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HomeMy WebLinkAbout20231204_Cover Hanover Design Services, P.A. Land Surveyors,Engineers, Land Planners Mr.Adam Parr, PE State Mining Engineer Division of Energy,Mineral, and Land Resources Department of Environmental Quality 512 N. Salisbury Street, 5th Floor Raleigh,NC 27604 Re: Cameron Pit(mining permit no. 65-26)November 30,2023 Dear Adam, Attached please find an application package for the proposed modification to Cameron Pit,421 Sand Mine LLC, Permit Number 65-26.We would like to update the modification application package submitted September 6, 2023.The proposed modification to the mine encompasses 80.59 acres of additional area to be covered under the permit.We have reduced the mining limits of excavation of pit 511, reducing the limits of excavation area by 4.82 acres.We have based the affected acreage chart on the new area plus additional area in the existing permit and also reduced the total mining area by the reduction in pit 5R. Hydraulic Dredge will be the mining method used for Pit 8.There will be no discharge to the waters of the state. The mine is bordered by some wetlands to the east and west. Please also note below our response to all comments or requests for additional information noted on your November 6 letter a copy of which is also attached. Please let us know if you have any further questions or comments. We look forward to hearing from you. Please copy gwayne@hdsilm.com and ascheib@hdsilm.com on all future request for additional information or mail a copy to the address below. Austin Scheib,Tech Hanover Design Services P.A. ascheib@hdsilm.com (910) 343-8002 Office (910) 343-9941 Fax 1123 Floral Parkway Wilmington,N.C.28403 Phone(910)343-8002 Fax(910)343-9941 Business Firm License No. C-0597 Hanover Design Services, P.A. Land Surveyors,Engineers,Land Planners 1. The permitted acreage table is not complete. Please complete the table to include total permitted acreage in addition to total affected acreage. Added to attached plan, and revised mining permit application. 2. You've stated that the flood plain manager has been notified and that you are awaiting comment/ approval. Please provide proof of notice and approval from the jurisdictional floodplain manager. Copy of correspondence is attached. 3. Some of the owners of record have been identified and labeled on the mine map,however not all adjoining landowners have been labeled.Please clearly indicate and label all owners of record adjoining the mine permit boundary. This includes owners north of the proposed expansion,west of the existing operation and west of the Cape Fear River, south of the existing permit boundary, and east of the existing operation east of Hwy 421. Added to attached plan. See exhibit. 4. You provided a response to item 13 of the additional information request dated May 19, 2023,where you provided a cross sectional drawing of the crossing. However,you did not provide engineering calculations demonstrating that the 48"sewer main would be adequately protected.Please provide engineering calculations demonstrating that the proposed crossing is adequate to protect the sewer main. The pipe is a 36"raw water line. First,this will be a dredge mine operation,therefore little expected traffic is to be expected over the crossing. Secondly,without knowing the exact specifications of the pipe and methods used for installation, it would not be possible to produce an exact calculation. Knowing this we increased the depth of cover over the pipe from 3' to 7'. This change in depth greatly increases the spread load area on the pipe reducing the effects of the live load greatly with only minorly increasing the dead load. CFPUA is consulting with their engineer. 5.Your response to item 17 of the additional information request dated May 19, 2023,was that dewatering will occur in the current permitted area for permit 65-26, however, operating condition IIIA.0 of Mine Permit 65-26 does not permit dewatering. Your application for a modification of permit 65-26 indicates that there will be no dewatering(question C.3.Q. Please clarify your intent to dewater and correctly fill out the response in the application. No de-watering is being proposed. De-watering structure is being removed on the#2 pit 6.Please provide a pumping O&M plan for any proposed dewatering activities. N/A- No dewatering is being proposed. 1123 Floral Parkway Wilmington,N.C.28403 Phone(910)343-8002 Fax(910)343-9941 Business Firm License No. C-0597 Hanover Design Services, P.A. Land Surveyors,Engineers, Land Planners 7.Please provide a response to the additional information request dated August 10,2023. A copy has been enclosed with this letter. See attached information. 8. Please demonstrate how you propose to stay in compliance with CERCLA and 2L standards once mining begins in the area with the elevated chloride levels. The area of concern has been removed from the proposed pit. See revised plan. 9. Please clarify how you will reconcile for monitoring of the chloride plume and the remedial action plan of DWM site NONCD0002575 if monitoring wells are removed during the mining process. The monitoring wells will remain within the area of concern. 10. Please provide proof of individual 401 Water Quality Certification from the Division of Water Resources. N/A no permits requested. 11. Please clarify how you will ensure that perimeter slopes will remain at 3:1 below the waterline while dredging.Please clarify how you will ensure that undercutting and sloughing of the slopes,that could potentially reduce the size of the buffer to wetlands, will be avoided. The top of bank of the proposed pit will be staked and On-board GPS will be used on the dredge as necessary to maintain 3:1 slopes. No sluffing is anticipated with a 3:1 slope being proposed. Request for additional information on August 3,2023 letter. 1. Please provide the current status with regards to DWM groundwater monitoring and sampling requirements. Please also provide an explanation of how your propose to mine this area and maintain compliance with any DWM agreements,regulations, or requirements. See response to items 8 and 9 above. 2. Based on December 2019 Annual Groundwater monitoring Report issued April 13, 2020,by ELM Site Solutions, 12 monitoring wells which were sampled have chloride concentrations which exceed 2L standards. Please provide an explanation of how you propose to mine the site and address elevated chloride levels to ensure that additional exceedances of 2L standards do not occur. In addition,please provide a clear proposal of how dewatering is proposed which would not cause, or contribute to, a surface water quality standard. No de-watering is being proposed. 1123 Floral Parkway Wilmington,N.C.28403 Phone(910)343-8002 Fax(910)343-9941 Business Firm License No. C-0597