20220241 Ver 1_Response to NCDWR Comments_20220513

Strickland, Bev
From: Thomas Brown <[e-mail]>
Sent: Friday, May 13, 2022 11:49 AM
To: Homewood, Sue
Cc: Thompson, Emily B CIV USARMY CESAW (USA); Brian North; Phillip Pressley
Subject: [External] Martin Marietta Belgrade Quarry, Response to NCDWR Comments
Attachments: MMM Belgrade Response to DWR Comments 5-13-2022.pdf; MMM Belgrade Bender
Overburden Road Alternatives Map.pdf; MMM Belgrade Bender Road Culvert
Design.pdf; MMM Belgrade Proposed Channel Design and Exisiting Conditions.pdf;
20.02.05.Belgrade.Mine.Map.APPROVED.pdf; MMM Belgrade Bender Haul Road
Map.pdf
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Sue,
Thank you for the discussion last week. Please see our attached response to your comments. We appreciate your
assistance with this project. If you need anything further, please feel free to reach out to me.
Thanks again,
Thomas Brown, PWS
Wetland Specialist I East Division
Martin Marietta
2235 Gateway Access Point
STE 400, Raleigh, NC 27607
m. (919) 268- 5297
e. [e-mail]
www.martinmarietta.com
1

Martin
Marietta
May 13, 2022
Sue Homewood
Division of Water Resources
Department of Environmental Quality
450 W. Hanes mill Rd, Suite 300
Winston Salem, NC 27105
Dear Ms. Homewood:
Thomas Brown
East Division Wetland Specialist
Please reference the Request for Additional Information from your office, received by email on March 23,
2022, associated with SWR#20220241. A response to the request can be found below, with the
questions/comments from the request underlined.
1. If the U.S. Army Corps of Engineers requests a response to any comments received as a result of the
Public Notice, please provide the Division with a copy of your response to the USACE. (15A NCAC 02H
.0502 c
Martin Marietta received comments from the Corps of Engineers on 5/11/2022. The Division will
be copied on our response to these comments.
2. Please provide a copy of the most current DEMLR approved mine map with the proposed pit expansion
areas and haul roads located on the map. (15A NCAC 02H .0506(b)(1) and .0502(a)(9)1
Please see attached current approved mine map associated with Permit 67-01. The Mine permit
will be modified once 404/401 permits have been issued.
3. Please clarify whether the "pit" limits shown throughout the application materials depicts must the limits
of the pits or the limits of the outer most proposed disturbed area necessary to mine within the pit area,
such as disturbances for associated activities such as access roads. berms. sediment/erosion control
measures, safety features, etc. (15A NCAC 02H .0506(b)(1) and .0502(a)(9)1
Martin Marietta East Division
2235 Gateway Access Point, STE 400, Raleigh, NC 27607
m. [phone] [e-mail]
www.martinmarietta.com

Page 2
The Pit limits shown in the application depicts the limits of all disturbance. There will be no
additional impacts to wetlands and waters associated with roads, berms, sediment/erosion
control measures, safety features or any other activity not described in the application.
4. Please provide a site plan that shows the entirety of the proposed haul roads for the Bender Pit. The
Division is unable to evaluate the project for avoidance and minimization without a complete
understanding of the entirety of the proposed haul roads, including how the various pieces connect and
where they terminate/begin within the pit and connect to other roads within the facility. (15A NCAC 02H
.0502(a)(9)1
Please see attached map (MMM Belgrade Bender Haul Road Map). Roads in high ground may be
slightly re -aligned due to other permitting requirements, safety requirements, or construction
requirements.
5. Please provide detailed plans for the stream relocation around the North Pit. The plans must include
plan and profile details, accurate dimensions (including proposed side slopes and floodplain access), any
proposed buffers, proposed bed and bank materials and construction sequence/details. Please provide
specific information regarding tie in locations with the existing stream. (15A NCAC 02H .0506(b)1
MMM is providing the attached plans for relocating the stream around the north pit. The
designed channel will mimic the bottom width of the existing stream. Side slopes on the proposed
channel will be constructed at no more than a 2:1 slope. Where the existing stream connects to
the created channel, the existing stream will be plugged with clay or other suitable material and
the bank in this area may be armored with rip -rap. The created channel banks will be stabilized
and vegetated with a riparian seed mix.
MMM is providing four cross sections of the existing stream profile, along with photos of each
cross section. These cross sections were taken as follows: Site 1 was taken upstream of the
proposed relocated channel tie in. Site 2 was taken just downstream of the proposed upstream
channel tie in. Site 3 was taken upstream of where the proposed channel will tie back into the
original channel. Site 4 was taken downstream of where the proposed channel will tie back in to
the original channel. Spoil piles exist on the south side of the stream where it was excavated
before MMM controlled the property. A photo of the feature upstream of the road culvert is also
provided to show active agricultural impacts to the system.
6. Please provide detailed plans and profiles for the proposed haul roads, as well as detailed construction
sequences for each site. Please ensure that the plans clearly document that the proposed culverts will be
installed to ensure equilibrium between the unimpacted portions of the wetlands and provide aquatic life
passage. The plans should also include a detailed construction sequence demonstrating that the
construction will be conducted "in the dry" and showing limits of all erosion control measures necessary
to protect the adjacent wetlands. Please also clarify if any additional vegetation clearing will be needed
adjacent to the proposed road for construction access. (15A NCAC 02H .0506(b)l

