HomeMy WebLinkAboutAlamance Aggregates - Written Comments 3 Wehner, Jud
From: Miller, David
Sent: Tuesday, December 18, 2018 8:01 AM
To. Wehner,Judy
Subject: FW: [External] Written comment for 12/5 State Public Hearing
From: rsfexplorer[mailto:rsfexplorer@aol.com]
Sent: Monday, December 17,2018 12:55 PM
To: Miller, David<david.miller@ncdenr.gov>
Cc: nosnowcampmine@gmail.com
Subject: [External]Written comment for 12/5 State Public Hearing
My name is Ronald Saunders and I have been living at 1025 Clark rd S
ye now Camp NC 27349 for the past 2years. And I have all the same concerns that everyone has been talking about and oppose the mine. PLEASE
consider all of us!! Would you want to live next door to the mine?
this matter. Thank you for your time and consideration in
Sent from my Verizon, Samsung Galaxy smartphone
1
Wehner, Judy
From: Miller, David
Sent: Tuesday, December 18, 2018 8:03 AM
To: Wehner,Judy
Subject: FW: [External] Snowcamp Aggregate Mine
From: Hundley David USGR [mailto:david.hundley@syngenta.com]
Sent: Monday, December 17, 2018 11:49 AM
To: Miller, David<david.miller@ncdenr.gov>
Subject: [External] Snowcamp Aggregate Mine
CAUTION:
Dear Dr.Taylor,
I am deeply concerned about the proposed crushed stone mine that is within 1 mile of my home. Having worked for the
EPA,with a degree in Environmental Health, I know that the threat of air and water contamination in the surrounding
_ area is real.This project should not be approved. Had Alamance County been open and transparent about the site,we
would not be at this point. We depend on the State to keep us safe.
[, personally,suffer from asthma. It is well documented that a mine of this type releases small particulates that area
risk to respiratory systems. The reason we built in a pastoral area was for my health.
We have just dug a 365 ft.well as our water source and have had it tested twice to assure that the water is safe. We
also share a 30 acre lake with neighbors that is clear and clean. Who will be responsible for compromised and polluted
water if this mine is allowed to operate?
There is no upside to this project except to a company out West. A heavy industrial business in the middle-and I don't
mean that metaphorically-of a rural residential area is reckless. This mine belongs in an industrial area.
Please do not approve this site for mining.
Regards,
Tina Sutton Hundley
837 Soapstone Trail
Snow camp, NC
This message may contain confidential information. If you are not the designated recipient,please notify the sender immediately,and delete the original and any
copies.Any use of the message by you is prohibited.
1
Wehner, Jud
From: Miller, David
Sent: Tuesday, December 18, 2018 7:32 AM
To: Wehner,Judy
Subject: FW: [External] Written comment for 12/5 State Public Hearing
From:Shivon Eck[mailto:noelseck86@gmail.com]
Sent: Monday, December 17,2018 2:07 PM
To: Miller, David<david.miller@ncdenr.gov>
Subject: [External] Written comment for 12/5 State Public Hearing
L9.111"MILI
Dr. Kenneth Taylor-DEQ
Good Aftemoon,
I am emailing to address specific concerns in regards to the Snow Camp Mine. I live on 7.5 acres 1.2 miles
from the proposed mine site. For the following reasons, I am against the Snow Camp mine:
1)I own and operate i USDA licensed wildlife rescue facility at this location and my USDA inspector as well
as my attending veterinarian have expressed their concerns for the safety of the animals residing at Wild Tails,
LLC. Birds have highly sensitive respiratory systems and among the animals I care for are grazers, which
would be ingesting any pollutants traveling from the mine site.
2) The historic Holman Mill ruins and dam are on my property. My home and animal facilities are downstream
from the dam, which already is compromised and not stable. A third of my property flooded in both
great concern for this reason. In addition,the stone and brick walls are leaning and no Hurricanes and again in the heavy rain we received in November. The operation's enormous water usage is a
within such close proximity is a threat to the stability of these ruins. t reinforced so blasting
3) With the elementary school within a mile and half, our children will be subjected to the air and water
Pollution produced by this operation. It is unbelievable that an operation such as this would be allowed so close
to the Colonial Pipeline and an elementary school.
Thank you for taking our concerns into careful consideration. Please do not allow this mine to threaten and
compromise the safety of this community.
Regards,
Shivon Eck
t
Wehner, Judy
From: Miller, David
Sent: Tuesday, December 18, 2018 7:30 AM
To: Wehner,Judy
Subject: FW: [External] Written comment for 12/5 State Public Hearing
From: Gail Pedersen [mailto:gailpedersen489@gmail.com]
Sent: Monday, December 17,2018 3:06 PM
To: Miller, David <d avid.miller@ncdenr.gov>
Subject: [External] Written comment for 12/5 State Public Hearing
Report
Dr. Kenneth Taylor-DEQ
Dear Sir:
As a resident of the Snowcamp Community, I am terrified of the possibility of having a Stone Quarry right up the road from where we
live. I live on Quakenbush Road and have been for the last 15 years. I've seen this community grow in leaps and bounds with positive
things to offer;community gardens, bee hives,fields of wild sunflowers and the birth of our grandchildren. We chose Snowcamp to live
over 15 years ago relocating from upstate New York to this beautiful,quiet, country place.
Having the quarry mine in our community will eventually destroy us. Destroy my grandchildren hopes and dreams of living in our house
that will be riddled with cancer-causing dust,well water that may be tainted with mud and all sorts of harmful minerals, or no well water
at all.
I often ask if you lived here would you want your precious children,wife, husband, grandchildren to be subjected to the noise,dust,
airborne carcinogens? I would say not! Why are we letting some money hungry company that can't even be traced back to the real
owners come in and take what we have worked so hard for?Why should they,the mining company,take our farmers livelihood,
generations of history and pride from our community.
All I want for Christmas is to live in harmony with our environment and to enjoy my grandchildren running and playing free without the
threat of some disease caused by that mine.
Sincerely
Bruce and Gail Pedersen
1
Wehner, Judy
From: Miller, David
Sent: Tuesday, December 18,2018 7:29 AM
To: Wehner,Judy
Subject: FW: [External] Written Comments for 12/5 State Public Hearing
Attachments: Ltr to Dr. Kenneth Taylor 121418.docx, Norman Jackson Ltr 121418.docx
From:Stephanie Thurman [mailto:steph.thurman59@gmail.com]
Sent: Monday, December 17, 2018 3:14 PM
To: Miller, David <david.miller@ncdenr.gov>
Subject: [External] Written Comments for 12/5 State Public Hearing
Dear Mr. Miller,
Attached are electronic copies of a letter from me and one from my neighbor. These were mailed together in the
same priority envelope on Friday. Just in case the envelope arrives after 5pm today, I wanted you to have these
on time albeit unsigned but signed ones are on they way. Thank you so much.
i
ANDY & STEPHANIE THURMAN
149 CLARK ROAD
SNOW CAMP,NC 27349
December 14, 2018
Dr. Kenneth Taylor
NC Department of Environmental Quality
1612 Mail Service Center
Raleigh, NC 27699-1612
Dear Dr. Taylor:
Per your letter dated November 20, 2018, 1 am writing to report a violation by Alamance
Aggregates, LLC with regard to their mining application and the 1,000 feet parameter for
landowner notification as required by Article 7.(b1)(b2) of The Mining Act of 1971 § 74-
50, Permits—General. My husband Andy and I reside at 149 Clark Road, Parcel ID 102696, in
Snow Camp which is approximately 650 feet, corner to corner,from the property owned by
Snow Camp Property Investments, LLC. We did not receive a certified letter notifying us of the
proposed mining operation which is a violation of the The Mining Act's requirement and is a
criteria for denying this mining permit.
I would also like to specifically address the actual notification letter referenced above that Chad
Threatt mailed to adjacent landowners in early October 2018, and how the letters' content is a
violation of the Act (reminder that our names were not on the list that Mr.Threatt provided
with the application packet. It is my understanding that all letters were identical and highly
unprofessional: no letterhead, no signature, cryptic and poorly composed. I obtained the
enclosed copy of this letter from a neighbor whose name was on the list). The letters'flatly
stated that "This operation will have no impact on your property in any way". This is
completely untrue when studies and research prove that mining quarries like the one proposed
by Alamance Aggregates LLC, do impact adjacent properties and the environment in a plethora
of ways. No one can predict exactly when, exactly where or to whom, but the Mining Act does
not require that, it only requires that we submit information to reinforce and support our
position that it will, and we have sufficiently done so. Our opposition to this operation is
warranted and justified and to diminish our anxiety over the risks involved, and to dismiss our
concerns without a comprehensive analysis of the issues that includes a thorough and
comprehensive review of Alamance Aggregates, LLC, would be irresponsible and reckless.
Unless Chad Threatt has a crystal ball and knows something that the scientists do not, or unless
he and his anonymous colleagues are geniuses who have discovered how to defy the third law
of physics that for every action there is an opposite and equal reaction,then the content of Mr.
Threatt's letter is deceptively misleading and completely untrue. Dishonesty and deception
desecrate the very core of not being in substantial compliance with the Act, another criteria for
denial of this permit.
Quite frankly, the entire business structure of Alamance Aggregates, LLC is sketchy. Exactly
who owns this company and where is their office? Do they have experience in operating a
crushed stone quarry? If so, will their operation utilize the highest level of industry standards
and will they adhere to established best practices? Can they provide references who will attest
to the quality of their work, their integrity and level of customer service? These are critical
questions to which the State of North Carolina should seek answers because Alamance
Aggregates LLC wants to work/conduct business in Alamance County, and should be required to
pass a comprehensive background check. There is too much risk involved in permitting a quarry
on this site to not complete what should be a fundamental part of this process.
