20240116_ADI_Received

NORMS &TUNSTALL
CONSULTING ENGINEERS P.C.
2602 Iron Gate Dr.Suite 102 1429 Ash-Little River Road
Wihnington,NC 28412 Ash,NC 28420
[phone] [phone]
[phone] Fax [phone] Fax
John S.Tuo stall,P.E. J.Phillip Norris,P.E.
T.Jason Clark,P.E. Joseph K.Bland,P.E.
Robbie P.Hennelly,E.I.
January 10, 2024
Mr. Adam Parr
NCDEQ / Division of Land Resources r'PIVED
Land Quality Section — 5th Floor RE. 1 --
512 N. Salisbury Street JAN 16 1024
Raleigh, NC 27604
LA',.;u
Re: Review Comment Response MINING PRO GPAM
King Sand Mine (Pits 1 & 2)
Brunswick County, NC
NT Project No. 18011
Dear Mr. Parr,
We are responding in red to the December 13, 2023, review comments as follows:
1. Please provide proof you have submitted your NOI for your NPDES permit. See attached
cover letter.
2. Please clarify if any wells exist within 500' of the excavation or if all the adjoining
properties are on municipal water. If there are any wells please clearly identify and label on the
mine map the neighboring wells within 500' of the mine excavation. All wells within 500' of the
proposed excavation area have been identified on the plans.
3. There is a potential intermittent stream located on the perimeter of the property. The NC
Division of Water Resources (DWR) is concerned about the proximity of the mine excavation
and the fill for the new access road. Please provide a Jurisdictional Determination JD from the
US Army Corps of Engineers (USACE) as well as a stream determination from DWR. The client's
environmental consultant has requested a stream determination with DWR. The environmental
consultant has requested a formal wetlands JD in lieu of the provided USACE wetlands
concurrence statement.
4. The mine permit boundary is only labeled on sheet C2. Please clearly identify and label
on the mine map the mine permit boundary on all sheets that show the permitted area. The mine
permit boundary has been updated on all sheets.
5. The hatching on the sediment pond is identical to the hatching of the undisturbed buffer.
Please differentiate the hatching in these two areas. The dewatering basin hatching has been
revised as requested.
NCBELS License C-3641

Mr. Adam Parr
January 10, 2024
N&T Project# 18011
Page 2
6. The affected area table in mine permit application has a note that the table is attached
separately. There is no attached table. Please provide an affected area table for the entire site.
A singular affected area table has been provided on Sheet C1 for your use.
7. The permitted area on the affected area table on the mine map only accounts for the
affected area. Please clarify the affected area table on the mine map. The permitted area should
include any proposed undisturbed areas. The updated table accounts for buffers and upland
areas as well. See updated table on revised Plan Sheet C1.
8. Please clearly indicate and label on the mine map the owner of record adjoining the mine
permit boundary. The property directly across SR 1323 (Ludlum Rd.) was not labeled. The
owner has been identified for the property across the street from the entrance as requested.
9. Please clarify your response to question C.3.b of the mine permit application where you
stated there would be no discharge to waters of the state. The sediment basins drawn on the
map show outlets to the wetlands. The permit page has been revised and is provided for your
use.
10. Please provide a pumping operations and maintenance plan (O&M) for the dewatering
activities. The pumping O&M plan has been provided for your use.
11. Please clearly label on the mine map the name of the mine permit applicant. The applicant
info has been identified on the mine map.
12. Please clearly indicate and label on the mine map structures located within 300' of the
mine excavation. All structures within 300' of the proposed excavation area have been identified
on the plans.
Sincerely,
NORRIS & TUNSTALL
C LTING ENGINEERS, P.C.
?sephK. Bland, P.E.
0-23 s-mining-Itr
CC' Brandon Hardee

NORRIS &TUNSTALL
CONSULTING ENGINEERS P.C.�--�
2602 Iron Gate Dr.Suite 102 1429 Ash-Little River Road
Wilmington,NC 28412 Ash,NC 28420
[phone] [phone]
[phone] Fax [phone] Fax
John S.Tunstall,P.E. J.Phillip Norris,P.E.
T.Jason Clark,P.E. Joseph K.Bland,P.E.
Robbie P.Hennelly,E.I.
January 12, 2024
NCDEQ —Stormwater Program
1612 Mail Service Center
Raleigh, NC 27699-1612
Re: NCG02 Notice of Intent Submittal
King Sand Mine
Brunswick County, NC
NT Project No. 18011
Dear Reviewer,
In connection with the subject project, please find enclosed the following:
• Check Made Payable to NCDEQ in the amount of$120.00 (Norris Check#2886)
• Original Notice of Intent
• NCSOS Annual Report
• Dewatering Calcs
• Pumping Operation & Monitoring Plan
• USGS Site Location
• USACE Concurrence Email
Please review this information for approval and contact us with any questions or comments you
may have. Thank you for your assistance with this project.
Sincerely,
NORRIS &TUNSTALL
CONSULTING ENGINEERS, P.C.
Joseph K. Bland, P.E.
J KB/ttw
1801101-12-24 ncg021tr
cc: Brandon Hardee
NCBELS License C-3641

