20240370 Ver 1_More Info Received_20240622

Soil & Environmental Consultants, Inc.
8412 Falls of Neuse Road, Suite 104, Raleigh, NC 27615 • Phone [phone] • Fax [phone]
sandee.com
S&EC 13220
June 22, 2024
To: U.S. Army Corps of Engineers (USACE), Wilmington District
Washington Regulatory Field Office
Attn: Billy W. Standridge
2407 W. 5t' Street
Washington, NC 27889
Cc: N.C. Division of Water Resources (DWR)
401 & Buffer Permitting Branch
Attn: Stephanie Goss & Sue Homewood
512 North Salisbury Street
1611 Mail Service Center
Raleigh, NC 27699-1611
* Submitted electronically via email.
From: Bob Zarzecki
Soil & Environmental Consultants, Inc. (S&EC)
Wetlands Department Manager
On behalf of Heidelberg -Materials SE Agg LLC (Applicant)
Re: Responses/Additional Information
USACE Letter dated May 24, 2024
Dear Mr. Standridge:
On May 24, 2024, we received your letter dated May 24, 2024, requesting additional information to
complete your review of the application submitted on March 12, 2024. Please find below and attached the
additional information that you requested.
Public Comments:
USACE Letter: "A total of two comments were received in response to the public notice. Comments
were received from one adjacent property owner and the Catawba Indian Nation. All correspondences
are summarized for your records and response. "
1) "Mr. KC. Williams expressed concerns regarding potential impacts to irrigation and drinking
water wells located on the properties west of'the project area. The properties include the

Williams Plant Farm as well as residential and agricultural property. The wells range in depth
from approximately 200 feet — 550 feet deep. "
Response: Heidelberg Materials met the Williams and discuss this issue during the
community meeting held in Sims, NC on March 21, 2024. They reached out to Mr. H.C.
Williams again on June 4, 2024, and were able to speak with him briefly about a Well
Protection Program. We are working to set up a meeting with Mr. Williams and his
family to quantify what a Well Protection Program would look for their commercial
operation. Attached is a copy of a Well Protection Program that is in place for the
residential wells surrounding our Stephenson Property at the Elliott Sand & Gravel
Operation in Erwin, NC for your reference. A copy of a Well Protection Program for Mr.
Williams will be submitted upon its completion. Heidelberg Materials does not believe
that the proposed expansion will result in any negative impacts to the Williams wells
given the presence of the existing pit, but is committed to ensure good relations with their
neighbors and will ensure that the Williams water needs are adequately met.
2) "The Catawba Indian Nation (Catawba) submitted comments by letter dated April 18, 2024.
Specifically, the Catawba stated that they had no immediate concerns with regard to traditional
cultural properties, sacred sites or Native American archaeological sites within the boundaries
of the proposed project areas. However, the Catawba requested to be notified if Native
American artifacts and/or human remains are located during the ground disturbance phase of
this project. "
Response: Heidelberg Materials does not oppose a condition placed in the 404 permit that
requires the Catawba to be notified if Native American artifacts and/or human remains are located
during the ground disturbance phase of this project.
USACE Request for Additional Information:
USACELetter: "Please be aware that Section 404(b)(1), of'the Clean WaterAct, states that no
discharge of'dredged or fill material shall be permitted if'there is a practicable alternative to the
proposed discharge which would have less adverse impact on the aquatic ecosystem, so long as the
alternative does not have other significant adverse environmental consequences. As such, please
elaborate on or provide additional information regarding the items) below:"
1) "The inclusion of the Morehead City Sales yard in the overall project purpose is overly
restrictive. Please provide an updated project purpose and adjust the alternatives analysis with
that criteria removed"
Response: The inclusion of the Morehead City Sales Yard has been removed from the attached
updated alternatives analysis per your request. The sales yard has also been removed from the
attached (Block 19) Project Purpose & Need.
2) "Please incorporate a geographical area element into the screening criteria in order to define
and limit the range of potential offsite alternatives. "
Response: The attached updated alternatives analysis incorporates a geographical area element in
the screening criteria per your request.
Page 2 of 3

3) "Please provide additional information on why the impacts to Stream F and the abutting
wetlands cannot be avoided by including an additional on -site alternative that addresses the
practicability of avoiding these resources. "
Response: The attached updated alternatives analysis and map set includes Alternative 5 which
avoids Stream F and abutting wetlands per your request. This alternative does not provide
adequate reserves.
Please don't hesitate to contact us if you have any questions or require additional information to complete
your review of the application.
Sincerely,
Bob Zarzecki
Bob Zarzecki, S&EC, Inc.
Digitally signed by Bob
Zarzecki
Date: 2024.06.22 16:06:21
-04'00'
Attachments:
• USACE Letter dated May 24, 2024
• Well Protection Program Example Agreement
• Updated Block 19 — Project Purpose & Need
• Updated Alternatives Analysis & Map Set (June 12, 2024)
Page 3 of 3

