MountAiry_22-1203_Response to Comments

PO Box 29682 804.784.6300 800.898.LUCK
Richmond VA 23242-0682 804.784.6390 Fax www.luckstone.com
LUCKUSTONE,.
IGNITING HUMAN POTENTIAL
Mr.Adam Parr 12/2/2022
NC DEQ
Division of Energy,Mineral and Land Resources
512 North Salisbury Street
Raleigh,North Carolina 27699
RE: Permit Modification—Response to Comments
Mine Permit No.86-01,Mount Airy Quarry,Surry County
Dear Mr.Parr,
On June 7,2021,Ararat Rock Products received a letter from the North Carolina Department of Environmental Quality
(NCDEQ)with comments pertaining to a permit modification for Mount Airy Quarry in Surry County,NC. Luck Stone
Corporation(Luck Stone)acquired Mount Airy Quarry,and all ongoing permit modifications,from Ararat Rock in late
2021. On May 9,2022,NCDEQ provided Luck Stone with a letter extending the response to comment period to
December 4,2022. Understanding this information,Luck Stone has completed the following responses to the permit
modification comments. Please review the following NCDEQ comments,the appropriate Luck Stone response and all
attachments:
1. Please provide proof,such as copy of the signed return receipts from celified mail,that all adjoining
landowners and chief administrative officer of each county and municipality have been properly notified.
§74-50(bl).
Luck Stone Response—For the initial modification submittal,Ararat only sent notifications to landowners
adjoining the new area to be permitted with the amendment. Please see the attached certified mail receipts of
ALL adjoining landowners and appropriate municipality representatives.
2. Please clarify the permit boundary near the entrance to SR 2007(Quarry Rd.).It appears that the permit
boundary does not extend all the way to the publicly maintained road.§74-49(1)states that nonpublic
roads are considered "Affected Land."
Luck Stone Response—The permit boundary has been updated to reflect the entire portion of entrance road all
the way to the publicly maintained road. The additional permit area has been updated within the mine
application and on the permit map.
3. Please refer to Section D of the mine permit application and provide a reclamation map that clearly
illustrates the reclamation plan for the entire site.The map should clearly illustrate the post mining use
of the entire site.It should also include all italicized items listed in the application
Luck Stone Response—Please see the attached Reclamation Map for the facility.
4. Please clarify your response to question C.12 of the mine permit application regarding the storage of
onsite fuel tanks,solvents,or other chemical reagents.Please explain how mobile equipment is serviced.
Luck Stone Response—Mine permit application question C.12 has been updated to include fuel storage on site.
Information regarding the servicing of vehicles has been included in the response.

5. Please explain the operations and activities located in the area labeled "Leased Area" as they pertain to
§74-49(1). "Affected Land"
Luck Stone Response—All areas labeled as"Leased,"are not on permitted land and should not be considered
"Affected Land."
6. Please provide a mine map that shows the entire permitted area.The maps provided did not show the
entire permit boundaly on the north side of the property.
Luck Stone Response—The layout of the permit map has been adjusted to include the entire current and
proposed permit area. Please see the attached permit map.
7. Please identify and label all adjoining landowners on the map,including those adjoining the previously
permitted boundary.
Luck Stone Response—The permit map has been adjusted to include all landowners adjoining both existing and
proposed permit boundaries. Please see the attached permit map.
8. Please label on the map that the 50-foot wooded buffer is proposed as an undisturbed buffer.
Luck Stone Response—The permit map has been adjusted to include the appropriate labeling regarding the 50-
foot wooded,undisturbed buffer. Please see the attached permit map.
9. Please clearly indicate and label on the map all undisturbed and unexcavated buffers for the entire site.
Luck Stone Response—Additional buffer labeling has been added to the permit map. It should be noted that
any area where the affected line is offset from the permit line represents an undisturbed buffer. Please see the
attached permit map.
10. Please provide a Jurisdictional Determination from the US Army Corps of Engineers for streams,
wetlands,or other surface waters at the site.
