HomeMy WebLinkAbout17-02 adilet 2019ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. Daniel Smith
Director
Certified Mail
Return Receipt Requested
7016 2140 0000 0565 1741
Mr. Scott Martino
Carolina Sunrock LLC
200 Horizon Drive, Suite 100
Raleigh, North Carolina 27615
NORTH CAROLINA
Environmental Quality
November 21, 2019
RE: Proposed Prospect Hill Quarry and Distribution Center
Caswell County
Roanoke River Basin
Dear Mr. Martino:
We have reviewed the application your company submitted for the referenced mine site.
In order for this office to complete its review of the referenced project in accordance with GS
74-50 and 51 of the Mining Act of 1971, please provide the additional or revised information in
accordance with the following comments:
1. Provide proof, such as copies of the signed return receipts from certified mail,
that the following adjoining landowners have been properly notified: Bethel UMC,
Phillip & Susan Allen, Scott Wilson-Houghtallen, Sara Cook, Richard & Jerry
Cates, Georgia P Lewis, William & Donna Brown, William Morris & Rita Hudgins,
Susan Hester and C S Painter Lands. If the notices have been returned as
"unclaimed", provide a copy of the envelope with the postal service sticker.
2. Please find enclosed two pieces of correspondence from the Department of
Cultural Resources regarding the proposed site. Please provide proof your
company has contacted the Department regarding the archeological field
investigation, including the location of the historical cemeteries. Any cemeteries
found must be located on the mine map with appropriate buffers.
3. Please find enclosed comments from the North Carolina Wildlife Resources
Commission regarding the proposed operation. Address all of the concerns
outlined in the memorandum.
North Carolina Department of Environmental Quality ► Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
c�N cnnaiun
919.707.9200
Certified Mail
Mr. Martino
Page 2
4. Provide proof that your company has obtained a valid wetland delineation
approved by the US Army Corps of Engineers and the necessary permits from
the Division of Water Resources to impact the large number of streams.
Enclosed are comments from that agency.
5. See the comments provided by the Ground Water Management Branch.
Because of inaccuracies in the pumping test procedures, re -perform the pumping
test and obtain a more accurate zone of influence. Provide an acceptable
monitoring plan consisting of a series of monitoring wells as mining progresses to
protect the potable water supply wells in the area. See the recommendations in
said comments. Include unfiltered testing of the wells for all of the metals on the
sample result sheets submitted with the hydrogeological study. Include an
adverse impact letter stating what steps your company will take if dewatering
activities at the mine should happen to impact any existing water supply well.
6. Please detail (list) the types of NPDES permits for mining and all other proposed
industrial activities for the subject site. Also include proof that your company is
obtaining all necessary NPDES permits for storm water and pit water discharge,
including an acceptable operations and maintenance plan to protect wetlands
and water ways.
7. Provide proof that your company has obtained a valid Air Quality permit for the
proposed operation.
8. Provide proof that the operation will not have an adverse effect on the Roxboro
Lake as it is a publicly owned recreation area.
9. The North Carolina Geological Survey has stated the site is located within the
Slate Belt and may have asbestos within the mined material. Explain how your
company will protect those individuals near the site from being affected by the
asbestos. In addition, provide proof that the release of radon will not be an issue.
10. See the email from the Winston Salem Regional Office regarding the erosion and
sediment control plan submitted with your company's application. The erosion
and sediment control issues noted in the email from the Winston Salem Regional
Office staff must be completely addressed.
Please note, this office may request additional information, not included in this letter, as
the mining application review progresses.
Please be advised that our review cannot be completed until all of the items listed
above have been fully addressed.
Certified Mail
Mr. Martino
Page 3
In order to complete the processing of your application, please forward two (2) copies of
the requested information to my attention at the following address:
Division of Energy, Mineral Land Resources
Department of Environmental Quality
1612 Mail Service Center
Raleigh, NC 27699-1612
As required by 15A NCAC 513.0013, you are hereby advised that you have 180 days
from the date of your receipt of this letter to submit all of the requested information. If you are
unable to meet this deadline and wish to request additional time, you must submit information,
in writing, to the Director clearly indicating why the deadline cannot be met and request that an
extension of time be granted. If an extension of time is not granted, a decision will be made to
grant or deny the mining permit based upon the information currently in the Department's files
at the end of the 180-day period.
Though the preceding statement cites the maximum time limit for your response, we
encourage you to provide the additional information requested by this letter as soon as
possible. Your prompt response will help us to complete the processing of your application
sooner.