I also want to point out that Article 7.(b1)(b3) of the Act requires/requests that various State
agencies review the application and submit a written response to their review within 30 days
from the date of the request. Mr. Eric Galamb, Application Review Coordinator for the Division
of Soil &Water Conservation, received this review request from Brenda Harris in a memo dated
October 1, 2018, however, no response was received from this agency by the requested date.
This is also a violation of the Act and one that has resulted in the absence of critical information
related to water and soil conservation with regard to this application/operation.
Every resident in Snow Camp lives quite well off well-water therefore we are very concerned
that the proposed operation will have unwarranted and unjustified adverse effects on potable
water supplies. Another question is who will be responsible for monitoring the water levels in
our wells? And who will monitor this monitoring? Risk of contamination to surface water and
groundwater supplies are proven hazards around quarries like the one being proposed, as is
continued exposure to toxic airborne particulate matter emitting from the site. It is important
to know who will be held accountable for these requirements in order to keep us safe. The
proposed operation will undoubtedly disrdpt and displace many species of wildlife once again
and expose them and their environment to harmful toxins (reminder that wildlife was recently
displaced due to the construction of the solar farm, and we are still dealing with storm water
runoff/erosion/standing water issues on our property from this project). The trauma that the
proposed operation would inflict upon our community will be intrusive and unhealthy, and has
the potential to impact generations of residents.
There are simply too many risks associated with utilizing this property for a mining operation.
The close proximity of Sylvan School to the Colonial Pipeline and the proximity of the Pipeline
to the operation's blasting area present a substantial potential physical hazard to the School
and the safety of 350 faculty, staff and students who occupy the campus on any given school
day. The Sylvan Community Health Center is also located on the School's campus and is the
community's only medical facility.
Approximately 40 years ago, a friend was taking flight lessons and I tagged along on one of his
sessions with him and his instructor. We departed from Causey Airport in Liberty, NC, and one
of the prominent natural landmarks that these two pilots used as a reference point was Major
Hill which is located in close proximity to the proposed mining site. If flight instructors/pilots
from any airport still utilize Major Hill as a reference, how will daily dynamite blasts affect the
air space above the blasting site for small planes flying at low altitudes?This is a question that
warrants an answer.
Lastly, I want to address the reclamation plan and the proposed recreational lake that will be
the end result when the mining operation ceases. Abandoned quarries/lakes typically become
remote havens for trespassers, bad behavior, littering and accidental drownings much like the
Soapstone Trail Lake was when we first moved to Snow Camp. The scenario for another
unmonitored abandoned quarry/ recreational area will be the exact same and may be
perceived as a hazardous public nuisance by some nearby residents.
In closing, I am extremely grateful to everyone in the community who has been working so
diligently to gather relevant facts and information, and I appreciate the opportunity to provide
these comments. We moved here in 1991 because of the land and the culture of the area. It fit
well with our lifestyle and our love of nature, animals and the outdoors. I never imagined that
almost 30 years later our six acres could become sandwiched between two heavy industrial
developments—both products of the same, somewhat outdated, county ordinance, and their
close proximity to one another is not balanced or fair to residents. This is not judicious planning
—it appears that no planning or thought went into this decision whatsoever, and if the County
planning director looked at the proposed quarry site on the Alamance GIS map when this
application was received, he/she would have immediately seen that the proposed site is across
the road from a 40-acre solar farm. This alone should have facilitated further consideration
with regard to judicious placement and balance. However,the Alamance GIS, the site to which
users are directed from Alamance County's homepage, is not a current representation of
existing parcels and does not show the solar farm at all. This is unacceptable considering that
the solar farm was completed almost three years ago and its absence from this aerial view may
have contributed to what appears to have been a hasty, uninformed and haphazard decision by
a single person. As a citizen and taxpayer,this is unacceptable.
Regardless, Alamance County assumes no responsibility for errors on the GIS mapping (as
stated in their disclaimer) but this is a significant omission and may be a contributing factor to
this situation. This application/operation is littered with red flags beginning with the credibility
of Alamance Aggregates LLC, and the citizens of this rural community are worried. I sincerely
hope that the State will carefully and thoughtfully consider the validity and legitimacy of our
concerns as they relate to water supply and air quality, our safety, environmental protection,
and the general welfare and future stability of this community.
Sincerely,
Stephanie J. Thurman
Enclosure: Chad Threatt notification letter
Norman Jackson, Jr.
262 Clark Road
Snow Camp, NC 27349
To Whom It May Concern:
I am a concerned resident of Snow Camp, NC. I live adjacent to the proposed quarry
on Clark Road. I received a letter from Alamance Aggregates LLC the first week of
October 2018, informing me that they had applied for a State Mining Permit. It was
quite a shock to learn that Alamance County had already approved their plan.
From what I understand through some quick research is the fact that this company is an
LLC, based out of Wyoming. And some of the major partners involved with the
company have been less than honest in the past.
The possibility of all that can go wrong with mining a quarry should be enough to stop it
now and ask why should they be allowed to continue?
I could repeat all the reasons for not allowing the proposed quarry to become a reality
but will only reiterate a couple of major concerns:
1. The water in the ground in the area on which we all depend is at risk. There is
only so much fresh water in the world.
2. The retaining /sediment pond that they plan to build will only have a 200,000
gallon capacity when they will be pumping as much as 500,000 gallons out daily
and the sediment pond could be drained when they deem necessary. So the suff
they are trying to retain could end up in the Haw River and beyond.
This matter depends on you and the State of North Carolina to carefully consider.
Please do not make a decision that you may later regret. Think of the future of our
earth. Good planets are hard to find.
Best regards,
Norman Jackson, Jr.
Wehner, Judy
From: Miller, David
Sent: Tuesday, December 18, 2018 7:23 AM
To: Wehner,Judy
Subject: FW: [External] No Snow Camp Mine
-----Original Message----
From: Nancy Steelman [mailto:nabosteelman@aol.comj
Sent: Monday, December 17, 2018 4:25 PM
To: Miller, David<david.miller@ncdenr.gov>
Subject: [External] No Snow Camp Mine
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to Report Spa m.<mailto:report.spam@nc.gov>
As a concerned resident of the area I attended the meeting at Sylvan. We are concerned for our air quality,water
quality and frankly the amount of water they would use making wells go dry. Contamination of wells and fields from
flooding on people and live stock are a concern. The air quality around the school children is also very concerning. We
live with the Colonial Pipeline running across our property. Blasting close to the pipeline is not a good idea. There is
absolutely nothing good that can be gained from this other than making a few people rich while impacting the livelihood
of community business and health.
Nancy Steelman
Sent from my iPad
t
Wehner, Judy
From: Miller, David
Sent: Tuesday, December 18,2018 7:22 AM
To: Wehner,Judy
Subject: FW: [External] Snow Camp gravel mine
From: Megan Totten [mailto:mltotten3@gmail.com]
Sent: Monday, December 17, 2018 8:19 PM
To: Miller, David<david.miller@ncdenr.gov>
Subject: [External]Snow Camp gravel mine
Wag 11610
Dr. Kenneth Taylor,
I attended the public hearing regarding the proposed Snow Camp gravel mine on December 5th,2018 at Sylvan
Elementary. I would like to also express my concerns of what the proposed mine will do to our community. In
regards to The Mining Act of 1971, this specific proposal raises red flags to criteria numbers 2, 3, and 4.
2) The land in which the mine would be blasting, includes or runs in close proximity to various ponds and
creeks. Wildlife in our area would be harshly affected.
3) There are major concerns as to how the mine will impact our community's water table, and concerns of
homes' wells cunning dry. Who would be responsible
Who would hold them accountable? for our wells; would Alamance Aggregrate be liable?
4) Sylvan Elementary is in alarmingly close proximity to the proposed site. Has there been an evaluation as to
how this mine will affect the air quality for our students and teachers? There is a clini
health care providers in our areac attached to Sylvan
Elementary, which serves and a great asset to our community, as there are no other available immediate
. How will this mine impact the clean water and clean air that is vital to the
clinic's everyday operation?
We ask that our community's concerns be heard and addressed. Thank you very much for your time and
attention to this matter.
Regards,
Megan Stanfield
t
Wehner Judy
From: Piazza, Mark <mpiazza@colpipe.com>
Sent: Monday, December 17,2018 5.43 PM
To: Wehner,Judy
Cc: Langley, Denise (Johnson); Smith, Brian L.,West,Tom; Little, Chip
Subject: [External] Comments on Mining Permit Application -Alamance Aggregates LLC, Snow
Camp, NC
Attachments: CPC Comments on Mining Permit Application Final.pdf
Ms.Wehner,
Thanks for taking time to speak with me today. Attached to this message are comments from Colonial Pipeline
Company on the Alamance Aggregates LLC permit application to operate a crushed stone mine in Snow camp.
NC. Please contact me with any questions.
a
Mark Piazza
Colonial Pipeline Company—Pipeline Compliance
678 762 2531—office
678 763 5911—cell
1
December 5,2018
To Whom It May Concern,
I own property that backs up to Alamance Aggregates properties on at least two sides. So I fill
my voice should be heard. Growing up in the 60's and 70's I lived off Highway 421 in
Greensboro outside of Martin Marietta Mine. This mine is back toward South East High School.
