound pressure level is dependent on its environment (absorption, reflections, etc.) and its distance from the noise source. And even though both sound power and sound pressure are expressed in decibels (dB), they are not the same thing and should not be confused. Decibel levels of sound power are referenced to a power level of 1 pW, while decibel levels of sound pressure have a pressure reference level of 20 µPa. 7/29 WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Regulatory Setting According to the North Carolina Mining Act of 1971 administered by the North Carolina Department of Environmental Quality (NCDEQ) Division of Energy Mineral and Land Resources (DEMLR), Wake Stone must obtain a modification of their current Mining Permit in order to expand their operations. Wake Stone must demonstrate that noise from their new operations in Pit 2 will not have a "significantly adverse effect on the purposes of a publicly owned park, forest or recreation area". However, the Mining Act does not quantitatively define what is meant by "significantly adverse effect". Thus, a task in this study involves research into the noise guidelines promulgated by other federal and state agencies with respect to noise impact for an outdoor park land -use. Table 1 summarizes some of these other noise guidelines. The natural soundscape is comprised of physical and biological sounds. Physical sound is created by wind, rivers, rock falls, etc., whereas biological sound is created by animals, birds and insects. Different habitats have specific soundscape characteristics depending on the climate, landscape and animal population. Evaluation of the level of impact on natural soundscape generated by human activity is dependent on the specific habitat in question. The State of North Carolina does not regulate noise, so the responsibility is on the local governments. Noise ordinances of the counties where Wake Stone operations occur do not specifically mention noise criteria for parklands. In order to determine the noise criteria applicable for parklands, guidance documents published by various agencies were reviewed and the quantitative recommendations are summarized below. Table 1. Various Noise Criteria for Parklands and Wilderness Areas Guidance Source Recommended Noise Criteria US National Parks Services (NPS) 45 dBA L10 and 38 dBA L50 US Federal Highway Administration (FHWA) 57 to 67 dBA Leq(1hr) US Federal Railroad/Transit Administrations (FRA/FTA) +5 to +10 dBA Leq(h) above Ambient US Federal Aviation Administration (FAA) 70 to 75 dBA Ldn US Environmental Protection Agency (EPA) 70 dBA Leq(24hr) or 55 dBA Ldn Federal Energy Regulatory Commission (FERC) 55 dBA Ldn and 49 dBA Leq Federal Interagency Committee on Noise (FICON) +5 dBA if Ambient is <60 dBA, +3 dBA if 60-65dBA, +2 dBA if Ambient is >65 dBA World Health Organization (WHO) 50 to 55 dBA Leq Worth Carolina Department of Transportation (NCDOT) 67 dBA Leq(h) or an increase of +10 dBA 3 assachusetts Environmental Protection (MassDEP) Increase of +10 dBA above L90 Ambient Washington State 55 dBA 07:OOAM to 10:OOPM 45 dBA 10:OOPM to 07:OOAM Minnesota State 65 dBA L10, 60 dBA 1,50, 07:OOAM to 10:OOPM 55 dBA L10, 50 dBA 1,50, 10:OOPM to 07:OOAM 0 8/29 Number: 1 Author: catkins Subject: Highlight Date: 4/14/20214:17:55 PM —Number: 2 Author: catkins Subject: Sticky Note Date: 4/14/2021 4:22:43 PM These 2 additional guidance sources were added in defense of maintaining the use of +10clBA as "significantly adverse effect." We believe the criteria established by NCDOT is particularly relevant because it defines +10 dBA as "substantial." ]Number: 3 Author: catkins Subject: Highlight Date:4/14/2021 4:17:58 PM WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US The US National Parks Service (NPS) recommended noise criteria is mostly intended for non - metropolitan area national and state parks. Umstead State Park is located within an expanding metropolitan area. As such, stringent NPS recommended criteria of 45 dBA L10 and 38 dBA L50 is too conservative. The Federal Energy Regulatory Commission (FERC) guidance document "Guidance Manual for Environmental Report Preparation, February2017 is intended for natural gas projects and pipelines. Section 4.9.2 of the FERC guidance document recommends a continuous noise level of 49 dBA Leq as criteria for Noise Sensitive Areas (NSA) which include parklands, campgrounds, and wilderness areas. This criteria can be adopted for quarry operations in proximity to parklands, however absolute noise level limits do not apply well in this situation given the fact that the Wake Stone Triangle Quarry has been in operation since 1982, and the location is in a metropolitan area surrounded by busy state and interstate highways. The focus should be placed on how much more noise might Wake Stone be producing in the future when Pit 2 is opened for operation. As shown in the previous section, humans can barely perceive a change in noise level of +/- 1 decibel, can likely perceive a change of +/- 3 decibels, can4pically perceive a change of +/- 5 decibels, and will generally describe a change of +/- 10 decibels as a doubling or halving in level. From this commonly accepted subjective response description, acousticians and regulatory agencies have generally agreed that a 9-decibel increase would represent the onset threshold of audible changes, and a 10-decibel increase would be a significant noise impact. Moreover, the State of North Carolina Department of Transportation (NCDOT) has defined the term substantial noise increase in their Traffic Noise Policy dated 10/6/16. In it, a receptor is considered impacted by noise if the predicted future hourly Leq equivalent noise level exceeds the existing ambient Leq noise level by 10 decibels or more. Consequently,4here a 5-decibel increase might be perceptible, it requires a greater increase in noise level to constitute a significant increase. Thus, this acoustical study has defined a "sianificantly adverse effect" as meaning a 10 decibel or more increase in future noise levels when compared to existing noise levels. 0 9/29 EM Number: 1 Author: catkins Subject: Highlight Date: 4/14/20214:25:34 PM 11 Number: 2 Author: catkins Subject: Highlight Date: 4/14/2021 4:25:23 PM —,Number: 3 Author: catkins Subject: Sticky Note Date: 4/14/2021 4:32:58 PM Again, in defense of using +10 dBA as "significant," we acknowledge that +5cIBA would likely be noticeable, and somewhere between +5 and +10 would likely be considered a negative effect. However, to achieve the level of "significant adverse effect," use of a 10 dBA increase isjustified. JNumber: 4 Author: catkins Subject: Highlight Date: 4/14/20214:26:24 PM WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Existing Noise Measurements Existing ambient noise measurements were performed in and around Umstead State Park from 11/16/20 to 11/23/20 and again from 12/7/20 to 12/14/20. Long-term noise measurements lasting a week were performed at the six monitoring locations (LT-#) shown in Figure 3. The purpose of the long-term noise measurements were two fold, (1) to document actual existing noise conditions at selected locations throughout the park, and (2) to serve as a measured noise level against which modeled existing noise levels could be compared to ensure the model was performing as expected. Larson Davis Model 720 (LD-720) environmental noise monitors were used to measure the long-term noise data. The monitors were checked for proper calibration before and after use using a Bruel & Kjaer Model 4231 acoustical calibrator. As such, the noise monitoring system met or exceeded the accuracy requirements found in ANSI Standard S1.4 for Type 2 quality. The monitors were deployed in trees at the respective sites and the microphones were covered with windscreens. Noise data was digitally stored in hourly intervals with noise metrics including Leq, Lmax, Lmin, L1, L10, LSO and L90 sound levels. All sound levels were expressed in A -weighted decibels (dBA) using an RMS `slow' response. Figure 3. Long -Term Ambient Noise Monitoring Sites 10/29 WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US The averaged results of the long-term noise monitoring data are summarized in Table 2 for the hours of 7:00 AM to 5:00 PM during which time Wake Stone is typically operating. Three scenarios are provided, (1) time periods when the quarry was in full production mode, (2) periods when the quarry was on a reduced work schedule performing mostly maintenance activities, and (3) Sunday periods when no work was being performed. The results in the table