20220241 Ver 1_Alternatives Analysis 12-6-2022_20221206

Development of Alternatives
In order to develop potential alternatives, MMM considered factors such as technical and logistical
feasibility, economic and business planning requirements, and potential impacts to jurisdictional waters
and other environmental resources.
With respect to business planning and systematic and cost-effective quarry operations to serve the
relevant market area, MMM is seeking to mine existing economically viable aggregate reserves at its
Belgrade Quarry to supply the market in the short and medium term.
Generally, transportation costs (and haul distances) are significant components of aggregate product
cost and price, which constrains the geographic market area a quarry may viably serve.
The Belgrade Quarry available aggregate reserves within the existing pit are being depleted, and
expansion of the Belgrade Quarry to mine additional aggregate reserves is necessary in order for MMM
to continue to cost-effectively serve the market area in the short and medium term (10 and 20 years).
Offsite Alternatives Analysis
Offsite Alternative Requirements and Limitations
MMM determined that in order to serve the same market area that Belgrade Quarry currently serves,
potential offsite alternatives need to be within a 5-mile radius of the current site as discussed below. As
shown on Figure 1, MMM's Clarks Quarry and Onslow Quarry are less than 20 miles from Belgrade
Quarry (all shown with a 10-mile rarrket
etermining exact market areas for these three quarries can
be difficult, as they do have somehowever alternatives farther than 5 miles from the current
site would leave other areas of tharea at a disadvantage in relation to haul distance. As fuel
prices continue to rise, aggre ate hnce becomes even more important.
In terms of acreage, it i icult to rovidein exact acreage needed for a quarry project without
understanding the geologic data uncle�ying a particular parcel(s) and the cost of developing that parcel
as a quarry, which includes an analysi f development costs and the cost of transporting mined
materials to the market place. MMM evaluated parcels that are a minimum of 300 acres in size because
is the minimum acreage necessary to allow for the development of (i) an approximately 200-acre pit, (ii)
approximately 25 acres of overburden storage, berms and buffers, (iii) approximately 75 acres for a
plant, shop, scale house, employee building, roads and infrastructure, all of which are components of
the proposed project. Moreover, the development of at least an approximately 200-acre pit is necessary
to justify the investment of capital to develop and operate the mine over its life, and the cited acreages
for attendant land uses such as buffers, overburden storage, and a plant and shop are necessary to
support the development and operation of a 200-acre pit. For comparison, the Current pit at Belgrade
Quarry is over 300 acres. Developing a marine limestone quarry site in this area for less than a 200 acre
pit would not be economically viable due to the cost of development.
As for Geology, much of the area surrounding this part of NC is mapped as having limestone bedrock,
though in reality, it is very sporadic in thickness and quality for aggregate production. Martin Marietta
has previously conducted exploratory drilling on many of the proposed alternatives and as explained in
the analysis below, the results have been negative.

Project cost can impact project alternatives in several ways. One way is property acquisition cost. Of
the properties shown in the alternatives analysis, none are for sale. As such the cost to buy a property
from an owner that is not actively trying to sell their property can be much higher. Property can be
leased from an owner for a quarry site, and often is, but the cost of the lease including royalties paid to
the owner can be exponentially higher than purchasing a property.
The time required to open a new quarry is also a limiting factor associated with the cost of any offsite
alternative. Permitting and opening a new quarry site can take up to 10 years or longer. This leaves the
market unserved for a period of time.
MMM Developed the following offsite alternatives with numbers corresponding to those shown on the
maps attached as Figures 2-5 and in the chart attached as Figure 6 (provided in Supplement).
At the request of the Corps, MMM also evaluated hauling unprocessed "shot rock" from an offsite
source to be processed at the current Belgrade Quarry facility. That evaluation is also included below.
As discussed in the December 06, 2022 letter to the Corps, additional details associated with the analysis
below of Offsite Alternatives was supplied to the Corps. That information is business confidential and
exempt from disclosure under FOIA.
Offsite Alternative 1:
According to NWI mapping, this property�as approximately 1374 acres of wetland. Even with
this much wetland area, there would be room to construct a pit on this property. But MMM
conducted exploratory drilling on this property and the results determined that there were no
minable reserves. For this reason, Offsite Alternative 1 would not meet the purpose and need
and therefore would not be the Least Environmentally Damaging Practicable Alternative
(LEDPA).
Offsite Alternative 2:
According to NWI mapping, this property has approximately 10 acres of wetland. Given the
small acreage of mapped wetlands (which would require ground truthing) this site could be ideal
to avoid and minimize impacts. However, MMM has conducted exploratory drilling on this
property and the results determined that, although it contains some limestone, reserves are
very limited and would not be sufficient to justify production or the investment of capital. For
this reason, Offsite Alternative 2 would not be the LEDPA.
Offsite Alternative 3:
According to NWI mapping, this property has approximately 39 acres of wetland. This property
is just over the required size and as shown in Figure 3 a majority of the wetland features are in
the center of the site. As such, this site would require extensive wetland impacts to develop.
Furthermore, MMM has conducted exploratory drilling on this property and the results