We used to climb up to the top of the side as kids and watch them work. Besides the noise from
blasts there was truck noise and it stayed very dusty. When I was a young girl we lived on a
gravel road and had to have it oiled a few times a year to keep the dust down. I'm aware that
this procedure would not be allowed now, but my point is it didn't help with the rock dust. The
problem I have with the quarry is the air quality. My mom is in her 80's and already has trouble
breathing. Now, after researching on my own, I understand the rock dust has been proven to
cause silicosis. This is a progressive incurable lung disease. Long term exposure to particle
matter is strongly associated with heart disease, stroke, infertility and pregnancy complications.
As I grew older I had bronchitis frequently until I graduated high school and moved from the
area. My own daughter learned to walk in a hospital because she was born with asthmatic
problems from birth, and was in and out of the hospital for most of her first two years of life with
breathing problems. Who's to say that didn't stem from my exposure in childhood.
Studies done in other areas of the country show some mines have samples containing 3% of
asbestos and up to 37% of silica. Both of these substances are known to cause cancer. I am a
cancer survivor and would not wish that on my worst enemy!Are the Alamance Aggregates
prepared to put up 20m high poles to monitor pm10 dust rising vertically into the atmosphere by
being uplifted on the air thermal created above the quarry due to the effect of sunlight hitting the
exposed rock?Are they willing to pay for these procedures up front? This information was made
public in Arizona after these procedures had to be taken because of sickness.
I called the office of the aggregates and received a call back from Mr. Chad Theatt. He could not
directly tell me anything other than they had done all polimanary testing in order to file to
become a Mine. He said that Ike Powell with Cybernetics had done the testing about 6 months
ago but could not give me exact dates. He also said Chris Rhienhart with Hydro Geologist out of
Raleigh, NC had done the water study, and blasting survey to receive the mining permits
probably back in September. He could not tell me if the blasting had taken place on the land
here in Snow Camp, NC. I asked about the rock dust and he assured me they would wet down
all rock leaving the quarry before getting on the open road. I asked where that water would
come from? The 500,000 gallons we had heard they would be pulling out of the ground daily
and he said that he had misspoke when he said that. He said they would take out 40 to 50
thousand gallons from the 3 ponds on site. I asked if there were already 3 ponds and he said
no,just one, but they would be building more. He preceded to say they could use dirty water to
wash the rock. This left more speculation as to where said water would come from and if the
neighboring wells would suffer, Mr. Theatt assured me they would not.
Wehner, Judy
From: Miller, David
Sent: Tuesday, December 18, 2018 8:10 AM
To: Wehner, Judy
Subject: FW: [External] Snow Camp Mine/written comment for 12/5 State Public Hearing
Attachments: Snow Camp Mine.pdf
From: Debbie Sanders [mailto:dpsanders57@gmail.com]
Sent: Sunday, December 16, 201811:26 PM
To: Miller, David <david.miller@ncdenr.gov>
Subject: [External] Snow Camp Mine/written comment for 12/5 State Public Hearing
CAUTION: External email.Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to Report Spam.<mailto:report.spam nc.gov>
Sent from my Whone
1
Ver,Judy
From: Miller, David
Sent: Tuesday, December 18,2018 8:11 AM
To: Wehner,Judy
Subject: FW: [External] Written comment for 12/5 State Public Hearing
From: S WOolfe [mailto:swoolfe44@gmail.com]
Sent: Sunday, December 16, 2018 7:53 PM
To:Miller,David<david.miller@ncdenr.gov>
Subject: [External] Written comment for 12/5 State Public Hearing
Report Span;
To Dr.Kenneth Taylor, NC DEQ:
My husband and I would like to express our opposition to the permit for a gravel mine on Clark Road in Snow
Camp,NC.
We own a small horse farm in Snow Camp, NC on Mike Lindley Rd- our farm is approximately 2.5 miles from
the proposed gravel mine. We are extremely concerned about the environmental impacts of the potential mine-
we depend on a well for water here and are worried that the gravel mine will damage the local aquafer with
blasting and the expected de-watering process. We are also concerned about degradation of our air quality, a
massive increase in local industrial traffic, and serious negative impacts on our property value. Snow Camp is a
quiet residential and farming community- and all of us depend on clean well water for drinking and managing
our animals; cows, horses, goats, chickens, and sheep. This community produces beef, dairy products, eggs,
poultry, and lamb -all of which are high quality and enjoyed by North Carolinians. One of my neighbors
manages a herd of 250 goats who produce milk daily for goat cheese products. I have neighbors who make wine
too -Wolf Winery is only a mile from the proposed mine. Protecting water quality for our community should be
enough to halt this mine, but there are so many other reasons this mine does not belong in Snow Camp. The
proposed mine will be located only a mile and a half from an elementary school. The proposed mine has a
major gas pipeline crossing the very tract of land the mine will be located on-blasting in proximity to the gas
line puts the whole community,not to mention mine works in jeopardy. There's a myriad of questions regarding
air quality degradation resulting from operating a mine of this type. Daily blasting will damage nearby wells,
and home foundations,not to mention our quiet and peaceful enjoyment of our countryside. Snow Camp
already deals with heavy truck traffic from timber trucks,milk tankers, chicken trucks, hog trucks, and cattle
trucks - adding heavy trucks carrying gravel is more than our rural roads can withstand. There are questions
regarding the integrity of the owners of the mining company that have not been answered, there are
environmental and community impact studies that have not been conducted, and there's a whole community of
land owners who are opposed to this kind of heavy industrial activity happening next door.
My husband and I sincerely hope the Dept. of Environmental Quality will prevail where Alamance County
failed and do the right thing by the community of Snow Camp -please do everything to protect our water, air,
homes, and us, from harm.
Sincerely,
i
Personally, I cannot see how dumping half a million gallons a day of contaminated water into
Cane Creek can possibly be construed as giving"special management'to these endangered
species and the waters in which they live.
I hope you will take these concerns into consideration, and deny permitting for the proposed
quarry.
Respectfully,
Jason Dowdle
6067 Hoagie Creek Lane
Snow Camp NC 27349
December 16,2018
Snow Camp, North Carolina
Dr. Kenneth Taylor
Department of Environmental Quality
Raleigh,North Carolina
Dear sir,
I am writing to you a second letter about a very specific area of interest concerning the proposed
crushed stone quarry in Snow Camp, in southern Alamance County.
The plans for the proposed quarry state that the de-watering of the quarry site will produce
something like 500,000 gallons of water a day,which will be dumped into either or both of two
creeks, Cane Creek, and its tributary, Reedy Branch.
Both Cane Creek and Reedy Branch are highly vulnerable streams with fragile ecosystems.
Cane Creek has stretches that have returned to a nearly wild state and are home to diverse
wildlife including kingfishers and bald eagles. In addition, both streams have areas which
constitute wetlands. Both the streams and the wetlands are of special concern to the Army Corps
of Engineers,whose mandate is to protect streams and wetlands.
According to residents of the area,their wells often have significant amounts of metals in the
water,including copper, iron and manganese, which are not present in the surface water. It is my
expectation that the water from the quarry will also contain these same metals in addition to
other harmful contaminants such as powdered silica. When dumped into these streams in the
proposed quantity, it can only be expected that the overall water quality in these streams will be
substantially affected.
In addition to the general harmful effects on the stream's overall ecosystems,there are several
varieties of mussel which live in these streams and their tributaries. As you may know, all
species of mussel in the state have faced severe habitat loss. Many survive only in tiny fractions
of their original range. And all species of mussel in the state are listed by the North Carolina
Wildlife Resources Commission as State Special Concern, State Endangered, or Federal and
State Endangered.
There are at least four species of mussel which will be specifically endangered by pollution from
this project:
Eastern Creekshell, Villosa delumbis, in Cane Creek, State Endangered
Notched Rainbow, Villosa constricta, in Cane Creek, State Special Concern
Atlantic Pigtoe,Fusconaia masoni, in the Haw River, State Endangered
Brook Floater,Alasmidonta varicosa, in the Haw River, State Endangered
According to the NC WRC, for these mussels they state, "All headwater areas that flow into
these occupied habitats should receive special management."
state aj'e�hsted by the North Carolina Wildlife Resources Commission as State Special Concern, State
Endangered, or Federal and State Endangered.
There are at least four species of mussel which will be specifically endangered by pollution from this project.
Eastern Creekshell, Villosa delumbis, in Cane Creek, State Endangered
Notched Rainbow, Mom conAtrida, in Cane Creek, State Special Concern
Atlantic Pigtoe, Fusconaia masons;in the Haw River, State Endangered
Brook Floater,Alasmidonta uasicosa, in the Haw River, State Endangered
According to the NCWRC, for these mussels they state, "All headwater areas that flow into these occupied
habitats should receive special management"
Personally, I cannot see how dumping half a million gallons a day of contaminated water into Cane Creek can
possibly be construed as giving"special management" to these endangered species and the waters in which they
live.
I hope you will take these concerns into consideration, and deny permitting for the proposed quarry.
Respectfully,
Jason Dowdle
6067 Hoagie Creek Lane
Snow Camp NC 27349
z
Wehner, Judy
From: Miller, David
Sent: Tuesday, December 18, 2018 8:11 AM
To: Wehner,Judy
Subject: FW: [External] Snow Camp Quarry
Attachments: Second Quarry Letter.docx
From:Jason Dowdle [mailto:jason@ncartphotographer.com]
Sent:Sunday, December 16, 2018 3:37 PM
To: Miller, David <david.miller@ncdenr.gov>
Subject: [External] Snow Camp Quarry
Report
December 16, 2018
Snow Camp, North Carolina
Dr. Kenneth Taylor
Department of Environmental Quality
Raleigh, North Carolina
Dear sir,
I am writing to you a second letter about a very specific area of interest concerning the proposed crushed stone
quarry in Snow Camp, in southern Alamance County.