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
May 24, 2024
Regulatory Division
Action ID No. SAW-2020-01319
Mary Anne Hoerle
Heidelberg Materials SE Agg LLC
3825 Barrett Drive, Suite 300
Raleigh, North Carolina 27615
Dear Ms. Hoerle:
Reference is made to the application of March 4, 2024, for Department of the Army
(DA) permit authorization to impact 1.48 acres of wetlands, 2,152 linear feet of stream,
and 6.17 acres of open water pond associated with the expansion of the Neverson
Quarry in Sims, Wilson County, North Carolina. The purpose of this correspondence is
to provide you with U.S. Army Corps of Engineers (Corps) comments and those we
received from environmental review agencies and the public related to review of the
public notice associated with your application.
A total of two comments were received in response to the public notice. Comments
were received from one adjacent property owner and the Catawba Indian Nation. All
correspondences are summarized for your records and response.
1) Mr. H.C. Williams expressed concerns regarding potential impacts to irrigation and
drinking water wells located on the properties west of the project area. The properties
include the Williams Plant Farm as well as residential and agricultural property. The
wells range in depth from approximately 200 feet — 550 feet deep.
2) The Catawba Indian Nation (Catawba) submitted comments by letter dated April 18,
2024. Specifically, the Catawba stated that they had no immediate concerns with
regard to traditional cultural properties, sacred sites or Native American archaeological
sites within the boundaries of the proposed project areas. However, the Catawba
requested to be notified if Native American artifacts and/or human remains are located
during the ground disturbance phase of this project.

-2-
Please provide a comprehensive, detailed response to address each of these
concerns listed above.
Please be aware that Section 404(b)(1), of the Clean Water Act, states that no
discharge of dredged or fill material shall be permitted if there is a practicable alternative
to the proposed discharge which would have less adverse impact on the aquatic
ecosystem, so long as the alternative does not have other significant adverse
environmental consequences. As such, please elaborate on or provide additional
information regarding the item(s) below:
1) The inclusion of the Morehead City Sales yard in the overall project purpose is
overly restrictive. Please provide an updated project purpose and adjust the
alternatives analysis with that criteria removed.
2) Please incorporate a geographical area element into the screening criteria in order
to define and limit the range of potential offsite alternatives.
3) Please provide additional information on why the impacts to Stream F and the
abutting wetlands cannot be avoided by including an additional on -site alternative
that addresses the practicability of avoiding these resources.
Your response to the comments must be given full consideration before we can
make a final decision on your application. You may submit additional information, revise
your plans to help resolve the issues, rebut the issues made or request a decision
based on the existing record. Please be aware that, depending upon the level of
detailed information you provide, we may still have concerns and/or questions that will
need to be addressed. We must receive a written response by June 24, 2024,
otherwise your application will be withdrawn. If withdrawn, it will be re -opened once the
requested information is received. If you have questions or comments, please contact
me at telephone [phone] or contact me at email address
[e-mail].
Sincerely, J
Billy andridge
Regulatory Project Manager

-3-
Enclosure
Copies Furnished (via email):
Sue Homewood
NC Division of Water Resources
sue. hom ewood @deq. nc. gov
Mr. Bob Zarzecki
Soil & Environmental Consultants, Inc.
[e-mail]