determined that there were no minable reserves. For these reasons, Alternative 3 would not be
the LEDPA.
Offsite Alternative 4:
According to NWI mapping, this property has approximately 234 acres of wetland. Though this
property is large enough, as shown in Figure 3 several wetlands cross the center of the site and
would therefore require extensive impacts. Furthermore, MMM has conducted exploratory
drilling on this property and the results determined that there were no minable reserves. For
these reasons, Alternative 4 would not be the LEDPA.
Offsite Alternative 5:
According to NWI mapping, this property has approximately 68 acres of wetland. Though this
property is large enough, as shown in Figure 3 much of the wetland features cross the center of
the site and would therefore require extensive impacts. Furthermore, MMM has conducted
exploratory drilling on this property and the results determined that there were no minable
reserves. For these reasons, Alternative 5 would not be the LEDPA.
Offsite Alternative 6:
According to NWI mapping, t�property ham pproximately 21 acres of wetland. Though this
property is only slightly above the required size, most of the mapped wetlands are shown near
the borders and could possibly be avoided. However, MMM has conducted exploratory drilling
on this property and the results determined that there were no minable reserves. For this
reason, Alternative 6 would not meet the purpose and need and would not be the LEDPA.
Offsite Alternative 7:
According to NWI mapping, this property has approximately 3 acres of wetland. Given the
minimal amount of mapped wetlands this property could be one of the better alternatives to
avoid impacts. However, MMM has conducted exploratory drilling on this property and the
results determined that there were no minable reserves. For this reason, Alternative 7 would
not meet the purpose and need and would not be the LEDPA.
Offsite Alternative 8:
According to NWI mapping this property contains approximately 64 acres of wetland with most
of the wetlands mapped in the boarders. A majority of these wetlands could be avoided. MMM
has explored this alternative and results show thin low -quality limestone. As such, return on
investment would not be sufficient to justify production or the investment of capital, therefore

mining this property is not practicable and it would not meet the purpose and need of the
project.
Offsite Alternative 9:
According to NWI mapping this property contains approximately 158 acres of wetlands. The
property is also divided by a road and several homesites. The entire eastern side of the property
is mapped as wetland. MMM has not conducted any exploratory efforts on this property and
limestone reserves are unknown. The portion of the property between the road and the
wetland area is only 150 acres. As such, the usable area of this property would be too small to
meet the requirements and therefore would not be the LEDPA.
Offsite Alternative 10:
According to NWI mapping, this property has approximately 69 acres of wetland. At 304 acres,
the property is just big enough to meet the requirements stated above but is oddly shaped and
would be difficult to fit the required infrastructure. Furthermore, MMM has conducted
exploratory drilling on this property and the results determined that there were no minable
reserves. For these reasons, Alternative 10 would not be the LEDPA.
Offsite Alternative 11:
The property is split by a road, and according to NWI mapping contains approximately 123 acres
of wetland. Much of the wetland is located on the western side of the property. The area
between the wetland and the road is approximately 240 acres with a portion of this upland area
currently in use as a recently constructed solar farm. MMM has not conducted any exploratory
efforts on this property and limestone reserves are unknown. Given that the usable amount of
acreage is under the required 300 and that a portion of that is currently used for power
production, this alternative would not be practicable and therefore would not be the LEDPA.

