20240617_ADI_Reply

CAROLINA GEOLOGICAL SERVICES, INC
June 14, 2024
Mr. Adam Parr
Mr. Corey Clayton RECEIVED
NCDEQ, DEMLR p2P
1612 Mail Service Center ,lfpy j 7 W24
Raleigh, NC 27699-1612
LAND Ty
Subject: Core Creek Mine South, Carteret County, ADI response MINING PROAGRAM
Dear Mr. Parr;
On behalf of Noah Simpson, NSN Investments LLC, I am writing in response to your May 23,
2024 letter requesting additional information on the above-referenced mining permit application.
I will respond to each item in the order of your letter for clarity.
1-The dewatering basin is a design from the NCDOT, and was suggested for use by your
department on similar projects. The design details and specifications were provided to me by
NCDEQ-DEMLR-Mining office, but I am attaching them for your reference. The size is based
on the maximum volume anticipated, since the actual pump has not yet been determined.
2. The perimeter berm is designed to be a simple diversion berm to contain any potential runoff
from the disturbed area, as is standard in most sand mines in this area. The berm is located
just within the perimeter of the mining limits. The line representing the berm on the mine map
therefore designates the mining limit and the location of the perimeter berm, since the location
of the berm is defined by the mining limit. With the width of the berm being approximately 18
feet, the width of the line would be less than 1-tenth of an inch. The line on the map is intended
to be a schematic representation of the berm. The berm detail gives the width information.
3. The "sediment basin" is actually a "dewatering basin", as per the NCDOT specification. The
berm around the mining area is a "perimeter' diversion berm, not a "screening berm". A
"screening berm" is intended to be of sufficient height to screen the operation from view, while a
"diversion berm" is intended to keep runoff within the mining area. The dewatering basin is
located on the edge of the mining area to minimize impact to potential mineral reserves. Since
the basin itself is constructed by a berm, the basin itself forms the perimeter berm of the mining
area. In other words, the perimeter berm is continuous in this area, with the dewatering basin
itself serving as the diversion berm, containing all runoff inside the mining area. A note has
been added to the mine map to clarify this.
4. As described above, the sides of the dewatering basin against the mining area also serve as
the diversion berm (not a "screening berm"). The outlet of the dewatering basin (not a
"sediment basin") is shown on the details of the basin by NCDOT.
5. As shown in the dewatering basin detail notes, the stone energy dissipator is specified in
NCDOT Standard Roadway Design 876.02. A copy of that design is attached.
PO Box 429, GARNER, NC 27529

page 2
Mr. Adam Parr and Mr. Corey Clayton
6. The Pumping Operation and Maintenance Plan was written specifically for this site in
consultation with the wetlands specialists that worked on this site. The purpose of the Plan is to
address any potential impact from dewatering on the adjacent wetlands. The Plan states that
the natural hydration of the wetlands at this location is from the seasonal flooding and influx of
surface water, and not from upwelling of groundwater, therefore, there should be no impact from
dewatering. The Plan requires quantifiable action in recording pumping times and volumes, as
well as specific inspections of the discharge outlet and the conditions of the wetlands. The
wetland vegetation is to be inspected at least quarterly, as this is the primary method for
determining any potential impact to the wetlands, especially since it was determined that the
hydration of the wetlands is from surface water inflow and not by upwelling of groundwater. A
statement has been added to this section of the O&M Plan that more clearly defines the
potential impact to the wetlands vegetation that should be noted. A further statement has been
added to the plan that specifies that if distressed wetland vegetation is observed, then a
wetlands specialist should be consulted to determine the specific cause. If the cause is
determined to be due to the dewatering activity, the pumping will be reduced or suspended until
the vegetation is recovered.
7. The acreage on the Mine Map was determined by precise measurement of the scaled map,
confirmed by GIS data. Note that all mining limit lines are parallel to the property lines, the
existing roadway, or the wetlands delineation line, so there are mappable data points that can
be used for calculating the acreage, as well as establishing the visible stakes that will be
required to mark the mining limit.
8. As required in most NC Mining Permits, the Mining Area will be clearly delineated by stakes
or posts visible from a distance. Note that all mining limit lines are parallel to the property lines,
the existing roadway, or the wetlands delineation line, so there are mappable data points that
can be used to establish the location of the stakes
We trust that this information will allow you to complete your review of this Mining Permit
application. Please let me know if you need any additional information.
Sincerely,
James Izzell
Carolina Geological Services, Inc.
enclosures

This PUMPING OPERATION AND MONITORING PLAN was prepared in
accordance with the requirements specified in the National Pollutant Discharge
Elimination System (NPDES) General Permit for Mining (NCG020), and specifically
as applied in the Certificate of Coverage for this location:
Core Creek South Mine
Certificate of Coverage
NCG020***
Mr. Ralph Thomas
Hardesty Loop Road
Newport, Carteret County, NC
June 14, 2024
This plan is designed to satisfy the requirements of Part G, Section b of the
NPDES General Permit NCG0200.

