01_Narrative

III
Mine Permit Modification
Altapass Mine — Mining Permit No. 61-16
The Quartz Corp USA
Mitchell County, North Carolina \ `cnRo'
S&ME Project No. 213314
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PREPAREDSpruce Pine, North Carolina 28777

March 22, 2024
North Carolina Department of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Attention: Mr. Adam Parr, PE—Assistant State Mining Engineer
Reference: Mine Permit Modification—Response to Comments
Altapass Mine— Mining Permit No. 61-16
The Quartz Corp USA
Mitchell County, North Carolina
S&ME Project No. 213314
Dear Mr. Parr:
S&ME has received and reviewed the comments for the above referenced mining permit application provided via email
between the North Carolina Department of Environmental Quality(NCDEQ), and Jeffery Curtis of The Quartz Corp (TQC)
on January 23, 2024. S&ME has provided the following responses to the requested modifications. Please find NCDEQ's
comments in bold and italics, and S&ME's response follows:
NCDEQ Comment No. 1:Please label the names of owners of record of all tracts of land adjoining the permit
boundary, on the mine map. The mine maps provided only labeled the PIN and provided no table to cross
reference the owners name with the PIN Please be sure that this map shows the existing permitted boundary and"
the proposed boundary. If the boundary survey map is to be used as the adjoining landowner map,please be sure
to verify that the names on the map match those owners notified.
S&ME Response 1:The names of owners of record of tracts of land adjoining the permit boundary have been added to
Appendix III — Drawings (Drawing Nos. 1, 2, and 3), Drawing 2 shows the existing and proposed permit boundaries.
NCDEQ Comment No. 2:Please provide proof such as copy of the signed return receipts from certified mail, that
all adjoining landowners and the chief administrative officer of each county and municipality have been properly
notified. Notice for SECKEL WILLIAM, and POWELL J DEWEY ESTATE was not provided.
S&ME re-sent notifications to adjoining landowners including William Seckel, the Powell J. Dewey Estate, and Mr.Allen
Cook who is the Chief Administrative Officer for Mitchell County. These individuals were not previously notified. A figure
and table summarizing the notified adjoining landowners and proof of landowner notification consisting of USPS
electronic delivery notification has been added to Appendix V.
NCDEQ Comment No. 3: The parcel labeled "Tract 3", on the boundary survey, across Altapass Hwy., was
previously included within the permit boundary, however it does not appear with the permit boundary on the last
revised set of maps. Please clarify if this parcel is proposed to be removed from the permit boundary. Please
provide a mine map with the entire proposed permit boundary and account for all acreages in the acreage table.
S&ME Response 3: Tract 3 was added to the permit boundary as shown in the Drawings in Appendix III.
S&ME, Inc.12016 Ayrsley Town Blvd.,Suite 2-A I Charlotte, NC 282731 p 704.523.4726 1 www.smeinc.com

© Mine Permit Modification — Response to Comments
Altapass Mine— Mining Permit No. 61-16
Mitchell County, North Carolina
IIIS&ME Project No. 213314
NCDEQ Comments No. 4: Your response to that last request for additional information stated that there will be no
explosives used for the activities described in the modification application. Please be advised that the application
is requesting information that describes the activities for the entirety of the operation, not limited to the activities
for the proposed changes. Please verify that there will be no blasting on site whatsoever.
S&ME Response 4: The North Carolina Mining Permit Application is included as Appendix IV. The response to Question
11 has been modified to acknowledge the potential for use of explosives during freshwater reservoir construction. The
design of this feature is currently in progress and will be addressed with a subsequent Mine Permit Modification
application package.
Please contact us at your earliest convenience if you have any questions or need additional information.
Sincerely,
S&ME, Inc.
Ty Brooks, E.I. Cedric H. Ruhl, P.E.
Project Engineer Senior Engineer
[e-mail] [e-mail]
Senior Review by: Christopher J. L. Stahl, P.E. (Principal Engineer/Vice President
Attachments:
Mine Permit Modification application package
RECEIVE®
APR 01 7014
LAND QUALITY
MINING PROGRAM
March 22, 2024 2

Mine Permit Modification—Response to Comments
Altapass Mine—Mining Permit No. 61-16 s
The Quartz Corp USA � ' I
Mitchell County, North Carolina
s
58tME Project No.213314
Table of Contents
1.0 INTRODUCTION............................................................................................................I
1.1 Existing and Proposed Land Use................................................................................................. 1
1.2 Additional Parcel...........................................................................................................................2
2.0 NATURAL AND CULTURAL RESOURCES .............................................................2
2.1 Stream and Wetland Delineation.................................................................................................2
2.2 Threatened and Endangered Species Habitat Assessment......................................................3
2.1.1 Gray Bat............................................................................................................................................4
2.1.2 Northern Long-eared Bat..................................................................................................................5
2.1.3 Tricolored Bat...................................................................................................................................6
2.1.4 Bog Turtle.........................................................................................................................................6
2.1.5 Appalachian Elktoe...........................................................................................................................7 v
2.1.6 Monarch Butterfly............................................................................................................................ 7
2.1.7 Virginia Spiraea................................................................................................................................7
2.1.8 Rock Gnome Lichen..........................................................................................................................8
2.3 Scoping Letters to Regulatory Agencies.....................................................................................8
2.4 Cultural Resources.........................................................................................................................9
3.0 PERMITTING ...................................................................................................................9
3.1 Mine Permit Modification.............................................................................................................9
3.1.1 Buffers............................................................................................................................................... 9
3.1.2 Denial Criteria.................................................................................................................................. 9
3.1.3 Reclamation Bond........................................................................................................................... 11
3.1.4 Calculations....................................................................................................................................12
3.1.4.1 Stormwater Management...............................................................................................................12
3.1.4.2 Temporary Holding Basin..............................................................................................................12
3.2 NCDOT Driveway Permit..........................................................................................................12
3.3 401/404 Permit..............................................................................................................................12
3.4 NPDES Wastewater Permit........................................................................................................13
March 22, 2024 i

