20210329_T-Lewis-2

NCEMR PUBLIC HEARING (MARCH 29, 2021) REGARDING MORTON SAND
MINE NCEMR APPLICATION FOR PERMIT
COMMENTS BY TYNDALL LEWIS, McDAVID ASSOCIATES, ENGINEERS FOR
JONES COUNTY REGIONAL WATER SYSTEM
I would like to offer comments regarding the NC Division of Energy, Mineral and Land
Resources (NCEMR) application for permit submitted by Tim Morton Trucking, LLC to
construct and operate a 17.4 acre sand mine on a 32.3 acre tract on Scott Farm Road. The
proposed mine location is located approximately one half mile east of the site of the new
Jones County Water Treatment Plant (WTP) and Wells 9 & 10 now in construction. The
new WTP and Wells 9 & 10 are expected to be placed in operation no later than September,
2021. The proposed mine would have a maximum depth of 35 feet.
It has taken several years for the County to plan and construct Wells 9 and 10 and the Water
Treatment Plant and at a significant cost. The new wells and Water Treatment Plant are
essential for the County's compliance with Central Coastal Plains Capacity Use Area
requirements. The County is investing over $11,000,000 in these current improvements.
McDavid Associates, Inc. believes the construction and operation of the mine may have
significant detrimental impacts on operations of the County's new WTP and Wells 9 and 10.
NCEMR is requested to require the mining permit applicant be responsible to retain services
of a Company employing qualified hydrogeologists to thoroughly investigate existing
groundwater characteristics at the site and in the area and model how those characteristics
may be impacted from the proposed mining operation. In particular, the potential impacts
with respect to future operation of the County's new Wells 9 and 10 and Water Treatment
Plant should be addressed by the applicant. Lowering of the water table surface can have
significant impacts on the position and movement of the fresh water — salt water interface,
particularly in shallow groundwater systems. Increasing chloride levels in the groundwater
could result in Wells 9 and 10 and the new WTP becoming useless thereby rendering years of
planning and expenditures of over $11,000,000 useless.
Other secondary issues to be reviewed and evaluated include quantifying how mine de -
watering will lower ground water levels in the area thereby decreasing yields from other
wells along with potential detrimental impacts associated with mine abandonment and
associated potential for groundwater contamination.
The opportunity to present these comments is appreciated.
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20210329 T-Lewis.docx