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HomeMy WebLinkAbout1-Combined Cover and Narrative Response to ADI2Quarry Phone Numbers: (919) 266-9266 - Knightdale (919) 677-0050 - Triangle (919) 775-7349 - Moncure (252) 985-4411 - Nash County (843) 756-3400 - N. Myrtle Beach WAIF STONE CORPORATION y'IYw,wakestQneGQrp,ca 1 Locations: 6811 Knightdale Blvd., Knightdale, N.C. 222 Star Lane, Cary, N.C. 9725 Stone Quarry Rd., Moncure, N.C. 7379 North Halifax Rd., Battleboro, N.C. 3990 Hwy 9 Business East, Loris, S.C. March 22, 2021 David Miller, State Mining Specialist N.C. DEQ —Division of Energy, Mineral and Land Resources 521 North Salisbury Street Raleigh, North Carolina 27611-7687 Subject: Wake Stone Corporation — Triangle Quarry Mining Permit No. 92-10 Responses to ADI Letter Dated February 10, 2021 Dear Mr. Miller, Busi -ess Office Address: P.O. Box 190 6821 Knightdale Blvd. Knightdale, N.C. 27545 (919)266-1100 Fax: (919) 266-1149 Please find attached duplicate copies of supplemental information pertinent to the pending Triangle Quarry Mining Permit Modification Application. Included in the data package submitted under this cover you will find: • A narrative response to the ADI questions, • An updated Piedmont Land Design Erosion and Sedimentation Control Plan, • An updated Piedmont Land Design Erosion Control Calculations, • An updated Wake Stone Corporation Site Plan drawing set, • The final noise study report prepared by WSP USA, Inc., and • A USB "thumb drive" containing digital copies of all the above documents. We believe these materials satisfactorily address the questions raised in the February 10, 2021 ADI letter. We look forward to your review of these materials as you prepare the modified Mining Permit for issuance. Please let us know if you have additional questions. Sincerely, Wake Stone Corporation C#6 N4;U- L. Cole Atkins Geologist/Environmental Specialist Response to ADI request dated February 10, 2021: 7. Please provide the following information for the proposed bridge: Design and construction sequencing details. Design considerations for wildlife passage along the Crabtree Creek corridor. A stormwater and sediment control management plan for run-on and runoff from the bridge. The request has not been met. Clarification of this statement was sought by Wake Stone by means of a Microsoft Teams meeting with DEMLR staff on February 25, 2021. Our understanding from that conversation is that these items are more specifically requested in subsequent comments, including 19(c), 19(k), 19(aa), and 19(cc) below. In addition, more detailed plans for piping of pit dewatering wastewater from the new pit across Crabtree Creek to the existing pit have been added to WSC Site Plans, page 11 of 12. 12. Please perform a noise study, that evaluates the potential for noise impacts to William B. Umstead State Park (Umstead Park). The protocol for the study must be approved by the Mining Program before the study is conducted. The results are pending. The Wake Stone Noise Study Protocol was submitted to the Mining Program on September 2, 2020. After Mining Program review, the study protocol was accepted by DEMLR with several additional requests and conditions as detailed in a letter from Mr. David Miller dated November 4, 2020 (letter attached). The study was conducted in accordance with this protocol, and a draft report was submitted to the Mining Program on February 11, 2021. Comments and requests for additional information regarding the noise study report were submitted to Wake Stone in a letter from Mr. David Miller dated February 25, 2021 (letter attached). Wake Stone has addressed these comments and requests with the help of acoustical engineering consultants WSP USA, Inc., and all responses have been incorporated into the final Wake Stone Triangle Quarry Expansion Acoustical Study report attached. 14. Please provide additional information regarding screening for the following locations: Future reserve section — The operation would be visible to 1-40 and parts of Old Reedy Creek Road. East side of the proposed pit — Pit operations may be visible from Umstead Park. Original WSC response: a) The future reserve area will not be logged or cleared as part of this permit action, and therefore provides 1000-1400 feet of undisturbed vegetation between Interstate 40 and the southern end of Old Reedy Creek Road from any proposed mining activity. In addition, the 1-40 right of way provides an additional 100-200 feet of dense vegetation, and the topography rises sharply above 1-40. The dense, mature hardwood and pine vegetation on this slope rises well above the line of site for any proposed mining activity. The photo below clearly illustrates that there is no need for additional screening in this area. However, conditions will be evaluated again at such time as a mining permit modification application is submitted to impact the future reserves, and additional berming and/or vegetative screening will be considered at that time if warranted. Additional Information: Wake Stone is confident that the proposed berm along Old Reedy Creek Road is more than adequate for visual screening of this area, particularly given that mining activities will not take place in this area as part of this permit action. Existing topography and vegetation will provide additional screening along 1-40. The photos attached (including the addition of winter photos) should clearly illustrate this visual screening. 