Please contact me at (919) 707-9220 if you have any questions.
qicerely,th A. Wehner
Assistant State Mining Specialist
Enclosures
CC' Ms. Tamera Eplin, PE
North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi I I. Hamilton
October 7, 2019
MEMORANDUM
TO: Brenda Harris
Land Quality Section
Division of Land Resources, NCDENR
FROM: Ramona M. Bartos Ma- RNSQ&A��
Office of Archives and I listory
Deputy Secretary Kevin Cherry
SUBJECT: Application for Mining Permit, Carolina Sunrock, LLC, Prospect Hill Quarry, Caswell County,
ER 19-2783
Thank you for giving us the opportunity to review and comment on the above project pursuant to Chapter 74,
Article 7 of the North Carolina General Statutes.
The proposed area of disturbance is adjacent to a tract of land surveyed in 1977 for the City of Roxboro
reservoir. That survey identified multiple archaeological sites. Two of those sites (31CS31 and 31CS50) are
along the northeastern boundary of the project area. These Archaic period resources were not assessed for the
National Register of Historic Places. Additionally, there are several historic properties along the western and
southern boundary of the project.
There is a high probability that additional archaeological resources may be present within some portions of the
630-acre proposed area of disturbance. Prior to the initiation of any ground disturbing activities within the
project area, we recommend a comprehensive archaeological survey of the project area be conducted by an
experienced archaeologist. The purpose of this survey will be to identify and evaluate any archaeological sites
that may be damaged or destroyed by the proposed undertaking. Potential effects on unknown resources must
be assessed prior to the initiation of construction activities.
Our office now requests consultation with the Office of State Archaeology Review Archaeologist to discuss
appropriate field methodologies prior to the archaeological field investigation, including review of the project
area to determine high probability areas that will require survey and low probability areas that will not. A list of
archaeological consultants who have conducted or expressed an interest in contract work in North Carolina is
available at httlls://fdcs.nc.gov/dncr-arch/Consultants-list-2019-08-colurniis.l-)df. The archaeologists listed, or
any other experienced archaeologist, may be contacted to conduct the recommended survey.
One paper and one digital copy of all resulting archaeological reports, as well as one digital copy of the North
Carolina site form for each site recorded, should be forwarded to the Office of State Archaeology through this
office for review and comment as soon as they are available and in advance of any construction or ground
disturbance activities. Our report guidelines can be found at https://files.tic.gov/dncr-
arch/OSA Guidelines Dec2017.ndf.
Location: 109 Last Jones Street, Raleigh NC 27601 Mailing Address: 4617 blad Service Center, Raleigh NC 27699-4617 Telephone/Fax: (919) 807-6570/807-6599
We have determined that the project as proposed will not have an effect on any historic structures.
While we note that this project review is only for a state permit, the potential for federal permits may require
further consultation with us and compliance with Section 106 of the National Historic Preservation Act.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
please contact Renee Gledhill -Earley, environmental review coordinator, at 919-807-6579. In all future
communication concerning this project, please cite the above referenced tracking number.
Department of Natural and Cultural Resources
Division of Historical Resources
Governor Roy Cooper Office of State Archucology
Secretary Susi Fl. Hamilton John N•tintz, State Archaeologist
November 13, 2019
Brenda M. Harris
Mining Program Secretary
North Carolina Department of Environmental Quality
512 North Salisbury Street
Raleigh, NC 27699
Re: Prospect Hill Quarry, Caswell County, ER 19-2783
We have been notified that one or more historic cemeteries are located in the subject project area.
Cemeteries are protected under North Carolina General Statutes Chapter 14-148 and 14-149, and are
afforded consideration tinder Chapter 65.
We therefore recommend that prior to the initiation of permitted ground disturbing activities, all
cemeteries in the project area be delineated and documented by a professional archaeologist. In order to
ensure that cemeteries in the parcel are treated in a manner consistent with state law, we also
recommend that an avoidance plan be developed for each identified cemetery and an unanticipated
discoveries plan be developed in case any burials are discovered in the process of mine operations.
Please note that our office now requests consultation with the Office of State Archaeology Review
Archaeologist to discuss appropriate methodologies prior to field investigations. A list of archaeological
consultants who have conducted or expressed an interest in contract work in North Carolina is available
at https:Hfiles.nc.gov/dncr-arch/Consultants-List-2019-08-columns.pdf. The archaeologists listed, or any -
other experienced archaeologist, may be contacted to conduct the recommended work.