indicate that noise produced by existing operations in Pit 1 may be audible throughout the park but only to a minor degree when compared to the relatively low noise produced during maintenance periods. Interpreting results relative to no work periods is difficult because all transportation and community noise sources are less noisy on Sundays. Table 2. Measured Leq Noise Levels During Work Hours Site No. Location in Umstead State Park Measured Leq (7AM - 5PM) dBA Difference vs. Production dB Production Main- tenance Sunday No Work Main- tenance Sunday No Work LT-1 Picnic Grounds 53 51 48 -2 -5 LT-2 Company Mill Trail 50 49 46 -1 -5 LT-3 Residence Property Line 55 57 53 1 -3 LT-4 Mid Gate 52 48 45 -3 -6 LT-5 Trenton Road Gate 51 49 46 -2 -5 LT-6 Sendero Gate 47 43 43 -4 -4 Note: Sound levels rounded to the nearest full decibel. The results of the six long-term noise monitors are shown in Figures 4 thru 9. The data collected over the week was reduced by averaging the results of each corresponding hour during the week. Thus the results yield typical hourly noise levels that can be expected at each monitoring location. The blue dot is the computed Ldn level and the average Lmax, Leq, and L10 and L90 percentile levels are shown for each hour. The Lmax level could have been caused by any loud event such as a nearby bird chirp, crow call, aircraft, or noise produced by Wake Stone's operations. The Leq, L10 and L90 results are more indicative of constant noise levels throughout the park. The effects of morning and evening commuter traffic (i.e. rush hour) is evident centered around 7:00 AM and 5:00 PM, respectively. More notably, the L10 levels at all sites are already well above the National Park Service's recommended noise guideline of 45 dBA L10 at all times of day and night regardless of Wake Stone's operations. 11/29 WSP USA, Inc. " 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Figure 4. Long -Term Ambient Noise Levels for Site LT-1 90 so d 75 0 N 70 N a W 6s v 'y 60 .0 55 Z -o 50 M 45 90 35 30 Typical 24-hour Ambient Noise Levels Umstead Park, Site 1 11/16/20 - 11/23/20 �/ Illl�lllllillllllilll " b g g $ o n m e �n e r oo m Time of Day (Start Ho of ur) —Lmax —Leq —L10 —L90 Figure 5. Long -Term Ambient Noise Levels for Site LT-2 Typical 24-hour Ambient Noise Levels Umstead Park, Site 2 11/16/20 - 11/23/20 90 85 80 - — — — — -- —. --- _ —. — ---. --. — —. a 75 t — — — — - - — tl t__ t� 70 CO 65 N W Q W 'C 55 _ 50 m W 45 40 35 30 c o N M N ^Time of Day (Start of ur) Ho . . . . . ., -Lmax -Leq -L10 �00 12/29 90 so d 75 0 N 70 N a W 6s v 'y 60 W 0 55 2 -o 50 M 45 40 35 30 WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Figure 6. Long -Term Ambient Noise Levels for Site LT-3 0 Typical 24-hour Ambient Noise Levels Umstead Park, Site 3 12/7/20-12/14/20 S S 4 8 8 S 8 m e n e r oo m Time of Day (Start of Hour) -Lmax -Leq - 110 -L90 Figure 7. Long -Term Ambient Noise Levels for Site LT-4 Typical 24-hour Ambient Noise Levels Umstead Park, Site 4 12/7/20 - 12/14/20 90 85 80 p 75 N N .. 70 W Q v 65 W N 60 0 55 Z d 50 m 45 40 35 30 S o N M N ^ Time of Day (Start of Hour) -Lmax -Leq -L10 -L90 13/29 90 so d 75 0 N 70 6 a 0 65 v 'y 60 W 55 2 50 7 A 45 40 35 iU 90 85 80 p 75 0 N .. 70 W Q � 65 W y 60 J N 0 55 Z V 50 m 45 40 35 30 WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Figure 8. Long -Term Ambient Noise Levels for Site LT-5 Typical 24-hour Ambient Noise Levels Umstead Park, Site 5 11/16/20 - 11/23/20 ~ N m ^Time of Day (Start of Hour) - - - - - - - - - - -Lmax -Leq -LSO -190 Figure 9. Long -Term Ambient Noise Levels for Site LT-6 Typical 24-hour Ambient Noise Levels Umstead Park, Site 6 11/16/20 - 11/23/20 o N M -Cr N ^Time of Day (Start of ur) Ho . . . ., N -Lmax -Leq - L30 -L90 14/29 WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US In addition to long-term monitoring, short-term noise measurements, lasting 15 minutes, were also manually performed at four selected sites in Umstead State Park during the weeks of 11/16/20 to 11/23/20 and 12/7/20 to 12/14/20. A Svantek Model 971 (SV-971) sound level meter was used for these measurements, which meets the requirements for ANSI Standard S1.4 for Type 1 accuracy. The purpose of the short-term noise measurements was to positively identify and correlate audible noise sources with the sound levels being measured. This was particularly important to perform during the production blasts occurring during the monitoring periods. Short-term noise data was collected during full quarry operation with blasting in the morning and the afternoon, full quarry operation with no blasting in the morning, reduced quarry operation maintenance day in the afternoon, and in the morning with the plant closed. A summary of the short-term noise data results are shown in Table 3. While in Umstead State Park, noticeable noise sources included traffic noise from local roads, overhead aircraft and helicopter noise from RDU airport, and typical nature noise, such as running water, rustling leaves, birds, and insects. At monitoring locations closest to the quarry, noise levels between the quarry and I-40 were nearly indistinguishable, except for the backup alarms from equipment operating in the quarry. During blasting, warning sirens employed prior to the blast could be heard from inside Umstead State Park. The blast, which only occurs for a fraction of a second, was noticeable by ear and could be felt as well as being heard. A final siren followed the blast for about one minute. Table 3. Short -Term Noise Measurements Results Site No. Site Location Measured Short -Term Noise Level L10 dBA Leq dBA L90 dBA ST-7 Foxcraft Lake 47 45 42 ST-8 Entrance Gate Trail 46 44 41 ST-9 I-40 & Old Reedy Creek Road 71 70 68 ST-10 Campgrounds 43 42 38 Note: Sound levels rounded to the nearest full decibel. The measurement data was later reviewed to identify and isolate the blast event that occurred during short-term measurements at sites ST-7 and ST-8 on 11/18/20 at 13:40. The sound level data was stored in 1-second intervals and an audio wavefile was recorded throughout the measurement. The recorded wavefiles were listened to while simultaneously viewing the measured noise data in order to audibly identify the 1-second interval where the maximum sound level from the blast occurred. The noise level during the blast was 59 dBA at Site ST-7 and 47 dBA at Site ST-8. The measured blast sound level was later also used to estimate the sound power emission of the blast for use in the noise model. 15/29 WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Further analysis was conducted by comparing the noise produced by the blast event to that of other common environmental sound sources of comparable loudness captured during the 15-minute short-term noise measurements. In this case, as shown in Figure 10, two aircraft overpasses were identified as being within 5 decibels of the blast noise level. The vertical axes of the charts are the same scale for ease in visual comparison. Figure 10. Comparison of Blast Noise Level to Other Noise Sources Blast Event: 59 dBA Leq(1s) at Site M-7 on 11/18/20 Time Aircraft Overpass: 54 dBA Leq(1s) at Site M-7 on 11/23/20 )9:01:15 AM 09:01:30 AM 09:01:45 AM 09:02:00 AM 09:02:15 AM 09:02:30 AM 09:02:45 AM 09:03:00 AM 09:03:15 AM 09:03:30 AM 09:03:45 AM Time Aircraft Overpass: 55 dBA Leq(1s) at Site M8 on 11/23/20 09:28:30 AM 09:28:45 AM 09:29:00 AM 09:29: 15 AM 09:29:30 AM 09:29:45 AM 0930:00 AM 09:30:15 AM 09:30:30 AM 09:30:45 AM 09:31:00 AM n- 16/29 WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Noise Prediction Model Noise levels associated with operation of the existing quarry (Pit 1) and future quarry (Pit 2) were predicted using the Cadna-A® noise model, developed by DataKustik, GmbH. The Cadna-A model implements ISO Standard 9613 for environmental noise sources and outdoor sound propagation. It is a comprehensive, three-dimensional, ray -tracing model in which noise sources are assembled from point, line and/or area components each emitting sound power levels (PWL) in octave bands or broadband A -weighted format. Distance losses, elevation differences, ground attenuation, wind effects, building shielding, attenuation through walls, and barrier/berm effects are computed in the Cadna-A model, and the resulting sound pressure levels (SPL) are predicted at any number of receptors of interest. As is standard practice, all receptors were modeled at a height of 5 feet above the ground. As shown in Figure 11, the Cadna-A base model for the project was developed by importing geo-referenced aerial imagery along with topographic