1 b) On the east side of the proposed pit, additional undisturbed dense vegetation exists on both sides of Foxcroft Lake. Additionally, the topographic ridge east of Foxcroft Lake and the ridge across Crabtree Creek on the existing mine site (which extends 50 feet vertically above creek level) provide attenuation of line -of -site views from Umstead State Park. These buffered areas provide complete screening for most of the Park. The only area of the park with the potential for visibility into the mining operation is the small area immediately to the northeast of Foxcroft Lake along the property boundary. The photos below illustrate the dense vegetation on either side of Foxcroft Lake. The west side of the lake will have a 50'+ undisturbed buffer, and the topography rises 10-18 feet in elevation in this buffer. It is also important to note that initial stripping and pit development will be in the area west of Foxcroft Lake, which will very quickly put all mining activity in this area below grade and behind a cut -slope that will essentially act as an already vegetated, undisturbed visual and noise attenuating berm. If upon clearing the area west of Foxcroft Lake it is determined that operations are visible from the park, additional screening could be added in the form of dense evergreen vegetation or fabric screening on the proposed security fence. Additional Information: Additional photographs (during the winter season), taken from the same locations below, show that the density of tree vegetation provides excellent visual screening from Umstead Park. It is important to note that there are no established trails in this area of Umstead Park, and that any mining activity that may be visible from immediately at the property line would only be during the initial overburden removal period. Fence fabric (such as illustrated below) could be utilized during this brief phase of mine development if needed. Also, Operating Condition 12 (C) of the current mining permit stipulates that "Other berms may be required as mining progresses to reduce the noise and visual impact upon Umstead State Park." Wake Stone anticipates this condition will remain in the modified permit and will address the need for additional screening as deemed necessary by the Division. Photo Locations 1 Photo 1 Photo 2 Photo 3 14 Ps ` v p 4 p¢ R h r l NW s oR.�� f1Ai 5 �i�•� I W tL1 IV It 6 1 - - Available Galars Example of fence fabric that could be used for visual screening 19. Please provide the following revisions to the plan drawings: A detailed construction sequence addressing practices that will prevent sediment loss to Crabtree Creek during retaining wall and bridge construction. REVISIONS NEEDED: Notes 2 and 3 of Bridge Construction Schedule must be revised to clarify that initial clearing and grubbing will be limited to that which is necessary to install perimeter erosion and sedimentation control (ESC) measures. After perimeter ESC measures are installed, additional clearing and grubbing may progress. Bridge Construction Schedule notes have been revised on Erosion Control Plan SITE 1 to clearly specify that clearing and grubbing will be limited to those areas required for installation of perimeter erosion and sediment control measures. Additional clearing and grubbing for bridge construction will not commence until installation of those measures is complete. k. Planting plan (riparian where required) for screening and stabilization adjacent to proposed headwall. REVISION NEEDED: A riparian seed mix should be specified. Proposed limits of disturbance do appear to include a portion of the riparian buffer. Wake Stone intends to minimize disturbance to the riparian buffer to the maximum extent practicable, and absolutely will not disturb any riparian buffer outside of the area illustrated on the Neuse Buffer Authorization approved by the Division of Water Resources on June 4, 2020. The approved impacts to the riparian buffer are permanent and will consist of bridge end bents and wing walls, with compacted fill up to bridge elevation. However, should it be determined that incidental impacts within the approved area can be returned to functional riparian zones, a riparian seed mix, as illustrated on Erosion Control Plan SITE 10, will be utilized. Silt bag detail and maintenance requirements. ADDITIONAL DISCUSSION RECOMMENDED: To maximize water quality, specification of a floating intake for the pump located within the skimmer cell is preferred. Regardless of method used, care is to be taken to prevent withdrawing sediment from the