WATER WELL PROTECTION PROGRAM
Introduction
As part of the approval of a Special Use Permit by the Harnett County Board of
Adjustment on January 9, 2023, for the +/- 177 acres Covington Road Property, PIN # 0576-80-
7529.000 (the Subject Property), Heidelberg Materials (f/k/a Hanson Aggregates, and
hereinafter "Heidelberg Materials") agreed to institute a Well Protection Program (WPP) for
property owners located near the Subject Property. Only property owners located on Byrd's Mill
Road between Covington Road and NC Highway 217, Harnett County, North Carolina, shall be
the beneficiaries of this WPP (hereafter "eligible property owners").
Program
If, after the start of mining operations on the Subject Property, an eligible property owner
incurs well failure (well ceases to produce water) for any reason other than outlined below, he or
she shall give written notice to Heidelberg Materials outlining their well situation and shall ask
Heidelberg Materials to move forward with the provisions of the Well Protection Program as
outlined within this document.
Following property owner written notification, Heidelberg Materials will provide a
temporary source of potable water to the property owner, and upon verification of the water -
producing failure, Heidelberg Materials, at its sole expense, shall move forward in providing a
new permanent water source. Subject to availability and at Heidelberg Materials' sole discretion
following consultation with the well owner, the new permanent water source will be either a new
drilled well or connection to the existing county water source.
All written notices required by the above shall be sent to: Heidelberg Materials
Aggregates Southeast LLC, 3825 Barrett Drive, Suite 300, Raleigh, NC 27609. Attention:
General Manager.
To expedite the process a second notice may be hand delivered to: Elliott Sand Plant,
4880 NC Highway 217, Erwin, NC 28339. Attention: Plant Manager.
Replacement Water Sources
If an eligible property owner's well has gone dry, excluding mechanical failure, failure to
provide normal maintenance of the system, or drought, Heidelberg Materials shall use its best
efforts to provide a suitable substitute water source to the property owner at Heidelberg
Materials' sole expense within twenty-four (24) hours of receiving the written complaint.
Heidelberg Materials shall continue to supply a suitable substitute water source until such time
that a new well is drilled, or connection is made to the existing public water system.

Neverson Quarry Expansion
BLOCK SHEETS
BLOCK 19 — Proposed Project Purpose
Heidelberg Materials Southeast Agg LLC (Heidelberg Materials) is a North Carolina
licensed corporation and subsidiary of Heidelberg Materials. Heidelberg Materials
operates eight (8) aggregate quarries in North Carolina, including the Neverson Quarry
located in Wilson County, NC.
The expansion plan addresses all phased (Phases 1 & 2) stream, wetland, open water
and Neuse Buffer impacts under a single Individual Permit Application. If approved, this
permit would allow Heidelberg Materials to continue to provide crushed stone products
for public and private construction projects within the currently supplied and
surrounding market areas.
Crushed stone, from operations like this, is used to make concrete and asphalt roads,
concrete for homes and office buildings, and is used in a wide variety of erosion control
projects. Aggregate operations are relatively long lived and are vital to the economic
health of communities. About 10 tons of aggregates are required annually for each
North Carolina citizen. A typical residential subdivision requires about 300 tons of
aggregate per home. The single largest market for aggregates is road and street
construction, including base and asphalt paving for highways, parking lots and other
pavements. One mile of typical 2-lane asphalt road with aggregate base requires about
25,000 tons. Other large markets are concrete for bridges, pavements and building
structures, riprap and erosion control stone, and railroad ballast. Approximately 50
percent of all aggregate is used for publicly funded construction projects (i.e., highways,
water and sewer systems, public buildings, airports and other county and municipal
public works projects).
Basic Project Purpose:
The basic project purpose is to mine aggregates to meet market demands.
Water Dependency Determination:
The project is not water dependent.
Overall Project Purpose:
The overall project purpose is to provide for the continued operation of the existing
Neverson Quarry by expanding the existing pit to provide mined aggregates to the
currently supplied and surrounding market areas.
Revised June 2024

Heidelberg
Materials
Alternatives Analysis
Heidelberg Materials would like to continue their business at Neverson Quarry supplying
aggregates to the local market. The quarry currently serves projects and plants located in
Wilson, Nash, and Johnston counties, as well as parts of eastern Wake County. Neverson
Quarry also participates in rail accessed markets due to its location along an active rail line.
Outlined below are potential alternatives and their merits.
Alternative 1 (Off -Site Locations)
Owned Active Locations:
The Neverson Quarry aggregate market could be supplied with stone from an alternate
Heidelberg Materials location. This option would avoid all stream and wetland impacts; however,
this option is impractical from a business perspective. The nearest Heidelberg Materials
locations are Rocky Mount Quarry (28 miles away by road) and Princeton Quarry (26 miles by
road). Supplying the Neverson market from this location would put Heidelberg Materials at a
significant competitive disadvantage by adding distance and cost to all hauls.
Owned Inactive Location:
The Neverson Quarry Market could also be supplied by one of our idled locations, Elm City
Quarry. This site has been inactive since approximately 1995. The site is currently permitted for
mining; however, the processing plant equipment has been removed and the pit has been
allowed to fill with water. Re -opening this site would require significant financial investment.
Based on current industry rates, a good budgetary number for a new plant and associated
infrastructure would be in excess of $30 million. Furthermore, the distance between Elm City
Quarry and Neverson Quarry is 21 miles by road. Supplying the Neverson market from this
location would put Heidelberg Materials at a significant competitive disadvantage by adding
distance and cost to all hauls.
Unowned New Locations:
The Neverson Quarry market could be supplied with aggregate from a newly developed quarry
location. A search was conducted for available property (as of November 13, 2023) in the
general area of the current quarry. The first criteria considered was parcel size and proximity to
the existing quarry/market. Only two properties greater than 100 acres were for sale within 10
miles of the current site.

