20240417_ADI_Reply

Elliott Consulting
202 Elliott Road
PO Box 112
Adam Parr, PE Aydlett, North Carolina 27916
State Mining Engineer Phone: [phone]
NC Dept. of Environmental Quality
Division of Energy, Mineral and Land Resources
Land Quality Section
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
--------------------------- ------------------ -- - - -------- -- -----------------------------------
Dear Mr. Parr:
I am writing to you on behalf of R. Gary Thompson, applicant for The Sandlot (excavation) mining
permit. This letter is in response to your request for further information on Mr. Thompson's permit
application. Response to items in your request are as follows:
1. Pumping O&M plan -A pumping O&M plan was submitted in January 2024 along with the
NCG02 NOI application for dewatering the mine. A copy of the plan is attached with this
letter.
2. Undisturbed and unexcavated areas-All areas in the permit boundaries which were
formerly designated as undisturbed and which had berms, discharge pipes, riprap apron,
and office access path, have now been redesignated as unexcavated buffer. Revised mine
map is enclosed. Revised application documents with corrected unexcavated buffer areas are
also attached.
3. Stockpile area on acreage table- Stockpile area has been updated on revised mine map. The
1.21-acre stockpile number on the table is referring to 1740 feet of 10-ft wide perimeter berm
and other berms which will remain in place around the pond at reclamation. Other berms
(visual screens) will be removed at reclamation and their footprints will be graded and sown
with groundcover. Some temporary stockpiles, shown on the revised mining map, will be
located inside the excavation area, and later removed as excavation proceeds.
Two copies of all documents are enclosed with this letter.
Thank you,
f�
Ken Elliott
Elliott Consulting
4/15/2024

PUMPING OPERATION AND MAINTENANCE PLAN
SAND MINE DEWATERING WITH SEDIMENTATION POND
Operator: TR Equipment Company,Inc., R.Gary Thompson,President
PO Box 190, Harbinger, NC 27941
Job Location: The Sandlot,7831 Caratoke Hwy.,Powell's Point, NC 27966
County: Currituck County
Prepared by: Ken Elliott,consulting
Date: January 13,2024
This plan defines responsibilities for operating,inspecting,and maintaining equipment and structures
used for dewatering The Sandlot sand mine safely,and that dewatering will not degrade or negatively
impact any wetlands or waters of the state.
Description and Current State of The Sandlot Mine Site and Mining Application:
The Sandlot is a proposed 6.12-acre sand mine excavation to be operated by R.Gary Thompson,
president of TR Equipment Company, Inc.,applicant, in a 16.06-acre permit area,of which 7.67 acres will
be affected,located at 7831 Caratoke Highway,in Powell's Point, NC in Currituck County.The permit
area is on cultivated,sandy land at 10-ft elevation,leased by the applicant from Lyn Van Lurette Trust,
LLC,PO Box 190,Kitty Hawk, NC 27949. The site is located 0.5 mile east of North River,which flows
southward from there 0.75 mile to Albemarle Sound.
In August 2023,Mr.Thompson received an approved zoning compliance permit from Currituck County
Planning&Inspections to construct a 0.87-acre sand pit excavation on the subject property. This
excavation is located inside the proposed State mining permit area and will serve as a separate sediment
pond for the State-permitted excavation and will be incorporated into the main excavation upon
reclamation.
Currently Mr.Thompson is applying for a mining permit with the NCDEQ Division of Energy,Mineral and
Land Resources to construct the sand mine and begin operation in March or April 2024. An NPDES
General Permit application for dewatering is being submitted to NCDEQ and registration for water usage
has been submitted to the Division of Water Resources. A Stormwater Pollution Prevention Plan is
under development and will be implemented upon approval of the discharge permit application.
Sand Mine Dewatering:
It will be necessary to dewater the pond as it is being excavated to allow excavating equipment to enter
the area safely and efficiently remove sand from the pond bottom. This will allow for full permitted
depth of excavation of the pond and proper reclamation of the edges of the pond. It is the intention of
the operator to only dewater the excavation as needed,which will not entail full-time dewatering.
For excavation purposes,dewatering will occur intermittently 12-16 times per year. The operator plans
to excavate approximately 25,000 cubic yards of sand at a time while dewatering and stockpile it for