bottom of the basin. A note has been added to the SILT BAG detail on Erosion Control Plan SITE 10 that a floating intake for dewatering of basins will be used where practicable if or when a silt bag is utilized. However, it should be noted that dewatering of a skimmer basin for maintenance, removal, or conversion is typically a water depth of a few inches or less. Cavitation as a result of using a floating intake is just as likely to stir up sediment due to the shallow water depth. That is why Wake Stone's preference (as previously indicated) for dewatering basins is to pump the water to the quarry pit where more effective settling and treatment for water quality is possible. Wake Stone will take all necessary steps to ensure that water quality is maximized no matter what method of dewatering is utilized. Plans showing diversion ditches routed so that discharge passes through at least 2 baffles prior to entering skimmer cell. Lower diversion ditch enters basins 5 & 6 in the skimmer cell. ADDITIONAL CLARIFICATION REQUIRED: Slope drains have been added to address this comment. These slope drains cross the length of basin 5. Once the basin filles with water, the Program are concerned about damage to or inoperability of the drains, primarily due to potential for them to float. Please provide more details regarding the hold down stakes in the slope drain construction details. An additional detail for hold down stakes located within the impoundment area of the basins is required if the standard method is insufficient to resist flotation. STANDARD TEMPORARY SLOPE DRAIN detail on Erosion Control Plan SITE 10 has been modified to illustrate the use of a horizontal stake across the top of the slope drain and attached to the vertical hold-down stakes to prevent floatation. Clarification that the location of the diversion ditch between basins 5 & 6 is correct. ADDITIONAL DISCUSSION RECOMMENDED: The diversion ditches bypassing these basins are very long and makes sharp directional changes to convey bypass flow to basin 4. The Division would like to recommend: That these ditches be surveyed upon completion to confirm positive drainage throughout. Although the Division has reviewed the design calculations and they technically do not support it, permanent turf reinforcement matting in ditches 1A, 1B, and 2 due to their unusually long length and duration of anticipated use, is advisable. If acceptable drawing notes need to reflect this. Wake Stone will survey both diversion ditches before, during, and after construction to ensure positive drainage throughout. However, the use of permanent turf reinforcement is not supported by the design calculations. Furthermore, as overburden removal progresses, the drainage areas for both diversions will be continuously reduced until eventually all drainage is to the newly established pit. These diversions were developed using the 25-year design storm only because they may be in place for more than one year. They are not, however, permanent structures, and therefore do not require permanent turf reinforcement. Reconciliation of the access road it is shown in the undisturbed buffer (sheet 4). REVISION NEEDED: There is still a section of the access road that is in the undisturbed buffer. Road alignment should be adjusted so that it is outside the proposed undisturbed buffer. All existing and proposed haul/access roads should be shown and labeled throughout the entire site. Appears that new security fencing impacts access roads. The short section of the access road that appears to be in the undisturbed buffer is an existing road. No improvements for this access road (other than the construction entrance as indicated on Erosion Control Plan SITE 4) will be required. This road will only be utilized for initial access to the property for installation of erosion and sediment control measures and for bridge construction activities. Once erosion and sediment control measures are in place, the new proposed construction entrance will be utilized exclusively, and any portions of the existing road that are shown in the undisturbed buffer, crossed by the proposed security fence, or under the footprint of the proposed berm will be abandoned. A locking gate has also been illustrated on the Erosion Control Plan at the proposed relocated entrance, and details for the gate have been added to the WSC Site Plan detail on page 10 of 12. Notes have also been added to the WSC Site Plans to clarify existing and proposed roads. Identification of pipe and culvert sizes on the plan sheets. REVISION, OR CLARIFICATION NEEDED: There is a temporary pipe located at the second entrance. In previous conversations, Wake Stone intended to leave this entrance in permanently to serve as access for emergency vehicles. If this pipe is permanent, add to energy dissipator table on Drawing "Site 11". Add inlet and outlet pipe protection for this culvert pipe. The label for the 15" pipe in the existing ditch at the proposed relocated construction entrance has been