Mine Permit Modification—Response to Comments a
Altapass Mine—Mining Permit No. 61-16
The Quartz Corp USA " I =
Mitchell County, North Carolina
S&ME Project No.213314
4.0 CONSTRUCTION..........................................................................................................13
4.1 Construction Sequencing............................................................................................................13
4.1.1 Construction...................................................................................................................................13
4.1.2 E&SC and Construction (Stream/Culvert Installation)................................................................14
4.1.3 E&SC and Construction (Temporary Holding Basin)...................................................................15
4.1.4 Close Out........................................................................................................................................15
4.2 Erosion and Sediment Control...................................................................................................16
Figures
Figure 1 -Site Vicinity Quadrangle Map
Figure 2-Site Vicinity Highway Map
Appendices
Appendix I-Existing Mine Permit Map
Appendix 11-Property Boundary Survey
Appendix III-Mine Permit Modification Drawings
Appendix IV-North Carolina Mining Permit Application
Appendix V-Public Notification Documentation
Appendix VI-Reclamation Bond
Appendix VII-Scoping Letters and Responses
Appendix VIII-Archaeological Survey
Appendix IX-NCDOT Driveway Permit Figure and Approval
Appendix X-Calculations
Appendix XI—NPDES Wastewater Permit Submittals
March 22, 2024 ii

Mine Permit Modification—Response to Comments a
Altapass Mine— Mining Permit No. 61-16
The Quartz Corp USA I "
Mitchell County, North Carolina E
S&ME Project No.213314 _
1.0 INTRODUCTION
S&ME, Inc. (S&ME) is pleased to submit this Mining Permit Modification on behalf of The Quartz Corp USA
(Quartz Corp). Quartz Corp has an active mining permit(Permit No. 61-16)for their Altapass Mine Site in Spruce
Pine, Mitchell County, North Carolina.The most recent permit modification was approved on June 19, 2007.
Quartz Corp intends to construct a temporary holding basin on the land covered by the active permit, add one
additional parcel (PIN:0799-09-16-2177)which is contiguous to the active permit, and construct an improved
access road from Highway 226 across the additional parcel.
Quartz Corp is in the process of evaluating several potential grading alternatives for a freshwater reservoir that will
be constructed within the permit boundary. The freshwater reservoir is necessary to provide suitable water during
time periods when the water in Grassy Creek is too turbid for use in mineral processing operations. A subsequent
Mine Permit Modification application package will be submitted upon selection and design of the freshwater
reservoir configuration. The subsequent Mine Permit Modification application package will demonstrate how the
improved access road from Highway 226 shown in this application will be extended to the proposed reservoir
location. No stream or wetland impacts will be conducted prior to receipt of both a Mining Permit and applicable
404/401 permits.
1.1 Existing and Proposed Land Use
The project area is located in Spruce Pine, Mitchell County, North Carolina as shown on Figures 1 and 2. The
existing land conditions generally consist of steep wooded terrain south of the North Toe River, and industrial and
residential areas north of the North Toe River.The existing permitted land use is shown on the existing Mining
Map included as Appendix I and consists of stockpile and processing facilities north of the North Toe River,
processing, excavation, and stockpile areas on the east side of Grassy Creek near the confluence of the North Toe
River, and relatively large areas of unallocated land abutting the east and west banks of Grassy Creek.The existing
permitted limits do not include access to North Carolina Highway 226.A new property boundary survey was
conducted as part of this Mine Permit Modification and is included as Appendix II.
The proposed land use is shown on the Drawings in Appendix III and includes construction of a lined temporary
holding basin with associated pump and pipe infrastructure and an improved access road from Highway 226.The
temporary holding basin consists of an approximately 950,000-gallon reservoir with a double-liner system that can
temporarily store wastewater effluent during outages of the primary treatment system. The wastewater stored in
the basin will be pumped back to the treatment system as early as practical. The emergency basin will not require
clearing to construct.
Erosion and sediment control measures will be installed prior to land disturbance and will remain in place until the
tributary drainage area is stabilized with permanent ground cover. The design, including final grading plans are
subject to change pending incorporation of geotechnical information that was obtained from recent drilling
activities.
The proposed land use does not include mining for commercial activities.
March 22, 2024 1

