20230801_ADI_Response

RAFTING AND DESIGN
SERVICES,INC.
6728 Carbonton Road
Sanford, NC 27330
[phone]
July 17, 2023
Mr. Adam Parr
NC Department of Environmental Quality
Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
Reference: Havelock Drugstore Mine - Resubmittal
Dear Mr. Parr;
Please find attached the resubmittal for the above referenced project addressing comments
received on the April 12, 2023.Two (2) copies of the revised plan sheets are attached.
Responses will be noted in Green. Please review the following responses to comments:
1. Mining has been indicated in the floodplain. Please provide proof of notice and approval from the
jurisdictional floodplain manager.
We have correspondence from Jody Griffin at Martin County which is attached, stating they
would only have stipulations if there are structures in the floodplain, which for this site there are
not.
2. Please provide proof that you have obtained a Central Coastal Plain Capacity Use Area
(CCPCUA)permit with Division of Water Resources Groundwater Management Branch for
dewatering activities. The registration form may be obtained from the following link:
https://www.ncwater.or�z/CCPCUA
We have opted to change the mining from temporary dewatering to mining the entire site wet.
There will be no pumping of any waters and all of the water within the pits will stay contained
within the pits.There will be no dewatering on site.
3. Please see enclosed comments from the North Carolina Department of Natural and Cultural
Resources(NCDNCR). Please provide proof of a reconnaissance level archaeological survey
conducted by an experienced archaeologist for the property that will be impacted by the mining
activity and installation of the infrastructure.
We agree that location of the proposed site could potentially be a location that there is
probability of archaeological and potential historic sites. If archaeological findings or evidence
of a historic site is found during the excavation of the site the operator will contact the
appropriate agencies to review any findings. Based on state law DCNR nor DEMLR have the
legal authority to require a survey in order to obtain approval of a state mining permit
application and issuance of a state mining permit.

4. Please clarify the construction of skimmer basins with regard to the expected groundwater levels.
The construction details on sheet C11 state that the basins have no outlet and that water will
infiltrate.The proposed basin table on sheet C3 shows basins with a top elevation of 7.0 and
bottom elevation of 4.0. Groundwater depth on the Reclamation maps is estimated at elevation
8.0. How will the basins function when it appears they are constructed below the top of
groundwater?
This was a typo on our end, which has been corrected. The top of the ponds are at the
existing grade of wherever they are placed, around 8'-9' elevation. Groundwater is
estimated to be at 6', not the before mentioned 8'. This has been corrected on the
mine maps.
5. Please clarify skimmer basin maintenance details on sheet CIO that reference skimmers since
sheet C11 states basins will have no outlet.
This is a typo and has been corrected. There are no outlets for the proposed sediment
basins.
6. Please verify that the permit boundary extends to the start of the Public Maintained Road. It
appears from Martin County GIS and NCDOT Public Street Information Database that public
maintenance ends at the corner of SILVERTHORNE,JAMES H property.
The current owner holds an easement for subject access, and an updated land entry
agreement has been provided by the owner for said deeded easement, per deed
book 0-28, page 766.
7. Please clarify how the processing plant will be fueled since you have indicated there will be no
fuel tanks stored onsite.
The site will be fueled by an external fuel tank mounted in a truck or on a trailer.
8. Please provide an in depth hydrogeologic study to illustrate the effects of dewatering on the
wetlands in the vicinity. The study should model the cone of depression as the mine reaches final
depth as well as an operation and maintenance plan for pumping activities.
We have opted to change the mining operation to the entire mine being mined wet
with no pumping or dewatering. All material will be mined and placed into a stockpile
within the pit so water will drain back into the pit and will not be dewatered or pumped
outside the pit boundaries.
9. Please provide additional details including construction and maintenance details for wetlands
crossing.
A detail has been added on sheet C-14 for temporary wetland stream crossings for this
project. This detail is directly from the NCDEQ Erosion and Sediment Control Design
Manual.

10. Information provided in the NOI for the NPDES Stormwater permit indicates outfall locations.
Please clarify the discrepancy between this and the mine maps that indicate the sediment basins
will have no outlet. Please clearly indicate and label on the mine map all outfall locations.
This has been changed to reflect the proposed wet mining operation, and will be sent
back to NPDES.
11. Please provide a Jurisdictional Determination(JD) from the USACE for the wetlands.
A JD Package has been submitted for this project on 3/22/2023. Everything that was
submitted is attached with this resubmittal.
12. Please see the enclosed comments from the North Carolina Wildlife Resource Commission.
Please provide a mitigation plan to address the concerns related to the threatened and endangered
species outlined in the comments.
The comments provided by the NC Wildlife Resource Commission have been
addressed in the attached mitigation plan.
Sincerely,
Drafting and Design Services, Inc.
Michael Thomas Blakley