One paper and one digital copy of all resulting archaeological reports, as well as one digital copy of the
North Carolina cemetery form for each cemetery recorded, should be forwarded to the Office of State
Archaeology through the State Historic Preservation Office for review and comment as soon as they are
available and in advance of any construction or ground disturbance activities.
Thank you for your cooperation and consideration. If you have questions concerning the above
comments, please contact me at 919-814-6555 or john.mintz@ncdcr.gov. In all future communication
concerning this proiect, please cite the above -referenced tracking number.
Sincerely,
.f-r( John Mintz
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® North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
III 1010 [0 "T.110 111KYJ' I
TO: Brenda M. Harris
Mining Program Secretary
Land Quality Section
FROM: Olivia Munzer, Western Piedmont Coordinator
Habitat Conservation
DATE: 27 September 2019
SUBJECT: New Mining Permit Application for Carolina Sunrock LLC, Prospect Hill Quarry and
Distribution Center, Caswell County, North Carolina
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
permit application. Our comments are provided in accordance with provisions of the Mining Act of 1971
(as amended, 1982) (G.S. 74-46 through 74-68 15 NCAC 5).
Carolina Sunrock LLC applied for a new mining permit for the proposed Prospect Hill Quarry and
Distribution Center located at 1238 Wrenn Road in Prospect Hill, Caswell County, North Carolina. The
property is currently comprised of agricultural fields and forest, the majority of which was clear-cut for
timber harvest in 2018. Of the 630-acre property, a total of 380 acres will be disturbed for mining
activities.
Sugartree Creek and unnamed tributaries to South Hyco Creek and Sugartree Creek flow through the site.
Sugartree Creek in the Roanoke River basin is classified as a High -Quality Water and Water Supply 1I
stream by the NC Department of Water Resources (NCDWR). The permit indicates two small wetland
areas will be impacted permanently by the site development and construction; however, Sheet 5 indicates
streams will be permanently impacted by mining, particularly during Phase IV.
The NCWRC has known records of the state significantly rare Carolina ladle crayfish (Cambarus davidt)
and an undescribed crayfish species near the site. The lack of records from the site does not imply or
confirm the absence of federal or state -listed species. An on -site survey is the only means to determine if
the proposed project may impact federal or state rare, threatened, or endangered species. Adjacent to the
site, a Dry Oak —Hickory Forest Natural Community lies within the Russell Loop Dry Forest Natural
Heritage Natural Area (NHNA). A natural community is a rare or high -quality natural community and a
NHNA is a site with special biodiversity significance.
We hesitate to concur with the approval of this mining pen -nit. We have concerns for the direct and
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: (919) 707-0220 • Fax: (919) 707-0028
Page 2
27 September 2019
Prospect Hill Mine Permit Application
Caswell County
indirect impacts to aquatic and terrestrial resources in and adjacent to the proposed project. We offer the
following recommendations to minimize impacts to aquatic and terrestrial wildlife resources.
1. In addition to direct impacts, we have concerns on the indirect impact of the operation on the
streams and wetlands. The Hydrogeological Study Report (page 18) indicates substantial water -
table drawdowns were observed during testing and similar or greater impacts (in extent and
magnitude) could be seen during quarry dewatering. Additionally, the aquifer may not recharge
at the rate of dewatering, particularly during drought years and/or with sustained and prolonged
dewatering. The return water withdrawn during operation will be discharged in the westernmost
of the larger unnamed tributaries. We are concerned the portion of the streams and the wetlands
within the site may dry up or be abnormally low, which would impact aquatic resources.
2. NCWRC has records of the Carolina ladle crayfish and an undescribed crayfish species in the
watershed. Since the impact of dewatering will likely impact stream flow, we request surveys for
crayfish at the site. For questions, please contact W. Thomas Russ, the Foothills Aquatic Wildlife
Diversity Research Coordinator, at 828-659-3324 or Thomas.russ@ncwildlife.org.
3. The permit application indicates (page 14) that a 100-foot (ft) buffer will be provided along
Sugartree Creek and the larger two unnamed tributaries, and intermittent and ephemeral streams
and wetlands will have a 50-ft buffer. We are pleased to see the applicant will provide
Undisturbed buffer widths generally recommended by NCWRC. However, the applicant indicates
on page 7 that "Phases I, II, and III within Pit A will be mined leaving a 50-undisturbed buffer
along all streams and wetlands within the ultimate pit boundary of Pit A", which is inconsistent
with the buffer widths on page 14. Furthermore, Sheet 5 indicates that Phase IV involves
"expanding the Pit A through existing streams and wetlands to achieve the ultimate pit boundary
of Pit A, installation of a creek crossing to access Pit B, and the stripping and mining of Pit B".