contour data in 2-foot intervals. The topographic contour data was provided by Wake Stone for the quarry areas and current North Carolina One -Map Lidar data was used for the surrounding regions of the study area. Conservative worst -case noise assumptions were used in populating the model. For example, all noise -producing equipment was assumed to be operating simultaneously. A ground factor of G=1.0 for soft ground was set as the default for the model. Specific areas with different ground types were then defined, including the quarry site with G=0.5 for mixed hard and soft ground, and water and paved areas with G=0.0 for hard ground. To represent worst -case noise conditions during winter when leaves would be off trees, areas with foliage were not included in the Cadna-A model. And it should be noted that per ISO 9613, a "favorable wind condition" was assumed in the model in which a mild wind blows towards each receptor regardless of where the noise sources are located. U brief summary of the conservative assumptions incorporated into the noise model include: • All equipment on site, including mobile and stationary equipment, were assumed to be operating simultaneously based on their usage factors averaged over a full week. • Less -absorptive ground factors were assumed for areas not covered with foliage such as for the quarry site with loose dirt piles and water surfaces, as shown in the picture to right. • Blasting, which will only occur a couple times a week, was assumed to be occurring during the typical hour (i.e. worst -case) averages reported herein. • No attenuation was assumed for foliage. • Favorable wind conditions blowing from the noise source towards each receptor was assumed. A 17/29 Page: 17 Number: 1 Author: catkins Subject: Sticky Note Date: 4/14/2021 6:11:32 PM As requested in the General Comments of the Noise Study ADI letter, this list of conservative assumptions used in the noise model was added. Also added is a photograph of the plant and stockpile area to support the use of less absorptive ground factors. J Number: 2 Author: catkins Subject: Highlight Date: 4/14/2021 4:39:55 PM WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Figure 11. Perspective View of Cadna-A Noise Model (Looking Northeast) The Cadna-A base model was then configured to estimate noise levels generated by the quarry operations for the following conditions: • Existing Production - includes the current production activities in Pit 1, hauling of rock to the primary crusher, and typical crushing, plant and yard operations. • Future Overburden Clearing - includes clearing of overburden at the expansion Pit 2 and hauling of overburden across the proposed Crabtree Creek Bridge to the overburden storage area on the west side of Pit 1. This condition also includes the same typical crushing, plant and yard operations as the Existing Production condition. • Future Production - includes production at the expansion Pit 2 and hauling of rock across the proposed Crabtree Creek Bridge around the north side of the existing Pit 1 to the primary crusher. This condition also includes the same typical crushing, plant and yard operations as the Existing Production condition. The Future Production condition was further divided into four scenarios (280got, 2669ot, 210-R)ot and 1601%ot) based on the elevation of projected working benches in the expansion Pit 2. These scenarios were modeled individually to represent how the production work will decrease in elevation over time as the new pit is excavated. It should be noted that worst -case noise producing condition occurs when equipment is operating at grade, i.e. Future Production at 280 feet. ❑0 18/29 Page: 18 Number: 1 Author: catkins Subject: Sticky Note Date: 4/14/2021 4AS:31 PM Just replaced abbreviated "ft" with "foot." LTI Number: 2 Author: catkins Subject: Highlight Date: 4/14/2021 4:44:00 PM Number: 3 Author: catkins Subject: Highlight Date: 4/14/2021 4:44:03 PM LTJ Number: 4 Author: catkins Subject: Highlight Date: 4/14/2021 4:44:08 PM LTI Number: S Author: catkins Subject: Highlight Date: 4/14/2021 4:44:10 PM WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US For each of these conditions, noise levels generated by the quarry were estimated for a typical hour of operations with all equipment operating. Noise model inputs included: The locations of existing and future production areas where mobile equipment would be operating, haul truck routes, customer truck routes, and locations of EAI crushers conveyors, plant and yard equipment. Sound power levels of mobile equipment were primarily derived from noise emission measurements taken during Wake Stone quarry operations. For stationary processing plant equipment (crushers, screens, and conveyors), sound power levels were estimated based on a review of technical literature for similar equipment. For mobile heavy equipment sound power emission levels were taken from the FHWA's Roadway Construction Noise Model (RCNM). 0 • The estimated number of hours per week, obtained from Wake Stone, that each piece of mobile and stationary equipment is used during a typical 50-hour work week was used 0 to calculate a usage factoA representing the percentage of time each piece of equipment is operating during a typical hour of production. The equipment -specific usage factors were then applied as an adjustment to the equipment sound power levels within the Cadna-A model. • For the future overburden clearing and production scenarios, proposed terrain contour lines in 2-foot intervals for the expansion Pit 2, widening of haul roads, and the new bridge over Crabtree Creek were also included. For the future overburden clearing and production scenarios, two noise mitigation measures that Wake Stone has already committed to were included in the noise model: 1. An approximately 15ot tall earthen berm on the north and west sides of the expansion Pit 2. 2. An approximately 14 1ot tall noise wall to the north of the haul road along the north side of the existing Pit 1. � s is standard practice, noise emitted by backup alarms was not included in the noise model. This is due to several reasons, (1) it can be difficult to anticipate where and when a vehicle will need to backup, (2) the alarms are a required safety device, and (3) the alarms are not that loud with respect to receptors located more than a few hundred feet away. For example, a typical loud pure -tone backup alarm might emit a sound level of 105 dBA Lmax at 4 feet behind the vehicle. This would reduce to only 77 dBA Lmax at 100 feet, and would be down to 63 dBA Lmax at 500 feet. When averaged over an hour, the results would be negligible. 0 0 Note (*) - The acoustical usage factor is the standard way that construction equipment noise is computed when averaging it over some time period. It takes into account the fraction of time the equipment is operating at full power (i.e. loudest) during a typical work shift, in this F1 o case averaged over a 50 hour work week. The acoustical usage factor affects the resulting Leq sound levels, but the generated Lmax sound levels remain unchanged. 19/29 Page: 19 Number: 1 Author: catkins Subject: Highlight Date: 4/14/20214:46:09 PM Number: 2 Author: catkins Subject: Sticky Note Date: 4/14/2021 4:47:07 PM Replaced "the primary and stationary" crushers with "all" crushers for clarification. Number: 3 Author: catkins Subject: Sticky Note Date: 4/14/2021 4:49:15 PM see Note (*) below JNumber:4 Author: catkins Subject: Highlight Date: 4/14/20214:48:04 PM Number: 5 Author: catkins Subject: Highlight Date: 4/14/20214:48:17 PM Number: 6 Author: catkins Subject: Sticky Note Date: 4/14/2021 4:49:51 PM changed abbreviated "ft" to "foot" Number: 7 Author: catkins Subject: Highlight Date: 4/14/2021 4:48:19 PM J Number: 8 Author: catkins Subject: Highlight Date: 4/14/2021 4:50:29 PM ,Number: 9 Author: catkins Subject: Sticky Note Date: 4/14/2021 4:54:04 PM Per Report Specific Comments on the Noise Study ADI, this discussion of "why back-up alarms were not included" was added. It is important to note that back-up alarms were addressed in the noise study, theyjust were not included in the modeling portion of the study. —,Number: 10 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:00:08 PM Per the Report Specific Comment regarding usage factors, this note was added for clarification. It is also important to note that the usage factors were applied to both the current conditions and the future conditions. There was no attempt to minimize potential increases in noise. It is simply a means of refining the model to be more