20240515_ADI_Reply_10-A10

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NORMS & TUNSTALL
CONSULTING ENGINEERS P.C.
2602 Iron Gate Dr.Suite 102 1429 Ash-Linde 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.
t RECEIVED MAY 15 2024
May 14, 2024
Corey Clayton
Assistant State Mining Engineer
NCDEQ / Division of Land Resources
Land Quality Section — 5th Floor
512 N. Salisbury Street
Raleigh, NC 27604
Re: Response to Review Comments
Babson Sand Mines
Brunswick County, NC
NT Project No. 22080
Dear Mr. Clayton,
In connection with the subject project, we are responding to the review comments dated
February 6, 2024, in red below:
1. Please indicate receiving watercourses and wetlands on the mine maps. This information
has been included and revised mine maps are enclosed.
2. Add the feature labeled as PNVVWUS, identified on the PJD from the USACE, to the mine
maps. This information has been included and revised mine maps are enclosed.
3. Please confirm that no wetlands or streams will be disturbed for this project. No wetlands
or steams will be disturbed for this project.
4. Please provide a pumping O&M plan to mitigate adverse impact to the surrounding
wetlands. Enclosed is the pumping O&M plan as requested.
5. Provide a response to the application question "Are acid producing minerals or soils
present?" There are no acid producing minerals or soils present; enclose is the updated page 9
of the application.
6. Please explain what activity, if any, is proposed for the space between the two mining
areas. There is no activity proposed for the space between the two mining areas.
NCBELS License C-3641

t
Response to Review Comments
Babson Sand Mines
NT Project No. 22080
May 14, 2024
Page 2
7. Berms are proposed along the haul road and potentially elsewhere within the mine permit
boundary. Please include any proposed berms on the mine map along with a typical cross-
section of the berm. There are no berms proposed.
8. Provide a reclamation map showing the surface area of the proposed lake to remain as
well as any other features proposed to remain after mining activities cease, such as haul roads
and berms. Please see enclosed reclamation map.
9. If the haul road is to remain on site after reclamation is complete, please provide a plan
to stabilize the roadway. The existing farm road will remain a soil roadway.
10. Please verify that neighbors have been notified by submitting a copy of the Certified Mail
return receipts. Please find enclosed copies or certified mail receipts, green cards and RTS
envelope received.
Sincerely,
NORRIS & TUNSTALL
CONSULTING ENGINEERS, P.C.
2ph K. Bland, P.E.
JKB/ttw 22080 05-14-24 Itr resp.
cc: Julia Tripp

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)In excavation(s)of unconsolidated(non-rock)materials,specify the angle of all cut slopes including specifications
for benching and sloping.Cross-sections for all cut slopes must be provided on the mine map(s).
See plans for cross section.
D)In hardrock excavations,specify proposed bench widths and heights in feet.Provide cross-sections of the mine
excavation clearly noting the angles of the cut slopes,widths of all safety benches and mine benches,and the
expected maximum depth of the excavation.
NIA No Rock.
7. Describe other methods to be taken during mining to prevent physical hazard to any neighboring dwelling,house,
public road,or public,commercial or industrial building from any mine excavation.Locate all such structures on the
mine map if they are within 300 feet of any proposed excavation.
No blasting or vibrating equipment is proposed.Extensive undisturbed buffer to be provided as well as a berm.
8. Describe what kind of barricade will be used to prevent inadvertent public access along any high wall area and when it
will be implemented.Vegetated earthen berms,appropriate fencing and adequate boulder barriers may be acceptable
high wall barricades.A construction detail/cross-section and location of each type of barricade to be used must be
indicated on the mine map(s).
The haul road will be gated and berms installed along each side. There will be undisturbed vegetated buffers retained around
the perimeter of the project.
9. Are acid producing minerals or soils present?
*69 NO
If yes,how will acid water pollution from the excavation,stockpiles,and waste areas be controlled?
Revised September 21,2021 Page 19

PUMPING OPERATION & MONITORING PLAN
BABSON SAND MINES RECEIVED MAY
15 2024
Brunswick County, North Carolina
For
Sawyer Rivers Sand LLC
330 Military Cutoff Road, Ste A-2 Wilmington NC 28405-8303
Julia Tripp/ 910-287-3234 / [e-mail]
-
_ 041 620 -
Prepared by:
NORRIS & TUNSTALL CONSULTING ENGINEERS, P.C.
1429 Ash-Little River Road
Ash, North Carolina 28420
[phone]/[e-mail]
License# C-3641
N&T Project# 22080