4. We have concerns that the overburden/pond fines disposal areas are adjacent to streams and only
separated from the streams by a silt fence and undisturbed stream buffer. If the stream buffer is
less than 100 ft, consider using a small berm or other type of structure to safeguard the stream
from sediment in case the silt fences fail.
5. Due to the presence of dry oak -hickory forest natural communities in the area, we recommend the
applicant plant hickories and oaks in addition to shortleaf pine and maple.
6. The applicant indicates on pages 14, 16, and 18 that they will reseed using native grasses and
trees. However, the grasses and lespedeza listed on the seeding schedule (page 20) are all non-
native and/or invasive species. Non-native plants should be removed from the seeding schedule
and replaced with native alternatives. Consider an alternative mix of red clover, creeping red
fescue, and a grain, such as oats, wheat, or rye. Specifically, this project would be ideal for
planting native, wildflower seed mixes that will create pollinator habitat within the reclaimed
areas. Please see the attached document for recommendations on native seed mixes for disturbed
sites.
7. We recommend that water quality, and perhaps surface flow, are monitored downstream of the
discharge point.
8. Ensure Erosion Control and Sedimentation Basins and associated structures (i.e., dissipater pads)
are located outside the recommended stream buffers, which are a minimum 100-foot for perennial
streams and a 50-foot for intermittent streams and wetlands.
Page 3
27 September 2019
Prospect Hill Mine Permit Application
Caswell County
Thank you for the opportunity to comment. Further information and free technical guidance from the
NCWRC is available upon request. For questions or comments, please contact me at (919) 707-0364 or
olivia.munzer a.ncwildlife.org.
ec: Sue Homewood, NC Division of Water Resources (NCDWR)
David Bailey, U.S. Army Corps of Engineers
W. Thomas Russ, NCWRC
Print this form to PDF Return PDF of this form to DEMLR CO by email. cc DEMLR RO, DWR SPU. Send a copy to the permittee.
MINING PERMIT APPLICATION REVIEW FORM
for the
DIVISION OF WATER RESOURCES
1X811i
Project Name Propect Hill Quarry DEMLR Permit 17-02 County Caswell Applicant's Email:
smartino@thesunrockgroup.com
PERMIT ACTION TYPE:
i {
Have land disturbing activities??
started? Date?
Latitud 36.300266
YES
F(
Longitude:-79.167534
NO
Please return comments to (at DEMLR CO): Judy Wehner
Comments due by: 9/27/2019
SECTION BELOW TO BE FILLED OUT BY DWR:
Date Commencin
Is the RO concerned that the operation, as proposed, would violate standards of water quality? Yes
Comments: The GW modeling shows a significant lowering of the water table within the footprint of the mine
and surrounding areas. The model anal zes the impacts of this lowering on local WSWs however it should
also be used to analyze indirect hydraulic impacts on all surrounding wetlands and streams. In addition. 15A
NCAC 02B .0214 has very stringent limitations on industrial wastewater and stormwater in WS-II waters. Also
Phase IV of this project indicates buffers will be impacted and .0214 states that no new development is
allowed in the buffer. 15A NCAC 028 .0224 has verV specific requirements for NPDS wastewater discharges
that should be addressed in detail. These questions should be further researched with DEMLR Stormwater
Unit and with DWR classifications and/or industrial wastewater unit to determine restrictions/limitations.
Watershed/Stream Name & Classification: _ Sugar Tree Creek, WS-11-, HQW and South Hyco Creek, WS-I1: B:
HQW
DWR Compliance Status of Mine: NA
Does this mine (or previous owner) have DWR back fees to pay? If yes, amount:
Is this mine an active permit in BIMS?
YES NO
401 Wetland Cert. required?
401 Wetland Cert. existing?
F [ Permit
Does DWR RO have enough information to
determine if a 401 certification is required?
I� (Application indicates a
Nationwide Permit for first
Phases but an Individual Permitwill
_
be necessary for Phase IV.
USACE.may not allow applicant
Rwi Santamh.-r )nln
Print this form to PDF Return PDF of this form to DEMLR CO by email. cc DEMLR RO, DWR SPU. Send a copy to the pefmittee.
to sepa_r_ate project into phases
Is an O & M Plan needed? YES NO
( minor direct impacts for
first few phases. Significant
Are wetlands for Phase IV. Also
lands disturbed at this site? (
may be significant indirect
impacts from hydraulic
drawdown of watertable
Does DWR RO suspect or know of nearby
wetlands to the site?
