HomeMy WebLinkAboutletter to Judy Final 12-17-2019December 17, 2019
Ms. Judith A. Wehner
NCDEQ
512 N. Salisbury St.
Raleigh, NC 27699
RE: Proposed Alamance Quarry and Construction Materials Quarry
Alamance County
Cape Fear River Basin
Dear Ms. Wehner,
We have reviewed your letter of June 21, 2019 requesting additional information. We have
revised and/or added the appropriate information that was requested. Please review the below
and included information to see that it is satisfactory. Should there be any more additional
requests, please reach out directly and we will ensure that it is provided timely.
Sincerely,
Chad Threatt
Revised Information to North Carolina Environmental Quality Questions 1 Through 6
• Send certified mail; return receipt requested letters to Duke Power Company and
Colonial Pipeline outlining the proposed access across the rights -of -way. Provide copies
of said letters and signed return receipts.
o Please see the attached certified mail receipt and letters.
Provide a thorough geologic investigation of the site that outlines any fractures, dikes,
rock type, radon presence etc. See the comments provided by the NC Geological
Survey. Determine the location of the diabase dikes in the area by acceptable methods,
such as magnetometer.
o Please see the attached Geologic and Geophysical Investigation report from
Timothy W. Clark, P.G.
Provide results of an on -site pump test and modeling of ground water movement.
Determine the possible impact of the diabase dikes may have on the area ground water
wells with respect to the dewatering activities. Revise the ground water monitoring plan
to include the requested studies. Note that conditions may be placed in any issued
permit that will require well replacement or deepening of impacted wells.
o Please see the attached report from Groundwater Management Associates. Inc.
See the Attachment 1 provided to this office by Colonial Pipeline Company regarding
blasting operations. Note that any permit issued will require adherence to the
recommendations and may contain additional conditions required by the Department.
o We are communicating with Colonial Pipeline to meet their request.
See the enclosed comments from the Winston Salem Regional Office regarding the
erosion and sediment control plan review submitted with the application. Address all of
these issues.
o Please see the below remarks to the Winston Salem Regional Office comments.
Provide a construction sequence and staged seeding for the overburden storage area.
o Please see the attached updated plans.
Comments to Winston Salem Regional Office Questions 1 Through 22
Sediment skimmer basins must be designed for the 25-year storm. As submitted, the
sediment skimmer basins have been designed for the 10-year storm. Please revise.
o All Skimmer basins have been resized for a 25-year storm (1=8.02 in/hr.)
Auxiliary spillways for sediment skimmer basins may not be shown within fill material for
each basin.
o Majority of the spillways are now in the cut areas. Skimmer 6, 7, 11, 22, and 25
all have spillways in fill material because the skimmer outlet pipe had constraints
(stream buffer, property line, etc.) which required the bottom elevation to be
raised, resulting in a basin that is in fill.
• Please provide match lines on sheets C3O1A through C301 F
o Match lines added to drawing.
• Final plans submitted for review may not be stamped "Preliminary — Not for
Construction".
o The "Not for Construction" note has been removed
A detailed construction sequence must be sown on sheet C301 B for the installation of
the proposed 24' arch span culvert and the proposed retaining wall. The construction
sequence must include sediment controls for areas adjacent to the stream during the
culvert placement and retaining wall construction. Also, particular attention must be
given to maintain the stream buffers for the maximum duration possible during culvert
placement. Construction drawings must also show fill placement on either side of the
stream as the road fill retaining walls are brought to final grade.
o Construction sequence has been added along with additional erosion control
measures. Additionally, all backfill for the wall and roadway will be clean washed
stone for the entire length of the walls.
No sediment control measures have been shown for the proposed fence clearing around
the perimeter of the property. Please provide acceptable sediment control measures for
these areas.
o Added silt fence on the down -slope side of security fencing.
