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HomeMy WebLinkAbout20110309 Ver 4 _Addendum to permit application _20180409Addendum to permit application Existing Site Conditions The approximately 62 acre project area includes overgrown open areas and mixed hardwood/pine forest. The area is adjacent to the existing Onslow limestone quarry. The USDA Soil Survey of Onslow County shows that the soils within the project area are mapped as Norfolk with a small amount of Goldsboro and Lynchburg. A man made open water tributary which becomes a stream flows across the project area. The stream flows into an unnamed tributary to the New River. The quarry opened in 1995. The site location was selected due to the strategic location and the depth of limestone. Previous permits from USACE have been issued under the following Action IDs. 199400588, 200500582, SAW-2011-00666, SAW-2016-01209. Previous Water Quality Certifications have been issued under DWR Project: 2011-0309. Description of Avoidance, Minimization, and Compensation Martin Marietta is limited in directions that we can expand the Onslow Quarry. Expansion without an impact to waters of the US is impossible at this time. Expanding our north-east pit to the north avoids impacts to a larger stream and wetland system. This larger system flows from below our plant site and below our southern pit to converge and flow north. It continues flowing to the north side of Duffy Field Road, bisecting the property until it flows into another unnamed tributary on the north side of our proposed expansion area. In the past we have impacted this stream with a crossing but have avoided expanding through it by creating a new pit to the west. We are avoiding these higher quality Streams and their adjacent wetlands by expanding through a lower quality channel with no adjacent wetlands. Martin Marietta currently holds a Nationwide Permit to expand our northeast pit to the north, through a manmade tributary that flows into an intermittent channel. This permit and the associated Water Quality Certification are attached as Exhibit A. Our original plan was to avoid this intermittent channel, leaving it and a 50ft buffer extending into our pit area. Through further planning, we have now determined that this is not practicable due to safety and haul truck logistics, and loss of revenue resulting from not mining below the channel. This proposed plan is attached as Figure 1 and Figure 3. We are also proposing to expand into a small wetland (Figure 2) in order to eliminate a blind turn in our haul road that has caused safety concerns. These items are further discussed below in our alternatives analysis. Alternatives Analysis Alternative 1: (No Action Alternative) Mining through previously permitted open water only. Martin Marietta is currently permitted to mine through 0.25 acre of an open water tributary by a Nationwide 39 under Action ID SAW-2016-01209 and DWR Project 2011-0309v3. This “No Action Alternative” would avoid direct impacts to 1260 linear feet stream channel, denoted as Stream A on the attached maps. However, indirect impacts would still occur. Once mining commenced in the area, Stream A would extend into the pit, with a northern and southern slope that reach from the stream buffer to the pit floor. Flow to the stream would be cut off and the stream and its buffer would be essentially on top of a hill. Haul trucks driving around the edge of the pit would have to travel around the Stream A buffer, adding approximately ½ mile to the haul distance and creating a blind “hairpin” turn as shown in figure 4. On a daily basis our trucks would travel approximately 60 extra miles, causing them to take fewer trips per day, consume more fuel per haul, release more fuel emissions per ton of product, and reduce the life of each truck. The blind hairpin turn at the end of the Stream A buffer would also create a safety hazard. The road will be used by both haul trucks and other passenger vehicles. Loaded these haul trucks can weigh up to 100 tons. Martin Marietta values each employee and visitor at each of our sites and prioritizes the safety of each individual first and foremost. Endangering employees, customers, and visitors with a potentially unsafe haul road is unacceptable to Martin Marietta. Avoiding this Stream also causes MM to leave behind approximately 375,000 recoverable tons of limestone. This tonnage represents approximately $5.6 million in lost sales revenue. During a recent mining permit modification, the DWR reviewed the recently issued NW39 permit and threatened to revoke the 401 Water Quality Certification if MM does not apply for an individual permit to impact Stream A. This email is attached as Exhibit B. In summary, based