(JD- must have delineation
map in application verified by
Is a wetland delineation required prior to
USACE
DWR issuing the permit?
(Consultant
(Onsite?
( Offsite?
Stream Determination Needed?
(see above
Stream Determination Completed?
F (
i
Does DWR RO need a statement that no
wetlands/streams are disturbed
F (
for this project from applicant?
Buffer Determination Needed?
Buffer Determination Completed?
(
`
Recycle system permit existing?
(Permit #
New Recycle System permit required?*
(—
Enough information to determine?
Non -discharge permit existing?
(Permit #Perm
{
i (Unknown.
Will wastewaters discharge to HQW waters
r
(7Q10
tee
with a 7Q10=0?
(
Flow.
must
determine,
( Has Violation
( O&M Requirements
Does DWR require DEMLR to hold the
( HQW17Q10 Concerns
permit (e.g. so DWR can review it further or
( Pay back fees or renew
because DWR requires more information)?
DWR permit
, ( Other.
Please describe the reason to
Rav Santamhar 9n1n
Print this form to PDF Return PDF of this form to DEMLR CO by email. cc DEMLR RO, DWR SPU. Send a copy to the permittee.
hold the permit. significant_
concerns about possible
indirect impacts to streams
and wetlands.
RO contact:
i ( Hold Until. -
Mine must wait to dewater until an O&M plan is
approved?
Reviewed by:
DWR RO Surface Water: SLH Regional Office: WSRO Date: 9/21
RO Aquifer Protection Section: Regional Office: Date:
Rwt SPntPmhnr )ni o
VOY COOPER
Governer
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
MEMORANDUM
TO: Ms. Judy Wehner
Land Quality Sec ' n1`
FROM: Michael Baue +`'/}
Ground Water anagement Branch
Division of Water Resources
NORTH CAROLINA
Environmental Quality
September 25, 2019
SUBJECT: Comments on the Mining Permit Application Request for:
Carolina Sunrock, LLC.
Carolina Sunrock Prospect Hill Quarry & Distribution Center
Caswell County
Please find attached a copy of the mining permit request for the above referenced project.
RECEIVED
SE'p 2 5 ZU19
LANE) QUAL!
Ty
MfNING PR0GM
The Carolina Sunrock Prospect Hill Quarry & Distribution Center located in Caswell County might have an unduly
adverse effect on ground water supplies since mine dewatering is proposed onsite. The hydrogeological study provided
with the mine permit application indicates that the mine may pump between 1.75 million gallons of groundwater per day
(mgd) and 3.42 mgd depending on pit depth. The hydrogeological study also indicates that the existing nine monitoring
wells will be gauged to track/monitor the drawdown of the aquifer on a routine basis. However, a majority of those wells
were placed near the center of the property and not outside the excavation boundary.
The Division recommends the following:
• Before dewatering activities begin, monitoring wells should be constructed outside of the excavation limits.
These wells should be placed between the excavation and areas where existing water supply wells were located
during the water supply well survey (mine application package figure 9). The Division recommends constructing
three monitoring wells on the north side of the excavation near water supply wells 10 — 15, two on the northeast
side of the excavation near water supply wells 17 — 21, one on the south side of the excavation near water supply
well 25, and one on the southwest side of the excavation near water supply well 29.
• Monitoring wells should be gauged for water levels monthly starting at least two months prior to any dewatering
activities at the mine.
• Since there are existing water supply wells in the area, the Division of Energy, Mineral, and Land Resources
should obtain an adverse impact letter from Carolina Sunrock, LLC. stating what steps the company will take if
dewatering activities at the mine should happen to impact any existing water supply wells.
The mine will need to register water withdrawals with the Division of Water Resources on an annual basis since the water
withdrawals are over 100,000 gallons per day. The registration form may be obtained from the following link:
https://www.ncwater.org/wwatr
Facilities are required to register their water withdrawals in accordance with the North Carolina General Statute G.S. 143-
215.22H. This statute requires any non-agricultural water user who withdraws 100,000 gallons or more in any one day of
ground water or surface water to register and update withdrawals. This statute also requires transfers of 100,000 gallons or
more in any one day of surface water from one river basin to another river basin to register and update their water
transfers. Water withdrawal registrants must complete the annual water use reporting form by April 1 for the previous
year.