accurate. WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Noise Model Results Once the Cadna-A model was fully populated, it was allowed to run to compute resulting sound levels for the various quarry operating conditions at eight discrete receptor locations (R-#) in Umstead State Park as shown in Figure 3. Six of the receptors were selected to correspond with the long-term noise monitoring sites, and another two receptors were added in response to requests from DEMLR. The results are summarized in Table 4 and are expressed as typical hourly equivalent sound levels (Leq(1hr)) in A -weighted decibels (dBA). Again, the results shown in the table represent realistic worst -case conditions that assume all quarry equipment is running simultaneously. As can be seen in Table 4, sound levels from future Pit 2 operations are expected to range from 31 to 55 dBA Leq(1hr) across all eight discrete receptor locations in Umstead State Park. Naturally, the louder sound levels will occur closer to the quarry work, and the quieter sound levels will occur farther away. This range of anticipated sound levels compares very closely with the sound levels produced by existing quarry operations in Pit 1 which range from 31 to 52 dBA Leq(1hr). The results in Table 4 for receptors R-2 and R-3 are of particular significance from the point of view of ensuring that the Cadna-A noise model is calculating correct noise levels. Receptors R-2 and R-3 are the closest to Wake Stone's existing work in Pit 1. As such, it would be reasonable to expect that the measured and modeled noise levels at these two receptors should match relatively closely. As can be seen, the model is nearly perfectly calibrated with the measured noise results for existing noise during production hours. Thus, the model can be relied upon to predict accurate future noise levels as well. Table 4. Predicted Existing and Future Sound Levels for Quarry Operations Receptor Measured Predicted Average Hourly Noise Level, dBA Leq(1hr) Existing Production dBA Leq Existing Quarry Overburden Stripping Production 280 ft Production 266 ft Production 210 ft Production 160 ft Existing I-40 Traffic R-1: Residence Property Line LT-3: 55 46 49 49 48 47 46 58 R-2: Company Mill Trail LT-2: 50 50 51 52 52 52 52 38 R-3: Picnic Area LT-1: 53 52 52 52 52 52 52 50 R-4: Residences LT-5: 51 35 35 35 35 35 35 47 R-5: Reedy Creek Park Trail LT-4: 52 37 38 39 39 38 38 39 R-6: North Turkey Creek Trail LT-6:47 31 31 31 31 31 31 29 R-7: Foxcroft Lake N/A 50 55 53 53 52 52 45 R-8: Crabtree Creek N/A 48 49 50 50 50 50 38 Note: Sound levels rounded to the nearest full decibel. Table 4 also shows the predicted sound level attributable to traffic on I-40. These results are shown only for comparative purposes and have no bearing on the current noise analysis. The traffic noise levels were not measured; they were computed using the Cadna- A model by imputing traffic volumes, fleet mixes (i.e. trucks and cars) and Qpeeds counted during the 15-minute short-term noise field measurements (expanded to a full hour). The 20 / 29 Page: 20 Number: 1 Author: catkins Subject: Highlight Date:4/14/2021 5:01:15 PM 11 Number: 2 Author: catkins Subject: Highlight Date: 4/14/2021 5:02:09 PM WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Uodel can then compute just traffic noise (no other sources) in the surrounding vicinity in accordance with FHWA/NCDOT guidelines. It should be noted that the results shown herein are based on just one traffic count observance during a time frame when traffic volumes still might be lower than is typically the case due to COVID restrictions. Of more importance for the intent and goal of this study, the results in Table 5 show the noise delta increase (+) or decrease (-) for future Pit 2 operations relative to existing sound levels produced by Pit 1 operations. As can be seen, once the overburden has been cleared, none of the receptors are expected to be exposed to a noise increase greater than 3 decibels during all phases of production for Pit 2. In fact, the majority of receptors will not experience an increase of more than 1 decibel. For perspective, such minor noise level increases are typically considered to be trivial and insignificant from an acoustical engineering perspective. During the overburden stripping phase, future sound levels will be no louder than what is expected during the various production phases except at receptor R-7 Foxcraft Lake which might experience a temporary 4 decibel increase. Consequently, it can be concluded that noise levels associated with Wake Stone's future operations involving Pit 2 are expected to remain well below the selected 10-decibel increase criterion, and thus will not pose a "significantly adverse [noise] effect on the purposes of a publicly owned park, forest or recreation area din Umstead State Park]". Table S. Expected Differences in Sound Levels for Quarry Operations Receptor Predicted Future re: Existing Noise Level Delta, dB Overburden Stripping Production 280 ft Production 266 ft Production 210 ft Production 160 ft Production 280 ft vs 1-40 Traffic R-1: Residence Property Line 3 3 2 1 1 -10 R-2: Company Mill Trail 0 2 2 2 2 14 R-3: Picnic Area 0 0 0 0 0 2 R-4: Residences 0 1 1 0 0 -12 R-5: Reedy Creek Park Trail 1 1 1 1 1 -1 R-6: North Turkey Creek Trail 0 1 1 1 1 2 R-7: Foxcroft Lake 4 3 3 2 2 8 R-8: Crabtree Creek 1 2 2 2 2 12 Note: Sound levels rounded to the nearest full decibel. 0❑ 21/29 Page: 21 Number: 1 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:OS:24 PM Per Report Specific Comment from ADI letter, this text was added to explain "how the existing 1-40 traffic was modeled." Number: 2 Author: catkins Subject: Highlight Date: 4/14/2021 5:02:17 PM WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Blasting Noise Concern over blasting noise affecting Umstead State Park has garnered significant attention during this process. To be clear, controlled blasting occurs now in existing Pit 1. Future blasting in expansion Pit 2 would be very similar in terms of noise event magnitude i.e. similar charge weights) and occurrence (i.e. only a couple times per week). Warning sirens will continue to be used as they are today. To evaluate the significance of blasting noise, the same Cadna-A model was used to predict sound levels in Umstead State Park attributable solely to a typical blast event. Sound power data to model the blast was back -calculated from the short-term noise measurements performed in the park during monitoring period blasts, as shown in Figure 10. The results, as summarized in Table 6, were then computed for the maximum sound level (Lmax) expected during a blast event expressed in A -weighted decibels (dBA) using an RMS `slow' time response. The `slow' time response was selected to be consistent and allow comparison with many of the other park noise criteria presented in Table 1. As can be seen in Table 6, sound levels from blasting in future Pit 2 are expected to range from 44 to 73 dBA Lmax across all eight discrete receptor locations in Umstead State Park. Naturally, the louder sound levels will occur closer to the quarry work, and the quieter sound levels will occur farther away. 4or comparison, this range of anticipated sound levels produced by existing blasting operations in Pit 1 range from 38 to 57 dBA Lmax. It is important to note that soundgevels on these orders of magnitude do not represent a concern for inducing hearing damage 5 r anyone exposed to them. Table 6. Predicted Existing and Future Sound Levels from Blasting Receptor Predicted Blasting Noise Level, dBA Lmax slow Existing Quarry Overburden Stripping Production 280 ft Production 266 ft Production 210 ft Production 160 ft Existing 1-40 Traffic R-1: Residence Property Line 51 N/A 73 72 69 67 58 R-2: Company Mill Trail 57 N/A 64 63 59 53 38 R-3: Picnic Area 52 N/A 60 61 60 60 50 R-4: Residences 38 N/A 47 48 47 47 47 R-5: Reedy Creek Park Trail 42 N/A 54 53 51 47 39 R-6: North Turkey Creek Trail 41 N/A 44 44 44 44 29 R-7: Foxcroft Lake 54 N/A 71 69 64 62 45 R-8: Crabtree Creek 57 N/A 64 63 59 57 38 ❑0 0 Note: Sound levels rounded to the nearest full decibel. Blasting is notAxpected to be needed during removal of overburden. Blasting noise[�I►nax data shown for information only - not used for noise evaluation purposes0but is Qg included in the modeled typical hour Leq noise levels. 