20230533 Ver 1_Gold Rock-NCDWR Request for Additional Information Response_2023-07-28_20230728

-40- WithersRavenel
.. our People. Your Success.
July 28, 2023
NCDEQ - Division of Water Resources
Raleigh Regional Office
Mr. Zach Thomas
3800 Barrett Drive
Raleigh, NC 27609
Re: FSC Gold Rock Asphalt Plant - NCDWR Request for Additional Information Response
Battleboro, Nash County
NCDWR Project #20230533
USACE AID: SAW-2021-02689
WR Project #02080270.01
Dear Mr. Thomas,
This letter is in response to the Request for Additional Information (RFAI) email dated 6/15/2023.
Below are the items addressed in the RFAI email and our response:
NCDWR Request for Additional Information Email (6/15/2023):
1) Please provide more details regarding the need for wetland impact W1 on the PCN for this
project [15A NCAC 02H .0506(f) and (g)j. This Office believes that the wetland impacts can be
moved or reconfigured to minimize the impacts. Please revise the plans to avoid the impacts
or provide a detailed explanation of why this plan for the activity cannot be practically
accomplished, reduced, or reconfigured to avoid impacts to these impacts.
a) Please describe in detail why the gravel yard footprint needs to encroach 0.294 acres
into wetland A and why the adjacent vacant parcels owned by Wake Stone cannot be
utilized for gravel storage to avoid impacts to the wetland feature.
Following receipt of the RFAI, the applicant began looking for an alternate site and
layout for the proposed plant. The proposed location is owned by Wake Stone and is
to be leased for the asphalt plant facility. The applicant entered into talks with Wake
Stone regarding use of an additional parcel located south of the proposed location.
Residential land use in the vicinity of any proposed asphalt plant location must be
carefully considered. The proposed location was chosen in part due to the distance
from the residential lots located to the southwest and the ability to effectively screen
the plant's activities. Utilizing the Wake Stone parcel located to the south would have
likely been opposed because it would locate the asphalt plant too close to the
residential area to the southwest. Additionally, it is not feasible for the applicant to
pursue a long rezoning process on a parcel that is likely to be denied due to opposition.
Utilizing the existing plant location at the Wake Stone quarry for storage is not an
option as this land is owned by Wake Stone and is planned to become part of a future
mine expansion.
It is not practical to reduce impacts to Wetland A because the proposed asphalt plant
requires sufficiently sized and safe aggregate storage yard for employees and staff due
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FSC Gold Rock Asphalt Plant 4: Withers Rave n e l
NCDWR Request for Additional Information Response ❑ur People. YourSuccess-
Battleboro, Nash County
7/28/2023
to the need to safely maneuver large equipment with clear lines of sight. Additionally,
the need to screen the asphalt plant and reduce noise for nearby residential homes
dictated the desired site layout. This layout properly sites the plant while providing the
needed aggregate storage and enough space for safe maneuverability of large
equipment. There is inadequate space for large equipment to safely maneuver around
the western end of Wetland A, necessitating impacts in this area. Impacts to Wetland
A have been minimized to the greatest extent practicable while still having a viable site
layout and preserving most of the wetland.
Please contact me if you have any questions about the information provided.
Sincerely,
WithersRavenel
Rick Trone
Environmental Scientist
Attachments:
1) NCDWR Request for Additional Information email (6/15/23)
Page 2 of 2

From:
Thomas, Zachary T
To:
Trone. Rick
Cc:
brent.woodCalconstructionnartners.net; Standridae. Billy W CIV USARMY CESAW (USA)
Subject:
[EXTERNAL] RE: [External] RE: DWR# 20230533 - FSC Goldrock Asphalt Plant, SAW-2021-02689
Date:
Thursday, June 15, 2023 5:08:24 PM
Attachments:
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Hi Rick,
After my review, I need further clarification on the avoidance and minimization described in the PCN
before I can move forward:
Avoidance & Minimization for Wetland Impacts - Please provide more details regarding the need for
wetland impact W1 on the PCN for this project [15A NCAC 02H .0506(f) and (g)]. This Office believes
that the wetland impacts can be moved or reconfigured to minimize the impacts. Please revise the
plans to avoid the impacts or provide a detailed explanation of why this plan for the activity cannot
be practically accomplished, reduced, or reconfigured to avoid impacts to these impacts.
• Please describe in detail why the gravel yard footprint needs to encroach 0.294 acres into
wetland A and why the adjacent vacant parcels owned by Wake Stone cannot be utilized for
gravel storage to avoid impacts to the wetland feature.
If you have any questions, please let me know.
Thank you,
Zach Thomas
Environmental Program Consultant, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone]
zachary.thomasna deq.nc.gov
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Raleigh Regional Office
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Raleigh, NC 27699-1628
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