The plans for the proposed quarry state that the de-watering of the quarry site will produce something like
500,000 gallons of water a day, which will be dumped into either or both of two creeks, Cane Creek, and its
tributary, Reedy Branch.
Both Cane Creek and Reedy Branch are highly vulnerable streams with fragile ecosystems. Cane Creek has
stretches that have returned to a nearly wild state and are home to diverse wildlife including kingfishers and bald
eagles. In addition, both streams have areas which constitute wetlands. Both the streams and the wetlands are of
special concern to the Army Corps of Engineers, whose mandate is to protect streams and wetlands.
According to residents of the area, their wells often have significant amounts of metals in die water, including
copper, iron and manganese, which are not present in the surface water. It is my expectation that the water from
the quarry will also contain these swine metals in addition to other harmful contaminants such as powdered
silica. When dumped into these streams in the proposed quantity, it can only be expected that the overall water
quality in these streams will be substantially affected.
In addition to the general harmful effects on the stream's overall ecosystems, there are several varieties of mussel
which live in these streams and their tributaries. As you may know, all species of mussel in the state have faced
severe habitat loss. Many survive only in tiny fractions of their original range. And all species of mussel in the
1
Wehner, Jiddy
From: Miller, David
Sent: Tuesday, December 18, 2018 8:12 AM
To: Wehner, Judy
Subject: FW: [External] Dr. Kenneth Taylor-DEQ -Written comment for 12/5 State Public Hearing
From: Susan Abernethy [mailto:sgabernethy@gmail.com]
Sent:Sunday, December 16,2018 8:54 AM
To: Miller, David <david.miller@ncdenr.gov>; NoSnow CampMine<nosnowcampmine@gmail.com>
Subject: [External] Dr. Kenneth Taylor-DEQ-Written comment for 12/5 State Public Hearing
CAUTION:
Report Spam.
As land owners with property very close to the proposed site, we are quite concerned with several issues.
1. Impact on the aquifer level and water quality- all residents are dependent on well water, as you know. The
very nature of the retrieval of stone beneath the water level makes this process catastrophic to the many people
who are dependent on this aquifer to live.
2. Destruction of air quality- this mining operation can introduce carcinogenic dust which can be carried by the
wind for miles. Even without the cancer-causing element,the dust itself is problematic for those of us with
pulmonary challenges.
3. Constant noise pollution. There will be frequent blasting, and constant operation of noisy grinding
machinery.
4. Interference with the gas line that runs through this property
5. Possible impact on the earth dam shared by all the land owners Soapstone Homeowners Association.
The potential economic benefits of the mine are minimal for Alamance County, especially considering that
ownership is based in Wyoming, compared to the certain disastrous consequences. Please help us stop this.
Susan Abernethy and Dennis Rasmussen
Paul Rasmussen and Ashley Beavers
1142 Soapstone Trail
Snow Camp,NC
Mailing address:
423 West Davis Street
Burlington NC 27215
336-214-1668
At f) Virus-free. www.avast.com
1
Wehaer, Judy
From: Miller, David
Sent: Tuesday, December 18, 2018 8:12 AM
To: Wehner,Judy
Subject: FW: [External] Written comment for 12/5 State Public Hearing
From:Susan Abernethy [mailto:sgabernethy@gmail.com]
Sent:Sunday, December 16, 2018 8:52 AM
To: Miller, David <david.miller@ncdenr.gov>
Subject: [External] Written comment for 12/5 State Public Hearing
-tt Spam.
• p.
As land owners with property very close to the proposed site,we are quite concerned with several issues.
1. Impact on the aquifer level and water quality- all residents are dependent on well water, as you know. The
very nature of the retrieval of stone beneath the water level makes this process catastrophic to the many people
who are dependent on this aquifer to live.
2. Destruction of air quality-this mining operation can introduce carcinogenic dust which can be carried by the
wind for miles. Even without the cancer-causing element, the dust itself is problematic for those of us with
pulmonary challenges.
3. Constant noise pollution. There will be frequent blasting, and constant operation of noisy grinding
machinery.
4. Interference with the gas line that runs through this property
5. Possible impact on the earth dam shared by all the land owners Soapstone Homeowners Association.
The potential economic benefits of the mine are minimal for Alamance County, especially considering that
ownership is based in Wyoming, compared to the certain disastrous consequences. Please help us stop this.
Susan Abernethy and Dennis Rasmussen
Paul Rasmussen and Ashley Beavers
1142 Soapstone Trail
Snow Camp,NC
Mailing address:
423 West Davis Street
Burlington NC 27215
336-214-1668
Ante Virus-free. www.avast.com
1
For those whom do not lose water will there be contaminants introduced to their water vein? A contaminated
vein would not only affect the local communities but people in other communities that have no idea this is even
going on in Snow Camp. I can not see how long tern health effects would not be inevitable.
I personally have already been involved in an accident with a logging truck here in Snow Camp
because he was speeding. Truckers make money by the loads they haul,the more loads the more
money. These roads will turn into raceways for these truck drivers.
Thank you for hearing our concerns.
Please help Snow Camp.
Kirk and Dixie Adams
Snow Camp Residents for 12 years. Approximately 3 miles from proposed site.
Sent from my Whone
2
Wehner, Judy
From: Miller, David
Sent: Tuesday, December 18, 2018 8:14 AM
To: Wehner,Judy
Subject: FW: [External] Dr. Kenneth Taylor-DEQ - No Crushed Stone Quarry in Snow Camp NC
From: Kirk [mailto:kirkndixie@aol.com]
Sent:Saturday, December 15,2018 8:25 PM
To: Miller, David <david.miller@ncdenr.gov>
Cc: nosnowcampmine@gmail.com
Subject: [External] Dr. Kenneth Taylor-DEQ- No Crushed Stone Quarry in Snow Camp NC
CAUTION:
Repoit Spam.
Dr. Kenneth Taylor,
Myself along with most of the snow camp area are concerned about the rock quarry that is
supposed to be coming to our area.
Snow Camp is a beautiful,peaceful, quiet place that we are fortunate to live in. There is beautiful
scenery as well as an abundant of wildlife here the people are generous and friendly and I don't
believe I have met anyone from here that treated me like a stranger. These are the reasons I
moved to Snow Camp 12 years ago.
I personally find this Quarry alarming to say the least. This will Single-handedly destroy what
makes Snow Camp unique from other areas in North Carolina.
I have Seen rock quarries before, they are Huge massive holes in the ground,there is no
reclaiming this property once this rock quarry moves on. It will be a big dead space In Snow
Camp.
Why would state officials allow this to happen to our beautiful community?
Something like this affects everybody not only the people in Snow Camp but neighboring
communities also. The noise, dust and truck traffic is going to be horrible.
Oh and FYI there is a gas pipeline that either runs through or close to the proximity of the property in question
for the rock quarry so add explosions and fire to our list of concerns as well.
There is also concern that well water could possibly be contaminated, everyone in Snow Camp is
on well water this could potentially affect the community and surrounding communities.
500,000 gallons a day pumped from the ground! Thats mind boggling.
I can not run my water longer than 45 minutes before I have to shut it down because of the low
pressure. So I fear for myself as well as my neighbors and nearby communities,what are we
supposed to do if our wells go dry?
i
Wehner, Judy
From: Miller, David
Sent: Tuesday, December 18, 2018 8:14 AM
To: Wehner,Judy
Subject: FW: [External] Comment about 12/5 State Public Hearing- No Snow Camp Mine.
-----Original Message----
From:Steven and Annie Jackson [mailto:4dogs@mindspring.com]
Sent: Saturday, December 15,2018 5:27 PM
To: Miller, David<david.miller@ncdenr.gov>
Subject: [External] Comment about 12/5 State Public Hearing-No Snow Camp Mine.
CAUTION: External email. Do not click links or open attachments unless verified.Send all suspicious email as an
attachment to Report Spam.<mailto:report.spam@nc.gov>
Hello, Mr.Miller
Thank you for this opportunity to communicate my feelings about the proposed Mine in Snow Camp.
We all know the health, noise,gas line, power line dangers of this proposed mine.
We also know that it literally backs up into many families backyards.
We also know that a whole community that relies on well water would be (from other experiences nationwide)
irreversibly damaged.
I am choosing to try and reach out to you and whomever will vote on this permit in a moral fashion.
I am aware of the mining laws of 1971- (surely outdated) and I am aware of the terrible zoning laws in Alamance
County( again not truly up to date).
It seems like what we have here is a Mining Company that appears to resemble a type of ambulance chaser mentality-
going to small communities(with out dated zoning laws) and underhandedly trying to sneak by county permits.
This particular company is not even a NC company-they have gone Bankrupt at least once-they are deeply associated
with a company out of Charlotte that was found guilty of bid rigging and possibly more.
I understand your particular situation- being that even if you do not approve if this mine-the laws on the books
ridiculously lean toward the mining company.
I am a law abiding citizen-and I am sure you are as well- but there are times in our life where we have to make a moral
judgement and a moral stand, against something that even though protected by a terrible law is not morally sound.
This will affect way to many people(children included) in a very negative way for years to come and years after if this
mine is approved.
We will all still be here-or our family's-while this company is long gone.
I am hoping and praying that when it comes time to vote on this mining permit-you all vote with your hearts and not
your minds.
Thank you,Steven Schrenzel. Snow Camp resident for 27 years.