later usage. Once the stockpiled sand is depleted,the operator will dewater the excavation again and
remove another quantity of sand.
Mine dewatering wastewater will be treated before release to the Waters of the State. Use of a
sedimentation pond separate from the excavated mine is a traditional and effective means to remove
sediment from wastewater generated during mine dewatering operations.
Sedimentation Pond Construction and Overflow Discharge:
The operator plans to utilize his existing 0.87-acre sand pit located 25 feet northeast of the main
excavation area as a sedimentation pond for dewatering the main pond. The sediment pond will have a
4-ft tall berm constructed around the pond perimeter to help maintain dewatering volume. The pond
berms will have a minimum of 1.5 feet of freeboard between the water surface and the top of the
sediment pond bank. The sediment pond will be located adjacent to an existing groundwater-levelling
ditch which flows westward 1100 feet to wetlands draining to North River.
Sediment pond water level will be controlled by a half-pipe flash-board water height control device
installed in the northern corner of the sediment pond berm.The control structure will allow water to
flow across the flash boards into a 125' long x 24"wide PVC discharge pipe running northward through
the sediment pond berm to an outlet discharging to a 20-foot-long riprap-protected apron in the
discharge ditch,leading 1100 feet to wetlands. From there,discharge water will drain 0.5 mile to North
River and Albemarle Sound.
Dewatering Procedure:
The operator will install an 8-inch dewatering pump between the main excavation and sediment pond at
the north end of the excavation.Discharged water from the dewatering pump will enter the sediment
pond at its southern corner and will overflow through a constructed half-pipe flash board water height
control device discharge point located on the northern corner of the sediment pond.The discharge
point will release clear water through the water-height control device into the existing discharge ditch
draining to wetlands and North River.
Water will be pumped from the excavated pond to the sediment pond by the 8-in gasoline-powered
transfer pump operating at idle speed,approximately 1100 rpm. Estimated maximum flow from the
pump will be 8,000 gallons/hour,operating 12 hours per day,0.096-mgd. It is the intention of Mr.
Thompson to lower the water level in the excavation approximately 20-25 feet below normal ground
level as needed.
Time and distance will allow all sedimentation to occur to acceptable levels before the overflow water
reaches its outfall and then the waters of the State. Water will flow a minimum of 250 feet to reach the
overflow point which will give enough surface area to allow sufficient sedimentation to occur. There will
be a minimum of 1.5 feet of freeboard between the water surface in the sediment pond and the top of
the sediment pond bank. Stormwater drainage will be unable to enter the sediment area and damage
the sediment pond rates,due to the height of a surrounding 4-ft tall sediment pond berm.

Wetlands Protection:
Removing water from the excavation using a sedimentation pond with overflow is a valid dewatering
method for this size excavation. The pond can be dewatered quickly,and water removed from the pond
will be used to uniformly hydrate adjacent wetlands.
Once dewatered,excavation activity will be focused on removing sand from the pond as quickly as
possible to shorten the periods of dewatering. This will allow the groundwater level in the pond to
return to normal as soon as possible to lessen possible impacts to adjacent wetlands,once dewatering
ceases.
Groundwater Control:
Groundwater levels are not expected to be impacted in areas outside of the immediate excavated
dewatering area. Groundwater levels are expected to remain stable despite dewatering of the
excavation. The excavation site is located 1100 feet east of a 1500-acre North River wetlands area,
which serves to drain and hydrate the area adjacent to the proposed permit area.
Groundwater level depletion is not expected to affect any neighboring groundwater wells.The closest
residences to excavation are located 330 feet from the proposed excavation,with others further.
Properties along Caratoke Highway are served by the Currituck County Water System.
The operator will construct and install three groundwater level monitoring wells between the proposed
mining area and adjacent residences to the south and west. The wells will be installed before
dewatering activity begins,and the wells will be checked monthly for groundwater levels once
dewatering begins. Locations of the monitoring wells are shown on the attached mining maps.
In addition,per Currituck County ordinances,the mine operator will post a$3,000 bond for active
groundwater wells located within 1,500 feet of the mine excavation area. The bond will provide funds
to repair any problems with neighboring water supply wells within 1500 feet of The Sandlot excavation
edge,if the problems occur during times of dewatering activity. The operator will also provide a written
performance guarantee to repair any problems with neighboring water supply wells within 2000 feet of
The Sandlot excavation edge,if they occur during times of dewatering activity.
Sedimentation and Erosion Control:
The operator will maintain a minimum 25-ft wide unexcavated buffer on the north,south,east,and
west sides of excavation activity.
All erosion and sedimentation will remain inside the permit area.The operator will construct and
maintain a 10-ft wide x 2-ft tall grass-covered sand berm around the perimeter of the current affected
area of the excavation during all phases of operation,inside the unexcavated buffer.Stormwater falling
inside the active mining area will be directed to drain into the excavation by diversion drains.