on the explanations above, the no-action alternative, which would not involve discharge into waters, is not practicable. Alternative 2: (Preferred Alternative) Mining through entire reach of intermittent stream Onslow Quarry currently has approximately 5 to 8 years of permitted reserves. In order to extend the life of the quarry, MM needs to expand the pit. Expanding the pit to the north will extend the life of this quarry to 11 to 15 years. As discussed in Alternative 1, a stream channel and a manmade open water tributary, which flows into it, are located between the current pit and approximately 5 million tons of reserves. As shown in Figure 1, mining through the stream avoids the problems associated with alternative 1, such as the blind haul road turn. This alternative would impact 104 linear foot of perennial Stream, 1,156 linear foot of Intermittent Stream and 0.01 acre of wetland. NC Stream Assessment (NCSAM) forms have been completed in the presence of the Corps of Engineers and the Division of Water Resources. These forms and results are attached as Exhibit C. Working from the results of the NCSAM evaluation, MM proposes to mitigate at a 2:1 ratio for impacts to 104 linear feet of perennial stream and at a 1:1 ratio for impacts to 216 linear feet of intermittent stream. To further improve the safety of the Quarry, MM proposes to impact an additional 0.14 acre of wetland located in the south western corner of the pit, as shown in Figure 2. Figure 4 shows that there is currently a blind turn in this location which has been an ongoing safety hazard. At this time passenger vehicles are not allowed to travel this section of haul road without first contacting the haul trucks on radio. MM proposes to mitigate for this impact, 0.14 acre, and the impact to 0.01 acre of wetland shown in Figure 1, at a 2:1 ratio. MM believes that this is the only practicable alternative. The safety concerns associated with the blind hairpin turn, extra cost and time due to a longer material haul, and loss of reserves under the stream make avoiding these impacts impracticable. Alternative 3: Expanding in other directions. Martin Marietta has extensively explored expanding the Onslow Quarry in other directions. Expanding to the western pit to the west is limited by the property boundary. Hwy 258 and Union Chapel Church Rd limit our expansion to the east. Duffy Field Road also bicects the quarry site and is a limiting factor on where we can expand. Connecting the eastern and western pits would impact approximately 12 acres of wetland and over 3000 linear feet of stream. This alternative would not extend the life of the mine as much as the preferred alternative, and has much greater environmental and floodplain impacts. Therefore this alternative is not the least environmentally damaging alternative and is not practicable at this time. Expanding the southern pit to the south could impact as much as 10 acres of wetland and several thousand linear feet of stream. This alternative could extend the life of the quarry as much as our preferred alternative, but with more impacts to streams and wetlands it is not the least environmentally damaging alternative at this time. The stream and wetland systems to the south and through the middle of the property are higher quality systems than the stream we are proposing to impact. Offsite alternatives: Offsite alternatives were not evaluated. An offsite alternative would not meet the Project Purpose as described in block 19 of the permit application. Mitigation for impacts Martin Marietta proposes to mitigate for 216 linear feet of intermittent stream channel at a 1:1 ratio, 104 linear feet of perennial stream channel at a 2:1 ratio and 0.15 acre of wetland at a 2:1 ratio by purchasing 424 warm water stream credits and 0.3 Riparian wetland Credits from Bachelors Delight Mitigation Bank. Please see the letter dated February 27, 2018 Attached as Exhibit D. Floodplain The project would involve 0.15 acre of impacts to the 100 year floodplain. These impacts are shown in the attached map, Figure 5. A Floodplain Development permit was issued by the Onslow County Planning and Development Department on March 15, 2018. This permit is attached as Exhibit E. Endangered Species Act (ESA) A Query of the North Carolina National Heritage Program database indicates that there are no records for rare species, important natural communities, natural areas, or conservation/managed areas within the proposed project boundary. National Historic Preservation Act (Section 106) Martin Marietta is not aware of any properties or structures that are listed or eligible for listing with the National Register of Historic Properties within the immediate vicinity of the project area.