Mine Permit Modification—Response to Comments a
Altapass Mine—Mining Permit No. 61-16
The Quartz Corp USA III
Mitchell County, North Carolina E
S&ME Project No. 213314
1.2 Additional Parcel
The proposed Mining Permit Modification includes the addition of one parcel between the currently permitted
mining limits and NC Highway 226 to provide highway access. The parcel is shown on the Drawings in Appendix
III and described in the North Carolina Mining Permit Application in Appendix IV. The parcel ID and acreage are
summarized as follows:
• Parcel ID = 0799-09-16-2177.
• Area = 6.56 acres.
Property owners adjacent to the proposed additional parcel have been notified as required. The Chief
Administrative Officers for the Town of Spruce Pine and Mitchell County have also been notified. A figure and
table showing notified landowners and proof of notification is provided in Appendix V.
2.0 NATURAL AND CULTURAL RESOURCES
S&ME has performed natural and cultural resources due diligence activities in the footprint of the proposed
freshwater reservoir and access roads, summarized as follows.
2.1 Stream and Wetland Delineation
S&ME performed a jurisdictional delineation to identify the location of jurisdictional Waters of the U.S.within the
boundaries of the project areas in September 2022.Jurisdictional waters are those waters, including wetlands,
which are subject to Section 404 of the Clean Water Act (CWA) under the federal regulatory authority of the U.S.
Army Corps of Engineers (USACE), as well as Section 401 of the CWA under the regulatory authority of the North
Carolina Division of Water Resources (NCDWR). Our approach to performing the jurisdictional delineation
included:
• Assessment and documentation of site conditions as to the presence and/or absence of wetland areas,
using the three-parameter approach (hydric soils, hydrophytic vegetation, and wetland hydrology)set
forth in the 1987 USACE Wetlands Delineation Manual and appropriate Regional Supplement.
• Identification and demarcation of waterways(rivers,streams, and other jurisdictional linear features),
lakes,and ponds,considered to be Waters of the U.S.under the jurisdiction of the USACE and NCDWR
utilizing the North Carolina Division of Water Quality's (NCDWQ's) Stream Identification Method and
Form (Version 4.11).
• Identification and demarcation of upland/wetland boundaries and waterway boundaries with sequentially
numbered flagging.
Relevant supporting information, including Mitchell County GIS data, U.S.Geological Survey(USGS)topographic
maps, Mitchell County Topographic Maps,the Mitchell County Soil Survey,the U.S. Department of Agriculture
publication Hydric Soils of the U.S., and representative aerial imagery were reviewed prior to conducting field
work. Upon completion of the field delineation,the delineated boundaries were located in the field with a
Trimble© GeoXH Global Positioning System (GPS) unit capable of sub-meter accuracy.
March 22, 2024 2

Mine Permit Modification - Response to Comments
Altapass Mine- Mining Permit No. 61-16 4
The Quartz CorpUSA
Mitchell County, North Carolina
S&ME Project No. 213314 _
The location of potentially jurisdictional streams and wetlands are shown on the Drawings in Appendix III. The
design including final grading plans are subject to change pending receipt of topographic survey information.
Impacts to streams and wetlands have been minimized and will be avoided where possible. Stream and wetland
impacts will be permitted as described in Section 3.3 of this report.
2.2 Threatened and Endangered Species Habitat Assessment
To determine compliance with applicable sections of the ESA of 1973 (16 USC 1531-1543), S&ME biologists visited
the site in September 2022 to conduct surveys for relevant federally protected species. Prior to the site visit, S&ME
submitted a request for information to the NC Natural Heritage Program (NCNHP).The NCNHP responded with a
report dated August 15, 2022 that listed element occurrences, natural areas,and managed areas within a one-mile
radius of the project area.The report identified two element occurrences, neither of which hold federal protection
status, and one natural area within the project area. No managed areas were recorded within the project area. The
report identified eight element occurrences, none of which hold federal protection status,two natural areas, and
seven managed areas within one mile of the project area.Three of the managed areas are owned by the State of
North Carolina.
S&ME also consulted the US Fish and Wildlife Service (USFWS) Information for Planning and Consultation (IPaC)
system for a list of species that are known or expected to be near the assessment area.The IPaC report identified
the species listed in Table 1 as having potential to be directly or indirectly affected by activities in the project area.
Table 1:Federally Listed Species Summaxy
Common Name Scientific Name Federal Status bitat Obseived •
Foraging habitat present. No caves/portals observed.Site
Gray Bat Myotis grisescens Endangered clearing for construction will occur outside of maternity
roosting season for bats.
Northern Myots Foraging habitat present.No caves/portals observed.Site
Long-eared Bat septentrionalis Threatened clearing for construction will occur outside of maternity
roosting season for bats.
Proposed Foraging habitat present. No caves/portals observed.Site
Tricolored Bat Perimyotis sub/(ovus Endangered clearing for construction will occur outside of maternity
roosting season for bats.
Clemmys Similarity of
Bog Turtle muhlenbergii Appearance No habitat observed within project LOD.
(Threatened)
Appalachian Alasmidonta Endangered Suitable habitat observed in Grassy Creek.No impacts to
Elktoe raveneliona creek proposed.
Monarch Butterfly Donous plexippus Candidate No open fields or meadows observed on-site.
March 22, 2024 3

Mine Permit Modification—Response to Comments
Altapass Mine—Mining Permit No.61-16
The Quartz Corp USA III
�•
Mitchell County, North Carolina �
S&ME Project No.213314
Common Name Scientific Name Federal StatLIS
Virginia Spiraea Spiraea virginiano Threatened Potential habitat along lower portions of Grassy Creek. LOD
sited to avoid these areas.
Rock Gnome Gymnodermo lineare Endangered No habitat observed.
Lichen
Descriptions of the relevant species taken from USFWS sources are provided below.
2.1.1 Gray Bat
Status: Endangered
Biological Determination: May Affect, Not Likely to Adversely Affect
Gray bat has unicolored dorsal fur(gray after the mid-summer molt, at other times sometimes chestnut brown or
russet), paler below,with hairs darker basally;wing membrane(gray)connects to the foot at the ankle.There is a
distinct sagittal crest on the skull. Gray bat is most likely to be confused with M. luci(ugus,M. sodolis,M.
*4000, austroriparius, and M. septentrionalis. It is distinguished from these by uniform-colored dorsal fur from base to tip
(all others have contrasting shades, bi- or tri-colored dorsal fur) and by attachment of wing membrane at the
ankle, not at base of toe.
Mating occurs in September-October.Adult females store sperm through the winter and become pregnant soon
after emergence from hibernation. One young is born late in May or in early June. Larger colonies are more
successful in raising young. Most young are able to fly in 20-35 days, depending on colony size. Individual females
typically do not produce young until their second year. Recorded maximum longevity approximately 14-17 years
but may be longer. Maternity colonies include from a few hundred to many thousands of individuals.
Wintering caves often are hundreds of kilometers from summer range. Individuals regularly migrate 10-270 miles
between summer maternity sites and winter hibernacula. In some arcas, the same caves are used in winter and
summer, in other areas (e.g., Missouri,Arkansas) many caves used in summer are vacant in winter. Females depart
wintering caves in late March and early April, males in late April and May. Evidence suggests that bats migrate in
small flocks (Barbour and Davis 1969). Small caves may be used as rest stops.Gray bats show strong philopatry to
both summering and wintering sites.
Roost sites are nearly exclusively restricted to caves throughout the year, though only a few percent of available
caves are suitable.Winter roosts are in deep vertical caves with domed halls. Large summer colonies utilize caves
that trap warm air and provide restricted rooms or domed ceilings; maternity caves often have a stream flowing
through them and are separate from the caves used in summer by males.
In the summer, maternity colonies prefer caves that act as warm air traps or that provide restricted rooms or
domed ceilings that are capable of trapping the combined body heat from thousands of clustered individuals.
Undisturbed summer colonies may contain up to 250,000 bats, and average 10,000 to 25,000. Summer caves are
nearly always located within 0.6 mile of a river or reservoir over which the bats forage.
March 22, 2024 4