22/29 Page: 22 Number: 1 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:11:16 PM Text added for clarification. (Number: 2 Author: catkins Subject: Highlight Date: 4/14/2021 5:07:02 PM —Number: 3 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:12:05 PM Minor rephrasing for clarification. JNumber:4 Author: catkins Subject: Highlight Date: 4/14/2021 5:10:31 PM Number: 5 Author: catkins Subject: Highlight Date: 4/14/2021 5:12:57 PM Number: 6 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:13:24 PM "in" replaced with "for" Number: 7 Author: catkins Subject: Highlight Date: 4/14/2021 5:14:23 PM J Number: 8 Author: catkins Subject: Highlight Date: 4/14/2021 5:14:42 PM ,Number: 9 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:20:38 PM Per Report Specific Comment in ADI letter regarding blasting noise, clarification was made here that Lmax data was not used for evaluation purposes. It would be inappropriate to compare Lmax data to Leq data, which is the criteria that was set forth for comparing current modeled conditions to future modeled conditions. WSP USA, Inc. " 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US The results in Table 7 show the noise delta increase (+) or decrease (-) for future Pit 2 blasting events relative to existing sound levels produced by Pit 1 blasting events. As can be seen, blasting noise levels will remain readily audible throughout Umstead State Park but will reduce somewhat as the floor elevation of Pit 2 decreases. The loudest increase in blastin noise levels are expected near receptor R1 on the west side of the new quarry Pit 2 This isWaributable to Pit 2 being physically much closer to receptor R1 than Pit 1 is today. There will be some noise reduction shielding provided by the 15-foot earthen berm that Wake Stone has committed to erect along the property boundary with receptor R1. Thus, even though future blasting noise will be louder in some locations, it should not be used as a measure for compliance with the 10-decibel increase criterion due to how infrequently blasting will occur; the short impulsive nature of the blasting event,Und the fact 0 that identical blasting occurs today in the existing Pit 1. Table 7. Expected Differences in Sound Levels for Blasting Events Receptor Predicted Future re: Existing Blasting Noise Level Delta, dB Overburden Stripping Production 280 ft Production 266 ft Production 210 ft Production 160 ft Production 280 ft vs 1-40 Traffic R-1: Residence Property Line N/A 22 21 19 17 14 R-2: Company Mill Trail N/A 6 6 2 -4 25 R-3: Picnic Area N/A 9 9 8 8 10 R-4: Residences N/A 9 9 9 9 0 R-5: Reedy Creek Park Trail N/A 11 11 8 5 14 R-6: North Turkey Creek Trail N/A 4 4 4 4 16 R-7: Foxcroft Lake N/A 17 15 10 8 26 R-8: Crabtree Creek N/A 7 6 2 0 25 Note: Sound levels rounded to the nearest full decibel. Blasting is notAxpected to be needed during removal of overburden. Blasting noiseUnax data shown for information only - not used for noise evaluation purpose,,M but is included in the modeled typical hour Leq noise levels. 23 / 29 Page: 23 Number: 1 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:22:11 PM removed "simply" attributable Number: 2 Author: catkins Subject: Highlight Date: 4/14/2021 5:21:31 PM ;Number: 3 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:27:51 PM her explanation for not using Lmax data for comparison purposes JNumber:4 Author: catkins Subject: Highlight Date: 4/14/2021 5:25:46 PM Number: 5 Author: catkins Subject: Highlight Date: 4/14/2021 5:23:10 PM Number: 6 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:28:32 PM same as above Number: 7 Author: catkins Subject: Highlight Date: 4/14/2021 5:28:17 PM J Number: 8 Author: catkins Subject: Highlight Date: 4/14/2021 5:28:07 PM WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Backup Alarms '-;loud backup alarms are typically the number one source of noise complaints from the public at any construction site due to their intentionally annoying pure -tone beepers. Their purpose is paramount for protecting the life and safety of people working near the equipment. The Mine Safety and Health Administration (MSHA) does not require a specific sound level for backup alarms to emit; they simply state that the backup alarm "shall be audible above the surrounding noise level". To this end, Wake Stone will replace the standard backup alarms on their equipment with either manually -adjustable or ambient -sensitive models. These quieter backup alarms produce tone levels approximately 20 decibels quieter (i.e. about a quarter as loud) compared to a standard backup alarm. An even more attractive backup alarm from a community noise perspective is one such as the BBS-TEK Series of backup alarms manufactured by Brigade Electronics https:,[/brigade- electronics.com/products/reversing-and-warning-alarms/ (or equivalent). These alarms produce a much less annoying broadband "white noise" sound rather than a pure -tone. Wake Stone will evaluate the suitability of the various quieter backup alarms based on safety, cost and effectiveness and install them as needed. Sound Isopleth Contours The Cadna-A model Ulso produces sound isopleth contour lines of equal loudness attributable only to Wake Stone's noise production (i.e. not including any other background noise sources). Figure 12 illustrates the sound contour lines for the existing condition, i.e. operations occurring in Pit 1. Similarly, Figure 13 shows the sound contour lines for the worst -case future noise condition, i.e. production occurring in Pit 2 at the surface elevation of 280 feet. The contours are drawn in 9-decibel increments represented by the color gradient in the legend. The purple dashed line around the outside shows the extents o Umstead State Park and the area within which the sound contours were computed. Careful examination of the two figures shows how noise produced by Only Wake Stone's operations emanate from the pits, interacts with the surrounding topography, and propagates with varying efficiency in various directions. Interpolation between the contour lines allows for the estimation of quarry -generated sound levels at any point of interest within Umstead State Park. Qhe sound contours do not represent total sound levels (i.e. cumulative noise levels), nor do they necessarily represent the predominant noise at any given location. They only represent the modeled noise contribution of quarry activities. Lastly, Figures x and 15 show isopleth contour areas for the delta or difference between the sound levels produced in the future versus existing quarry operating conditions. The first figure shows the quarry site and immediate vicinity. The second figure shows Umstead State park in its entirety. As can be seen in the three shades of green, the vast majority of Umstead State Park is expected to experience a noise increase of less than 3 decibels due to Wake Stone's operations expanding from Pit 1 to Pit 2. In fact, more than half of the park will experience an increase of less than 1 decibel. El 0 El m 24 / 29 Page: 24 Number: 1 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:33:40 PM Additional information for backup alarms has been added. Although not included in the model (as indicated above), this section does offer mitigation measures for backup alarms, to which Wake Stone has agreed to take. J Number: 2 Author: catkins Subject: Highlight Date: 4/14/2021 5:30:35 PM Number: 3 Author: catkins Subject: Highlight Date: 4/14/2021 5:36:07 PM Number: 4 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:41:02 PM clarification that the sound isopleth contours do not include nor take into account other background noises which are likely louder for the vast majority of the park Number: 5 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:44:08 PM 1-decibel increments were replaced with 5-decibel increments to make the background map easier to see and the colors easier to discern. TINumber: 6 Author: catkins Subject: Highlight Date: 4/14/2021 5:41:37 PM Number: 7 Author: catkins Subject: Highlight Date: 4/14/2021 5:44:19 PM —)Number: 8 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:47:16 PM further clarification that the figures do not include nor represent any other background noise JNumber: 9 Author: catkins Subject: Highlight Date: 4/14/2021 5:47:09 PM Number: 10 Author: catkins Subject: Sticky Note Date: 4/14/2021 5:57:13 PM Figure 14 was redone (and renamed Figure 15) to make the background map visible, and additional property lines were added for clarity. A new figure 14 was generated to show a high level of detail in the area of most concern. JNumber: 11 Author: catkins Subject: Highlight Date: 4/14/2021 5:50:17 PM WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Conclusions A comprehensive acoustical study was performed for the Wake Stone Triangle