5901 Hoagie Creek Lane
Snow Camp, NC. 27349
Sent from my iPad
1
Wehner, Judy
From: Miller, David
Sent: Tuesday, December 18, 2018 8:15 AM
To: Wehner,Judy
Subject: FW: [External] Written comment for 12/5 State Public Hearing
From: Lohr,Cynthia H [mailto:cyndee.lohr@unc.edu]
Sent:Saturday, December 15,2018 1:31 PM
To: Miller, David <david.miiler@ncdenr.gov>
Cc: NoSnow CampMine<nosnowcampmine@gmail.com>
Subject: [External] Written comment for 12/5 State Public Hearing
Report
Dr. Kenneth Taylor, DEQ:
After watching the video of the State Public Hearing on 12/5, 1 want to express my agreement with everything
that was stated by my fellow Snow Campers! They did an excellent job of expressing our concerns for the
health and safety of all in the community if this mine is built. And as the last speaker pointed out, it's not just
the Snow Camp community that will be affected.The contaminates produced by the mining operation will go
downstream to poison waterways all the way to the coast! How can the state allow this to happen?
My husband and I have owned property in Snow Camp, only a 1/2 mile from the mine site for 18 years. The
beauty and serenity of the area has given us a feeling of being in Paradise!
PLEASE DON'T ALLOW PARADISE TO BE TAKE AWAY from us and all the others in the community of Snow
Camp!
Cyndee Lohr
cyndee.lohr@unc.edu
t
Wehner, Judy
From: Miller, David
Sent: Tuesday, December 18, 2018 8:15 AM
To: Wehner,Judy
Subject: FW: [External] Written comment for 12/05/2018 State Public Hearing
From:jonny smith [mailto:jcsjcs@bellsouth.net]
Sent:Saturday, December 15,2018 12:41 PM
To: Miller, David <david.miller@ncdenr.gov>
Subject: [External] Written comment for 12/05/2018 State Public Hearing
Report Spam
am writing to oppose the proposed mine in Snow Camp. I am a 71 year old state retiree who lives on a fixed
income. My address is 623 Hunters Creek Lane, Snow Camp, NC.
I am very worried about the blasting and water usage of the proposed mine. I live approx 2-3 miles (as the crow flies)
from the site.
I depend on a well for my water supply. It is excellent water, but a few years ago, it was just red mud.Willy Saul and
Sons, Plumbing inspected my well and discovered that it had collapsed about 20 feet covering the pump. They thought a
minor earthquake had caused this. They were able to insert another pump into the well because there was such a good
reservoir of water However, I am afraid of the blasting causing another collapse or if the aquifer that supports my water
supply causing my reservoir of water to drop, then I would need to have another well drilled.
I do not have the funds to have a well drilled. Therefore, my only option would be to move out of this area. That would be
an expense I cannot afford either, but what choice would be left to me? I consider this proposed mine an intrusion into my
rights as a landowner and I sincerely hope this will not be permitted to happen.
Sandra King
i
F
• Concerned
Property
Owner
s
<'SHbwing Hydrology,
• - FEMA F'l bdplain , •.
of."Unnamed Creek,"
Ponds-and Lakes _
` . .
oq,f'
+ lei .
4 f"= Proposed Quarry Area'
Exhibii; 1, Surface Water Exposure of-
My'Prop", to the Mine Rife Effluence
c>
How will sediments removed from traps and ponds be removed and where will it be
disposed?
• Will any of the discharges into onsite or nearby surface waters increase turbidity of
those waters?
• Will any discharges into nearby surface waters cause those waters to rise into the
current FEMA flood plains or to rise beyond the current FEMA floodplains?
Conclusion
I have addressed some of the surface water issues that preclude approval of the permit.
There are many other issues,such as the effects on groundwater and air quality,which also
preclude the approval of the permit. I am sure those issues will be thoroughly addressed by
other interested parties.
In many cases mining brings economic benefits to the State. However,the dangers and hazards
that the AA LLC mine will inflict on the local community and broader areas of the State outweigh
any possible economic benefits the AA LLC mine could provide.
Comments from Anne Albright re Alamance Aggregates LLC permit application, 12/15/2018 Page 6
A good portion of the property will be denuded of trees and other vegetation that currently
moderate the effects of storm water runoff.
Considering the steep slopes,the sizes and locations of overburdens and stockpiles,the
denuding of the property,and the likelihood of more hurricanes and tropical storms,the
potential for surface water contamination is great.
It is imperative to have a definitive and complete grading/erosion plan approved and permitted.
Lack of an approved and permitted grading/erosion plan precludes the approval of the
Application.
6. The permit should be denied due to miscellaneous additional issues that have not been fully
addressed or suitably clarified in the permit application or the LaBella site drawings.
• How exactly will 500,000 gallons (or 2,475 cubic yards) of de-watering per day as per
the application permit be handled so that it does not enter the onsite or local surface
waters?
• What types of water will be generated by or as a spinoff of the mining process, e.g.,
process water, mine de-watered water,storm water runoff and seepage water?
How will these types of waters be kept out of the onsite and nearby surface waters?
What quantities of these waters will be discharged into or allowed to enter the onsite or
nearby surface waters?
• Specifically,what toxic chemicals or other contaminants will be generated by the mining
process?
How will they be kept out of the onsite and nearby surface waters?
What quantities of these contaminants will be discharged into or allowed to enter the
onsite or nearby surface waters?
• What quantities of sediments and rocks will be generated by the mining process that
can enter the onsite and nearby surface waters?
How will they be kept out of the onsite and nearby surface waters?
What quantities of these solids will be discharged into or allowed to enter the onsite or
nearby surface waters?
Comments from Anne Albright re Alamance Aggregates LLC permit application, 12/15/2018 Page 5
10'from the center to the bank,so the C201 measurements are short by at least 10'for
Unnamed Creek, not to mention the buffer sizes don't conform to the Alamance County HIDO.
This all means that the Permit was incorrectly approved by Alamance County in the first place
and should not have even gotten to the State level.
inadequate buffering of the five creeks and streams precludes the approval of the application.
4. The Permit should be denied because the wetlands areas on the property have not been 401
certified or 404 permitted.
The LaBella C201 "Mine Map" shows the presence of numerous small but discrete wetland areas
on the site.One wetland area is in the center of the proposed pit.
There is no supporting documentation that these wetland areas have been 401 certified or 404
permitted.
Many ponds and streams in the area are sourced totally or in part by underground springs.The
interconnectedness of the surface and ground waters requires that the entire property be
certified.
Lack of certification and permitting of the wetland areas precludes the approval of the
Application.
S. The Permit should be denied because a grading/erosion control plan has not been approved
and permitted for handling storm water runoff.
LaBella C301 is the "Sedimentation & Erosion Control Plan."There is no evidence that this plan
has been approved and permitted.
The property is on an area steeply sloped in several directions.The 8.29 acres for storage
overburden slopes steeply westward toward the Unnamed Creek and its FEMA floodplain.The
stockpile and plant processing area is 23.28 acres and slopes steeply south toward an onsite
creek that flows west into the Unnamed Creek and its FEMA floodplain. These areas are now
covered by trees and other vegetation, which would be mostly removed during site preparation.
C301 shows lots of control structures—temporary check dams,temporary sediment/silt fences,
stone outlets,temporary diversion ditches and berms—all routing water into numerous
skimmer basins or stone outlets.Specific areas of water routing are shown in C304"Drainage
Areas".
There is no indication of what the ultimate destination of the storm water runoff would be. One
stone outlet seems to be directing water toward Reedy Branch and the others outlets toward
the Unnamed Creek.
Comments from Anne Albright re Alamance Aggregates LLC permit application, 12/15/2018 Page 4
The quality of headwater streams will determine the quality of rivers.
-Wesley Daniel, Michigan State University,2014
I. The Permit should be denied due to the Mine's proximity to the existing Colonial Pipeline.
LaBella C101 "Existing Conditions"shows"APPARENT GAS LINE EASEMENT"crossing the
northern panhandle of the property.This is an actual, existing Colonial pipeline that carries
toxic and flammable materials.A pipeline rupture due to blasting or other mining activities
causing vibrations would definitely be a contamination problem to surface water in the area
(not to mention other unpleasant ramifications).
As of 10/31/2018,Tom West, Colonial rep,was just hearing about the permit application.
The potential for a rupture of the Colonial Pipeline precludes the approval of the application.
2. The Permit should be denied because there are four onsite streams that are within the area of
operations.
The LaBella C201 "Mine Map" shows the presence of four onsite streams that would be affected
by the Mine:
• The eastern most stream on the property flows out of an onsite pond and into Reedy
Branch, which is a WS-V protected water supply that feeds into the Cape Fear Watershed by
way of Cane Creek.
• The other three on-site existing streams flow into the Unnamed Creek, which borders the
property on the west and also feeds directly into the Cape Fear Watershed by way of Cane
Creek.
The presence of four onsite streams precludes the approval of the application.
3. The Permit should be denied because,even if the streams are not considered to be within the
area of operations,there is inadequate buffering to protect them.
The stream buffers for all five streams and creeks shown on C201 do not even comply with
Alamance County HIDO 4.F Stream Buffers, which states:
All industries regulated by this ordinance shall be required to maintain a minimum
stream setback from any perennial or intermittent stream. Stream setbacks shall be
measured from the "area of operations" to the bank of the stream.
For Class IV industries the stream setback is 100 feet.
For the Unnamed Creek,the setback,or buffer, is measured by LaBella from the center of the
creek, which is incorrect. It should be measured from the bank of the creek. It is approximately
Comments from Anne Albright re Alamance Aggregates LLC permit application, 12/15/2018 Page 3
On a broader level, I'm concerned about the impacts these three surface water issues will have on more
populated, economically significant, and environmentally-sensitive areas downstream.The Unnamed
Creek flows northward into Cane Creek. I'm sure you know Cane Creek flows into the Haw River,which
flows into Jordan Lake,which is a source of drinking water for some towns and cities.And then The Haw
continues on to the Cape Fear and then into the Atlantic Ocean.