Page 3
Please see attached plans and profiles for the proposed haul roads. All Roads will be constructed
in the Dry. Culverts will be field located in the lowest points to ensure equilibrium of the reach
and flow of waters. The culvert in the stream crossing associated with the overburden road will
be buried 1ft to allow aquatic life movement. Erosion control measures will be installed prior to
construction. These measures will be designed and approved in the NC Mining Permit process.
7. Please provide additional detailed information regarding the need for the second haul road, the
"Overburden Road," which is proposed to cross a large wetland complex between the existing mine facility
and the proposed Bender Pit. While the Division recognizes that this road has been located in the
narrowest portion of the wetland system, the direct impacts are still substantial and indirect impacts do
not appear to have been considered. It is stated that "having a direct path" would reduce each trip, please
provide maps with alternative road locations that were considered and the associated distances for each
alternative to further justify this statement. Please provide further explanation of "necessary for
operation efficiency and safety under the circumstances" and "substantial savings". f15A NCAC 02H
.0506 b
Please see combined response to 7 and 8 below.
8. The Division needs to understand the projected volume of traffic that will use the Overburden Road in
order to further evaluate Avoidance and Minimization. How many estimated trips will trucks and/or other
machinery take per day over the proposed Overburden Road durine: 1.) initial site development and 2.)
minine operations. 115A NCAC 02H .0506(b
During a normal operating day at the site, approximately 4,500 cubic yards of overburden material
per day will be hauled from the Bender Pit, using 3 trucks, for a total of approximately 130 truck
trips per day. At the same time, approximately 4,000 tons of product will be hauled to the plant
from the Bender Pit, using 3 additional trucks, for a total of approximately 80 truck trips per day.
The road as proposed and designed will allow a direct path from the proposed Bender Pit to the
southern end of the existing pit, where we are planning to deposit overburden material. As shown
on the attached "Haul Road Map" without this road, overburden trucks would need to travel north
on the same road as the product haul trucks, and then loop back south on the existing road.
Measuring this distance, trucks would travel approximately 0.7 miles farther each way, or 1.4
miles farther each trip, resulting in an additional 182 miles traveled each day. These additional
miles are costly in fuel, truck maintenance, and time. Additional travel distances also equate to
more emissions. Furthermore, using the product haul road to transport overburden material
would place 6 off road trucks traveling the same road, along with the numerous passenger trucks
carrying employees, not to mention loaders, drills, mechanic trucks or other equipment that travel
to and from the pit at various times during the day. MMM therefore believes that a single road
to the pit would create an unsafe condition and is not a practicable alternative due to these
reasons.
The proposed overburden road is located in the narrowest portion of the wetland system in order
to minimize impacts to wetlands. MMM considered placing the road in other areas of the
wetlands, and even considered constructing two one lane roads which would allow overburden
trucks to work in a one-way loop traffic pattern, but we did not consider this to be the least
environmentally damaging alternative because of the additional wetland impacts and therefore