Maintaining the Dewatering Equipment and Erosion Control Measures:
Inspections and maintenance are required to obtain the intended function of safely dewatering the sand
mine,and to maintain the life of any nearby wetlands or waters of the State. Items to inspect and
maintain during the anticipated 10-year life of the mine dewatering permit are:
• Inspect embankments, berms and appurtenant structures,and repair as needed.
• Monitor overflow ditches for damage or stoppage from beaver activity, repair as needed.
• Repair any damage to vegetated areas or berms with compacted earth fill, reshaping,sodding,
reseeding,and mulching as needed.
• Promptly repair all leaks in delivery facilities by replacing valves,fittings,gaskets,and worn or
damaged parts.
• Maintain all screens,filters,valves,timers,and other electrical and mechanical equipment in
good operating condition,following manufacturer's recommendations.
Monitoring the Dewatering Process and Effects of Dewatering:
Analytical and qualitative monitoring of mine dewatering wastewater will be in accordance with the
NCG020000 permit,as follows:
• The Sandlot excavation will discharge mine dewatering wastewater into wetlands draining to
North River,classified as SC,and to Albemarle Sound,classified as SB.
• Per requirements of the NPDES permit,discharge water will be sampled quarterly and analyzed
for pH,Total Suspended Solids(TSS),turbidity,and salinity. Samples with benchmark
exceedances will require the operator to increase sampling, per NPDES permit,until sample
results are cleared.
• All excavated ponds in The Sandlot excavation area will be inspected daily by the operator to
identify any abnormal conditions.
• All berms and erosion control structures will be inspected for damages monthly and within 24
hours after every storm event greater than 1.5 inches,and all structures will be repaired
immediately.
• Special inspections will be conducted immediately following severe storms,vandalism,and
other significant events.
• Dewatering process will be inspected daily during periods of dewatering the excavation.
• Rain gauge data will be collected by monitoring local rain gauge data monthly and after each
rain event.
Wetlands Monitoring:
Wetlands are located westward of the proposed Sandlot mine site. level 1 wetlands landscape
assessment by US Fish&Wildlife Service indicate one type of wetlands near the parcel in question:
• PFO1Cd—Freshwater Forested/Shrub Wetland, partially drained,700 ft west of excavation
boundary.

Level 2 wetlands assessment has not been performed on the site. Discharge ditches will serve as
hydration devices to help maintain normal groundwater levels. Operator will monitor drainage ditches
weekly to always ensure presence of water in the ditch.
Records
Data will be collected as follows:
• Visual monitoring of adjacent wetlands and farmland for potential dehydration during mining or
dewatering activities will take place weekly. Solutions to any degradation caused by any mining
activity will include alteration of dewatering process. DWQ will be consulted as needed;
alterations to process will be recorded.
• Elliott Consulting will maintain the following records in a permanent file at the Elliott Consulting
office at PO Box 112, 202 Elliott Road,Aydlett, NC 27916:a record of all significant actions
taken;as-built drawings; permits; analytical results from sampling; and related material. Copies
of all inspections, monitoring reports and lab analyses shall be provided to NCDWQ on a regular
basis and as requested.
• Stormwater Pollution Prevention Plan and other pertinent documents and records will be
available online for inspection at www.thompson-sp3.com.
BMP Conditions
• The permittee will utilize best management practices to ensure that dewatering The Sandlot
excavation will not degrade or negatively impact any wetlands or waters of the State. BMP's
will include:
o All berms and erosion control and sedimentation control structures will be inspected for
damages monthly and within 24 hours after every storm event greater than 1.5 inches,
and all structures will be repaired immediately.
o A paved construction entrance will be maintained at intersection of the mine access
road and Caratoke Highway.
o Operator will maintain riprap outfall protection on the overflow drainage ditch
downstream of sediment pond.
o Groundcover will be established on all sections of the permit area when not in use by
mining activities.
Signed,
Ken Elliott
forTR Equipment Company, Inc.,Operator
The Sandlot,Powell's Point, NC
January 13, 2024