Quarry to evaluate the potential for expanded operational noise produced in the future to impact outdoor recreation areas in the adjacent Umstead State Park. Various noise guidelines were considered, existing noise levels were measured, and existing and future noise levels were modeled. The results indicate that operating noise from the future Pit 2 will only increase noise levels throughout the vast majority of Umstead State Park by less than 3 decibels; well below the recognized definition for a substantial noise increase impact of 10 decibels. Thus, it can be concluded that expansion of Wake Stone's operations into Pit 2 will not pose a "significantly adverse [noise] effect on the purposes of a publicly owned park, forest or recreation area lin Umstead State Park]". Professional Certification I hereby certify that this plan, specification, or report was prepared or reviewed by me and that I am a duly certified acoustical professional as recognized by the Institute for Noise Control Engineering (INCE). u- TJJL�, Erich Thalheimer WSP USA, Inc. Principal Noise & Vibration Engineer INCE Board Certified No. 20104 in0E The Institute of ;4cise Contra I Engineering of the United States of America, Inc. in recognition of professional standing and contributions attests that ERJCH THALHEMER a member of the Institute is Board Certified in Noise Control Engineering Par the hoard at directors r 2of o�, 25 / 29 WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Figure 12. Isopleth Sound Contours for the Existing Condition Oote: Sound isopleth contour levels attributable only to noise produced by Wake Stone's operations (i.e. does not include other background noise sources such as traffic noise from I-40 or aircraft noise from Raleigh Durham Airport). 0 26/29 Page: 26 Number: 1 Author: catkins Subject: Highlight Date:4/14/2021 5:58:13 PM — Number: 2 Author: catkins Subject: Sticky Note Date: 4/14/2021 6:01:37 PM Figure 12 was updated with a clearer legend, additional property lines, and a clearer background map. Footnote was also added to clearly indicate that no background noises are included in this Figure. WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Figure 13. Isopleth Sound Contours for the Future Condition L.!.lote: Sound isopleth contour levels attributable only to noise produced by Wake Stone's operations (i.e. does not include other background noise sources such as traffic noise from I-40 or aircraft noise from Raleigh Durham Airport). 0 27 / 29 Page: 27 Number: 1 Author: catkins Subject: Highlight Date:4/14/2021 6:01:43 PM _Number: 2 Author: catkins Subject: Sticky Note Date: 4/14/2021 6:01:54 PM Figure 13 was updated with a clearer legend, additional property lines, and a clearer background map. Footnote was also added to clearly indicate that no background noises are included in this Figure. WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Ugure 14. Quarry Site Isopleth Sound Difference Contours (Future - Existing) 11 Dote: Sound isopleth contour levels attributable only to noise produced by Wake Stone's operations (i.e. does not include other background noise sources such as traffic noise from I-40 or aircraft noise from Raleigh Durham Airport). 28 / 29 Number: 1 Author: catkins Subject: Highlight Date: 4/14/2021 6:02:38 PM — Number: 2 Author: catkins Subject: Sticky Note Date: 4/14/2021 6:03:47 PM Figure 14 is an additional figure that was added to illustrate the modeled noise increase at a high level of detail in the area of most concern. JTI Number: 3 Author: catkins Subject: Highlight Date: 4/14/2021 6:02:40 PM WSP USA, Inc. 100 Summer Street Boston, MA 02111 (617) 426 - 7330 www.wsp.com/en-US Ugure 15. Park Area Isopleth Sound Difference Contours (Future - Existing) Dote: Sound isopleth contour levels attributable only to noise produced by Wake Stone's operations (i.e. does not include other background noise sources such as traffic noise from I-40 or aircraft noise from Raleigh Durham Airport). 29 / 29 Page: 29 Number: 1 Author: catkins Subject: Highlight Date: 4/14/2021 6:03:58 PM - Number: 2 Author: catkins Subject: Sticky Note Date: 4/14/2021 6:06:18 PM Figure 15 is a revised version of Figure 14 from the draft report. Additional property lines were added, the legend was made more legible, and the color gradients were made semitransparent to allow the background map to be visible. TI Number: 3 Author: catkins Subject: Highlight Date: 4/14/2021 6:04:00 PM General Comments: • A 10dBA increase/decrease seems to be course measure of significant impact. The Division understarnds that this standard is used by NCDOT and other agencies evaluating noise impacts. However, considering a state park is adjacent to the prop05ed quarry, the Division believes a more conservative standard 5hauld he considered. Please provide further justification for a use of this standard. After DEMLR raised this issue, �Vake Stone and WSP had much discussion about defining "significant adverse effect" as it relates to noise impacts. As indicated on page 6 of the report, "humans can barely perceive a change in noise level of +/- 1 decibel, can likely perceive a change of +/- 3 decibels, and can easily perceive a change of +1- 5 decibels...". Based on this description, we concede that a 5 d3A Increase, as easily perceived, may constitute a -negative or adverse impact. However, to rise to the level of "significant," we agree that the use of + 10 dBA was justified. Ithough not included in the original draft report, as was stated Z ove, NCDOT an of ers have used the 10 decibel increase as a criteria for requiring mitigation. Furthermore, it should be noted that although potential quarry noise has been called into question as a potential "significant adverse effect on the purposes of a publicly owned park. forest or recreation area." there is nothing in the North Carolina Division of Parks and Recreation mission or purpose that has any reference to noise or the expectation of the absence of noise, See pages 2-3 of the William B. Umstead State Park General Management Plan (attached)_ Considering that the noise impacts of RDU Airport, US Interstate 40, and US Highway 74 (which is currently proposed to be widened and expanded) all far exceed the noise impacts associated with the expansion of the quarry, and considering that the area of Umstead Park that is nearest the expansion area is closer to RDU Airport and does not have any established trails, campgrounds, or other facilities, there is nothing to suggest that a more stringent standard should be considered for defining "significant adverse effect." n.._.--. -..- J:,-,.--:- - tar -I., ri_-_ J,---:1.-J-,..,--!------.-&:.----..-,-- iL-. ._.,,- Comment on 10 dba criteria for significant adverse effect proposed by Wake Stone • The applicant can assert any level it wants to determine significant adverse impact. DEQ should not accept whatever level the applicant asserts as they are not impartial to the question. In fact a 10dba increase would reduce the area one could hear natural sounds by 90%, hardly acceptable by any standard. • The study is focused on the wrong question, so the answers are not relevant. They study tries to assert its impact is not on sounds as they will be heard by park visitors, but rather only on one hour average sounds which tend to diminish the loudest most objectionable sounds through the one hour averaging. • The real question is obvious, how will the expansion effect sounds park visitors will hear, those are not one hour average sounds, rather the loudest impacts that pierce the quiet of the forest the park is trying to protect. • There are ways to reflect this impact, L10, L1, Lmax all better indicators of the sounds park visitors will hear. • The report measured 1-1, but chose not to disclose those values. Lmax was reported by the applicant, but the applicant asks DEQ to not consider it as it is different from the Leq one hour average. In fact L1, and L10 and Lmax all would better reflect the real question; how will sounds in the park change. • The study confirms the existing quarry operation has already intruded the entire park with significant noise intrusions, and the expansion will increase both the intensity of noise and the area effected by the noise intrusions. • This is why the 50 year Sunset clause was a key requirement of the 1981 permit, to end such impacts and prevent them from continuing to impact the park indefinitely. The 2018 removal of the sunset clause by DEQ was itself a mistake that DEQ should correct by reinstating that permit condition. Its removal in 2018 after 37 years, was not