Page 4
did not propose it. An example of the one-way loop road system is shown on the attached map
(MMM Belgrade Bender Overburden Road Alternatives).
9. Please explain why a narrower road with traffic controls (e.g. the use of a flagger or remote light to
control traffic) are not a practical alternative to the proposed designed with two travel lanes. (15A NCAC
02H .0506(b)l
The proposed overburden road must be designed to MHSA standards. For the trucks currently in
use at the Belgrade Quarry, the requirements are as follows: A safety Berm that is taller than half
the tire height, a minimum 10ft distance between passing trucks and a minimum 10ft distance
between trucks and the safety berm. Proposed impacts with a two-lane road are 100ft wide.
Using the same required safety standards, a one -lane road would still need to be approximately
70ft wide and would only impact approximately 0.25 acres of wetland less than a two-lane road.
MMM believes that the use of a one lane road would not only cause a hazardous condition, but
would also cause trucks to sit and wait for another truck to pass, reducing the load count per day
and increasing emissions and fuel use while idling. Because of these reasons listed above, in this
situation a single lane road it is not practicable nor is it the least environmentally damaging
practicable alternative.
10. Please explain how the roadway runoff will be captured/treated. Will any stormwater from the roads
discharge into or adiacent to anv wetlands or streams. 115A NCAC 02H .0506(b)l
Stormwater runoff from the roadways will be captured at each end of the road by appropriate
BMPs or directed to flow into the mine pit. These BMPs will be designed and approved during
the mine permit process.
11. Please provide an analysis of expected indirect impacts to the section of stream between the road and
the portion to be rerouted around the North Pit. This section of channel will be further removed from
downstream waters and be located between two impacted sections of channel which has the potential
to further degrade the functions within the channel. (15A NCAC 02H .0506(b)l
There are no expected indirect impacts. The stream originates as low energy ditches in farm fields
across the road from the site. Flow rates in this section of stream will not be restricted or
increased by this project. As such no negative morphological effects are expected. Moreover,
the section of this stream in question was altered in the past by channelizing for agricultural
purposes and the existing NCDOT Culvert. For the reasons listed above, re-routing the stream
around the pit is not expected to cause any negative impact to the section of stream between the
road and the proposed channel.
12. Please provide a mitigation plan which will meet the requirements of 15A NCAC 2H .0506(c). Please
note Item (c)(7) indicating that no more than 25%of the mitigation requirements may be satisfied through
preservation. (15A NCAC 02H .0506(c)l

Page 5
In order to meet these requirements, MMM proposes to purchase mitigation credits at a 0.75:1
ratio along with preserving the Woods Property as described in the application. MMM is currently
working with a Bachelor's Delight Mitigation Bank to secure 674 stream credits and 6.72 wetland
credits. A copy of this Credit Reservation will be forwarded to the Division once it is received.
Preserving the Woods Property will provide wetland preservation mitigation at a ratio of 11.6:1.
Furthermore this proposal would also preserve a buffer on one side of approximately 4100 linear
feet of the White Oak River. This combined mitigation plan far exceeds the DWR required 1:1
mitigation ratio.
13. Please provide information to include a map showing any residential wells within 500 feet of the new
pit boundaries. (15A NCAC 02H .0506(b)(3)1
There are no residential wells within 500ft of the Bender Pit. Martin Marietta is currently unaware
of any wells within 500ft of the Northern Expansion area. The attached current mine map includes
known offsite wells. All groundwater concerns will be addressed with DWR's Groundwater
Management Branch via the Central Coastal Plain Capacity Use Area Permit (NCG02005) during
the Mine Permit Process.
14. The Division is concerned that indirect hydrologic impacts will occur in adjacent wetlands as a result
of mining activities. Please provide a detailed hydrologic analysis/modeling of mining activities, including
pit dewaterine. on the adiacent wetlands. 115A NCAC 02H .0506(b)(3)1
MMM appreciates the conversation with Sue Homewood to talk through this issue on 5/6/2022.
As explained in the call, the cone of depression normally shown in limestone mining is in relation
to deeper ground water and not surface ground water. As seen on maps and NCWAM forms
provided in the application, high functioning wetlands exist approximately 70ft from our current
pit area. These wetlands are separated from the pit by a perimeter road and berm. Similar
conditions will exist in the proposed Bender Pit. A perimeter road and berm will be constructed
within the proposed limits of disturbance, before the overburden slopes down to the actual mine
pit. Outside of the limits of disturbance, a minimum 50ft buffer will be maintained around the
existing wetlands. Due to the shape of the wetland boundary, in many places this buffer is as
much as 70 to 100 ft.
Furthermore, the wetlands surrounding the Bender Pit receive much of their hydrology from
backwater of the White Oak River. MMM believes that due to this reason and the fact that the
pit face will be separated from the wetlands by a distance of approximately 100ft or more, there
will be no negative effects on the hydrology of the nearby wetland systems.

Page 6
We appreciate the opportunity to respond to this request. Please feel free to contact me by phone or
email at any time for any additional information or clarification.
Sincerely,
Thomas Brown
East Division Wetland Specialist
Attachments by email:
20.02.05.Begrade.Mine. Map.APPROVED
MMM Belgrade Bender Haul Road Map
MMM Belgrade Bender Overburden Road Alternatives Map
MMM Belgrade Bender Road Culvert Design
MMM Belgrade Proposed Channel Design and Existing Conditions

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Site 1 Photo, Upstream of Proposed Channel
Site 2, Downstream of Upstream Proposed Channel Tie in

Site 3, Upstream of Proposed Downstream Channel Tie in
Site 4, Downstream of proposed Channel

I

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