20230518_ADI_Received

RECEIVED
MAY 18 2023
LAND QUALITY SECTION
RAFTING AND DESIGN
SERVICES,INC.
6728 Carbonton Road
Sanford, NC 27330
[phone]
May 15,2023
Mr.Adam Parr
NC Department of Environmental Quality
Division of Energy, Mineral and Land Resources
A612 Mail Service Center
Raleigh, NC 27699-1612
Reference: Butler Mine-Mine Permit Plans Resubmittal
Dear Mr. Parr;
Please find attached the resubmittal for the above referenced project addressing comments
received on the May 8,2023. Responses will be noted in Green. Please review the following
responses to comments:
Please clarify your response to question C.53 where you indicate a 50 foot undisturbed buffer with a 50-
foot by 6-foot-high berm between mining activities and wetlands. The mine map shows a 30 foot
undisturbed buffer and a 20 foot by 2-foot-high vegetative berm. The application recommends a 50 foot
wide undisturbed buffer unless smaller buffers can be justified. Ifyou are proposing a smaller than 50-
foot undisturbed buffer,please provide a justification.Please keep in mind that undisturbed is defined as
no mining activity, including excavation, roads,fill berms, etc.
The attached question/answer from the Mine Permit Application reflects the change in answer
to accurately show the justification of smaller buffers and methods to maintain the buffers and
wetlands surrounding the pit.
Sincerely,
Drafting and Design Services, Inc.
Michael Thomas Blakley

RECEIVED
MAY 18 2023
NORTH CAROLINA MINING State of North Carolina LAND QUALITY SEC TMail Service Center
PERMIT APPLICATION Department of Environmental Quality Raleigh,NC 27699.1612
Division of Energy,Mineral,and Land Resources [phone]
5. A)A buffer will be required between any mining activity and any mining permit boundary or right-of-way.It may be an
unexcavated buffer(no excavation,but roadways,berms,and erosion 8 sedimentation control measures may be
installed within it),an undisturbed buffer(no disturbance within the buffer whatsoever),or a combination of the two,
depending upon the site conditions.Note that all buffers must be located within the mining permit boundaries.
How wide a buffer will be maintained between any mining activity and any mining permit boundary or right-of-way at
this site?A minimum buffer of 25 feet is recommended,although a wider buffer may be needed depending on site
conditions.Show all buffer locations and widths on the mine map(s).
A proposed 50-foot minimum undisturbed buffer with an additional 50 foot wide
by 6-foot-high vegetated earthen berm will provide an overall vegetated buffer
of 100 feet between mining related activities and any mining permit boundary.
B)A minimum 50 foot wide undisturbed buffer will be required between any land disturbing activities within the mining
permit boundaries and any natural watercourses and wetlands unless smaller undisturbed buffers can be justified.
Depending on site conditions,a buffer wider than 50 feet may be needed.
How wide an undisturbed buffer will be maintained between any land disturbing activities within the mining permit
boundaries and any natural watercourses and wetlands at this site?Show all buffer locations and widths on the mine
MOO).
A 50-foot minimum undisturbed buffer with a 50-foot by 6-foot-high vegetative earthen berm
will provide an overall vegetated buffer of 100 feet between mining related activities and the
majority of any neighboring stream or wetland.The exceptions to this will be a 30 foot wide
undisturbed buffer with a double row of silt fence and silt fence outlets between this buffer
and a 20 foot wide vegetated earthen berm,where jurisdictional wetlands protrude into
mineable reserves.Wetland boundary to be flagged and flagging to be maintained
throughout site operation to ensure no accidental impacts.
6. A)Describe methods to prevent landslide or slope instability adjacent to adjoining permit boundaries during mining.
Minimum 2 horizontal to 1 vertical slopes or flatter for clayey material and minimum 3 horizontal to 1 vertical slopes or
flatter for sandy material are generally required unless technical justification can be provided to allow steeper slopes.
Removal of sand from below the water table within the active mine excavation
will result in the side slopes reaching their natural angle of repose. However, any
excavation that occurs above the water table will be conducted at a 3 horizontal
to 1 vertical or flatter slope.
B)Provide a cross-section on the mine map(s)forall rill slopes(berms,waste piles,overburden disposal areas,etc.),
clearly indicating the intended side slope gradient,installation of any benches and/orslope drains(with supporting
design information)if needed, and the method of final stabilization.
Cross-sections and labels defining a minimum slope of 3 horizontal to 1 vertical or flatter for all fill slopes have been
provided In the mining plan set The method of final stabilization for all fill slopes and other areas affected by the
mining operation are provided in Sheets C8 and C10 to protect their integrity and promote slope stability.
Revised September 21, 2021 P a g e 18