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HomeMy WebLinkAbout20211217_response_letter" Hanson H EI DE L BERG CEM ENTGroup Hanson Aggregates Southeast LLC South Region North Carolina Territory Office 3825 Barrett Drive, Suite 300 December 16, 2021 Raleigh, NC27609 RECEIVE® Fax 9193802616 Mr. Adam Parr DEC 17 2621 www.lehichhanson wrn Assistant State Mining Specialist NCDEQ — DEMLR LAND QUALITY SECTION 512 North Salisbury Street Raleigh, NC 27604 Subject: Response to DEMLR October 4, 2021 ADI Hanson Aggregates Southeast, LLC — Princeton II Quarry NC Mine Permit No. 51-05 Revised Mine Modification Map Submittal Princeton, Johnston County, North Carolina Dear Mr. Parr: Having met with the Department on October 11, 2021 and following further review, Hanson Aggregates Southeast LLC is hereby responding to the above referenced request for additional information. We will address each item as received in your letter. 1. Please provide proof of approval for the road crossing and driveway entrances from NC DOT. Please provide a construction sequence for installing the road crossing. Hanson plans to submit a driveway permit application following approval of this current mine permit modification. One entrance on Rains Mill Road is directly across from the existing entrance to our facility. Driveway entrances will also be requested to cross Old Cornwallis Road north of Rains Mill Road. A sample driveway permit obtained following a mine modification at our Rocky Mount II Quarry has been included with this response to show a typical construction layout previously approved by the NCDOT. Driveway construction sequence details have been added to the X-4 Mine Map. 2. Please provide proof of encroachment agreement from Duke Power. Ordinarily, it is not necessary to modify any agreement to cross the powerline right of way. Hanson is not encroaching into the Duke Easement or hindering their ability to access their lines/poles. This easement is the same easement that crosses the street into our current active permit limits and mine site. 3. Please provide an approved jurisdictional determination (ADJ) from the USACE for proposed wetland and stream impacts. Hanson has not been unable to meet with the USACE since the properties were delineated in 2018; however, the DWR did visit the site on 10/27/21 and prepared the NBRRO 21-350 Stream Buffer Determination on 11/8/21. The DWR agreed with the stream maps prepared by S&EC in 2015 and 2018. Hanson acknowledges that approved jurisdictional determinations (ADJs) need to be made for certain wetland delineations before DEMLR can approve any disturbance near the flagged wetland features shown on the mine maps. Thus, to gain approval of this mine modification application, Hanson has elected to limit the area of disturbance to the following areas until USACE ADJs can be obtained and an individual permit, including mitigation, is approved. - Driveway entrance from Rains Mill Road - Construction of overburden piles OB Pile #6 and OB Pile #7 - Construction of visual screening berms on all four (4) sides of the tract directly across from the Old Pit, visual screening berms on both sides of Old Cornwallis Road, and the visual screening berms north of OB Pile #7. - Two driveway entrances to cross Old Cornwallis Road from the New Pit area - Install a "New Pit" quarry operation via portable crushing plant and the product(s) hauled across Rains Mill Road to the existing plant operations. The area requested for a "New Pit" quarry operation has been greatly reduced to stay a minimum 100-feet from wetland areas previously delineated by S&EC in 2018. Further expansion of the "New Pit" quarry would not be requested until the USACE has issued an AJD, and a mitigation plan (individual permit) has been approved. - Construction of OB Pile #8, west of Stream "C" will not be requested until the USACE has issued an AJD, and a mitigation plan (individual permit) has been approved. 4. Please provide calculations for any new pipes associated with the proposed driveways. The driveway entrance detail has been amended and can be found in the lower left corner of the X-4 Mine Map. Calculations prepared by Draper Associates for the 18-inch ID Reinforced Concrete Pipe are included in the detail. 