Please note the following comments addressing permanent ditch placement and
stabilization:
o All proposed ditches must be assigned a specific number (i.e., #1, #2, #3, etc.)
corresponding to the design calculations. In addition, a schedule must be
provided on the detail sheets of the plans showing each proposed ditch and
methods for stabilization
■ Design calculations have been numbered; also, added ditch numbers and
a stabilization schedule to sheet C 301A and C402
o The following proposed permanent ditches may not be constructed as shown
with temporary diversions shown within the ditch line: (1) FES #1 to 6+50, (2)
FES #2 to 6+50, (3) 7+00 to 14+00 (West), (4) 8+50 to 14+00 (East), (5) Access
road (East side) 14+00 to stream buffer, (6) Access road (West side) 14+00 to
stream buffer, (7) Access road (East side) 17+50 to 20+00, (8) Access road
(West side) stream buffer to 20+00.
■ Removed the temporary diversions and relocated the skimmer basins so
that the ditches flow into the temporary skimmer basins
o An adequate sediment control measure must be placed at the outlet of the
access road ditch (East side) stations 18+50 to stream buffer.
■ Skimmer basin intercepts all flow from ditch
o An adequate sediment control measure must be places at the outlet of the ditch
from the outlet of sediment skimmer basin #8 to the stream buffer. Note: the
drainage for this ditch is 4.86 acres, which would necessitate the use of sediment
skimmer basin.
■ Outlet ditch will only have flow during events in which skimmer 8 utilizes
the emergency spillway.
o An adequate sediment control measure must be placed at the outlet of the ditch
from the outlet of sediment skimmer basin #11 to the stream buffer. Note: the
drainage for this ditch is 3.S8 acres, which would necessitate the use of sediment
skimmer basin.
■ Ditch has been removed and skimmer 11 has been shifted and upsized.
o Adequate sediment control measures are needed at the outlets of ditches
discharging toward Clark Road. In addition, a rock check dam will need to be
placed in the ditch along Clark Road below the outlet of FES#2.
■ Skimmers now intercept all flow from ditches. Also, a check dam was
added downstream of FES 2.
o Ditches adjacent to sediment skimmer basins #4, #5, #6, and #7 are required to
discharge into the sediment skimmer basins. As shown, discharges are routed
around the basins.
■ Relocated Skimmers to intercept all upslope ditch flows
• No adequate sediment control measures have been shown below the fill slope north
east of proposed sediment skimmer basin #7. In addition, proposed fill in this area is
shown within the proposed temporary diversion berm, which is not acceptable.
o Changed grading in area, which eliminated the need for additional sediment
control measures.
• It appears that permanent storm water control measures will be needed within the
proposed plant areas located west of the proposed pit excavation. In addition, the
temporary diversion berms that have been shown will not function properly on fill
material and cannot be properly maintained throughout the grading process.
o Per our phone conversation on 7/15/19, no permanent storm water measures will
be necessary as the site will be permanently stabilized after construction
activities. Sheet flow will be provided in a stable manner through the preserved
stream buffers.
• Proposed baffles within sediment skimmer basins must be located such that runoff
entering each basin will be filtered through three baffles. Please reevaluate baffle place
placement and the temporary diversion berm configuration such that this requirement
may be properly addressed.
o Baffles were reevaluated and moved to ensure flow through three baffles is
possible; please see sheet C 302.
It appears that sediment skimmer basin #13 could be relocated further to the east (back
uphill) so that additional areas below the basin would not have to be cleared. In addition,
the temporary diversion berms leading to sediment skimmer basin #13 may not be
shown directing site runoff over constructed fill slopes.
o Basin 13 has been moved uphill; a temporary slope drain with temporary
diversions at the top of the slope have been added
Please provide reasoning to support the clearing of additional areas as noted below:
o Areas below the proposed temporary diversions around sediment skimmer basin
#23.
■ It is all within the mine area
o Areas around sediment skimmer basin #25.
■ Within the mine area
o Areas shown as being graded below sediment basin #1.
■ Clearing is necessary for fence installation, basin installation, pipe
installation and spillway installation. Additional cleared area is also
needed for access and maintenance of skimmer.
o Areas around sediment skimmer basin #2.