Mine Permit Modification—Response to Comments
Altapass Mine—Mining Permit No. 61-16
The Quartz Corp USA III
Mitchell County, North Carolina E
S&ME Project No.213314
Young often feed and take shelter in forest areas near the entrance to cave roosts. Foraging is generally parallel to
streams, over the water at heights of 6 to 9 feet.The energy demands on adult females are tremendous during
lactation,and individual females sometimes feed continuously for seven or more hours per night.They feed
mostly upon flying insects, including mayflies and beetles.
S&ME's assessment of the project area did not identify caves or portals that would serve as suitable roost sites
within the proposed limits of disturbance. However,according to the USGS Mineral Resources online spatial
database, one mine was identified on the site, and ten other mines are recorded in a 0.50-mile radius of the
project area.The mine site recorded on the site is identified as the C.W.Allen Prospect of unknown operator type
(35.90203, -82.06928).The record likely relates to surface excavation that occurred along the western project area
boundary.
Although no evidence of caves, mine shafts or portals were observed on-site,the project area contains suitable
foraging habitat for this species.
Primary clearing activities will be scheduled outside of March 15- November 1,thereby avoiding the gray bat's
period of highest activity.
2.1.2 Northern Long-eared Bat
Status:Threatened
Biological Determination: May Affect, Not Likely to Adversely Affect
The northern long-eared bat(Myotis septentrionatis) is a medium-sized bat about three to 3.7 inches in length but
with a wingspan of 9 to 10 inches.This bat generally is associated with old-growth forests composed of trees 100
years old or older. It relies on intact interior forest habitat, with low edge-to-interior ratios. Relevant late-
successional forest features include a high percentage of old trees, uneven forest structure (resulting in
multilayered vertical structure), single and multiple tree-fall gaps, standing snags, and woody debris.
Foraging occurs within forests, along forest edges, over forest clearings, and occasionally over ponds. Eleven
individuals (10 males, 1 female)tagged with chemical lights observed during the summer in Missouri, foraged
almost exclusively among the trees of hillside and ridge forests, rather than utilizing floodplain and riparian
forests;frequently foraging occurred within one to three meters of the ground. Foraging bats doubled back
frequently and only slowly moved out of the observation area. In Iowa,females were found primarily foraging in
mature deciduous uplands with adjacent deep ravines and in a disturbed riparian area with an adjacent floodplain
and agricultural lands.
Hibernation occurs primarily in caves, mines, and tunnels,typically those with large passages and entrances,
relatively constant and cool temperatures, high humidity, and no air currents. Hibernators frequently roost in
crevices, drill holes, and similar sites where they may be overlooked during surveys but roosting in the open is not
uncommon.A lack of suitable hibernacula may prevent occupancy of areas that otherwise have adequate habitat.
Although no evidence of caves, mine shafts or portals were observed on-site, the project area contains suitable
foraging habitat for this species.
March 22, 2024 5