If you have further questions regarding the water withdrawal registration please contact Jolm Barr with the Division of
Water Resources at (919) 707-9021 or email him atjohn.barr@ncdenr.gov.
North Carolina Department of Environmental Quality I Division of water Resources
5i2 North Salisbury Street 1 1611 Mail Service Center I Raleigh North Carolina 27699 1611
Knr.: o+n.7.;ru
91q.707.9000
Wehner, Judy
From: Eplin, Tamera
Sent: Tuesday, October 15, 2019 12:54 PM
To: Wehner, Judy
Cc: Lentz, Zachary
Subject: 17-02 Carolina Sunrock / Prospect Hill Quarry
Attachments: DOC101519-10152019115311.pdf, DOC101519-10152019115300.pdf
Hello Judy,
The DEQ and WSROS comments are attached. Thank you for additional time to review.
DAQ and WQROS comments are attached.
Significant comments on the plans:
1. The proposed mine is in an area of High Quality Waters, as discussed by Sue
Homewood.
2. Access for at least one haul road is shown in a wetland and across the Limits of
Disturbance. Will this road be used?
3. Contour elevations are necessary.
4. The applicant does not use traditional basin design, wherein water enters the basin on
the upgradient side, goes through 3 baffles that divide the basin into fourths (from the
basin floor), with a 2:1 to 6:1 length to width ratio. Add the outlets discharging directly
into the buffers of creeks leading to the lake, and it is unlikely this mine will avoid
impact to the creeks and buffers.
5. In some cases, the baffles are at the bottom of the interior slope of the basins, which is
not approvable.
6. If they insist on a U shaped baffle, I'm curious how they intend to maintain them.
7. Silt fence should be placed a minimum of 10 feet below any fill slope to allow for access,
maintenance, and sediment storage.
8. The disturbed area equals the drainage area for basin calculations. Does off -site
drainage need to be taken into account?
9. Drainage areas should be very clearly shown on the erosion control plan.
10.Any drainage of any basin that close to a creek for any reason, such as to perform basin
maintenance, would need to be through a silt bag.
11.They have significant area draining around and below sediment basins to a stone
outlet. Stone outlets are not treatment measures, and only meant to prevent silt fence
laydown in small areas already determined to have acceptable design for silt fencing
(1/4 acre per 100 ft silt fencing, less for steeper slopes). Redesign is needed.
12.They have their LOD right on the buffer lines. This does not allow any vegetative buffer.
All sediment loss is a buffer violation.
13.Demolition debris needs to go to a site regulated by the Division of Waste Management.
14.Diversions need to go the end of the sediment basin opposite the skimmer
intake. Generally speaking, the basins are not placed to maximize the flow path of the
water, which is necessary to allow settling of sediment.
15.Will residents near the lake need to use the mine road for access?
16.Stone outlets are not approvable placements for skimmer outlet stabilization.
17.The C value for disturbed soil should be 0.6, not 0.3.
18.They proposed stone outlets, but didn't provide a detail.
19.They should utilize PAMS, with specifications.
20.Any diversions left in place longer than 30 days should have matting/stabilization upon
installation.
21.They should provide measures around the stockpiles.
22.404/401 certifications?? They should show areas of approved permanent and
temporary impact, clearly labeled on the plans. For review of ESC, need a copy of the
application and the approval, or a copy of the application and documented receipt.
23.They should clearly stake their LOD, describe within the sequence.
24.Are they using ESC measures to treat stormwater/process water from the proposed
asphalt/concrete plant onsite?
25.Sheet 7b — they're proposing open pits going across streams???
26.They list a creek crossing in the sequence of events, but not the ESC plan.
27.They should provide a listing of status of all other applicable permits and list their
significance within their construction sequence.
28.Dewatering excavations below the water table should not overwhelm the sediment
basins when rainfall is expected.
29.When they resubmit, they need to demonstrate a clear translation between the mine
maps and the ESC plan across the phases of the plan.
30.Until all items above are addressed, as well as any additional information you need, the
applicant should hold off and resubmit as one comprehensive package. They should be
advised that due to the nature of the initial submittal and comments provided,
additional review with additional comments is likely.
Please let us know if we may be of additional assistance,
Tamera Eplin, PE, CPESC
Regional Engineer
Land Quality Section, Winston-Salem Regional Office
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
(336) 776-9800 office
tamera.eplin(ancdenr.gov
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105-7407