Luck Stone Response—A formal wetland delineation has been completed by a third-party wetland scientist for
the facility,however,a jurisdictional determination has not been completed as there are no proposed impacts to
wetlands in the immediate future. No wetland impacts are planned within the next 5 years.
11. Based on the information provided the drainage areas of small intermittent streams adjacent to the pit
area have the potential to be indirectly impacted form the rerouting of their entire drainage area and
surface flows into the pit.This has the potential to remove existing hydrology from some of these features
adjacent to the pit and therefore remove existing uses of the stream channels which may result in a
violation of water quality and/or wetland standards.Please provide a hydrologic analysis of the indirect
impacts to these intermittent streams adjacent to the pit area.
Luck Stone Response—All previously submitted E&S design information associated with the proposed affected
acreage to the east is being rescinded for this resubmittal. Luck Stone will submit an updated pit expansion plan
at a future date. During that time,Luck Stone will consider pre-construction drainage and surrounding water
features when designing the expansion and associated E&S controls.
12. Please clarify your response to CA of the application with regard to Air Permit#05021 R09.Please see
the enclosed comments from the Division of Air Quality(DAQ).
Luck Stone Response—Permit Amendment Application has been updated to show that an Air Permit
#05021R09 was issued to the site and later(2017)rescinded.
13. Please address all comments enclosed,provided by the Land Quality Section(LQS)Winston Salem
Regional office.
Luck Stone Response—Please see the below responses.
Comments from Land Quality Section

1. NC Wildlife Resources Commission {NCWRC} recommends a 100-ft buffer to lessen
impacts to the Ararat River. This may impact the mine footprint and proposed measures,
so at least another iteration of review will be necessary
Luck Stone Response—For a majority of the permitted area,a 50ft undisturbed buffers has been proposed.
Specific to the impacts adjacent to the Ararat River,the flood plain extends well beyond the 100 ft.boundary of
the river. In staying out of the flood plain,the 100 ft.buffer is maintained,and in many cases exceeded by a
significant margin.
2. Seeding specifications were also commented on by NCWRC and would have to
be addressed within the application.
Luck Stone Response—Luck Stone uses the below seed mix at many of our sites;we are happy to consider the
addition of Oats to this mix as an option for cover crop. This mix has been included in the updated permit
amendment form.
Seed Mix
Tall Fescue 60 Ibs per acre
Hard Fescue 20 Ibs per acre
Creeping Red Fescue 10lbs per acre
Weeping Lovegrass 10 Ibs per acre
Ladino Clover 10 Ibs per acre
Bird Foot Trefoil 10lbs per acre
Kobe or Korean Lespedeza 5 Ibs per acre
Alfalfa 10 Ibs per acre
Annual Ryegrass 10lbs per acre
Millet 10 Ibs per acre
3. Calculations for the sediment basins are based upon 10-year design storms.Redesign for the 25-yr storm
is necessary
Luck Stone Response—Luck Stone has decided to rescind all design information submitted in the last submittal
package associated with the eastern permit limit expansion. When appropriate for future expansion,Luck Stone
will submit a future amendment detailing expansion and proper E&S control design.
4. The acreage table required to be on the mine map shows O acres for sediment ponds despite several
being shown on the plan.It is understood that the permittee has viewed the sediment ponds as temporary
measures that do not need to be included in the table,but they must be included due to their potential for
long-term implementation and the indefinite timing of their installation and removal
Luck Stone Response—Luck Stone has decided to rescind all design information submitted in the last submittal
package associated with the eastern permit limit expansion. When appropriate for future expansion,Luck Stone
will submit a future amendment detailing expansion and proper E&S control design.
5. Please elaborate on what discussions have been held with the owner of the 128'wide
powerline easement shown on the plan as it relates to the proposed work in the
area.
Luck Stone Response—This area is a deeded Right of Way that allows the user to access the area to operate and
maintain their equipment. No formal discussion has been held,nor is one required if the future impacts meet
the requirements of the deed. Agreements will be made with the easement owner if future plans intend on
impacting the rights of the easement.
