19950153 Ver 2_Other Agency Comments_20140610

North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director

MEMORANDUM

TO:
David Shaeffer
Raleigh Regulatory Field Office, USACE

FROM:
Vann F. Stancil
Special Project Coordinator

Habitat Conservation Program

DATE:
June 10, 2014

SUBJECT:
Comments on 404 IP for proposed impacts to jurisdictional wetlands at Martin

Marietta’s Benson Quarry in Johnston County.

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed
the Individual Permit (IP) application. In addition, I have attended meetings with representatives
of Martin Marietta Materials, Inc. and visited the Benson Quarry to discuss expansion plans.
Clean Water Act of
Our comments are provided in accordance with certain provisions of the
1977
(33 U.S.C. 1251-1387) and the Fish and Wildlife Coordination Act (48 Stat. 401, as
amended; 16 U.S.C. 661 et seq.).

Benson Quarry is a granite mine located approximately 3.5 miles northeast of Benson in
southern Johnston County. It is currently limited to the south side of Stony Fork, a tributary to
Hannah Creek and the Neuse River. Martin Marietta Materials, Inc. recently sought a mining
permit modification to expand the Benson Quarry by 110.5 acres for a total permitted acreage of
270 acres. Expansion would open up the area on the north side of Stony Fork to mining.

Martin Marietta Materials, Inc. has applied for an Individual Permit to impact 26 acres of
jurisdictional wetlands to expand the pit at the Benson Quarry. The applicant has examined
several alternatives to extend the life of the quarry. The preferred alternative would expand the
quarry through the majority of the wetlands on the site. A bypass channel would be constructed
to transport water around the north side of the expanded quarry. Although Stony Fork was not

Mailing Address:
Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone:Fax:
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NCWRC COMMENTS 2 BENSON QUARRY IP
delineated as a stream, the Federal Emergency Management Agency (FEMA) requires a bypass
channel to convey water around the expanded quarry to avoid flooding on adjacent properties.

The primary adverse effects on aquatic and terrestrial wildlife resources from the expansion of
the Benson Quarry will result from the proposed destruction of the wetlands and surrounding
forested habitat along Stony Fork. The 26 acres of forested wetlands proposed for impacts
benefit water quality and provide important habitat for terrestrial and aquatic wildlife within the
Benson Quarry footprint.

The diversion of water from Stony Fork to the proposed diversion canal has the potential to alter
the hydrology and function of wetlands that are located between the point where water is
diverted to the channel and the future reserve area along the western border of the project. If a
diversion canal is constructed, concerns regarding erosion, sedimentation, and flooding adjacent
properties will need to be adequately addressed.

In general, more information is needed in the IP application to adequately assess the proposed
alternatives. The purpose and need section references NCDOT’s planned widening of I-95 at the
top of page 5. Please include more information about the expected time frame for this widening
project.

Alternative 3.1.2, Removal of Existing Waste Pile, on page 6 refers to a FEMA evaluation of a
permanent access or roadway across the wetlands. The applicant states that the FEMA
evaluation determined that it would not be possible to install a permanent roadway across the
wetlands without causing an increase in the 100-year flood elevation and potentially flooding
upstream properties. The study should be appended so that it can also be reviewed.

Alternative 3.1.4, Pit Expansion Through Wetlands with Diversion Channel North of
Overburden Pile, refers to the current zoning requirements. The applicant refers to the current
zoning requirements and how they influence various alternatives. Therefore the Special Use
Permit should also be appended. The applicant indicates that the potential reserves stated in the
text are not accurate because of the zoning requirement that would require the diversion channel
to be 250 feet from Camilla Road. If the zoning requirements affect the potential reserves and
require a change in the location of the diversion canal, this alternative should be omitted or
updated to reflect zoning requirements.