Background:
The NPDES General Stormwater Permit for Mining (NCG020000) addresses
impacts of mine dewatering wastewater pumping and discharge on surrounding areas,
including potential impacts to wetlands. The NPDES Permit requires that the mine have
a site specific plan for, 1) groundwater monitoring strategies to demonstrate the effect of
pumping and establish any pumping regime necessary to reduce potential impacts to
surrounding areas, and 2) detailed plans to maintain surrounding hydrology and
respective monitoring to demonstrate compliance.
In order to develop these plans, detailed studies must be done to understand the
site-specific parameters. First, any wetlands that may be potentially impacted must be
delineated according to US Army Corps of Engineers criteria. Second, a study of
potential impacts of groundwater levels must be conducted. This should include a
detailed examination of soil types, permeability, and various zones of groundwater within
the zone of influence. Third, based on the groundwater data, an assessment of potential
impacts to the wetlands by mine dewatering should be estimated. Finally, based on the
potential impact, a plan should be developed to limit as well as monitor the potential
impacts to the wetlands.
Site description:
The proposed Core Creek South Mine is located on Hardesty Loop Rd, north of
Beaufort, NC. It is located within the White Oak River basin. The mine excavation will
encompass 45 acres. Natural groundwater levels within the sand mine are within 5 feet
of the surface. The sand deposit being mined is a coastal deposit consisting of
sediments, ranging from a silty fine to medium grained sand. The excavation will be
reclaimed as a pond. The Mine Plan as submitted for the Mining Permit Application is
attached.
Wetland description:
The wetlands within the Core Creek Couth Mine project were delineated in 2023
as part of the mine permitting. The wetland area is confined to an area on the east side
of the property. This delineation was reviewed and approved by Mr. Thomas Charles, of
the US Army Corps of Engineers. Natural hydration of the wetlands is accomplished by
regular flooding, as well as natural surface drainage from rainfall. Hydration of the
wetlands does not appear to be directly connected to groundwater upwelling due to the
static groundwater level being at a lower elevation than the wetlands. The wetlands
have a clay layer in the soil that serves as an impermeable barrier, thus providing
additional protection from the influence of groundwater, and serving to enhance the
"perched"water from the inflow of surface water.
Pumping and mine dewatering:
This sand deposit is typical of other deposits in this area. The groundwater table
is several feet below the original ground surface, but above the total depth of the
excavation. Therefore, some groundwater will occasionally be pumped from the mining
area. Groundwater and stormwater will be collected within a large sump area in the
mined area. The dewatering pump intake floats on the surface of the collected water,
preventing any sediment from leaving the mining area. Water is then pumped to a

basin, where it is held until it occasionally overflows. The pond overflow flows into the
adjacent wetland. Based on the volume of the pump and projected water levels, it is
anticipated that a maximum of 1,500,000 gallons per day maximum will be pumped from
the pit.
Impact of dewatering on adjacent wetlands:
The wetlands that have been identified in the area of the borrow pit are confined
to the eastern site of the excavation. The hydration of the wetlands is accomplished by
surface water, rainwater runoff, and occasional flooding of the wetland area, and not
from the deeper groundwater found in the sand mine. Therefore, the mine dewatering
will have no impact on adjacent wetlands. In addition, the water that is pumped from the
mining area will directly discharge into wetlands on the same property. Therefore, the
dewatering activity will actually enhance the wetland environment, providing hydration
even during dry periods.
Monitoring:
Based on the observed disconnection between the water within the mining area
and the surrounding wetlands, it is anticipated that any potential dewatering at this mine
will have no impact on the adjacent wetlands. In order to confirm that there are no
impact to the wetlands, a monitoring plan should be established as a precaution.
1. Mine dewatering wastewater discharges should be quantitatively and qualitatively
monitored according to requirements of the NPDES permit. See the"Monitoring
Requirements" in the Stormwater Pollution Prevention Plan.
2. The Discharge Point should be examined weekly to make sure that it is functioning as
designed and that no sediment has discharged into the adjacent wetlands.
3. A written record shall be kept of pumping times and rates. A record of rainfall shall
also be kept in the Stormwater Pollution Prevention Plan.
5. The vegetation in the adjacent wetlands should be inspected at least quarterly. If any
vegetation appears to be distressed, an investigation should be conducted to determine
the cause. The indications of"distressed" vegetation may be a wilting or discoloration of
the leaves, stunted growth, or other obvious evidence that the vegetation is unhealthy.
The investigation of the wetlands should be conducted by a qualified wetlands specialist.
He should document the distressed vegetation and determine if the damage was caused
by natural regional conditions, or a site-specific issue. If the issue appears to be site-
specific, then the investigation should determine whether or not any lowering of the
groundwater table has affected the surface flow of the rehydration of the wetlands. If it is
conclusively shown that the dewatering of the pit and subsequent lowering of the
groundwater table has negatively impacted the wetlands, then the pumping should be
suspended until an alternative plan can be implemented to restore the wetlands.