Mine Permit Modification - Response to Comments O
Altapass Mine - Mining Permit No. 61-16
The Quartz Corp USA III
Mitchell County, North Carolina
S&ME Project No. 213314
Primary clearing activities will be scheduled outside of March 15- November 1,thereby avoiding the gray bat's
period of highest activity.
2.1.3 Tricolored Bat
Status: Proposed Endangered
Biological Determination• May Affect Not Likely to Adversely Affect
The tricolored bat (Perimyotis subflavus) is the smallest bat within found in the eastern and midwestern states. It
typically weighs about 1.5-3 ounces and its length is 3-3.5 inches from head to toe.The tricolored bat gets its
name due to its pelage hair upon close examination being brown at the tip, yellow in the middle, and dark at the
base.These bats have oblong ears.These bats also tend to be slow fliers with erratic and fluttering patterns while
foraging.
Tricolored bats appear to inhabit landscapes that are partly open,with large trees and plentiful woodland edges.
They are found in a variety of terrestrial habitats, including grasslands, old fields, suburban areas, orchards, urban
areas and woodlands, especially hardwood woodlands.They generally avoid deep woods as well as large, open
fields.They require specific habitats for hibernating, roosting and foraging.
These bats will hibernate in caves, mines and even buildings with variations in hibernation site selection by region.
They also tend to occupy the very back of the caves and other hibernation sites, where temperature is highest and
least variable,the walls of the cave are warmer, and humidity levels are higher.
Tricolored bats will roost in a wide variety of habitats, again varying by region.They may be found in caves,
crevices,trees and anthropogenic structures such as barns.They tend to feed over water bodies such as rivers or
lakes,where insect populations are highest.They also tend to select for more open foraging sites,with higher
canopies where canopies occur at all.
Primary clearing activities will be scheduled outside of March 15 - November 1, thereby avoiding the gray bat's
period of highest activity.
2.1.4 Bog Turtle
Status: Similarity of Appearance (Threatened)
Biological Determination: No Effect
The bog turtle (Clemmys muhlenbergii) is the smallest turtle inhabiting North America. Its length typically does not
exceed three to four inches and its weight is usually around four ounces. On its neck there is a orange/yellow
patch coloration found which helps distinguish it from other turtles.This species emerges from its hibernation in
early to mid-April and begin mating as early as May.A female typically lays a clutch of one to six small,white,
elliptical eggs in a shallow nest of sphagnum moss or tuft of grass above the water line.After seven to eight
weeks,the hatchlings emerge. Hatchlings often spend their first year near the nest.
'%./ Bog turtles live in the mud, grass and sphagnum moss of bogs, swamps, and marshy meadows.These wetlands
are usually fed by cool springs flowing slowly over the land, creating the wet, muddy soil needed by the turtles.
March 22, 2024 6

Mine Permit Modification - Response to Comments
Altapass Mine- Mining Permit No. 61-16 �
The Quartz Corp USA
Mitchell County, North Carolina III _
� ....�
S&ME Project No.213314
Species that are threatened due to similarity of appearance are not biologically endangered or threatened and are
not subject to Section 7 consultation. However,the project as proposed should have no effect on bog turtles
because the site does not contain suitable habitat for this species.Although some of the onsite wetlands can be
characterized as seeps, they are either located in wooded areas or flow across the existing gravel access road
where the substrate and duration of soil saturation is not likely considered conducive.
2.1.5 Appalachian Elktoe
Status: Endangered
Biological Determination: May Affect, Not Likely to Adversely Affect
The Appalachian elk-toe(Alosmidonto roveneliono) is a thin, kidney-shaped mussel with a shell that reaches a
maximum length of 117 millimeters.The shell ranges in color from yellowish brown to dark brown. Dark green
rays of varying widths occur on some shells of this species.
The Appalachian elktoe inhabits relatively shallow, medium-sized creeks and rivers with cool,well-oxygenated and
moderate-to-fast flowing water. It has been observed in a variety of substrate types including gravel mixed with
cobble and boulders, in cracks within bedrock, and occasionally in relatively silt-free, coarse sand.
The project as proposed may affect, but not likely to adversely affect the Appalachian Elktoe because the project
site is located adjacent to suitable habitat for this species. However,the project has been designed to avoid
impacts to Grassy Creek.
2.1.6 Monarch Butterfly
Status:Candidate
Biological Determination: No Effect
The monarch butterfly(Donaus plexippus) is reddish/orange in color with black vein like markings. It has a black
border around its wings with white spots. In the spring and summer, the monarch butterfly's primary habitat is
open field and meadows containing milkweed. In the winter it can be found on the coast of southern California as
well as high altitudes of central Mexico.
Species listed as candidate are not biologically endangered or threatened and therefore are not subject to formal
Section 7 consultation. However, the project as proposed should have no effect on the monarch butterfly because
the project site does not contain open fields or meadows.
2.1.7 Virginia Spiraea
Status:Threatened
Biological Determination: May Affect. Not Likely to Adversely Affect
Virginia spiraea (Spiraea virginiono) is a shrub endemic to the southern Appalachians.This plant species that
typically exists in clumps. Mature plants reach a height of three to ten feet.Young stems are greenish yellow to
dark brown and mature stems are dark gray.The roots form a complex system.The creamy white flowers are in
tightly packed bunches.
March 22, 2024 7