6. Part B.2.of the application lists minimum features that must be clearly illustrated on

the mine maps.The items below must be shown and labeled on the maps:
• Initial and ultimate limits of clearing and grading
• Outline and acreage of all pits/excavations
• Outline and acreage of all stockpile areas
• Location and acreage of all planned and existing access roads
and on-site haul roads
• Location and dimensions of all proposed sediment and
erosion control measures.
Luck Stone Response—All of the items listed above are on the provided permit map.
7. Part C.1 of the application calls for a detailed description of events for the
development and operation of the mine to be referenced to the mine maps.The
response provided lacks sufficient detail to adequately evaluate the plan and
proposed measures.Please provide detailed sequencing,referencing the
particular drainage areas and movement across the site.
Luck Stone Response—A completely updated application has been included with this submittal. This permit
application should address all comments from the NCDEQ.
8. Part C.3.b of the application indicates that the operation will not discharge to
waters of the State.This is not accurate since the removal of soil down to the
rock is considered mining and the sediment basin outfalls will discharge to
waters of the State.A permit is required for stormwater discharges (See part
C.3.d),and the outfalls must be shown on the mine maps.
Luck Stone Response—The site currently operates under NC NPDES permit:NCG020158,the permit
application has been updated accordingly.
9. Please provide documentation showing that the excavation will not extend
below the water table,as indicated in the application in part C.3.c.
Luck Stone Response—Excavations will be conducted below the water table. The permit application has been
updated accordingly.
10. Part D.1.of the application,asks for a description of the reclamation plan,
design information,and calls for information to be included on the
reclamation map.The application and mine maps lack clear sequencing for
grading,stabilizing,and demobilizing for reclamation,and a reclamation map
has not been provided
Luck Stone Response A completely updated application has been included with this submittal. This permit
application should address all comments from the NCDEQ. A reclamation map has also been included in this
submittal.
11. The scale for sheet C-10 showing the approximate mine excavation limits is at
1" =300.'Please revise this map so that it is shown at a scale no smaller than
1" =200'as required by the mining application.
Luck Stone Response—All prior mapping submitted by Ararat is being rescinded with this submittal. In order
to meet this request,a 1"=300' scaled permit map has been included with this submittal.

12. The pond shown on sheet C-2 located on the southern area of the site,directly
south of the existing power line easement and directly north of the Ararat
River,is within the pit mining area.Will this pond be dewatered,and at what
point will this occur?
Luck Stone Response All prior mapping submitted by Ararat is being rescinded with this submittal.
Regardless,all ponds will be either dewatered or filled and seeded upon reclamation.
13. A 32 acre area within the existing permit boundary is proposed as an
overburden area;please address erosion control for this area.
Luck Stone Response—Erosion and sediment control structures associated with the 32-acre overburden storage
area were approved through prior amendments. Based on the summary provided by NCDEQ on the latest
amendment,it looks like this approval occurred on January 7,2010.
14. Diversions should be installed along the top of the sediment basin wall directed
toward slope drains to prevent sheet flow over sediment basin slopes greater
than 7 feet,such as along the top of skimmer basins#1 and#6 to direct runoff
into both slope drains for this basin.
Luck Stone Response—Luck Stone has decided to rescind all design information submitted in the last submittal
package associated with the eastern permit limit expansion. When appropriate for future expansion,Luck Stone
will submit a future amendment detailing expansion and proper E&S control design. Regardless,the comment
has been noted and will be considered for future design submissions.
15. A diversion ditch is also needed along the top of skimmer basin#2 on the
northeast side to protect the cut slope and direct the runoff to enter the basin
on the northwest.
Luck Stone Response—Luck Stone has decided to rescind all design information submitted in the last submittal
package associated with the eastern permit limit expansion. When appropriate for future expansion,Luck Stone
will submit a future amendment detailing expansion and proper E&S control design. Regardless,the comment
has been noted and will be considered for future design submissions.