allowed per the mining act of 1971, and based on assertions that have been refuted with documents from the state archives showing Director Conrad would appeal the mining commission decision if he could not better protect the park. That's exactly what he did with the permit that allowed several changes that benefited the applicant and one that imposed the sunset clause. The applicant never mentions the changes the permit allowed items the mining commission final decision prohibited, placing berms in the buffer and development north of the 10 year line. • Director Conrad was the final agency decision as he was the only authority that could permit the operation and he did so per the Mining Act of 1971, and Wake Stone Accepted the permit as issued for 37 years. • The mining commission order itself said they were to approve the permit issued. • DEQ should reinstate the 50 year sunset clause and deny the expansion. • If a park users can easily perceive a noise intrusion to a nature preserve/ park that is in fact a significant adverse impact on the purpose of a nature preserve or park. • The assertion that a private company should be allowed to add industrial noise on top of its own industrial noise, to the extent it can double its current impacts is without merit and completely self-serving, DEQ should reject this assertion outright. • Further to argue the other noise intrusions from public purposes are also impacting the park should not become a reason to allow more uses to make similar or greater noise intrusions. The law does not say a mine can equal or double all public sound intrusions, it says the mine cannot have a significant adverse effect on the purposes of a park. • THE DBA levels in the study are the Leq, hourly average sounds, not sounds as will actually be heard by users of the park. separately requested by DEMLR, we offer the following responses to those comments: General Comments: A 1DdBA increase/decrease seems to be course measure of significant impact. The Division understands that this standard is used by NCOOT and other agencies evaluating noise impacts. However, considering a state park is adjacent to the proposed quarry, the Division believes a more conservative standard should be considered, Please provide further justification for a use of this standard. After DEMUR raised this issue, Wake Stone and WSP had much discussiorout defining "significant adverse effect' as it relates to noise impacts. As indicated on page 6 of the report, "humans can barely perceive a change in noise level of a/- 1 decibel, can likely perceive a change of +/- 3 decibels, and can easily perceive a change of+/- 5 decibels.. based on this description, we concede that a 5 dBA increase, as easily perceived, may constitute a negative Of adverse impact. However, to rise to the level of "significant," we agreed that the use of + 10 d6A was justified. Although not included in the original draft report, as was stated above, NCDOT and others have used the 10 decibel increase as a criteria for requiring mitigation. Furthermore, it sheuld be noted that although potential quarry noise has been called into question as a potential "significant adverse effect on the purposes of a publicly owned park, forest or recreation area," there is nu thing in the Nor 01 Cdrulind ❑Ivisiuu or Par ks drid Reraedtiun IIIissiun ur purpuse Old has any reference to noise or the expectation of the absence of noise. See pages 2-3 of the William B. Umstead State Park General Management Plan iattached). Considering that the noise impacts of RDU Airport, US Interstate 40, and US Highway 70 jwhich is currently proposed to be widened and expanded) all tar exceed the noise impacts associated with the expansion of the quarry, and considering that the area of umstead Park that is nearest the expansion area is closer Lo RDU Airport and does not have any estahlished trails. ramnernunds. or other far.ilities. there is nothine to sueeest that A Oeportman 2,39 Pm If a park users can easily perceive a noise intrusion to a nature preserve/ park that is in fact a significant adverse impact on the purpose of a nature preserve or park The assertion that a private company should he allowed to add industrial noise on top of its own industrial noise, to the extent it can double its current impacts is without merit and completely self serving, DEQ should reject this assertion outright. Further to argue the other noise intrusions from public purposes are also impacting the park should not become a reason to allow more uses to make similar or greater noise intrusions. The law does not say a mine can equal or double all public sound intrusions, it says the mine cannot have a significant adverse effect an the purposes of a park. THE ❑BA levels in the study are the Leq, hourly average scunds,nct sounds as will actually he heard by users of the park. Anil a ronly O Rs is stantin rd pr;;rtirp, nni--,p 4-mittpd by hnr-Iriip ;alnrmR waq not incIiidpd in the nni,-,p mndPI This is duo to several reasons, (1) it can be difficult to anticipate whore and when a vehicle 0 will need to backup. (2) the alarms are a required safety device, and (3) the alarms are not that loud with respect to receptors located more than a few hundred feet away. For example, 3 a typical loud pure -tone backup alarm might emit a sound level of 105 dBA Lmax at 4 feet behind the vehicle. This would reduce to only 77 dBA Lmax at 100 feet, and would be down to 63 dBA Lmax at 500 feet. When averaged over an hour, the results would be negligible. Back up alarms when averaged over an hours would be negligible? Is that how the back-up alarms would be heard by park visitors? This one statement about one of the loudest impacts of the quarry is dismissive of the impacts because they can be averaged over an hour, the sounds can be heard today throughout the park, the report says so. If that sound can be heard throughout the park how is it relevant that by averaging it over an hour it is no longer relevant? The study protocol stated it would measure noise impacts as they would be heard by park users, but that is not what the study reported. In fact the averaging of very loud but short duration sounds like rocks falling into and from trucks, blast sounds are some of the more intrusive sounds of a quarry on a state park. To filter them with a slow response setting and then diminish them with an hourly Leq shows how the report has failed to project the impact park users will hear. To imply that the backup alarms cannot be modeled because they don't know where the trucks back up is absurd, a review of quarry operations would clearly show when and where trucks back up regularly. Finally 63dba at 500 feet will impact the park as Pit 2 is much closer to the park boundary than 500 feet. The park boundary is within 100 feet from pit 2, so 77 dBa will enter the park. The backup alarms are required and should be modeled as used. If in the future different alarms are used that would be good, but the study should reflect todays actual worst case conditions not some undetermined future possible change. This is yet another example of the reports bias to dismiss or minimize its noise impacts on the park. WSP USIA, Inc. 100 5umrner weer Boston, MA 02111 1617) 426 - 7320 www,wspxom{en-us Blasting Noise Concern over blasting noise affecting Umstead State Park has garnered significant attention during this process. To be clear, controlled blasting occurs now in existing Pit 1. Future blasting in expansion Pit 2 would be very similar in terms of noise event magnitude 4e. similar charge weights) and occurrence (i.e. only a couple times per week). Warning sirens will continue to be used as they are today. • What are the sound contours for the siren and the blast today from Pit 1 and from Pit 2 and for the concurrent operation of Pitt and Pitt? • What are the actual sounds that park visitors will hear from the sirens and blasts, (not the 1 hour average sounds) • DEQ should ask for this information as it is some of the loudest impacts and not disclosed. • Park visitors don't hear LEQ average noise they hear actual blasts and sirens in real time. To evaluate the significance of blasting noise, the same Cadna-A model was used to predict sound levels in Umstead State Park attributable solely to a typical blast event. Sound power data LO model the blast was back -calculated from the short-term noise measurements performed in the park during monitoring period blasts, as shown in Figure 10. The results, as summarized in Table G, were then computed for the maximum sound level (Lmax) expected during a blast event