Mine Permit Modification—Response to Comments a
Altapass Mine—Mining Permit No. 61-16
The Quartz Corp USA III =
Mitchell County, North Carolina E
S&ME Project No.213314
Habitat for the Virginia spiraea includes periodically flood-scoured banks of high-gradient mountain streams,
meander scrolls, point bars, natural levees, and braided features of lower stream reaches, and occasionally near
disturbed rights-of-way.
This plant is often found on geologically active areas with erosion, deposition, and slumping, along rivers with
dynamic flooding regimes, sandbars,scoured river shores and flat rocks with crevices.These areas also are
associated with cobbles, boulders, and massive rock outcrops with sandy or clay soils and can be periodically xeric.
These plants are often seen in silt, mud, and sand. In North Carolina,this species occurs along rocky bars at river
edges. It grows between boulders and in fine alluvial sand and other alluvial deposits.These sites tend to be
seasonally saturated.
Portions of the lower edge of the banks along Grassy Creek exhibited potentially suitable habitat for this species.
Although no populations of Virginia spiraea were observed, the assessment was not conducted during the optimal
survey window, so the absence of this species cannot be definitely ruled out. However, the project should not
affect adversely affect this species because the LOD does not encroach within portions of Grassy Creek's banks
where potentially suitable habitat was observed.
2.1.8 Rock Gnome Lichen
Status: Endangered
Biological Determination: No Effect
The rock gnome lichen (Gymnoderma lineare), of the reindeer moss family, grows in dense colonies of narrow,
strap-like lobes, called squamules.The squamules are blue gray on the upper surface and typically shiny white on
the lower surface. Near the base of the lobe,the color darkens to black.The squamules are less than one
millimeter wide and one to two centimeters long.The small fruiting bodies occur at the tips of the squamules
from July to September.The fruits are colored black or brown and no larger than one millimeter.
The rock gnome lichen only grows in areas with a great deal of humidity, such as high elevations (above 5,000
feet)where fog often occurs or in deep river gorges at lower elevations. Habitat is restricted to vertical rock faces
occasionally exposed to seepage water.This plant does well on moist, generally open sites with northern
exposures but needs partial canopy coverage on southern or western aspect because it is intolerant of high-
intensity solar radiation.This plant will also occur in high elevation coniferous forests, containing red spruce and
Fraser fir, usually on rocky outcrop or cliff habitats present within.
The project as proposed should have no effect on rock gnome lichen because the project site does not contain
suitable habitat for this species.
2.3 Scoping Letters to Regulatory Agencies
S&ME previously submitted scoping letters to the following regulatory agencies:
• North Carolina Division of Water Resources(NCDWR);
North Carolina State Historic Preservation Office (NCSHPO);
• North Carolina Wildlife Resources Commission (NCWRC);
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Mine Permit Modification—Response to Comments
Altapass Mine—Mining Permit No. 61-16
The Quartz Corp USA I I
Mitchell County, North Carolina
S&ME Project No.213314 _
• United States Army Corps of Engineers(USACE);and
• United States Fish and Wildlife Service (USFWS).
Responses were received from the regulatory agencies except for NCDWR.The scoping letters and responses are
included in Appendix VII.
A Phase 1 Archaeological Study was conducted based on comments from NCSHPO which is described in Section
2.4 of this report.
2.4 Cultural Resources
S&ME conducted a Phase 1 Archaeological Study in the footprint of the proposed freshwater reservoir and access
roads in October 2022. The Archaeological Study used both pedestrian and shovel test pit methods for
identifying and evaluating archaeological sites for inclusion in the National Register of Historic Places (NRHP).One
archaeological site, a historic house site,was identified and recommended as not eligible for inclusion in the
NRHP.The Archaeological Study is included in Appendix Vill.
3.0 PERMITTING
The proposed activities will require a Mine Permit Modification, NCDOT Driveway Permit, and 401/404 Permit,
described as follows.
3.1 Mine Permit Modification
The Mine Permit Modification document consists of this report and all associated attachments including Drawings
and North Carolina Mining Permit Application. This Mine Permit Modification application includes buffers and
addresses denial criteria as described below.
3.1.1 Buffers
Buffers are shown on the Drawings in Appendix III. An undisturbed buffer of 25 feet is incorporated where the
mine permit extents adjoin property not owned by The Quartz Corp,with the exception of the proposed driveway
access at NC Highway 226 and existing developed areas north of the North Toe River. A buffer of 25 feet is
applied to delineated streams and wetlands including Grassy Creek. The 25-foot buffer width is consistent with
the existing Mining Permit as shown on the map included as Appendix I. Due to the nature of the site some
construction activities will be conducted within streams, wetlands,and their buffers. Stream and wetland impacts
will be permitted as described in Section 3.3 of this report. No stream or wetland impacts will be conducted prior
to receipt of both a Mining Permit and applicable 404/401 permits.
3.1.2 Denial Criteria
North Carolina General Statute(NCGS) §74-51(d) describes seven criteria that may be invoked to deny the permit
modification. The following sections describe how this modification will not invoke any of the seven denial
criteria. The denial criteria is provided in bold text and the description is provided in standard text.
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Mine Permit Modification — Response to Comments ®®
Altapass Mine— Mining Permit No. 61-16
The Quartz Corp USA I !
�- Mitchell County, North Carolina
S&ME Project No. 213314
Criteria 1 - §74-51(d)(1) That any requirement of this Article or any rule promulgated hereunder will be
violated by the proposed operation.
The activities described in this Mine Permit Modification will not violate any requirements of NCGS Chapter 74
Article 7 or any rule promulgated hereunder.
Criteria 2 - §74-51(d)(2) That the operation will have unduly adverse effects on potable groundwater
supplies, wildlife, or fresh water, estuarine, or marine fisheries.
The activities described in this Mine Permit Modification will not have unduly adverse effects on potable
groundwater supplies, wildlife, or fresh water, estuarine, or marine fisheries.
Criteria 3 - §74-51(d)(3) That the operation will violate standards of air quality, surface water quality, or
groundwater quality that have been promulgated by the Department.
The activities described in this Mine Permit Modification will not violate standards of air quality, surface water
quality, or groundwater quality that have been promulgated by the Department. Erosion and sediment control
measures will be installed prior to conducting land disturbance, and those E&SC measures will remain in place
until stabilization of the tributary drainage area with permanent vegetation or as otherwise specified on the
Drawings. Dust control measures will be utilized as required during construction to prevent significant amounts of
wind-borne dusting.
The temporary storage basin will incorporate two geomembrane liners to protect underlying soils and
groundwater.
Criteria 4 - §74-51(d)(4) That the operation will constitute a direct and substantial physical hazard to public
health and safety or to a neighboring dwelling house, school, church, hospital, commercial or industrial
building, public road or other public property, excluding matters relating to use of a public road.
The activities described in this Mine Permit Modification will not constitute a direct and substantial physical hazard
to public health and safety or to a neighboring dwelling house, school, church, hospital, commercial or industrial
building, public road or other public property, excluding matters relating to use of a public road.
March 22, 2024 10