Pumping Operation & Monitoring Plan
BABSON SAND MINES
PUMP SPECIFICATIONS
The selected pump will be the following:
• 4" Godwin Diesel
MONITORING OF WETLAND AREAS
Sediment discharge sampling per General Permit No. NCG020000
Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic
of the volume and nature of the permitted discharge. Analytical sampling shall be
performed during a measurable storm event. Samples shall be taken on a day and time
that is characteristic of the discharge. All samples shall be taken before the discharge
joins or is diluted by any other waste stream, body of water, or substance. Monitoring
points as specified in this General Permit shall not be changed without notification to
and approval of the Permit Issuing Authority [40 CFR 122.41(j)].
Recording Results
For each measurement or sample taken pursuant to the requirements of this
General Permit, the permittee shall record the following information [40 CFR
122.41]:
• The date, exact place, and time of sampling or measurements;
• The individual(s) who performed the sampling or measurements;
• The date(s) analyses were performed;
• The individual(s) who performed the analyses;
• The analytical techniques or methods used; and
• The results of such analyses.
Flow Measurements
Where required, appropriate flow measurement devices and methods
consistent with accepted scientific practices shall be selected and used
to ensure the accuracy and reliability of measurements of the volume of
monitored discharges.
Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations

published pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting
Acts, and to regulations published pursuant to Section 304(g), 33 USC 1314, of the
Federal Water Pollution Control Act, as Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this General Permit, all test procedures
must produce minimum detection and reporting levels and all data generated must be
reported down to the minimum detection or lower reporting level of the procedure. If no
approved methods are determined capable of achieving minimum detection and
reporting levels below the General Permit discharge requirements, then the most
sensitive (method with the lowest possible detection and reporting level) approved
method must be used.
Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater
discharges that are required to be sampled, the permittee may petition the Director for
representative outfall status. If it is established that the stormwater discharges are
substantially identical and the permittee is granted representative outfall status, then
analytical sampling requirements may be performed at a reduced number of outfalls.
Records Retention
Visual monitoring shall be documented and records maintained at the facility along with
the Stormwater Pollution Prevention Plan (SPPP). Copies of analytical monitoring
results shall also be maintained on-site or be available electronically to a DEMLR
inspector upon request. The permittee shall retain records of all monitoring information,
including
• All calibration and maintenance records
• All original strip chart recordings for continuous monitoring instrumentation
• Copies of all reports required by this General Permit, including Discharge
Monitoring Reports (DMRs) and eDMR or other electronic DMR report
submissions
• Copies of all data used to complete the Notice of Intent to be covered by this
General Permit
These records or copies shall be maintained for a period of at least 5 years from the
date of the sample, measurement, report or Notice of Intent application. This period may
be extended by request of the Director at any time [40 CFR 122.41].
Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an
authorized contractor acting as a representative of the Director), or in the case of a
facility which discharges through a municipal separate storm sewer system, an
authorized representative of a municipal operator or the separate storm sewer system
receiving the discharge, upon the presentation of credentials and other documents as
may be required by law, to:
• Enter upon the permittee's premises where a regulated facility or
activity is located or conducted, or where records must be kept under
the conditions of this General Permit;

• Have access to and copy, at reasonable times, any records that must
be kept under the conditions of this General Permit;
• Inspect at reasonable times any facilities, equipment (including
monitoring and control equipment), practices, or operations regulated
or required under this General Permit; and
• Sample or monitor at reasonable times, for the purposes of assuring
permit compliance or as otherwise authorized by the Clean Water
Act, any substances or parameters at any location [40 CFR
122.41(i)].
Discharge Monitoring Reports
Samples analyzed in accordance with the terms of this General Permit shall be
recorded on Discharge Monitoring Report (DMR) forms provided by the Director or
submitted electronically to the appropriate authority using an approved electronic DMR
reporting system (e.g., eDMR). Annual Summary DMRs shall be delivered to the
Division (Central Office) no later than March 1 of each year (See 2. of this section).
In addition, any samples analyzed in accordance with the terms of this permit that
violate a wastewater effluent limit or exceed a stormwater benchmark value shall be
submitted to the Division Regional Office on a DMR form and delivered to the Division
Central Files no later than 30 days from the date the facility receives the sampling
results from the laboratory. DMR forms are available on the Division's website
(http://portal.nedenr.org/web/Ir/npdes-stormwater). Regardless of the submission
method (paper or electronic), submittals shall be delivered to the Division, or
appropriate authority, according to the provisions above.
When no discharge has occurred from the facility during the report period, the permittee
is required to submit a discharge monitoring report, within 30 days of the end of the
specified sampling period, giving all required information and indicating "NO FLOW" as
per NCAC T15A 02B .0506.
If the permittee monitors any pollutant more frequently than required by this General
Permit using test procedures approved under 40 CFR Part 136 and at a sampling
location specified in this General Permit or other appropriate instrument governing the
discharge, the results of such monitoring shall be included in the data submitted on the
DMR.
The permittee shall record the required qualitative monitoring observations on the SDO
Qualitative Monitoring Report form provided by the Division and shall retain the
completed forms on site. Qualitative monitoring results should not be submitted to the
Division, except upon DEMLR's specific requirement to do so. Qualitative Monitoring
Report forms are available at the website above.
Submitting Reports
Two signed copies of the Annual Summary Discharge Monitoring Report (DMR) shall be
submitted no later than March 1 of each year to DWR Central Files not DEMLR):