The AA LLC mine will have a hazardous impact on surface waters important to people,farm animals and
crops, pets,wildlife, plant life, aquatic life, and microscopic organisms.The contaminants will spread
from the initial dumping into the Unnamed Creek all the way down to and including the Atlantic Ocean.
I shall now present my reasons as to why the permit should be denied based on the mine's adverse
effects on surface waters and FEMA floodplains. I shall refer mostly to the LaBella site plans dated
9/24/2018 and submitted with AA LLC's permit application.
Sincerely and best regards,
Anne Albright
2908 Green Hill Drive
Chapel Hill, NC 27514
919.602.0180 cell phone
P.S. If Alamance County had a permitting process that was transparent and oriented toward the welfare
of the actual residents of the County, it is likely we would not be here now.
Comments from Anne Albright re Alamance Aggregates LLC permit application, 12/15/2018 Page 2
December 15,2018
To: Dr. Kenneth Taylor
NC Department of Environmental Quality
1612 Mail Service Center
Raleigh, NC 27699-1612
Re: Written Comments Pursuant to the 12/5 State Public Hearing Regarding the Permit Application
Submitted by Alamance Aggregates LLC for a Crushed Stone Mine in Snow Camp, NC
Dear Dr.Taylor,
As a concerned property owner in Snow Camp, I greatly appreciated the opportunity to attend and
speak at the public hearing at Sylvan Elementary School on December 5.The large turnout indicates that
may other folks appreciated it,too.
I also appreciate the opportunity afforded us now to provide additional written input into the permitting
process. I find it much easier to write than to speak for 3 minutes!
This letter is to state my reasons as to why the North Carolina Mining Permit Application submitted by
Alamance Aggregates LLC and dated 9/27/2018 should be denied. I shall focus on the negative impacts
the mine will have on surface waters and FEMA floodplains.
Let me briefly explain my interest in the matter. I am part owner of approximately 100 undeveloped
acres on Workman Road in Snow Camp.The property was originally owned in my family by my great-
grandparents.The southern boundary of my property lies 991' north of the northern-most boundary of
property recently acquired by Snow Camp Property Investments LLC that is to be leased by AA LLC. (I am
sure you have noted that these two LLCs were originally registered in Wyoming and later received
permits to do business in North Carolina.)
The western boundary of my property is the center line of a creek that is downstream from the
proposed AA LLC mine.The western boundary of the AA LLC mine is the center line of that same creek.
According to AA LLC maps supplied with the permit application,that creek is targeted to receive all or
most of the process water from the mining activities.The creek is also subject to contamination from
site erosion, as the site slopes steeply and mostly toward that creek.
Please see Exhibit 1,attached,Surface Water Exposure of My Property to the Mine Site Effluence.
It is pretty obvious that the mine is sited where it is because of the ease of dumping contaminants and
waste into this relatively obscure and insignificant but year-round flowing creek that doesn't even have
an official name.
Even though my family always referred to the creek as"the South Fork" of Cane Creek, it is not an
official name. I'll be referring to it as the "Unnamed Creek" in this letter.
On a personal level, I'm concerned about these three surface water issues:
• contamination of the waters of the Unnamed Creek where it borders my property
• the contamination of the FEMA floodplain area on my property
• the increase in the size of the FEMA floodplain area on my property
Comments from Anne Albright re Alamance Aggregates LLC permit application, 12/15/2018 Page 1
Wehner, Judy
From: Miller, David
Sent: Tuesday, December 18, 2018 8:16 AM
To: Wehner,Judy
Subject: FW: [External] Written comments for 12/5 State Public Hearing
Attachments: Anne Albright- Letter to DEQ.docx
----Original Message-----
From: AnneA [mailto:anne.a[bright@mindspring.com]
Sent: Saturday, December 15, 2018 12:19 PM
To: Miller, David<david.miller@ncdenr.gov>
Cc: NoSnow CampMine<nosnowcampmine@gmail.com>
Subject: [External]Written comments for 12/5 State Public Hearing
CAUTION: External email. Do not click links or open attachments unless verified.Send all suspicious email as an
attachment to Report Spa m.<mailto:re port.spam @ nc.gov>
Hi, David,
I am attaching the letter I am submitting to the DEQ concerning the permit application made by Alamance Aggregates
LLC to establish a crushed stone mine in Snow Camp, NC.
Will you please direct it to the appropriate recipient.
Thanks and regards,
Anne Albright
2908 Green Hill Dr
Chapel Hill NC 27514
919.602.0280 cell
p.s.Thanks for your help with the questions I had while writing this up.
1
Jay Smith & Associates
® The Scandinavian Specialists since 1973
December 14,2018 IM
DEMLR Interim Director Danny Smith
1612 Mail Services Center
Raleigh, N.C. 27699-1612
RE: Comments for"Alamance Aggregates Snow Camp Quarry"
Snow Camp, Alamance County, NC
Greetings,
I am a both a resident and business owner/employer in "central' Snow Camp. I/we are located
within mile or two of the proposed quarry site.
I do have concerns about the so-called quarry operation. While I am not in "knee jerk"
opposition to this operation, I believe that the operation should NOT continue until and unless
there is thorough vetting by mining and ecological governmental authorities,and until
appropriate performance bonds have been posted by the company.
I am not automatically anti-development and not anti-quarry/mine. In fact, when I first heard
about it, because of my personal interest in minerals and mining,I was excited about the
possibilities of finding interesting mineral samples, etc. However, so much about this whole
project "smells bad" that I have strong concerns, which include:
I) I am very suspicious that the apparent secrecy leading up to this situation and the ongoing
apparent secrecy about the companX behind the operation is an indication that this will end
up being a "rape and run" operation which will leave long-term damage (such as
contamination of ground water). If this project does continue, they should be required to
provide a real, long-term performance bond guaranteed by a truly high-quality insurer.
(If the company responds that it cannot afford such a performance bond, then this is just an
indication that the company is not now or will not be then financially capable of meeting its
long-term obligations for the safety and health of the area. This concern is especially great
because of the extremely-long-term HEAVY METALS contamination possibility
discussed in point 3. In great contrast to the secrecy of this project, I have followed the
development of the Haile Gold mine in South Carolina(http://www.hailego]dmine.com/)—
while no project like this can be perfect, Haile is an example of openness and transparency
that is the opposite of the Snow Camp operation.
P.O. Box 650 Snow Camp, NC 27349 USA 1-800-447-8267 or 1-336-376-9991 24 hour Fax 1-336-376-6750
Members: ASDA, PTS, APS, SCC, SPS, SFF, KPK,ASPP, OFK, CSDA, CCNY www.laySmidi.com e-mail:is@laySmith.com
2) I am not a quarry expert, but for much of my life I have been around (and explored) more
than a few quarries, as well as actual mineral mining operations in various parts of the
country. A 29 acre hole that is up to 325 feet deep (as described in the press) does NOT
seem to me to be a typical aggregate rock quarry operation. Operation at that depth gets
very expensive and requires extensive ramping for equipment to get in and out, etc. It just
does not sound right or typical for an aggregate quarry. This leads to the next point.
3) I have a very strong hobby interest in the mineralogy of the Snow Camp area. This area has a
long and rich history of MINERAL MINING activity, from very early iron mines, to
pyrophyllite mines, to gold mines, to rich copper mines. Generally speaking, this is a gold-
and copper-rich area and there have been a variety of commercial mineral mining operations
in the area over the last couple hundred years. There is even a recent-history pyrophyllite
mine on the same (Clark) road! As can be seen in any of the available geologic maps of
this area, the rock types of the area are extremely diverse,with many HIGHLY
MINERALIZED AREAS. While there are areas of"country rock", much of that is fairly
weak and not suitable for aggregate. The areas of"country rock" that are strong enough
and suitable for aggregate are fairly limited. This, combined with the shape, size, and
depth of the mine, AND THE SECRECY has lead me to the conclusion that THIS IS
PROBABLY NOT AN AGGREGATE QUARRY,BUT IS PROBABLY ACTUALLY A
MINERAL MINE. The reason that this is a concern to me, whether this is really an
aggregate quarry or a mineral mine, is that the high levels of mineralization could result in
extensive HEAVY METALS ground water contamination as well as stream and river
contamination. The types of heavy metals usually associated with gold and copper mines
(which have also been in the area) are usually very nasty and have a history of poising
streams and rivers in other regions. Even if this is really pure aggregate quarry, eventually
the water that is being pumped out (500,000 gallons per day according to press reports) will
be coming through adjacent highly-mineralized rock structures and will eventually pull
dissolved heavy metals from those adjacent rock structures.
4) Last, but not least, is the issue of safety after the closing. By definition, when commercial
operation has finished, this quarry or mine will fill with water and become a lake. However,
there is a long and tragic history of drownings in quarry lakes because of the STEEP
SIDES between the top of the water level and the natural adjacent land level. Such
steep-sided quarry lakes are a public nuisance. No matter how many signs are posted or
fences are erected (but who will maintain fences forever), we all know that young people are
attracted to such lakes—sometimes with tragic results. Whether the drownings are the
result of swimming, whether legal or illegal, or because of people accidentally slipping or
falling into the water, DROWNINGS WILL HAPPEN. If the quarry is built, this problem
cannot be completely eliminated. However, the problem can be ameliorated BY POSTING
A PERFORMANCE BOND to require recontouring of the quarry sides, between water level
and the natural land level, so that a normal person could crawl out of the water. Depending
upon the height involved, this may require contouring up to a "shelf or deck" area slightly
above the water level even if the straight sides continue on up above that. The described
shelf or deck should be wide enough to accommodate emergency/rescue vehicles. Once the
2
commercial operation has closed, the status and safety of the lake and land will be permanent
—if the needed safety work is not done at time of closing, it will forever be the scene of
tragedy. The only practical means to control this is through the issuance of a
performance bond.