5. Please clearly label and indicate on the mine map and the legend the proposed silt fence. Done; please see revised mine maps. 6. Please clarify Erosion and Sediment Control (E&SC) measures and required basins in the proposed northern pit expansion area during the transition and establishment of a pit. Following installation of the driveway entrance from Rains Mill Road, construction of the visual screen berms along Rains Mill Road, Old Cornwallis Road, and the back side of the proposed new pit will start. Silt fencing will be installed along the toe of slope on the exterior and interior sides of the screening berms with silt fence outlets placed every 150 to 200-feet. On the interior sides of the screening berms, vegetated ditching will be used to direct any run-off to existing non -jurisdictional ditches that convey under the road to the existing old pit SDO-1 outfall. For the visual screen berm that is parallel to Little River, berm construction can only start where the interior side can drain toward existing stormwater structures. The remainder of the berm can be accomplished as construction of the new pit starts. The interior side can then drain to the pit, and normal mine dewatering can begin. Following construction of the visual screen berm at the corner of Rains Mill Road and Old Cornwallis Road, skimmer basin SB-6 can be constructed. Basin details and dimensions are shown in the right lower quadrant of the X-3 Mine Map. SB-6 will drain into a ditch feeding Stream "C". Once driveway entrances are installed on both sides of Old Cornwallis Road, visual screen berms can be installed on the west side of Old Cornwallis Road. Silt fencing will be installed on the exterior side of the berm, while vegetated ditching can be installed to direct run-off to skimmer basin SB-7, which will be constructed concurrently. Silt fence outlets will be placed every 150 to 200-feet. Access roadways will be constructed to reach the skimmer basins for basin initial construction, for visual BMP and outfall inspections, and for basin maintenance. Run-off from the access roadways will drain to the basin or the diversion ditches feeding the basin. Roadway details can be found in the left upper quadrant of the X-2 Mine Map. Once skimmer basin SB-7 is installed, construction of overburden pile OB Pile #7 can start. Following completion of the first bench, slope drains will be utilized to help prevent erosion along the slopes. Slope drain details can be found in the center of the X-2 Mine Map. Stabilized inlet and outlets will be installed on the slope drains. There are no plans to construct the overburden piles OB Piles #8A and 8B in this modification application, nor are there plans included to disturb any land west of Stream "C" until the USACE has issued AJDs and an individual permit has been secured. 7. Please clarify E&SC measures in the northeast corner of the project. Silt fence alone is inadequate protection for this area. A Skimmer Basin #9 has been added to provide erosion control for run-off originating from the northeast corner of the project during construction and after stabilization. Calculations for the "northern ditch" are included in the calculation section prepared by Draper Associates. 8. Please provide baffle detail for sediment basins. Please see skimmer basin details in the lower right quadrant of the X-2 Mine Map for stone baffle details. 9. Please provide calculations and procedures for stabilization for all diversion ditches. Calculations and stabilization for diversion ditches are provided in calculation package with detail described on the X-4 Mine Map. 10. Please clearly label contour lines shown on the mine map. The layer showing the contour line elevations was turned back "on" to clearly show the contour elevations. 11. Please clearly label and indicate on the mine map all stormwater outfalls. Current outfalls, SDO-1, SDO-2, and WDO-1 are clearly marked on the M&ECP-1 Mine Map. OB Pile #6 will have temporary stormwater outfalis that will be monitored daily during the 2-month construction of OB Pile #6 and the final stabilization with seed and mulch. OB Pile #7 will take longer than a one-time stripping project, so a new stormwater outfall, SDO-2, will be monitored following the initial construction of SB-7 Skimmer Basin. 12. Please clarify and provide larger scale details showing how the silt fence will be installed in relation to the construction entrances. Per our conversation with DEMLR there is no silt fence that is crossing the construction entrances. Silt fence will stop and protect the installation of the screening berms on either side. 13. Please provide maintenance requirements for the temporary crossing and wetland details. The temporary crossing that provides access to OB Pile #5 was approved in August-2020 and was installed in 2021 for the construction of OB Pile #5. Maintenance requirements for the stream and wetland crossing have been added to the M&ECP-2 Mine Map. Regarding the proposed RC-1 crossing that will provide access to the proposed OB Pile #8, Hanson has elected not to include any disturbance west of the Stream "C" until the USACE has issued an AJD for wetland areas delineated by S&EC in 2018. An existing crossing already exists; however, Hanson will apply to improve the current crossing upon approval of an individual permit. 