Central Files
Division of Water Resources
(DWR) 1617 Mail Service
Center
Raleigh, North Carolina 27699-1617
If wastewater monitoring results indicate a wastewater effluent limit violation, a
signed DMR form for that monitoring period shall be sent to the appropriate DEMLR
Regional Office (Attn: Stormwater Permitting Program) no later than 30 days from the
date the facility receives the sampling results from the laboratory.
If stormwater monitoring results indicate a stormwater benchmark value exceedance
or the facility is in Tier 2 monitoring, a signed DMR form for that monitoring period
shall be sent to the appropriate DEMLR Regional Office (Attn: Stormwater Permitting
Program) no later than 30 days from the date the facility receives the sampling
results from the laboratory. All stormwater outfall parameters shall be monitored and
reported for any monitoring period that the facility is following a Tier 2 response.
Addresses for each RO and the counties covered by each RO can be found here:
http://portal.ncdenr.org/web/guest/regional-offices. The permittee shall retain the
completed originals on site. Visual (Qualitative) monitoring results should not be
submitted to the Division unless specifically requested.
Blank DMR forms, Annual Summary DMR forms, and visual monitoring forms are
available at the website of the Division's Stormwater Permitting Program:
http://portal.ncdenr.om/web/ir/npdes-stormwater
The Permit Issuing Authority may require the permittee to begin reporting monitoring
data electronically during the term of this permit. The permittee may be required to use
North Carolina's eDMR internet application for that purpose. Until such time that the
state's eDMR application is compliant with EPA's Cross-Media Electronic Reporting
Regulation (CROMERR), permittees will be required to submit all discharge monitoring
data to the state electronically using eDMR and will be required to complete the eDMR
submission by printing, signing, and submitting one signed original and a copy of the
computer printed eDMR to the address above.
Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section
308 of the Federal Act, 33 USC 1318, all reports prepared in accordance with the terms
shall be available for public inspection at the offices of the Division. As required by the

Act, analytical data shall not be considered confidential. Knowingly making any false
statement on any such report may result in the imposition of criminal penalties as
provided for in NCGS 143-215.613 or in Section 309 of the Federal Act.
Non-Stormwater Discharges
If the storm event monitored in accordance with this General Permit coincides with a
non- stormwater discharge, the permittee shall separately monitor all parameters as
required under all other applicable discharge permits and provide this information with
the stormwater discharge monitoring report.
Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned
changes at the permitted facility which could significantly alter the nature or quantity of
pollutants discharged [40 CFR 122.41(1)]. This notification requirement includes
pollutants which are not specifically listed in the General Permit or subject to notification
requirements under 40 CFR Part 122.42 (a).
Anticipated Noncompliance
The permittee shall give advance notice to the Director of any planned changes at the
permitted facility which may result in noncompliance with the General Permit [40 CFR
122.41(1)(2)].
Spills
The permittee shall report to the local DEMLR Regional Office, within 24 hours, all
significant spills as defined in Part VI of this General Permit. Additionally, the permittee
shall report spills including:
• Any oil spill of 25 gallons or more, any spill regardless of amount that
causes a sheen on surface waters, any oil spill regardless of amount
occurring within 100 feet of surface waters, and any oil spill less than
25 gallons that cannot be cleaned up within 24 hours.
Bypass
Notice [40 CFR 122.41(m)(3)]:
• Anticipated bypass. If the permittee knows in advance of the need for a bypass, it
shall submit prior notice, if possible at least ten days before the date of the
bypass; including an evaluation of the anticipated quality and effect of the
bypass.
• Unanticipated bypass. The permittee shall submit notice within 24 hours of
becoming aware of an unanticipated bypass.
Twenty-four Hour Reporting
The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall

be provided orally within 24 hours from the time the permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its
causes; the period of noncompliance, including exact dates and times, and if the
noncompliance has not been corrected, the anticipated time compliance is expected to
continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of
the noncompliance [40 CFR 122.41(I)(6)].
• The Director may waive the written report on a case-by-case basis for reports
under this section if the oral report has been received within 24 hours.
• Occurrences outside normal business hours may also be reported to the
Division's Emergency Response personnel at [phone], [phone] or
[phone].
Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour
reporting at the time monitoring reports are submitted [40 CFR 122.41(1)(7)].
Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a
Notice of Intent to be covered under this General Permit, or submitted incorrect
information in that Notice of Intent application or in any report to the Director, it shall
promptly submit such facts or information [40 CFR 122.41(1)(8)].
DEWATERING METHOD
Water will be discharged to the nearby wetlands. Mining will begin towards the back of
the property and work its way to the front. Pump locations have been shown on the
plans.
Mine Area 1
• Place the portable pump at proposed location designated on the plans.
• Mine Area 3C
o Pump water into the existing wetlands
Mine Area 2
• Place the portable pump at proposed location designated on the plans.
• Mine Area 3B
o Pump water into the existing wetlands.
EROSION AND FLOOD PREVENTION
Silt fence will be installed along project boundaries and the haul road where wetlands
are immediately adjacent. Other measures will be implemented as deemed necessary.

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