corrected to "PERMANENT" instead of "TEMPORARY." This pipe has been labeled PIPE #3, inlet and outlet protection are illustrated, and details have been added to ENERGY DISSIPATER DETAILS on Erosion Control Plan SITE 11. X. The symbol used for silt fence must be distinct and not hidden beneath the line type used to delineate the limits of disturbance. See ee, below. aa. A supplemented seeding and planting plan that considers native vegetation in and around riparian areas. See k, above. CC. Provide additional erosion and sedimentation control measures as required to protect the stream, all public, and private property from damage. REVISION NEEDED: Extend perimeter silt fencing on the basin 7 side of bridge as is on the opposite side of bridge. See Erosion Control Plan SITE 2, 5, 7, and 8. Silt fence has been extended, and additional silt fence has been provided for construction of temporary basin 7. II. It appears the wall construction coincides with the footprint of basin 7. Please detail construction sequencing to confirm no impact to ESC measures. The retaining wall construction does in fact coincide with the footprint of temporary basin 7. Basin 7 will be utilized during bridge construction and perimeter road improvements. However, this section of retaining wall will be the last section constructed, at which time the remainder of the perimeter road will have been widened and all drainage directed into the existing pit. Once all drainage is directed to the pit, the basin will be removed, and the retaining wall constructed and backfilled to also drain to the existing pit. III. Show locations of stockpiles and concrete washouts. Temporary stockpile and concrete washout locations have been added to all Erosion Control Plan and WSC Site Plan maps. IV. Fence disturbance should be added to the acreage table in the permit. Fence area will be added to the acreage table on WSC Site Plans for informational purposes. It will not be added to the affected area for purposes of the mining permit for the following reasons: 1. As indicated on the Erosion Control Plan, the fence area "will not be cleared — stumps will remain or be grinded and used as mulch for ground cover" 2. Tree removal will be limited to the maximum extent practicable, and NO trees greater than 5" DBH or 6" stump diameter will be removed in Zone 1 of riparian buffers 3. No stumping, grubbing, or grading will be done in the area designated for fence construction. 4. The categories of land disturbance include: Tailings Ponds, Stock Piles, Waste Piles, Plant Area, and Mine Excavation. Minimal tree cutting and fence construction does NOT fall into any of these categories of land disturbance or affected acreage. Further explanation of "affected area" vs land disturbance is provided in item #20 below. V. Recommend wildlife friendly netting be used. Wildlife friendly netting will be used where practicable. ee. A minimum of 5 feet between the toe of the slope and the installation of the silt fence. REVISION, OR CLARIFICATION NEEDED: The location near Old Reedy Creek Road parallel to 1-40, it appears the silt fence is on the undisturbed buffer line. The security fence is shown between the silt fence and the slope. Is there adequate room to maintain or replace silt fence without entering into the undisturbed buffer? Sediment and erosion control measures may not be located within the undisturbed buffer. Please supply more information concerning this location. The undisturbed buffer as illustrated in this area on Erosion Control Plan SITE 6 is the area between the hatched pattern for the security fence area and the blue dashed property line (1-40 right of way). There is no land disturbance proposed in this area, and therefore no toe of any slope. The only slope is existing natural ground. The silt fence was proposed within the security fence construction area as an additional safeguard for construction of the security fence. Several feet between the proposed security fence and the silt fence provides plenty of room to maintain or replace silt fence without entering the undisturbed buffer. No sediment and erosion control measures are proposed to be located within the undisturbed buffer. ff. Adequate space for the installation, maintenance and removal of perimeter silt fence. Specific maintenance requirements for all proposed sediment and erosion control structures included on the plan. See ee, above. gg. A plan detail and construction specifications for the silt fence and silt fence outlet that complies with the skirt trench requirements per the Erosion and Sediment Control Planning and Design Manual. The skirt is to be trenched in, at a minimum, 8 inches vertically and 4 inches horizontally. REVISION NEEDED: The silt fence outlet detail needs to be revised to reflect an 8" trench, not 6". This correction has been made on the STANDARD SILT FENCE OUTLET detail on Erosion Control Plan SITE 10. hh. A structure/device for dewatering the temporary basins prior to removal and/or conversion to a permanent