Property A.- S NC 581 Hwy, Bailey, NC 27807
Property A, shown above, is a 284.9-acre parcel listed for $7.1 M located approximately 2.1
miles from the existing quarry. This property is suitably sized and does have road access. As
shown on the map below, the USGS streams layer for the county shows multiple potentially
jurisdictional features throughout the site. Based on this publicly available data, there is at least
6000 LF of potential streams that may need to be impacted to develop the site.
Property B - 9765 Old Lewis School Rd, Middlesex, NC 27557
Property B, shown above, is a 110.5-acre parcel listed for $1.6M located approximately 5.4

miles from the existing quarry. This property is somewhat small to support a quarry operation,
but it does have road access. This property also shows multiple potentially jurisdictional
featuresbased on the USGS streams layer for the county. Based on this publicly available data,
there is at least 2300 LF of potential streams that may need to be impacted to develop the site.
While both properties reasonably meet the first criteria for quarry development, there are still
many steps and substantial risk in assuming either of these locations could be developed into
an operational mine site. First, these properties would need to be drilled to determine if there is
suitable rock with economical overburden amounts. Assuming the geologywas appropriate,
then the land would likely need to be rezoned and a special use permit issued to allow for
mining. After that, various state -level permits would need to be secured, including a minimum of
a Mine Permit, Air Permit, and a NPDES Stormwater permit. Also, as mentioned above, both
sites are expected to contain jurisdictional features that may require an Individual Permit for
impact.
This is a just an outline of the expected steps required to develop a new quarry and an obstacle
at any one of them could stall the entire project. Furthermore, these development activities are
costly and time consuming. Therefore, due to the significant cost and risk associated developing
a new quarry site, this option is not considered viable.
Alternative 2 (Existing Pit)
Neverson Quarry could also choose to remain within their existing pit footprint. This option
would avoid all stream and wetland impacts, but mine life would be limited significantly. The
existing pit contains approximately 5.0 million tons of reserves. In current market conditions,
thisis enough for roughly four more years of mine life. After those reserves are exhausted, the
quarry would close and Heidelberg Materials' participation in the Neverson and Morehead
markets would cease.
Alternative 3 (Eastern Pit Mine Plan)
The Eastern Pit Mine Plan option allows Neverson quarry to expand its mining footprint under
the existing processing plant to open approximately 16.4 million tons of reserves. No streams or
wetlands would be impacted by the pit expansion, but impacts would occur in the relocated
plant site and overburden storage area. The processing plant would be relocated to the west of
the pit and the overburden would be stored on the southeastern property. The expected
wetland impact would be 1.403 acres and stream impact would be 602 linear feet. Based on
current industry rates, a good budgetary number for relocating the plant and associated
infrastructure would be in excess of $20 million. This option is considered not viable due to the
significant cost associated with relocating the processing plant relative to the amount of
reserves uncovered.

would be in excess of $20 million. This option is considered not viable due to the significant cost
associated with relocating the processing plant relative to the amount of reserves uncovered.
Alternative 4 (Western Pit Plan (PROPOSED))
The Western Pit Mine Plan option allows Neverson quarry to expand its mining footprint
westward to open approximately 46.6 million tons of reserves. The processing plant would
remain in its current location and overburden would be stored on the southeastern property.
This plan is Heidelberg Materials preferred alternative since it would allow open the greatest
number of reserves while avoiding the significant cost associated with relocating the processing
plant. The expected wetland impact would be 1.403 acres and stream impact would be 2,040
linear feet.
Alternative 5 (Southern Pit Mine Plan)
The Southern Pit Mine Plan option allows Neverson quarry to expand its mining footprint to the
south and open approximately 5.4 million tons of reserves. This option would avoid impact to
Stream F and its associated wetlands, but would still require impact to Stream Z. The expected
wetland impact would be 0.46 acres and stream impact would be 1,438 linear feet. This option
would only uncover an additional approximate 5 years of reserves for the site and therefore is
considered not viable.
CONFIDENTIAL

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