NORTH CAROLINA MINING State of North Carolina 1612 Mail Service Center
PERMIT APPLICATION Department of Environmental Quality Raleigh,NC 27699-1612
Division of Energy,Mineral,and Land Resources [phone]
C.PROTECTION OF NATURAL RESOURCES
1. Describe in detail the sequence of events for the development and operation of the mine and reference the sequence
to the mine map(s).Attach additional sheets as needed.
Once all permits have been obtained,the operator will clear and grub the proposed excavation area.
Excavation will begin and occur on an as needed basis.
2. Describe specific erosion control measures to be installed prior to land disturbing activities and during mining to
prevent offsite sedimentation(include specific plans for sediment and erosion control for mine excavation(s),waste
piles,access/mine roads,and process areas),and give a detailed sequence of installation and schedule for
maintenance of the measures.Locate and label all sediment and erosion control measures on the mine map(s)and
provide typical cross-sections/construction details of each measure.Engineering designs and calculations are required
to justify the adequacy of any proposed measures.
Extensive natural buffers will remain. The excavation area will be graded to drain internally to the pit area.
No movement of sediment is expected offsite or to any adjacent wetlands. Temporary silt fence to be
installed in areas adjacent to wetlands. Temporary diversion ditches and temporary sediment basin to be
installed until excavation limits potential for offsite runoff.
3. A)Will the operation involve washing the material mined,recycling process water,or other wastewater handling?
FIYES FX NO
If yes,briefly describe all such processes including any chemicals to be used.
B)Will the operation involve discharging fresh or wastewater from the mine or plant as a point discharge to the waters
of the State?
YES FNO FX
If yes,briefly describe the nature of the discharge and locate all proposed discharge points(along with their method of
stabilization)on the mine map(s).
Mine dewatering to NCDOT dewatering basins. Basins discharge at non erosive
velocity to adjacent wetlands to facilitate ground water discharge. Basins are
shown on mine maps.
Revised September 21,2021 Page 16

i 3c 11
Subject: Fwd: USACE wetland concurrence statement (with revised wetland
delineation map) for the Ludlum Road Project in Brunswick County, NC
(SAW-2023-01615)
---------- Forwarded message ---------
From: Beecher, Gary H CIV USARMY CESAW (USA)
<Gary.H.Beecher@ usace.army.mil>
Date: Wed, Aug 9, 2023 at 2:20 PM
Subject: USACE wetland concurrence statement (with revised wetland delineation
map) for the Ludlum Road Project in Brunswick County, NC (SAW-2023-01615)
To: Paul Farley<[e-mail]>
Cc: [e-mail]<[e-mail]
Mr. Farley,
I just realized that the wetland delineation map that I had recently sent out with
my Wetland Concurrence Statement had an incorrect key on it.
The wetland and upland acreage were reversed in the key.
I've attached a updated and revised Wetland Delineation map for this project.
Respectfully,
Gary
US Army Corps;
of Engineers
-
Mlimington Districl
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a
Gary Beecher
USACE Wilmington Field Office
Regulatory Project Manager
Office [phone]
Cell [phone]
gary.h.beecher@ usace.armymil
From: Beecher, Gary H CIV USARMY CESAW (USA)
Sent: Wednesday, August 9, 2023 1 :19 PM
To: Paul Farley<[e-mail]>
Cc: [e-mail]
Subject: USACE wetland concurrence statement for the Ludlum Road Project in
Brunswick County, NC (SAW-2023-01615)
Dear Mr. Farley,
Reference is made to ORM ID SAW-2023-01615, please reference this number
on any correspondence regarding this action located on Ludlum Loop Road in
Ash, Brunswick County, NC. (Parcel ID: 16300016)
The Corps received information from you requesting the Wilmington District,
Regulatory Division review and concur with the boundaries of an aquatic resource
delineation.
We have reviewed the information provided by you concerning the aquatic
resources, and by copy of this e-mail, are confirming that the aquatic resources
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delineation has been verified by the Corps to be sufficiently accurate and reliable
for permitting actions and the determination of compensatory mitigation
requirements. The boundaries of these aquatic resources are shown on the
delineation map labeled Ludlum Loop Road Tract Section 404/401 Delineation
Preliminary Sketch.
Regulatory Guidance Letter (RGL) 16-01
https://usace.contentdm.o llc.org/utils/getfile/Collection/p16021coll9/iid/1256
provides guidance for Jurisdictional Determinations (JD) and states `The Corps
generally does not issue a JD of any type where no JD has been requested". At
this time we are only verifying the delineation. This delineation may be relied
upon for use in the permit evaluation process, including determining
compensatory mitigation. This delineation verification is not an Approved
Jurisdictional Determination (AJD) and is not an appealable action under the
Regulatory Program Administrative Appeal Process (33 CFR Part 331). However,
you may request an AJD, which is an appealable action.
If you wish to receive a Preliminary Jurisdictional Determination (PJD), or an
Approved Jurisdictional Determination (AJD) please respond accordingly,
otherwise nothing further is required and we will not provide any additional
documentation.
Please contact me if you have any questions about this project or about the
USACE Regulatory Program.
Respectfully,
Gary
US Army Corps,
of Engineers
vVilmington District
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Gary Beecher
USACE Wilmington Field Office
Regulatory Project Manager
Office [phone]
Cell [phone]
gary.h.beecher@ usace.army.mil
Paul Farley I Senior Environmental Scientist
Davey Resource Group, Inc.
3805 Wrightsville Avenue, Suite 15, Wilmington, NC 28403
P: 910.452.0001 ext. 19011 M: 910.471.0507 1 F: 910.452.0060
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Ludlam Loop Road Tract `�
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Resource Group Delineation
Map Date: 6H23 3805 Wrightsville Avenue
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[phone]