16. IA diversion ditch is needed along the northwest and southeast sides of
sediment basin#3 to collect runoff in the subdrainage areas below the first
baffle,and direct it to enter the basin above the first baffle.
Luck Stone Response—Luck Stone has decided to rescind all design information submitted in the last submittal
package associated with the eastern permit limit expansion. When appropriate for future expansion,Luck Stone
will submit a future amendment detailing expansion and proper E&S control design. Regardless,the comment
has been noted and will be considered for future design submissions.
17. The diversion ditch on the north side of skimmer basin#4 should be extended
in a northeast direction to capture sediment laden runoff from the
downstream side of the ridge and direct it to the basin.
Luck Stone Response—Luck Stone has decided to rescind all design information submitted in the last submittal
package associated with the eastern permit limit expansion. When appropriate for future expansion,Luck Stone
will submit a future amendment detailing expansion and proper E&S control design. Regardless,the comment
has been noted and will be considered for future design submissions.
18. The current silt fence detail does not include the strength of the steel posts
used for silt fence and shows the depth of the backfill trench as being 6-inches
deep.The steel posts used for silt fence must be 1.25 lbf/LF at a minimum,

with a minimum length of 5-feet.The backfill trench for silt fencing needs to
be at least 8-inches deep with the post being at least 2-foot deep.Furthermore,
the current detail does not show the maximum spacing between the steel posts.
Please revise the detail to illustrate the above specifications.
Luck Stone Response—Luck Stone has decided to rescind all design information submitted in the last submittal
package associated with the eastern permit limit expansion. When appropriate for future expansion,Luck Stone
will submit a future amendment detailing expansion and proper E&S control design. Regardless,the comment
has been noted and will be considered for future design submissions.
19. The elevation of the top of the riser for sediment basin#3 is 0.14 inches lower
than the water elevation for a 2-yr,24-hr storm event.The top of the riser
should be above this depth to ensure the skimmer is the only outlet functioning
during a 2-yr,24-hr storm.Redesign is recommended.
Luck Stone Response—Luck Stone has decided to rescind all design information submitted in the last submittal
package associated with the eastern permit limit expansion. When appropriate for future expansion,Luck Stone
will submit a future amendment detailing expansion and proper E&S control design. Regardless,the comment
has been noted and will be considered for future design submissions.
20. Remove silt fence from the emergency spillway of any basin where it's shown.
Luck Stone Response—Luck Stone has decided to rescind all design information submitted in the last submittal
package associated with the eastern permit limit expansion. When appropriate for future expansion,Luck Stone
will submit a future amendment detailing expansion and proper E&S control design. Regardless,the comment
has been noted and will be considered for future design submissions.
21. Please clarify if any land-disturbing activity will occur south of the diversions
on sheet C-6; additional measures may be required.
Luck Stone Response—There will be no disturbance withing the newly requested permit area south of the
powerline easement. Luck Stone has decided to rescind all design information submitted in the last submittal
package associated with the eastern permit limit expansion. When appropriate for future expansion,Luck Stone
will submit a future amendment detailing expansion and proper E&S control design. Regardless,the comment
has been noted and will be considered for future design submissions.
22. Silt fencing typically has a design life of six months.Will the silt fence and
stone outlets be replaced every six months for the life of this mine?Please
address.
Luck Stone Response—Luck Stone has decided to rescind all design information submitted in the last submittal
package associated with the eastern permit limit expansion. When appropriate for future expansion,Luck Stone
will submit a future amendment detailing expansion and proper E&S control design. Regardless,the comment
has been noted and will be considered for future design submissions.
Thank you for your kind assistance in this matter. NCDEQ's extension was very helpful in allowing Luck Stone to
review the full prior amendment and respond accordingly. If you have any questions and/or comments,please contact
me at 804-514-8670.
Sincerely,
Brian Parker
Construction Engineer,Luck Stone Corporation