■ Construction for temporary diversions, skimmer basin, silt fence, security
fence, and access for maintenance.
o Areas around sediment skimmer basin #3.
■ Construction for temporary diversions, skimmer basin, silt fence, security
fence, and access for maintenance.
o Areas around sediment skimmer basin #12.
■ Construction for temporary diversions, skimmer basin, silt fence, security
fence, and access for maintenance.
o Areas around sediment skimmer basin #14.
■ Construction for temporary diversions, skimmer basin, silt fence, security
fence, 8' berm and access for maintenance.
o Areas around sediment skimmer basin #15, also ensure that discharge from
FES#4 is directed into skimmer basin #15.
■ Construction for temporary diversions, skimmer basin, silt fence, security
fence, 8' berm and access for maintenance.
o Areas around sediment skimmer basin #26.
■ Within the Mine area.
o Areas around sediment skimmer basin #27.
■ Within the Mine area
o Areas around sediment skimmer basin #24 (Note: clearing has been shown
through the 50' undisturbed buffer below sediment skimmer basin #24).
■ The Owner has changed the mining limits. Clearing will not occur within
the 50' stream buffer.
• Provide sediment control measures for the perimeter fence installation through the 50'
undisturbed buffer zone shown on sheet C3O1 E.
o Fence to clear span the jurisdictional area.
On sheet C3O1 E, sufficient sediment control measures must be shown on the south
side of the processing area (east of sediment skimmer basin #12). The temporary
diversion berm that has been shown will not function as intended because it will not have
positive drainage toward sediment skimmer basin #12. Also, areas have been shown
graded such that they will be directed into the 50' undisturbed buffer zone, which is not
acceptable.
o Added an additional skimmer basin and modified temporary diversions.
At numerous locations on the plan the disturbed limits have encroached into the
proposed 50' buffer zone. Please amend the plans to show no encroachments into the
50' buffer zone. Due to weight of plotted lines it appears that it crosses the into the 50'
buffer. After closer review all contours tie out just outside of 50' buffer.
o Additional notes on C301 have been added to instruct contractors to stay out of
50' stream buffer
• No sediment control measures have been provided for the "emergency access road". It
appears that this area will need to be disturbed to have proper drainage for vehicle
TKW-1311
o Access road will not be graded or altered other than the addition of 8" ABC stone.
An acceptable sediment control measure is needed below the north side of the proposed
8' tall berm shown on sheet C3O1 E. The proposed check dam is not an acceptable
sediment control measure.
o Existing Contours are sloping towards the stream buffer. The drainage area is
minimal; therefore, the stone outlets and sediment fence will suffice in this
particular location per our phone conversation on 7/15/19.
Acceptable sediment control measures must be shown below the construction of
proposed tailings pond #2. Silt fence shown below this measure is not an acceptable
sediment control measure. In addition, basin construction is encroaching into the 50'
undisturbed buffer zone.
o Tailing pond #2 has been relocated and re -graded
Additional silt fence outlets must be shown below the 8' proposed berm on sheet
C3O1 C.
o Added additional stone outlets.
A number of the temporary berms shown on the plan do not appear to be "temporary"
structures. Any "temporary" diversion berms used for permanent storm water
conveyance must be accompanied by design calculations and construction details.
o All diversions shown on the plan are temporary. Once construction activities are
complete the berms are to be removed and the site stabilized to ensure sheet
flow across site into stream buffers
• Provide elevations for the temporary diversion berm upstream of FES#9 to show that the
diversion will actually direct runoff into skimmer basin #8 and not through the pipe inlet at
FES#9. Should this not be the case, calculations for skimmer basin #22 will need to be
revised for the additional drainage area.
o Skimmer #22 was upsized to accommodate the additional drainage area
No sediment control measures have been shown west of the temporary diversion
directing runoff into skimmer basin #10. Only a perimeter security fence has been shown
below the basin.
o Added additional silt fence. We appreciate your assistance to date with this
project. If any additional items, beyond these comments are noted, hopefully, we
can obtain an approval with modifications.