structure. Provide a plan detail, construction specifications, and maintenance requirements for this device. Include the use of this device in the construction sequence. See I, above. Construction specifications for the skimmer basin are to include the excavation, embankment construction, spillway construction, and skimmer basin installation. Specify on the plan detail that an impermeable liner is to be installed on the spillway. The emergency spillway is to be installed in undisturbed ground (not over the skimmer pipe). Include a stone pad for the skimmer to rest upon and a rope attached to the skimmer for maintenance in the plan detail. Include the basin surface area dimensions, depth, side slopes, dam height, embankment width, length of emergency spillway, skimmer size, skimmer orifice size, and dewatering time on the plan sheets. REVISION NEEDED: Overland flow is still entering basin 4 as sheet flow from the upgradient area. Diversion ditches 10, 11, and 12 and an additional slope drain and energy dissipater have been added to prevent overland flow directly into basin 4. Locations are illustrated on Erosion Control Plan SITE 5 and 7, and energy dissipater details are included on SITE 11. nn. Provide design calculations, a plan detail, construction specifications, and maintenance requirements for the outlet stabilization structures. Construction specifications for the outlet stabilization structure are to include the width of the apron at the pipe outlet and at the end of the apron, the length of the apron, the stone size, and depth of stone. REVISION, OR CLARIFICATION NEEDED: Normal standard is that any basin expected to have a life of 1 year or more should be designed based on the 25-year storm. Applicant needs to specify how long each basin will remain in use. On Erosion Control Plan SITE 12, "Expected Duration of Use" has been added to the Table SKIMMER SEDIMENT BASIN DESIGN DATA. 20. New issue raised by modification to application: On the original Erosion Control Plan and Wake Stone Site Plans, a fifty -foot undisturbed buffer was illustrated along the northern proposed permit boundary, with a security fence as proposed by RDU Airport Authority. RDUAA proposed only ten feet of undisturbed buffer with a thirty-foot clearing for the security fence, essentially clearing our proposed buffer. Therefore, after negotiations with RDUAA, Wake Stone has agreed to provide the security fence for the Odd Fellows tract. Wake Stone will still be required to use the style of fence proposed by RDUAA as illustrated "Typical RDU Security Fence" on page 10 of 11 of WSC Site Plans, but instead of a ten -foot undisturbed buffer and thirty-foot clearing, we are proposing a 25-foot undisturbed buffer, a 10-foot clearing outside the fence, and 15-foot clearing inside the fence. However, the clearing for the fence will only be removal of vegetation; stumps will either remain or be ground in place, and mulch used for ground cover. No clearing will take place in zone 1 of the Neuse Buffer and only minimal clearing of vegetation in zone 2 in order to continue the fence across the buffers around Foxcroft Lake and to extend to Crabtree Creek at the western and eastern property boundaries. This fence installation was not included in the first submittal package that underwent our initial review and public comment. 1) Due to the fence installation, the undisturbed buffer has been reduced from 50' to 25'. 2) Trees will be removed as part of the installation. Per the Riparian Neuse Buffer Rules, effective June 15, 2020, fence installation that results in the removal of trees from Zone 1 is Allowable with Authorization. Buffer Authorization is required. Please provide a copy of this authorization. 3) Include all fence installation areas within Limits of Disturbance table shown on drawing 2 of 11, and 3 of 11 of Site Plan Map. WSC Response 20. 1) On the Erosion and Sediment Control Plan and Wake Stone Site Plans accompanying the April 8, 2020 Mining Permit Modification Application, a fifty -foot undisturbed buffer was illustrated along the northern and western proposed permit boundaries. Within that proposed buffer, a perimeter security fence as then proposed by RDU Airport Authority was also illustrated. RDUAA's proposed fencing plan would have provided only ten feet of undisturbed buffer setback from the property line, with a thirty- foot clearing proposed for security fence installation and a maintenance/patrol corridor. RDUAA temporarily halted their security fencing plan to address public concern, and ultimately removed the Odd Fellows tract from the overall fence plan. In so doing, RDUAA and WSC agreed that WSC would install security fencing of a comparable style to that proposed by RDUAA. WSC recognized this as an opportunity to provide a greater width undisturbed existing vegetation buffer along the northern and western property/permit boundaries. In our January 11, 2021 response to Item 20 of the July 23, 2020 ADI letter we provided the following discussion: "Additional Considerations: On the original Erosion Control Plan and Wake Stone Site Plans, a fifty -foot undisturbed buffer was illustrated along the northern proposed permit boundary, with a security fence as proposed by RDU Airport Authority. RDUAA proposed only ten feet of undisturbed buffer with a thirty-foot clearing for the security fence, essentially clearing our proposed buffer. Therefore, after negotiations with RDUAA, Wake Stone has agreed to provide the security fence for the Odd Fellows tract. Wake Stone will still be required to use the style of fence proposed by RDUAA as illustrated "Typical RDU Security Fence" on page 10 of 11 of WSC Site Plans, but instead of a ten -foot undisturbed buffer and thirty-foot clearing, we are proposing a 25-foot undisturbed buffer, a 10-foot clearing outside the fence, and 15-foot clearing inside the fence. However, the clearing for the fence will only be removal of vegetation; stumps will either remain or be ground in place, and mulch used for ground cover. No clearing will take place in zone 1 of the Neuse Buffer and only minimal clearing of vegetation in zone 2 in order to continue the fence across the buffers around Foxcroft Lake and to extend to Crabtree Creek at the western and eastern property boundaries." We also provided revised Erosion and Sediment Control Plan and Site Plan drawing sets illustrating the revised security fence and expanded undisturbed buffers. We believed we had clearly stated our plans for installing perimeter fencing by removal of only the minimal vegetation necessary, and without soil surface disturbance (clearing and grubbing). To reiterate this plan, our intention is to retain an undisturbed 25' wide buffer of existing vegetation along the northern and western permit boundaries. On the mine side of these undisturbed buffers, we plan to remove only such vegetation as necessary to install the RDUAA stipulated chain -link security fencing. No grubbing activities are planned. Tree stumps within the fence alignment will be shredded/mulched to land surface and the mulch used as ground cover. Any other trees cut for fence installation or future maintenance will be cut as near ground level as possible. The stumps will be left intact. Tree trunks and limbs will be removed using small rubber tracked skid -steer loaders. Fence post holes will be installed using the same small rubber -tracked skid -steer with 12" power auger attachment. Concrete for post anchors will be placed using the same small equipment. 20. 2) As we stated in the "Additional Considerations" paragraph of the January 11, 2021 supplemental data submittal, WSC will not remove trees within Zone 1 of the Neuse River Riparian Buffer area. Pursuant to 15A NCAC 02B .0714 (11) (f) (ii), fences are allowed within the Neuse River Riparian Buffer if "installation does not result in removal of trees from Zone 1". Per supporting information found at 15A NCAC 02B .0610 (40), "Tree means a woody plant with a DBH equal to or exceeding five inches or a stump diameter exceeding six inches." DBH is defined at 15A NCAC 02B .0610 (9) to mean "diameter at breast height of a tree measured 4.5 feet above ground surface level". During installation of the proposed perimeter security fence through any portion of Zone 1 of the Neuse River Riparian Buffer areas associated with Foxcroft Lake or Crabtree Creek, no trees with a DBH equal to or greater than five inches or having a stump diameter exceeding six inches will be removed. Under these constraints, no Neuse River Riparian Buffer Authorization is required for construction of said fencing. 20.3) A new hatch pattern for the fence construction zone has been added to Site Plan Maps and corresponding legends. Areas of fence installation have been tabulated and are included on pages 2 of 12 and 3 of 12 of the Site Plan Maps as a "special land use category" per your request. The tables illustrated on these pages however represent "Affected Areas" under the mining program which are typically used for the purposes of quantifying and tracking mine reclamation requirements. "Affected land" as defined in the Mining Act of 1971 (N.C. General Statutes, Chapter 74) is "the surface area of land that is mined, the surface area of land associated with a mining activity so that soil is exposed to accelerated erosion, the surface area of land on which overburden and waste is deposited, and the surface area of land used for processing or treatment plant, stockpiles, nonpublic roads, and settling ponds". Minimal tree removal with stumps either left in place or ground, and mulch used for stabilization, does not constitute soil being exposed to accelerated erosion. Furthermore, in the absence of inclusion in the categories of tailings ponds, stock piles, waste piles, plant area, or mine excavation, this area should not be considered "affected" for purposes of this mining permit modification application. The security fence construction area is however included in the Limits of Disturbance, as illustrated in the Erosion Control Plan. ROY COOPER Governor MICHAEL S. REGAN Secretary BRIAN WRENN Director Sam Bratton Wake Stone Corporation P O Box 190 Knightdale, NC 27545 NORTH CAROLINA Environmental Quality November 4, 2020 RE: Wake Stone Quarry Noise Study Protocol Permit No. 92-10 Cary (Triangle) Quarry Wake County Neuse River Basin Dear Bratton: After carefully reviewing the proposed Wake Stone Quarry noise study protocol, the Mining Program has the following comments: 1. Wake Stone will make all reasonable attempts to conduct two production shots as part of normal operations during the monitoring period. 