Mine Permit Modification- Response to Comments
Altapass Mine- Mining Permit No. 61-16
The Quartz CorpUSA
Mitchell County, North Carolina
S&ME Project No. 213314
Criteria 5 - §74-51(d)(5) That the operation will have a significant adverse effect on the purposes of a
publicly owned park, forest or recreation area.
The activities described in this Mine Permit Modification will not have a significant adverse effect on the purposes
of a publicly owned park, forest or recreation area.
Criteria 6 - §74-51(d)(6) That previous experience with similar operations indicates a substantial possibility
that the operation will result in substantial deposits of sediment in stream beds or lakes, landslides, or acid
water pollution.
Land disturbance associated with this Mine Permit Modification consists of construction activities that have a
limited duration. Land disturbance will not be conducted until installation of relevant erosion and sediment
control (E&SC) measures. E&SC measures will not be removed until the tributary drainage area is stabilized with
permanent vegetation or as specified on the Drawings. Erosion and sediment control measures have been
designed and specified in accordance with the North Carolina Department of Environmental Quality Erosion and
Sediment Control Planning and Design Manual.
Criteria 7 - §74-51(d)(7) That the applicant or any parent, subsidiary, or other affiliate of the applicant or
parent has not been in substantial compliance with this Article, rules adopted under this Article, or other
laws or rules of this State for the protection of the environment or has not corrected all violations that the
applicant or any parent, subsidiary, or other affiliate of the applicant or parent may have committed under
this Article or rules adopted under this Article and that resulted in
a. Revocation of a permit,
b. Forfeiture of part or all of a bond or other security,
c. Conviction of a misdemeanor under G.S. 74-64,
d. Any other court order issued under G.S. 74-64,
e. Final assessment of a civil penalty under G.S. 74-64, [or]
f. Failure to pay the application processing fee required under G.S. 74-54.1.
The Quartz Corp (applicant) and its parents and subsidiaries are in substantial compliance with NCGS Chapter 74
Article 7 and other relevant laws of the state.
3.1.3 Reclamation Bond
Quartz Corp currently holds a reclamation bond in the amount of one million dollars, which is the maximum
amount required by statute. Reclamation bond information is included in Appendix VI.
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Mine Permit Modification—Response to Comments
Altapass Mine—Mining Permit No. 61-16
The Quartz Corp USA III
Mitchell County, North Carolina E
S&ME Project No.213314
3.1.4 Calculations
Engineering calculations were prepared to evaluate various aspects of the proposed features. The calculations are
included in Appendix X and summarized as follows.
3.1.4.1 Stormwater Management
Construction of the improved access road will require installation of stormwater features including:
• Culverts;
• Energy dissipators;and
• Temporary and Permanent Erosion and sediment control practices.
The access road culvert crossing at an unnamed tributary to Grassy Creek has been designed to minimize changes
from existing conditions upstream or downstream.The proposed dual 48-inch diameter reinforced concrete pipes
will pass the anticipated flows from a 100-year, 24-hour storm without overtopping the access road. The receiving
riprap energy dissipator has been designed to provide downstream stability for culvert outflows from the 100-
year, 24-hour design storm.
*4./ 3.7.4.2 Temporary Holding Basin
The temporary holding basin will have an approximate operating volume of 950,000 gallons,with an additional
two feet of freeboard. Filling and dewatering times were evaluated for a range of pump flow rates. The
temporary holding basin will provide storage for 6 hours of plant operations assuming a constant inflow rate of
2,500 gpm. The design, including final grading plans are subject to change pending incorporation of geotechnical
information that was obtained from recent drilling activities.
3.2 NCDOT Driveway Permit
Construction of the freshwater reservoir and access roads includes a new driveway to provide access to the site
from North Carolina Highway 226. The Quartz Corp received Driveway Permit Approval from the North Carolina
Department of Transportation (NCDOT) on November 10, 2022. The NCDOT approval letter and driveway permit
figure are included as Appendix IX.
3.3 401/404 Permit
Temporary and permanent impacts to jurisdictional waters will occur at an unnamed tributary to Grassy Creek as
part of construction of an improved access road. The Drawings in Appendix III show field-delineated streams
and wetlands and conceptual grades.
Impacts to Waters of the U.S. (jurisdictional waters)are regulated by the USACE through Section 404 of the Clean
Water Act(CWA).The Wilmington District of the USACE handles Section 404 regulatory review. Section 401 of the
CWA grants corresponding regulatory authority to individual states. In North Carolina,the Section 401 regulatory
agency is the NCDWR.
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Mine Permit Modification—Response to Comments
Altapass Mine— Mining Permit No. 61-16 �
The Quartz Corp USA III
Mitchell County, North Carolina E
S&ME Project No.213314 _
S&ME initially submitted a pre-construction notification (PCN)for Nationwide Permit (NWP) No.44 through the
USACE Asheville Regulatory Field Office, and North Carolina's Water Quality Certification (WQC)General
Certification (GC) No.4267 by the state but withdrew the PCN after discussion with USACE and NCDWR. A new
PCN will be submitted after selection of a freshwater reservoir design alternative such that all proposed stream
and wetland impacts related to site development can be considered at one time. No stream or wetland impacts
will be conducted prior to receipt of both a Mining Permit and applicable 404/401 permits.
3.4 NPDES Wastewater Permit
Quartz Corp has a National Pollutant Discharge Elimination System (NPDES)Waste Water Permit(NC0000353)
that expired in 2016. Quartz Corp submitted a letter to NCDENR(now NCDEQ) on July 10, 2015 requesting
renewal of the permit. The NCDEQ prepared a draft NPDES permit renewal on October 17, 2018 which was
received by The Quartz Corp in 2020. Quartz Corp submitted a letter and supporting documents for a permit
renewal application to the NCDEQ on May 4, 2018. The initial July 10, 2015 letter requesting renewal;the NCDEQ