expressed in A -weighted decibels (dBA) using an RMS 'slow' time response. The `slow' tune response was selected to be consistent and allow comparison with many of the other park noise criteria presented in Table 1. • What blasts were measured for input to the model? What date and time and location? How Did the" back calculating" consider the effects of the current 250 foot buffer vs the 25 foot buffer proposed. • Were a series of blasts averaged? How do we know if the blast or blasts used were typical, larger or smaller? • What impact does the slow time response have on the sound measurement of an impulse sound of the blast? What was the fast sound measurement or the peak sound measurement of the same blast? Why was this not disclosed? • This is an important question and blasts can be loud but just a small fraction of a second, and the slow response may effectively filter out the blast sounds. • Per Trevor Boardman, application engineer at Larson Davis, the manufacturer of the model 720 meter used, "slow" may be an effective way to eliminate noise from loud quick sounds, ■ Slow • A sound level meter set to a slow setting has a one -second response time. This means that a it will take one second for a sound level meter to get up to the level of a constant tone. The slow setting is good at "ignoring" short, fast sounds like car doors slamming or balloons popping. The slow setting gives the smoothest output of the three weighting types, a sort of "average" sound level. This makes slow weighting a good choice for environmental noise studies, especially for studies that span many hours or even days. Slow weighting is noted with a capital S. For example, LAS means 'A -weighting level with slow time -weighting." • Fast • A sound level meter set to a fast setting responds to changes in sound in 0.125 seconds (125 milliseconds). That's about eight times faster than the slow weighting response. As you might imagine, the fast setting is more responsive to short, fast sounds than the slow setting. However, the fast setting is not perfect at measuring quick sounds, and still tends to output a relatively "average" sound level. The main difference between fast and slow weightings is that fast weighting gives higher resolution —a more detailed picture, if you will —of the measured sound. Fast weighting is noted with a capital F. For example, LZF means "Z-weighted level with fast time -weighting. " Impulse Impulse sound weighting is by for the least common of the weighting types. It was originally designed to measure sound levels for impulses —short loud sounds —like gunshots and explosions. Today, it is more common to see peak levels used to talk about impulsive sound. Impulsive weighting has the quickest response time (0.035 seconds or 35 milliseconds). That's about 4 times faster than the fast weighting response. One quirk of impulse weighting is that it has a slow decay. This was designed to mimic the human ear, which responds quickly to rising sound levels, but takes time to relax after the onset of such sounds. Impulse weighting is denoted with an uppercase I. Summing it Up No matter which weighting type you use for your measurements, make sure you choose the right one for a given application. It's important for sound studies to follow best practice, community noise ordinances, and manufacturer recommendations (although not necessarily in that order.) Sound levels are a powerful metric for determining the noise conditions of a site. Many sound level meters will let you measure with multiple weighting schemes at once. This functionality can be nice for developing a comprehensive understanding of sound levels at a measurement location. Table b. Predicted Existing and Future Sound Levels from Blasting Receptor Predicted Blasting Noise Level, dBA Lmax slow Existing Qu arry Overburden Stripping Production 290 tt Production 266 tt Production 210 ft Production 160 tt Existing 1 40 Traffic R 1: Rcsidcncc Property Line R-2i Company Mill Tra11 5l 57 N/A N/A 73 64 72 63 69 59 67 53 58 3R R-3: Picnic Area 52 N/A 60 61 64 60 50 R-4: Residences 38 NIA 47 48 47 47 47 R-5: Raedy Creek Park Trail 42 N/A 54 53 S1 47 Vic; R-G- North Turkey Creek Trail 41 N/A 44 44 44 44 29 R-7:Foxcroft Lake 54 N/A 71 69 64 62 45 R-8: Crabtree Creek 57 N/A 64 63 59 57 58 Note- gnnnd levels rnunded to the nearest fiil1 derihel. Blasting is not Rpected to be needed during removal of overburden. Blasting naiseUnax data shown for information only - not used For noise evaluation purposes06ut is included in the modeled typical hour Leq noise levels. bi 1* Blasting noise is a significant adverse effect on the public purposes of a state park. The fact that it can be heard throughout the park is evidence that the existing quarry has already had a significant adverse effect on the public purposes of a park, and is exactly why DEMLR Director Conrad denied the 1980 request for the permit. It is also an important consideration as to why he imposed a 50 year sunset clause on the blasting and mining operation. The 2017 and 2018 assertion by Wake Stone after 37 years that the 50 years sunset requirement was a "typo" has been refuted by documents provided to DEQ from the state archives. DEQ should correct the 2018 error they created when they changed the permit eliminating the 50 year limit on impacts. Failure to do so eliminates an important protection for the park that was key to the 1981 Quarry approval, and exposes the park to unlimited future noise impacts. R-S; Crabtree Creek 1 57 1 N/A 1 64 1 63 1 59 1 57 1 1�, Nnte� Smind levels rounded to the nearest fiill decihel. Blasting is notRpeeted to be needed during removal of overburden. Blasting noise Unax data shown for information only - not used For noise evaluation purposes0but is included in the modeled typical hour Leq noise levels. 13 6-3 22 / 29 • Why should Lmax data not be used in considering significant adverse effect on a park? To exclude the loudest noise intrusions as they will be heard is contrary to the purpose of the protocol for the study and contrary to the law, the question is not what is the average change in sound, but rather how will the expansion change the sounds heard by visitors to the park. • This statement alone should be sufficient basis to deny the expansion permit and reinstate the 50 year sunset clause. in fact the existing quarry and the proposed expansion both have significant adverse effects on the park and Wake Stone should be held to the 50 years limit they accepted when they accepted the permit in 1981 and each renewal for 37 years with the 50 year limit. Ugure 14. Quarry Site isopletlh Sound Dlrfere— Contours (Future - Existing) 12 comments K Z T and should not be allowed to increase in noise level or area impacted. PAGE 55 2 0 epoftman 4:42 PM The model isopleth shows an amazing reduction of noise north of pit2. Sound drops from 9-10 Dba increase to 0-1 abruptly. Why would mining noisejust stop abruptly at the park boundary? The park topography north of pit 2 is above the pit, and why would the impacts he so much less than the impacts of pit 1 with large 250 forested buffers and much higher berms? This seems to imply the model may not reflect the same conditions as are modeled in pit 1. Could there be a error in the modeled assumptions as to why mining sounds just stop at the park boundary in the future expansion scenario? ►, � � � w... ws, usw, ice. SDD Sammo�Sl�oN eossm, I,w oxr n 16171 �76-73j0 r� m�peaNm-u5 4.igure IS. Park Area Isopleth Sound ❑ifrerenee Contours (Future- Usd no Motc: Sound Iso plcth contour Ic Ms att rlhutab1 c on ky to noise prod u ccd by Wake 5tonc's operations [i c. d ocs not include ❑therharkwound noisesourccs such as traHlc noise from 1-40 oraircratt noise from Raleigh Durham Airport I. 29129 v PAGE a7 i " 0 ep Ortman 2:4E PM The study does not reflect the sound impacts of concurrent production in Pit 1 and Pit 2, but that is exactly what the proposed site plan would allow. ❑EQ should ask for the report to show the impacts of concurrent production in Pit 1 and Pit 2, as that is what the applicant is showing in the proposed site plan. failure to reflect this concurrent operation significantly understates the real sound impacts on the park. The narrative of the expansion request and the sound study says the sounds will just transfer from Pitt to Pitt, but the site plan would allow concurrent operation with significant noise intrusions not reflected in this study. ❑EQ should address this large discrepancy in the assumption of the proposed site plan and the different assumption of the sound study. Add a reply...