Dewatering Basin Design *items in red are inputs
Version 2.27.09
The volume of the borrow pit dewatering basin will be based on a 2 hour retention time. Using
the formula V= 8.0203 * Q * It where, V is volume in cubic feet, Q is the pump rate in gallons per
minute (GPM), and t is the retention time in hours. The pump rate is not to exceed 1,000 GPM
(60,000 GPH .
STEP 1 : Input required variables The volume of the borrow pit dewatering
basin will be based on a 2 hour retention
Pump Rate: 1000 GPM time. The pump rate shall not exceed
Retention Time: 2 hours 1,000 GPM (60,000 GPH). The contractor
may desire a greater retention time for
Required Volume: 16040.E ft' managing turbidity; however, work
associated with this increased volume will
be considered incidental.
STEP 2: Design of the Dewatering Basin
Final Required Volume: 16040.6 ft'
Design Depth: 3 `not to exceed 3 feet
Proposed Basin Side Slopes: 1.5 :1 side slopes *must be at least 1.5:1 or flatter
OPTIONS
2:1 (L:W) 3:1 (L:IM
Suggested Top Width (ft): 52 43
Suggested Top Length ft : 104 129
Final Design Top Width ft : 56 46
Final Design Top Length ft : 112 138
Final Design Depth ft : 3 3
Verify Storage(ft3) 16629.00 16641.00
OK OK
The dewatering basin shall be designed in accordance with the Borrow Pit
Dewatering Basin Detail Drawing.
Comments:

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REVISIONS
5.5.08 Drafted the Spreadsheet
Did not release. Waiting on approval of device
2.9.09 Revised sheet to match Special Provision and Detail Drawing
Included the detail drawing
Revised the volume equation to take into account sideslopes
Did not release.Waiting on detail drawing revision.
2.27.09 Revised the Detail Drawing tab to include the most current detail drawing.
RELEASED ON 3/6/09

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ROY COOPER
Governor on�- �
ELIZABETH S.BISER
Secretary
WILLIAM E.TOBY VINSON,JR. NORTH CAROLINA
Interim Director Environmental Quality
May 23,2024
Certified Mail
Return Receipt Requested
7022 0410 0003 1066 6105
Noah Simpson
NSN Investments LLC
1507 Live Oak St, Suite A
Beaufort NC, 28516
RE: Core Creek South Mine
Carteret County
White Oak River Basin
Dear Mr. Simpson:
We have reviewed the application and additional information your company submitted for the referenced mine site.
In order for this office to complete its review of the referenced project in accordance with N.C.G.S. §74-50 and
§74-51 of the Mining Act of 1971, please provide the additional or revised information in accordance with the
following comments:
1. Please provide construction and maintenance details, including dimensions and pump size for the
sediment basin.
2. Your proposed perimeter berm with 3:1 slopes and a 3' height is a minimum of 18' wide and has not
adequately been represented on the mine map. Please clearly indicate and label on the mine map the
location of the screening berm.
3. The location of the sediment basin does not appear to be accurately represented in relation to the
proposed screening berm and silt fence. Please provide additional details on the location and interaction
of the sediment basin,screening berm and silt fence.
4. The sediment basin appears to discharge through the screening berm. Please provide additional details
on the discharge and outlet of the sediment basin.
5. Please provide construction and maintenance details for the stone energy dissipator on the discharge
leaving the sediment basin.
6. The Pumping Operating and Maintenance plan relies on general observation rather than quantified data
for action. Please provide additional details in the POM including data driven mitigation measures.
7. Please clarify how the acreage was determined on the mine map.
8. Please clarify how area labeled mining limit on the map will be accurately delineated on site.
Please note, this office may request additional information, not included in this letter, as the mining application
review progresses. Be advised that our review cannot be completed until all of the items listed above have been
fully addressed. r
D North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
LrJ�— 512 North Salisbury Street 11612 Mail Service Center I Raleigh North Carolina 27699-1612
919.707.9200

� 1
Certified Mail
7022 0410 0003 1066 6105
Page 2
In order to complete the processing of your application,please forward two(2)copies of the requested information
to my attention at the following address:
Division of Energy,Mineral and Land Resources
Department of Environmental Quality
1612 Mail Service Center
Raleigh,NC 27699-1612
If hand delivering or delivering by shipping company(e.g.,FedEx, UPS),please deliver to our physical address:
Division of Energy, Mineral,and Land Resources
Department of Environmental Quality
512 N. Salisbury Street, 5th Floor
Raleigh,NC 27604
As required by 15A NCAC 513.0113,you are hereby advised that you have 180 days from the date of your receipt
of this letter to submit all of the requested information. If you are unable to meet this deadline and wish to request
additional time,you must submit information,in writing,to the Director clearly indicating why the deadline cannot
be met and request that an extension of time be granted. If an extension of time is not granted, a decision will be
made to grant or deny the mining permit based upon the information currently in the Department's files at the end
of the 180-day period.
Though the preceding statement cites the maximum time limit for your response,we encourage you to provide the
additional information requested by this letter as soon as possible. Your prompt response will help us to complete
processing your application sooner.
Please contact me at(919)707-9228 if you have any questions.
Sincerely,
Cmj Clayloa
Corey Clayton
Assistant State Mining Engineer
cc: Samir Dumpor,PE