Additional Offsite Option:
Hauling material from an offsite location to the Belgrade Quarry for processing.
MMM has researched the concept of hauling material from an offsite location to the Belgrade
Quarry plant for processing. Although this concept could have some potential positive
attributes —for example, it avoids the need to construct a new plant, office and scale facility --it
is likely that some sort of office/employee building and shop facility would nevertheless be
required at the new site, as well as required property boundary buffers, berms and overburden
storage.
More importantly, however, is that this concept would require hauling raw material expelled
from a blast, known as "shot rock", in over the road trucks from the pit location to the plant.
This has never been done by MMM in aggregate mining because it is inefficient, expensive, and
results in increased environmental impacts and truck haul distances. Hauling material in over
the road trucks requires that the shot rock be reduced to Rip -Rap size. This would require a
more expensive shot pattern and much more work by excavator mounted rock breakers to
further break up boulders. Given the nature of marine limestone, this is expected to create
more waste in that breaking limestone with a blast"is7not as controlled as a rock crusher,
creating more fine material. Shot rock would have to be double handled due to being loaded
into off road trucks in the pit, dumped into a stockpile and then loaded into over the road
trucks. This would also require additional loaders. After the trucks are loaded the material
would then be brought to the existing Belgrade plant for processing, before being loaded into
over the road trucks again as it is sold. This essentially doubles the number of trucks on the
road which would have a negative impact on the community and environment. Trucks traveling
between the pit and the plant would travel the same path every day back and forth. Due to
these additional trucks on the road and the negative impact it could have to the community that
lives on the route, it is likely that this concept would not be approved by local zoning
regulations.
Along with the additional cost of blasting, rock breakers, additional loaders and double handling
of material, it would be necessary for MMM to contract out the hauling of material between the
two sites (MMM does not have a trucking fleet in NC). It has been estimated that this haul
alone would add approximately $5 per ton to production costs.
MMM estimates that using current production and sales numbers, this concept would add
approximately $2.4 million per year in production costs. Due to these costs and the negative
impact to the community and air quality associated with doubling the number of trucks on the
road, this concept would not be practicable.

Onsite Alternatives Analysis
Alternative 1: No Action Alternative
The No Action alternative would involve mining what is currently permitted, and mining a small
portion of the Bender Pit.
In order to avoid a permit action, bridge crossings would have to be constructed in order to
avoid impacts. Given the width of the overburden road crossing, it would be impossible to build
a bridge that could hold a 70-ton haul truck without impacts from bridge foundations, therefore,
this road could not be constructed in the No Action Alternative. Furthermore, the cost of
constructing two other substantial enough bridges to enter the site from the north, in the
location shown in the preferred alternative, would not be practicable. Furthermore, avoiding
wetland impacts directly associated with the pit would not meet the purpose and need as this
would not supply enough aggregate to meet the short and medium term need as described in
the purpose and need.
The no action alternative could also involve mining a very small "North Pit". The stream
proposed for impact in our preferred alternative and required mining buffers, would separate
this pit from our existing pit. This would involve installing a bridge crossing or bottomless
culvert over the stream to access the new pit. Due to the required property line buffers and
stream buffers, the pit size would only b?% ro;Mit
.ely 4.5 acres. The smaller 4.5-acre pit
would also not be connected to the existing pit,s in the preferred alternative, meaning
that overburden and bench slopes would exist on all sides, reducing the footprint of rock tha
could be mined. These factors cut obtainable reserves from the North Pit in half and therefore
make it impracticable.
The local reserves currently available to supply the Maysville, Jacksonville and surrounding
geographic market area fall short of market demand. The no action alternative would not result
in economically viable continued service to the surrounding market area by local supply from
the Belgrade Quarry.
This alternative would not meet the basic or overall project purposes and due to costs, would
not be practicable.
Alternative 2: Preferred Alternative, Combined Bender Pit (Figure 8) and North Pit (Figure 7)
Bender Pit
The proposed 92.5-acre Bender Pit is located south of the existing pit on the east side of the
White Oak River. This proposed pit is separated from the current pit and plant area by a
wetland system, which encircles the proposed pit.
MM is proposing two road crossings in order to provide adequate safe access to the new pit
area.