2. Please place short-term noise meters at the following locations: i. At the two points where the property line cross the east and west ridgelines caused by the stream feeding Foxcoft Lake. ii. At the intersection of Old Reedy Creek Road and 1-40. 3. The short-term meters are required to monitor noise multiple times a day, during periods of quarry operation and during periods when the quarry is not operating. 4. Upon completion of the report, a draft copy of the report will be provided to the Mining Program for comment before the final is submitted. 5. Please provide production information for the two -week prior, the week of, and the two weeks after the monitoring study for the following: i. Primary Crusher: A. Daily hours operated B. Tons produced per day ii. Finishing Yard: A. Daily hours operated B. Daily total tons produced If these conditions are acceptable to you, please consider the protocol approved. If these conditions are not acceptable, please contact either Brian Wrenn or me to discuss the matter. As we have discussed, we would like to schedule a videoconference between your company, the Mining Program, and your consultant to discuss the study and how the final report output will be presented. The Mining Program staff will be in contact you shortly to set up this videoconference. D_E Q - North Carolina Department of Environmental Quality I Division of Energy. Mineral and Land Resources 512 North Salisbury Street 11612 Mail Service Center I Raleigh, North Carolina 27699-1612 �� 919.707.9200 If you have any questions or comments, please feel free to contact me at 919-707-9228. Sincerely v David Miller, PE State Mining Engineer Land Quality Section DM/bh cc: Mr. Bill Denton, PE ROY COOPER Governor MIC14AEL S. REGAN Secretary BRIAN WRENN Director Mr. Samuel T. Bratton President and CEO Wake Stone Corporation P O Box 190 Knightdale, NC 27545 NORTH CAROLINA Environmental Quality February 25, 2021 Subject: Cary (Triangle) Quarry's Draft Noise Study Mining Permit No. 92-10 Wake County Neuse River Basin Dear Mr. Bratton: I would like to take this opportunity to thank you and your staff at Wake Stone for allowing me and the staff of DEMLR the opportunity to review and discuss your proposed draft of the Wake Stone Triangle Quarry Expansion Acoustical Study. General Comments: A 10dBA increase/decrease seems to be coarse measure of significant impact. The Division understands that this standard is used by NCDOT and other agencies evaluating noise impacts. However, considering a state park is adjacent to the proposed quarry, the Division believes a more conservative standard should be considered. Please provide further justification for a use of this standard. During our discussion, Wake Stone described several conservative assumptions that were included in the model. Please provide a comprehensive list of these assumptions. Report Specific Comments: • Please include further discussion of the usage factors for equipment noise implemented in the modeling (p. 18). • On p. 17, a ground factor of G=0.5 was used for the quarry. Please provide a discussion explaining why this is appropriate. • Table 4, p. 20 — Please provide a detailed explanation of how the "existing 1-40 traffic" was modeled. • Blasting noise discussion p. 22 — Please explain how the blasting noise ranges compare similarly between the existing and proposed pits. The maximum blasting noise from the proposed pit seems significantly higher than the existing pit. • Footnote of Table 6, p. 22 — Please provide an explanation of how blast noise is not used for compliance purposes. Per our discussion, you indicated that the blast noise was included in the hourly averaging of the study. Please describe this. • Please describe why back-up alarms were not included in noise study. D_EQ�� North Carolina Department of Environmental Quality I Division of Energy. Mineral and land Resources 512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612 919.707.9200 Figure. 12 legend — Please provide color blocks for different dB ranges. It is difficult to discern colors using lines in legend. Figure. 14 — Please provide transparency for the color ranges so that the base layer map and landmarks can be seen. Please contact me if any further clarifications concerning the above are needed. I can be reached at: 919-707-9228. Sincerely, _ David Miller State Mining Engineer CC. Bill Denton PE., RRO