20240729_ADI_Reply_96-63

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ENGINEERING & ENVIRONMENTAL SCIENCE COMPANY
3008 ANDERSON DRIVE,SUITE 102
RALEIGH.NC 27609
[phone]
LETTER OF TRANSMITTAL
Date: July 26, 2024
To: NCDEQ-DEMLR
E .• p
1612 Mail Service Center JUL2
Raleigh,NC 27699-1612
From: T. Patrick Shillington,P.E. w iNING PROGKHrd..
Engineering and Environmental Science Company (EZS)
3008 Anderson Dr., Suite 102
Raleigh,NC 27609
Subject: Dunnie Hole Mine
Mining Permit Modification
Neuse River Basin
Submitted are two (2) copies of the revised mine maps/specifications, portions of the
mine application that have been modified, and evaluation for the above referenced
project. The revisions were based on the comments from NCDEQ-DEMLR in a letter
dated October 23, 2023. The following are responses to the review comments.
NCDEO-DEMLR Central Office
1. Mining has been indicated in the floodplain. Please provide proof of notice and
approval from the jurisdictional floodplain manager.
I have had difficulty finding the jurisdictional floodplain manager for this site. I
have called the county manager's office and the land development section of Wayne
County but did not receive a call back from them. I eventually called North
Carolina Association of Flood Plain Mangers and spoke to Ms. Erynk Futral
Eastern Branch. She indicated that I should talk to Barry Gray or Anthony Cape
with Wayne County,which I am trying to contact at this time.
It should be noted that the north side of the mine has been moved south away from
Contenina Creek and about 3/4 of the north side of the mine is outside of the 100
flood plain.

2. Please provide proof, such as a copy of the signed returned receipts for certified mail,
that all adjoining landowner and chief administrative officer of each county and
municipality have been properly notified.
Attached are the returned receipts from the certified mailings. Two of the
recipients did not sign the return receipts and two of the recipients may have not
received the letters although the addresses used were from the Wayne County Tax
Department.
3. The entrance haul road crosses the county line. Please be sure that you provide notice
to both the Wayne County chief administrative office and the Wilson County chief
administrative officer.
The return receipt for Wayne County is provided. We are waiting for the return
receipt for Wilson County.
4. Please provide proof that you have submitted your NOI for your NPDES Stormwater
permit.
Attached is the proof of submittal to the Stormwater Section
5. Please clarify the mining process. You've proposed that no mining below the water
table nor dewatering will occur. However, you've proposed reclaiming the site as a lake
once the mining is completed. Please clarify how you intend to maintain more than 4' of
water in the lake if mining below the water table is not to occur.
The attached Page 7 of the application has been changed to reflect excavation below
the water table. However, no dewatering will be conducted. Excavation will be with
an excavator that can reach an average depth of 25 ft. Groundwater is shallow and
several former excavations west of the site show shallow groundwater conditions.
6. Please provide additional details on the wetland disturbance Please provide proof of
correspondence with the USACE and approval for the disturbance.
Attached is proof of PCN submittal to USACE and NC Division of Water Resources.
ADDITIONAL COMMENTS:
The Wayne County GIS system indicated that the boundary with Wilson County is
further north than it actually should have been. After reviewing several information
sources, the boundary line was shifted south to the appropriate locations. The mining
activity and permit boundary were also shifted south outside of Wilson County. The
mine maps have been modified to reflect this change. Also the attached Pages 4 and 14
of the applications have been modified.
The shift also resulted in the mine being more than 1000 ft. from Contenina Creek at the
northwest corner of the mine and 140 ft. from the northeast corner of the mine. About 3/4
of the north mine boundary is outside of the 100 year flood limits to include the northeast
corner of the mine.
CIS