The northern crossing is shown in Figure 8 as "Haul Road to Plant" crosses two wetland areas
and would impact 0.45 acre of wetland. It is located to align with an existing established road,
which travels to the plant area. This proposed product haul road would also impact 0.18 acre of
wetland associated with the expansion and upgrade of an existing crossing as shown on the map
at the north-eastern tip of the proposed pit.
A second proposed haul road for overburden is shown as "Overburden Road" on the attached
map Figure 8. This road is aligned to allow the safest and most direct travel for hauling
overburden material to the existing mined out southern end of the current pit. This proposed
crossing would be constructed in the narrowest area of the wetland system which divides the
two pits while still allowing direct travel. Impacts associated with this road total 106 LF of
stream and 0.9 acre of wetland.
In the process of open pit mining of limestone, overburden removal is a continuous process.
Unlike a hard rock quarry, which has a smaller footprint and much deeper mine, the entire pit is
not stripped of overburden at one time. Instead, as soon as overburden is removed from
enough area, mining will begin and the two processes will commence simultaneously moving
across the pit area. This separation of two different roadways for overburden trucks and
product haul trucks is necessary for operation efficiency and safety under the circumstances.
Furthermore, having a direct path for overburden trucks would reduce each trip from the
proposed pit to the old pit where material is to be deposited by nearly 1 mile. This would result
in a substantial savings in efficiency, fueftts, equipment wear and diesel emissions.
The proposed Bender pit is comprised of mostly upland areas with 5 wetland fingers which
extend into the pit area. These impact areas have been studied for geological resources and the
proposed wetlands impacts will allow access to those areas, as well as to mine ore in upland
areas. The impacts total 7.43. As shown on the map (Figure 8), other wetland areas
surrounding the pit will have a 50ft buffer. As shown on the attached pit cross section (Exhibit
A), inside of this 50ft buffer a road/berm be constructed exist to allow travel around the mine
and to remedy any possible flooding of the pit. Inside of this berm, overburden will slope down
to the rock surface which will be mined.
MMM has sought to avoid and minimize impacts to the extent feasible, as discussed in the
Avoidance and Minimization sections below.
MMM believes that this alternative, together with the North Pit, discussed below, is the Least
Environmentally Damaging Practicable Alternatives for expanding limestone production at
Belgrade Quarry.
North Pit
The proposed 7.9-acre North Pit is an expansion to the north of the existing pit.
MMM is currently mining in the northern portion of the existing pit, as can been seen in the
attached Figure 7. Just north of this area lies a previously farmed field, currently owned by
MMM and currently zoned for mining. Valuable limestone reserves exist in this area (the
proposed "North Pit") which also contains a previously "straightened" stream system (Stream A)
that originates in an agricultural area directly across HWY 58. MMM is proposing to move this

ditched stream to the north, around the proposed mining area in order to mine these limestone
reserves. The portion of the stream has been evaluated using the NCSAM method and was
shown to be low quality. Downstream of this proposed impact Stream A becomes more
sinuous, as it has not been straightened. Two more NCSAM evaluation were completed on this
portion of the stream also, which rated this section of the stream as "low" and "medium".
Impacts to this low -quality segment total 793 linear feet.
Once mining has been completed in the northern part of the existing pit, the existing haul road
out of the pit, and bottom floor of the pit will be mined out. If these reserves are not mined
before this process is completed, it will be impossible to mine them in the future.
MMM believes that utilization of the North Pit, due to the low quality of this stream in this area,
and the proposal to avoid the higher quality lower portion of this stream, together with
constructing the Bender Pit described above, is the Least Environmentally Damaging Practicable
Alternative to continue serving the Belgrade Quarry market feppthe short and medium term.
The combination of the North Pit and the Bender Pit would meet the applicant's purpose and
need; but removing either component from this Alternative would result in a failure to meet the
applicant's purpose and need for the project.
Alternative 3: Western Pit (Figure 9)
Prior to 1988, MMM was actively mining a pit located on the western side of the White Oak
River, as shown on the attached Figure 9. This area was a leased property and though it is still
within MMM's current NC DEMLR mining permit, MMM no longer leases this property. If lease
access could be renegotiated with the owner, MMM could consider coming back to this area to
finish mining. However, this area was abandoned due to low quality limestone, and there are
only a small amount of reserves remaining.
Due to the small amount of remaining reserves in this area and the lower quality limestone and
high waste factor of the reserves that do remain, this alternative does not meet the purpose and
need of this project to cost-effectively serve the market area in the short and medium term.
Alternative 4: Expanding Existing Pit to the South (Figure 10)
In developing alternatives for continuing the life of Belgrade Quarry, expanding the current pit
through the large wetland area to the south and continuing into the proposed Bender pit was
researched and considered. Though mitigation costs associated with impacting this large
wetland system would be very high, it was found that this would be an economically viable
option, and due to reserves in this area, it would be the best way to maximize the life of
Belgrade Quarry in order to serve the surrounding market for years to come. However, though
this alternative would meet MMM's purpose and need, MMM has determined that due to the
impacts to higher quality wetlands and the floodplain of the White Oak River, this would not be
the least environmentally damaging alterative.