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]
B.MAPS
1. Clearly mark and label the location of your mining operation on six(6)copies of a 7.5-minute quadrangle and a county
highway map.These maps,in addition to six(6)copies of all mine maps and reclamation maps,must be submitted
with each permit application.
7.5-minute quadrangles may be obtained from the N.C.Geological Survey:
Mailing Address Physical Address
1612 Mail Service Center 612 N.Salisbury St.,5r^Floor
Raleigh,NC 27699-1612 Raleigh,NC 27604
Http://portal.ncdenr.org/webAr/geological home [phone]
County highway maps may be obtained from the N.C.Department of Transportation:
Mailing Address Physical Address
NCDOT GIS Unit NCDOT GIS Unit
1587 Mail Service Center 3401 Cad Sandburg Court
Raleigh,NC 27699-1587 Raleigh,NC 27610
http://www.ncdot.rgft/gis [phone]
2. A table/chart must be provided on the mine map that clearly lists the appro)dmate acreage of tailingstsediment ponds,
stockpiles,waste piles,processing areas/haul roads,mine excavations and any other major aspect of the mining
operation that is proposed to be affected/disturbed during the life of the mining permit.A tablelchart similar to the
following will be acceptable:
AFFECTED ACREAGE TABLE:
For new permits,complete only the total affected acreage column.
For modifications,complete all columns.
CATEGORY CURRENT AFFECTED PROPOSED CHANGE TO TOTAL AFFECTED
ACREAGE AFFECTED ACREAGE ACREAGE
Tailings/Sediment Ponds
Stockpiles 1.21
Waste piles
Processing AreaslHaul Roads 0.24
Mine Excavations 6.12
Other(Please explain) Unexcavated Buffers 4.65
Total Affected Acreage 12.22
Total Permitted Acreage 16.06
Revised September 21, 2021 P a g e ) 4

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]
E.DETERMINATION OF AFFECTED ACREAGE AND BOND
The following bond calculation worksheet is to be used to establish an appropriate bond(based upon a range of$500 to$5,000
per affected acre)for each permitted mine site based upon the acreage approved by the Department to be affected during the
life of the mining permit.Please insert the approximate acreape.for each aspect of the mining operation.that you intend to affect
during the life of this mining permit(in addition,please insert the appropriate reclamation cost/acre for each category from the
Schedule of Reclamation Costs provided with this application form)OR you can defer to the Department to calculate your bond
for you based upon your maps and standard reclamation casts.
CATEGORY AFFECTED RECLAMATION RECLAMATION
ACREAGE COSTIACRE COST
Tailings/Sediment Ponds Ac. X $ /Ac. = $ 0.00
Stockpiles 1.21 Ac. X $ 19800 /Ac. = $2,178.00
Waste Piles Ac. X $ /Ac. = $ 0.00
Processing Area/Haul Roads 0.24 Ac. X $ 1,800 /Ac. = $432.00
Mine Excavation 6.12 Ac. X $ 500 /Ac. = $3,060.00
Other Unexcavated Buff. 4.65 Ac. X $ 1,800 /Ac. = $8,370.00
TOTAL AFFECTED AC.: 12.22 Ac.
TOTAL PERMITTED AC.: 16.06 Ac.
Temporary&Permanent Sedimentation&Erosion Control Measures:
Divide the TOTAL AFFECTED AC.above into the following two categories:a)affected acres that drain into proposed/existing
excavation and/or b)affected acres that will be graded for positive drainage where measures will be needed to prevent offsite
sedimentation and sedimentation to onsite watercourses and wetlands.
a) Internal Drainage 12.22 Ac.
b) Positive Drainage Ac. X $1,500.00 = $ 0.00
SUBTOTAL COST:$ 1 4,040.00
Inflation Factor.
SUBTOTAL COST LIFE OF MINING OPERATION OR LIFE INFLATION COST
OF LEASE(YEARS)
0.02 X $ 14,040.00 X 10 = $2,808.00
Total Reclamation Bond Cost:
ETOTALRECLAMATION BOND COST= SUBTOTAL+INFLATION 69800.00
Round down to the nearest 100.00
NOTE:The reclamation bond cannot exceed$1 million per GS 74-54
Revised September 21, 2021 Page 114