I ask that the appropriate government authorities more closely examine this proposed project and
also treat it in the manner that they would treat it if the mine had been described as a mineral
mine that could expose heavy metals.
Thank you for your attention to this matter.
Sincerely rs,
Smi
3
December 14,2018
Show Camp,North Carolina
Dr. Kenneth Taylor
Department of Environmental Quality
Raleigh, North Carolina
Dear Dr. Taylor,
I am writing to you as a longtime resident of Snow Camp, North Carolina, in Alamance County.
I am writing concerning a crushed stone quarry which is proposed for southern Alamance
County, in the heart of Snow Camp.
I have lived with my wife, Laura, in Snow Camp for nearly 30 years. During that time I have
come to know Snow Camp as a very special place. Snow Camp is a beautiful rural township
with some of the most scenic countryside in the center of the state, and with a close-knit
community going back generations.
Broad rolling hills covered with forest or fields spread to the horizon. Churches and small farms
with tidy farmhouses, some of them 100 or even 150 years old, dot the landscape. The air is
clean and fresh. It is far enough from the hustle and bustle that most times of day all you hear is
birds singing, cows mooing,and trees rustling in the breeze.
Snow Camp has important history that goes back before the Revolution. Quakers founded it in
the mid-1700's, and built the fast mills in the area along Cane Creek Lord Cornwallis camped
hereafter the Battle of Guilford Courthouse,and stayed in a house that still stands, One of the
first textile mills in the entire southeast was built here in the 1830's, and provided fabric and
blankets for the Confederate troops from our state. There are families here who have owned their
land since King George III granted it to their forebears.
Over the last 150 years the area around Snow Camp has been quietly left alone, as our state
developed around it. Industry and railroads and highways surrounded it,but because of its
somewhat rugged terrain it has remained isolated and mostly undeveloped. Now it provides a
peaceful refuge from the busy life of the Triangle and the Triad, which bookend it.
The people who live here cherish that peace and quiet. Either they have known and loved it their
whole lives, or they have come here to seek it out. Snow Camp represents a chance to live in the
heart of North Carolina, a state we love, and yet live in peaceful,rural quietude. The folks who
already live here are welcoming to anyone who wants to come and share that quiet.
The proposed quarry would end all that as surely as if an international airport were located here.
The proposed location is right in the very heart of the most scenic and beautiful and historic part
of the Snow Camp Township. It would drop heavy industry right into the center of our
community and it would destroy it.
No more scenic vistas. Instead, clearcut forest and gouged earth. No more birds singing and
cows lowing. Instead,blasting and the roar of engines and crushers and trucks. No more spring
breezes fragrant with flowers and freshly tilled soil. Instead, diesel exhaust and plumes of
noxious dust. No more babbling creeks with historic millponds and fragile wetlands. Instead,
streams flooded 600,000 gallons a day of polluted mine runoff.
There are lots of good reasons to deny permitting this quarry. The local permitting process was
questionable at best. There has been no substantial environment impact study. The amount of
polluted water to be dumped into Cane Creek would damage or destroy fragile wetlands and
further pollute the important Haw River watershed. The owners of the shell companies set up to
promote this project are hiding behind corporate anonymity by chartering their corporations in
Wyoming,so there is no way to determine if they are in compliance with the NC Mining Act of
1971, Section 74-51(d)(7).
The property of the proposed quarry is crossed by the Colonial Pipeline which carries gasoline,
diesel, kerosine and jet fuel and could be catastrophically compromised by blasting,and by land
subsidence from de-watering. The Sylvan Elementary School is only a mile from the proposed
site(and pipeline),which would expose school children to toxic dust every day. Hundreds of
people and small farms and businesses near the site wholly depend on their wells for water,
which will probably either go dry or be polluted by the operation. And there are already two
quarries in Alamance County, and at least five within 50 miles.
The list goes on. But my real argument is this. Allowing this quarry to be built in Snow Camp
would drive a stake right into the heart of our community, a community which has been in
existence for over 200 years. It will be the end of Snow Camp as we have known it, and as
families have known and loved it for generations. Once gone,it can never be recovered. Over
500 residents of Snow Camp attended the state's public hearing and unanimously expressed their
opposition to this project.
Certainly the state needs industry,and it needs jobs. But is this quarry really needed, at this cost?
I am asking you to refuse permitting for this ill-conceived, ill-advised, and unnecessary project.
Respectful
ason Dowdle
jason@blueskyfihn.com
(336)269-0332
f
December 14, 2018
Dr. Kenneth Taylor
NC State Geologist
612 Mail Service Center,
Raleigh, NC 27699-1612
Dear Dr. Taylor:
.4-
I attended and presented at the December 5,2018 Hearing with the Department of Environmental
Quality at the Sylvan School in Snow Camp, NC. In this letter, I will address several points:
• NC DOT Review of Blasting near a Pipeline
• Groundwater/Dewatering Concerns
• Silica Content in the Geological Formation Targeted for Excavation and Blasting
• Lack of Accurate Studies
Proximity of Pipeline and Blast Analysis
The proximity of the mine to a hazardous liquid pipeline is not a usual circumstance for your agency to
review for a mining application.There are numerous agencies listed on your site and mining application
flow chart that will review the application for potential impact to air quality,water quality,ecology,
historic sites, parks, etc. I see no mention of having the NC DOT division that oversees pipeline safety
and who has issued guidelines(see attached)and requirements for excavating near a pipeline, review
this application. According to the US DOT Pipeline and Hazardous Materials Safety Administration:
Excavation damage is a leading cause of significant pipeline accidents...resulting in property damage,
injuries, and fatalities.Severe excavation damage results in an immediate release while less severe
damage can weaken a pipe and contribute to a future pipeline failure.
I feel it is imperative that you have the agency charged with pipeline safety in NC,review the planned
operations,the proximity of the blasting and heavy equipment excavation,and provide a guidance on
the acceptability of the plan as stated in the application.
Further, the blast impact analysis by GeoSonic is a generic report, not one generated specifically for this
property or its geology. It does not address the presence of a hazardous liquid pipeline less than 1500
feet from the zone of operation. Based on other locations where pipelines are to be constructed near an
existing mining operation,there are specifications for the type of steel (double wall) and the buffer sand
and concrete that must be constructed to surround the pipeline,as hard rock transmits seismic waves at
a substantially higher rate than does sand or soil.This is another reason why the generic blasting impact
report provided by GeoSonic is insufficient to assess the potential risk to surrounding homes or to the
pipeline.The potential hazards are great and the high consequence region surrounding this operation
warrants a much more thorough analysis.
Groundwater
In its application,Alamance Aggregates references a groundwater report by Carolina Geological
Services(CGS)which has not been submitted to the state with the application. It is imperative that the
study be provided, as it conflicts with the currently available data from the NC Geological Survey and the
USGS maps. LiDAR analysis shows numerous lineaments on the property,indicating potential faults that
would increase the transmissivity of the formation, causing the zones of depression and influence to be
much greater than the Company's estimation.
Possible Fractures/Faults
Wcl %adArt Mn Camp.NC H
Speculative Fracture Trace Analysis u de , 2W.A
LiDAR Topographic Hillshade -
At least 120 wells could be impacted by a zone of influence of one mile from the site.There is nothing in
the permit that protects our right to clean,drinkable water. Our only access to water is our private
wells, most of which are 60-200 feet deep. Dewatering at a rate of 500,000 gallons per day to a depth of
325 feet would devastate our community of water.
It is imperative that we review the groundwater report by Carolina Geological Services for
accuracy.
Silica Content
Many residents of the community expressed concerns about the potential air pollutants including fine
powder silica, known as crystalline silicate that would be released in the atmosphere by the proposed
Alamance Aggregates Crushed Stone Mining operation at 342 Clark Road,Snow Camp, NC. In discussions
following the hearing, I was asked about the research that I had previously conducted in preparation to
speak on concerns regarding dewatering of the water table. Specifically, I was told that someone had
stated that there was no silica in the rock formation at the proposed mining site. From what I have
learned about the Neoproterozoic era felsic lava formation that comprises the geology of the region of
the proposed mine,the only question is the concentration of silica dioxide in the formation. In felsic lava
it is typically 70-78%and in mafic,more in the range of 50%
(http://www.columbia.edu/-v*dl/igneous.htm).
According to the USGS map of that region,the rock type is part of the Zra and Zrb units.
f
Zr: Reedy Branch Tuff(Neoproterozoic)—Rhyodacitic and dacitic tuff containing abundant euhedral to
subhedral plagioclase crystals and lesser quartz phenocrysts in a very fine grained matrix of muscovite,
biotite, chlorite,epidote, calcite, ilmenite, and anatase; commonly contains small inclusions of dark,
fine-grained rock, most of which are smaller than 0.4 in (1 cm); a few may be as much as 6 in (15 cm)
long; some are angular and some are rounded
Zra: Reedy Branch Tuff that is slightly to moderately altered to quartz-sericite
Zrb: Reedy Branch Tuff that is strongly altered to quartz-sericite and, locally, is strongly sheared
Both units are tuffs and appear to be felsic in composition based on the unit description.
Also based on the USGS map,there is a rock sample for chemical analysis on the site or very nearby
(sample 5003}. The following table shows the content of silica dioxide (Si02) in that sample.