Alternative 5: Preliminary Plan (Figure 11)
A very preliminary plan was provided to the Corps in an early pre -application meeting. The plan
was shared as "Confidential Commercial Information" due to the fact that the plans were not
final and MMM was not ready to release them to the public. This plan shows less wetland
impacts and only one road crossing. MMM never intended for this plan to be final, but the
Corps has requested that we evaluate it as an alternative. This plan is no longer considered to
be confidential.
This plan was only meant to be preliminary and for discussion purposes only, as it was titled,
and did not include enough reserves to meet the need of an expansion at the Belgrade Quarry.
Requesting less than our final plan could be considered as "piece mealing" the project as a
permit for this preliminary plan would only lead to MMM applying for the additional wetland
impacts in the future. The plan also did not include the additional road crossing needed for
overburden haulage. As explained in the road crossing alternatives, a project without the
overburden road crossing would not only be unsafe, but would also not be economical and
would therefore not be practicable. Another difference in the plan is the location of the
northern road crossing. In this initial plan it was not aligned with the existing haul road. Again,
in its preliminary nature, the plan did not take the need to tie into the existing road into
condition.
For the reasons listed above, this plan does not t the purpose and need and is not the
LEDPA.
Alternative 6: No Build Alternative
The no build altern fivNwXine mining what is currently permitted, and then closing the
Belgrade Quarry.
The local reserves currently available to supply the Maysville, Jacksonville and surrounding
geographic market area fall short of market demand. The no build alternative would not result
in economically viable continued service to the surrounding market area by local supply from
the Belgrade Quarry.
This alternative would not meet the basic or overall project purposes.
Haul Road Assessment and Alternatives:
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 Figure 12 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
did not propose it. An example of the one-way to d system is shown on the attached map
Figure 13.
MMM has also explored the Alternative of a single I overburden road with a one-way traffic
pattern. All proposed roads must be designed to MSHA standards. For the trucks currently in
use at the Belgrade Quarry, I e 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 oul*nly impact approximately 0.25 acres of wetland less than a
two-lane road. MMM believ hat the use of a one lane road would not only cause a more
hazardous condition, but wo 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, although a single lane road with traffic controls could be feasible, in
this situation it is not practicable nor is it the least environmentally damaging practicable
alternative.
Conclusion
MMM believes that the above Offsite and Onsite Alternatives Analysis precisely address all
feasible alternatives to the project and confirm that the preferred alternative as described in
Onsite Alternative 2 is the Least Environmentally Damaging Practicable Alternative.

Attachments:
Figure 1: Quarry Radius Map
Figure 2: Offsite Alternatives Street Map (PUBLIC)
Figure 3: Offsite Alternatives NWI Map (PUBLIC)
Figure 4: Offsite Alternatives Imagery Map (PUBLIC)
Figure 5: Offsite Alternatives USGS Map (PUBLIC)
Figure 6: Offsite Alternatives Chart (Only Provided in Supplemental Business Confidential Package to Corps)
Figure 7: Northern Expansion
Figure 8: Bender Pit
Figure 9: Western Pit
Figure 10: Expand Pit to South
Figure 11: Preliminary Map
Figure 12: Overburden Road Distance Map
Figure 13: Overburden Road Alternative Map
Figure 14: Proposed Haul Road Map
S