Alternative 3.1.5, Pit Expansion Through Wetlands with Diversion Channel South of Overburden
Pile, is the applicant’s preferred alternative because it maximizes the life of the quarry. The
applicant states that they “would need approval to mine through approximately 26 acres of the
existing wetlands.” It is unclear if additional acres of wetlands would be impacted by berms
surrounding the quarry. In addition, the applicant states that, unlike Alternative 3.1.4, this
alternative avoids the possibility of future secondary impacts to wetlands upstream and
downstream of the future pit. The wetland impacts from this alternative are difficult to discern
on the map in the appendix. The large map of the quarry included in the mining permit
modification submitted in March 2014 to the NCDENR Land Quality Section suggests that there
are several acres of wetlands located on the western edge of the Benson Quarry property between
the beginning of the diversion canal and the edge of the future pit. Compared to Alternative

NCWRC COMMENTS 3 BENSON QUARRY IP
3.1.4 this alternative does reduce the acreage of wetlands subject to potential secondary impacts
due to altered hydrology. However, it does not appear to avoid the possibility. In summary, the
acreage of wetlands that will be impacted in various ways by this alternative should be described
in detail.

Alternative 3.1.7, Construction of a New Plant to Johnson Property, refers to the need for a long-
term roadway to cross the wetland system. The applicant states that “it is unlikely that FEMA
could approve a long-term roadway…” To better address the viability of any alternative
involving a permanent roadway across the wetlands, the previous FEMA study should be
included in the application in order to make a definitive decision, rather than saying an option is
unlikely.

Alternative 3.1.9, Passageway Under Wetlands, presents a creative solution to accessing needed
reserves without impacting wetlands. However, information about the potential reserves for this
option is not included in the alternative discussion. Information about reserves amounts and the
extended life of the quarry should be included in discussion of this alternative.

Regarding the aerial views of the alternatives shown in Appendix A, several alternatives include
overburden placed on land located to the west of the project boundary for Benson Quarry on the
western side of Raleigh Road. More information is needed to explain how this land beyond the
project boundary can be considered in the alternatives.

The NCWRC would like two additional alternatives for expanding the quarry to be considered: a
permanent bridge over the wetlands, and a conveyor or similar system to transport material from
the north side of Stony Fork to the processing plant on the southern side of Stony Fork. These
alternatives would allow access to the reserves on the north side of the wetlands without using
Camelia Road for access and minimize wetland impacts.

Additional information on existing alternatives, such as exact wetland impacts from the
applicants’ preferred alternative, are needed. In addition, tables summarizing the wetland
impacts, operational costs, and quarry reserves and life span for all alternatives would be helpful.

While we understand the applicant’s desire to obtain one permit that will address environmental
impacts for several decades into the future, some alternatives in the IP application have far less
wetland impacts while extending the life of the quarry. In addition, it is not possible to know
how mining operations, environmental regulations, product demand, etc. may change decades
from now. Future changes, such as viable markets for overburden or a willingness of
landowners on the eastern side of the Benson Quarry to sell their land could change the way
Benson Quarry expands in the future.

The Special Use Permit issued to Martin Marietta Materials by the Johnston County Planning
Department in 2004 contains language regarding the 250-foot setback area surrounding the
property in section 5 g. It states that “existing vegetation shall be retained…” and that “No
disturbance or removal of vegetation shall be permitted except for access roads…” The majority
of the forest along Camilla Road within the 250-foot setback area has been clear cut within the
last five years. It appears that Martin Marietta, Inc. has not adhered to this condition of the

NCWRC COMMENTS 4 BENSON QUARRY IP
Special Use Permit. Mature forest within the 250-foot setback could help reduce noise and dust
levels associated with mining operations.

In summary, the adverse effects of Benson Quarry expansion on aquatic and terrestrial wildlife
resources depend on the impacts to the wetlands and forested habitat associated with Stony Fork.
Currently the wetlands associated with Stony Fork appear to be functioning well and maintaining
their hydrology despite close proximity to the quarry. Additional alternatives need to be
considered and additional information provided for existing alternatives in order for NCWRC to
complete our review and to determine the Least Environmentally Damaging Practical
Alternative.

Thank you for the opportunity to review and comment on this Individual Permit. Please feel free
to contact me at [e-mail] or 919-284-5218 if you have any questions or
concerns about these project comments.

Ec: Jennifer Burdette, NCDENR-DWR
Karen Higgins, NCDENR-DWR
John Ellis, USFWS