Table 2.—X-ray fluorescence analyses of 16 samples from the crystal-rich rhyodacitic-dacdic Reedy Branch Tuff.
[Loce6ons of sampled sites are shown in figure 2.Major element values are given in weight percent,and trace element values are given in parts per million.
For samples A533,1515,6096,6128,6184,6244,6254,6441,6446,and 6449,elements were analymd by wavelength-dispersive X-ray fluorescence
(J.E.Taggart,AJ.Bartel,and D.F.6ierts,analysts).For samples 5003,5004,5005,5028,5030,and 5071,elements were analyzed by energy-
dispersive X-ray fluorescence(John Jackson,analyst).NA not anallued.LOI,loss on Ignition]
Lab no.
Field no. A533 1515 5003
Map sector J J I
Si02 67.9 67.58 66.2
A1203 15.4 15.5 17.5
Fe203 2.95 2.98
Mg0 0.91 0.98 <1.52
CaO 2.64 2.70 2.16
Na20 4.10 NA
K20 3.60 3.25 3.88
Ti02 0.42 0.44 0.45
P205 0.12 0.12 NA
MnO 0.06 0.07 0.05
LOI 9000C 0.85
Adthmeticsian 98.1 93.62 90.2
Total on lab report 99.00 99.70
From the analysis,sample 5003 contains 66.2%S102. Regarding the analysis, NC's Piedment Geologist
states that Si02 values depicted in whole rock geochemical analysis are not a direct measure of the silica
in the rock but is a way to express how much silicon is present in a rock sample from that region. Any
felsic rock will have a high percentage of Si02 in the analysis. The mineral quartz is silica. The rock in
the area likely does not have much visible quartz, but likely has abundant microscopic quartz. Quartz
veins may also occur in the area and may be crushed as part of the site activities.
From OSHA publication 3301: Crystalline silica exists almost everywhere in our natural
environment. It's abundant in soil,sand, dust, quartz,and granite rock. ...When they are inhaled,the
silica particles become trapped in the lungs and damage the tissue.
Small silica dust is carcinogenic, and exposure to silica has been recognized an occupational health
concern for decades.This size range of particle can travel long distances suspended in the atmosphere
and particles smaller than 5 µm are easily lodged in the lungs.
Lack of Studies and Testing Data
Of particular concern regarding the geology is the lack of studies of this property by the prospective
mining company.Studies referenced in the application are not indicative of this region.As the potential
hazards are great to the community, it is imperative that the company conduct or cause to have
conducted studies to assess the potential threat to the 120 Snow Camp families who live within a mile of
the site. I am among them at 1730 Quakenbush Road, directly across the street from the property, and
my well is just 2500 feet from the proposed operational site.
I appreciate your consideration. Our lives are in your hands.
Sincerely,
Jane a Hicks
1730 Quakenbush Road, Snow Camp, NC 27349 (936) 520-6156
VVV of g o a m 'u � ot cvi c �.E Tt 'v � 'E c
a 0 n >
Ed R n 'N R 5 0 ° o R m;� --�° d R R E
, 2 w c W '; a o > E W R ° N d � C d
m m
C R 2
m R m o o o R o E� o
o N d ¢D E t E
N L ._ ._ y o o `O. w
m w c ._ R d d c v Y u W d a v c
N U E a E O O U o R s y R 10 O N R > C y W R y C O L' W
E w
O m R - p .Q d .p m ° ¢t U r o.o m N x F L d 3 a c V
E p: 0 x
'Rco >,aoEo Ed o`E 0 - m m - c 'm ^� E�N Ld° ddo JEtc "
> o W o a R d � - a 'E
m x R m d E ` E o y
�m
a T O W R N W
un a E 0 ow 2a0 w = = mRRa .p mod
2 dL WC - TE3= NCd Y dNJ 'fC _ O `. x _. N mN _ EN
y O D E C O C [d]= ..J' d O D d 0 C C N LO R O1E N 'U R � C 3 J E
O d > y ,r L w N V M C d d
EE y cd �LRm t>` dW o a a oo N
E o to oo m E a
RoOt d n � w - 6 -
._ Ed
c '
O E `o m y ° c c y a w OR d o f W m x m
> ddNR
J o cR ¢o N € cd
¢ UE E tcHa0> ao o E
0 d oft E >
O wo 12m c
o m R oo t
mw .w
EN o w O aN d 9 u _ o d Y E
p O O
¢ N ^ .L.. Q d O N O R +� C n R C d
C N D JL.. ~ O O " a E -: > d O > '� m > N o N C
W U N E C I� N C R C :.. o R R
O c L .a o d m R J d x T o m_ d �n m r d P_' d o - o d N �l o f `. u d i . N
3o �0 _ a � } jR ¢ d R '" mEt } m p3dR ad :� xn.: HN = cJi NH mnc m�
N R a o a Mc c °
p . t n o w S 5 o T N d m
R b0 N C N U L W U C O ... N Y N N O O U U QI O 0 C � .0 d C O .r
J 0 N d O O C O Z 'O > > d - 4 Z O t R d N n n d d = O R L..
w E ` 3 n Z 'u ° > a x a '" E > c d
E „`o o n R d c t > a c vi m o C7
°> ad A w °
o 5 o ` Ncd.i.Y`.oCE$..
[Nt
m dx> i O y a ro o mto
` J m O
> Y E
E ° d O Z d o
v O -0 N E O
2 'E m � c L °N ° - > O W N ^ C
O 0 LU n O
E > E E o d NE
vo LLEn nE Sa°RC7:
UZ T > W W n C 4 > 'E O
0 d co_ o 'T° .> a c�_ m d °c Z V
v y x d a a E Z a = E a c N E > E w E a _w m > m
° Lom m c°� � � E >Rod °m cdio adi cdiN0r = r10 w0E p` uR "
No 'aa, 0 3 > op Ea x 'on LD Emu NL cam omnE nm� aoi
m o 0: x m .c_w_ c L � ti c o d y ¢ M 3 E r 0 �� c �N p o �0 w
m .o o- o u Ly Fcm m w`- o d � dEr
° ° o.a o :° 0 0 0 0 cdi = m .. D c 0 E D L o p c o
CD 0E 02 c N m o m `m o d -Mo m a c v v m n E d ,yn r2
c v °
xd am
mo 'M 0 o - m >L E No x
> > -d Nd 'a U
OTN dO
C ne tE dw O 'ROw>S, ,
5Zy dO
Z ar-J=ddEEc oNtCNv0`o Z t t w° Jw F E m o E
d
_ d c
w iE °
o C R u c 2
- 0 U E �_ w � y d w
CC C E eU d y N p C
d O 0 6 d d
G - O O N T y O' O O O
0 O U U m y
R > ° d O y O
q R Z } 2 R Z 1°p
x x `o a o « d c a W d > 3
W a
c G F W W O
R N Y R OI d 1 R10
R O O N Z
W R' WS x R d L d C D R w
W F 10- J R x )
2 W
C w U
O —It N
a U m m N u C
V
E y a E
C p C . N O 0) C O 0 Y d M '> D)
me ccC7 ° E
3 .�? 'm= 3y0 � ns ;o
> o c o
u h o '� a E ? > a ° o N . (3 m o o
o o m ° F o f 5 d n m
N
m 6 O
0 o m c n >
o m E E a x 0 m w 0 c 2 0 m d m c o
c o a a m m c E o E
E a d m c i o m ¢
o c c d — Q d m °i a o o m , y o
5
0 E S r. L o w E 'c d
m w d ai ` N '� c i s m 3 t
o 'm m E .2
°' OoEdcomcmTvi E E' mcE ao o� cEOc XnddmcU mr. o0
12
`m `m E o w o c a, S c E m m m c 'o m �
(.i co co co L c 0 E c .E E' m E
N N N �2 3: C > ya - 'L 6C fONOWCLN wN
N O N r N r N r N r NC N N n U d N d d Iq m (ap n N m ry O O T
> m > m Y Z > Y m Y m Y m Y m L 5 `� m E o m 0 ao UZ UZ UZ (n VJ (n mN oOO.wo -�om Q w—00 Z cf0i OO 1—N L°m' tN0 a—y N2p ENd 0d mOw mE(D (D (D U U U az z z z E 0 o
do J ao m m aNN NN c ... m n N > p O
U c n E n o (° ° c 5 m
w� E m -
(j m
o > '> o m % a
12 '62 d m
N d0 % . >w E
a Z % d ET
KNO
o
m m
'9 E `o E m
Q 2 c d m o a � F t EE2 r m Q m o E m x O
m 6 .0 d 0 U .a o m m N— m a L c o d
L ° d O ` O L O Ol Of C d I 7r,
~ m 'Q m C O d d C_ O n m m y m
N � � N �.. �� a 0. ° T ° EOnLmm
EN N jQ 6 QI C L_ E E O1 C 1p > m L C
K a a a ✓> 'o 3 3Ld. .a E m O U % �+ N
4 E E T N O d C m m m C L
N C :.. a N E E > T O m e U Q
F m m y C ° C° C N o d
n c L ¢ m
m ¢ ° N d O d U n U U > L m O 3 V O
(n o aCi [Li o d C c C .c g N U a 2 tJo 0
U'o E o E 3 m a m N E u
Z m d w ^ `
a m d E n 3 E a E E 'w o R
E a v z > m N « u
N d E ? v > m ❑ d ? ` m 2
m o0 Y m a a X E d o. nc
.3z
m=mN Z
Zm F(1 > m iUNd
C d a C 2 u%
d m« ^' O m O Q N wQE
cu ET�9a
5d
o o } m ad`me
md
I zzaaU 0 uz 0 z c z zJ TKO