draft permit dated October 17, 2018;and the May 4, 2018 application are included in Appendix XI.
4.0 CONSTRUCTION u
4.1 Construction Sequencing
The proposed construction sequence is provided as follows:
4.1.1 Construction
1. Ensure all applicable permits have been obtained. No stream or wetland impacts will be conducted prior
to receipt of both a Mining Permit and applicable 404/401 permits.
2. Notify the North Carolina Department of Environmental Quality(NCDEQ) Mining Program prior to land
disturbance: Shawna Riddle, 828-296-4617, [e-mail].
3. Hold pre-construction meeting if requested by NCDEQ.
4. Prior to any site disturbance activities (clearing, grubbing, grading, or excavation), install erosion and
sediment control measures. Compost filter socks can be installed as a silt fence alternative if site
constraints dictate.
5. Begin construction activities. Ensure all disturbed areas drain towards an installed erosion and sediment
control device.
6. Place compacted fill to meet design grades where necessary.
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Mine Permit Modification - Response to Comments
Altapass Mine- Mining Permit No. 61-16
The Quartz Corp USA " � =
Mitchell County, North Carolina
S&ME Project No. 213314
7. Upon completion of construction stabilize disturbed areas in accordance with the seeding specifications
or as shown on the Drawings.
8. Inspect all erosion control devices at weekly intervals and after every rainfall exceeding 1.0-in.within any
24-hour period to verify that they are functioning properly.Any accumulated sediment shall be removed
and placed in a designated spoil disposal area.Conduct periodic inspections of all erosion and
sedimentation controls and make any repairs or modifications necessary to assure continued effective
operation of each device.
4.1.2 E&SC and Construction (Stream/Culvert Installation)
9. Temporarily remove E&SC measures to facilitate culvert installation.
10. Install coffer dams according to plans and dewater ditch using pumps and filter bags if necessary.Any
dewatering shall be done through filter bags.
11. Contractor shall access stream for placement of coffer dam by foot within limits of disturbance shown on
the plans.
�./ 12. Setup pumps interior of coffer dam, hoses,filter bags, intakes, and diffusers as shown on the detail and in
a location as directed by the owner's on-site representative.
13. Prepare area for coffer dam by removing rocks and debris within streambed in order to prepare a level,
depressed area for placement of coffer dams. Reserve any streambed material for replacement when
coffer dams are removed.
14. Continue stacking sandbags as tightly as possible as shown on the detail until the upstream coffer dam is
in place and secure.
15. Contractor shall ensure tight seal of sandbag coffer dam during all phases of installation.
16. Sandbags should be placed along the edges of the coffer dam to keep water from cutting around the
coffer dam.
17. Concurrently, install the downstream coffer dam in the same manner.
18. With temporary dewatering piping, pump,filter bag, and compost filter sock in place, begin pumping
water from between the coffer dams. Keep pump set up in place during construction to continue
pumping if necessary. Additional pump equipment, filter bags, and compost filter socks should be on-
hand in the event of storm events.
19. Contractor shall monitor weather and work in dry conditions to the best extent possible. Contractor is
responsible for stabilizing the construction site to the best extent practical during a storm event.
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Mine Permit Modification—Response to Comments
Altapass Mine—Mining Permit No. 61-16 �
The Quartz CorpUSA
Mitchell County, North Carolina III S
S8tME Project No.213314
20. Excavate for the culvert structure.Strip substrate and stockpile. Excavate subgrade soil and stockpile.
Undercut and replace existing soft fill or residual soils beneath culvert area with compacted structural fill
materials as required by pipe specifications.
21. The culvert structure shall be installed in accordance with manufacturers specifications.
22. Culvert backfilling shall be performed in accordance with the engineered fill/backfill requirements.
23. Where indicated, install coir matting, reinstall silt fence or compost filter sock, and install slope matting.
24. Finalize crossing construction activities per plans.
25. Remove timber mats (if utilized).
26. Remove downstream coffer dam (if utilized). Replace any stockpiled streambed material.
27. Continue pumping any sediment laden material through the filter bag.
28. Remove upstream coffer dam and replace stockpiled streambed material.
29. Apply soil amendments, seed, and mulch to remaining disturbed areas according to the seeding
specifications.
4.1.3 E&SC and Construction (Temporary Holding Basin)
30. Excavate to design subgrade grades.
31. Smooth temporary holding basin irregularities of the subgrade as shown on the plans. Install the
geomembrane liner per the manufacturers specifications. Extend liner into anchor trench as shown on the
detail,and grade to final grades as indicated on the plans. Place compacted fill to meet design grades
where necessary.
32. Install influent and effluent pipes from the temporary holding basin to the facility as shown on the plans.
4.1.4 Close Out
33. Finalize construction activities.
34. Seed, amend soils, and mulch disturbed areas with seeding.
35. Establish permanent vegetation in disturbed areas.
36. Upon establishment of permanent vegetation remove temporary erosion control measures, as applicable.
Temporary matting, if used, shall be left in place.
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Mine Permit Modification - Response to Comments
Altapass Mine- Mining Permit No. 61-16
The Quartz Corp USA I I I
Mitchell County, North Carolina S
S&ME Project No.213314
4.2 Erosion and Sediment Control
Land disturbance will not be conducted until installation of relevant erosion and sediment control (E&SC)
measures. E&SC measures will not be removed until the tributary drainage area is stabilized with permanent
vegetation or as specified on the Drawings. Erosion and sediment control measures have been designed and
specified in accordance with the North Carolina Department of Environmental Quality Erosion and Sediment
Control Planning and Design Manual.
March 22, 2024 16

Figures
1. Site Vicinity Quadrangle Map
2. Site Vicinity Highway Map