14. Please provide proof of notification to the Division of Air Quality for any additional equipment including the proposed portable plant. An email was submitted to the RRO DAQ Supervisor, Taylor Hartsfield, on November 29, 2021 notifying her of the intent to install a "new pit" area across Rains Mill Road from the existing "old pit" and the operation of a portable primary crushing plant. Permitting requirements for such an operation were requested, and on 12/6/2021, Ms. Hartsfield replied via email. Her response acknowledged that an air construction permit would not be necessary; only a notification including an updated equipment list and flow diagram. Please see the attached copy of the request and response email correspondence. 15. The buffer determination letter that was submitted with the application expired in November 2020 and did not include all areas included in this current modification. Please provide an updated approved buffer determination. Please see the attached updated and complete NBRRO #21-350 Buffer Determination Letter dated November 8, 2021. 16. The species list in the Endangered Species Report was only valid for 90 days. Please provide an updated Endangered Species Report, or proof of approval from USFW for the existing report. Please see attached review request addressed to the US Fish and Wildlife Service and prepared by S&EC on December 14, 2021. The Threatened and Endangered Species Report includes S&EC's conclusion based on completed habitat and preliminary surveys. "It appears the proposed project may affect, but not likely to adversely affect any federally listed endangered or threatened species, their formally designated critical habitat, or species currently proposed for listing under the Endangered Species Act (ESA)." 17. Please provide an estimated life of the mine, in years, that can be used for the reclamation calculation. With the reduced pit area requested for this modification, the estimated mine life is 25 years. Hanson secures a $1,000,000 blanket reclamation bond for all its NC mine sites. Since Hanson has elected to reduce the number of disturbed acreage requested in this mine modification application, the following table has been revised to reflect those changes. When listing the current and proposed acreage for disturbance, the total acreage was divided into three (3)separate areas: I. "Old Pit" area for land east of Old Cornwallis Road, south of Rains Mill Road, and west of Little River 2. "New Pit" area for land north of Rains Mill Road 3. "Across River" for land west of Little River Total mine permitted area shall remain at 779.6 acres, and the total amount of land permitted for disturbance will increase from 233.6 acres to 400.9 acres. All the requested acreage for disturbance will occur in the "New Pit" area. The below table can be found in the application and on the M&ECP-1 Mine Map. ansonPggregates Current Current Current Proposed Proposed Prokw� Proposed 2021Mod ed SoufheastLLC erment Permitted Permitted Permitted Permitted New New New Total Princeton 8 Quarry Disturbance Disturbance Disturbance "Across Disturbance Disturbance Disturbance Disturbance Disturbance Permitted for gust-2021 Abri fication 'Old Pit" .New Pit" 'Total" "Old Pir "New Pit" "R��a Total" Disturbance /Sediment Ponds 12.1 0.0 0.0 12.1 0.0 2.6 0.0 2.6 14.7 Iles 15.2 0.0 0.0 15.2 0.0 0.0 0.0 0.0 15.2 e ks 69.3 0.0 0.0 693 0.0 3I.8 0.0 31.8 101.1 ssi ul Roads oetc 25.9 0.0 0.0 25.9 0.0 3.9 0.0 3.9 29.8 Excavation 993 0.0 0.0 993 0.0 46.4 0.0 46.4 145.7 . 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Area to be Affected 233.E 0.0 0.0 233.E 0.0 84.1 0.0 gq,7 318.3 (not for disturbance): Area, Buffers,nn95.4 ds, nds, Stream Channels, 207.1 243.5 546.0 0.0 . ..... 0.0 -122.4 423.E ne Permitted Acres 32930 1 207.10 1 243.50 1 779.9 1 0.00 0.00 0.00 0.0 779.9 Mine dewatering will occur in the "New Pit" and will discharge into an existing non jurisdictional ditch that currently drains southward into a culvert running under Rains Mill Road into the current surface water system in the "Old Pit" area, that ultimately discharges at the SDO-1 stormwater discharge outfall. Finally, a complete new set of mine maps has been included to reflect responses included in this letter and the amount of area requested for disturbance. Enclosed please find the following: - 2 (two) copies of this response letter - 2 (two) copies of the Calculations for Diversion Ditches prepared by Draper - 2 (two) sets of revised mine and reclamation plans - 2 (two) copies of an NCDOT Driveway Permit obtained at our Rocky Mount II Quarry following mine permit modification application approval - 2 (two) copies of DAQ email correspondence regarding air permitting requirements - 2 (two) copies of the 11/8/2021 NBRRO#21-350 DWR stream buffer determination - 2 (two) copies of the current Endangered Species Report dated 12/15/2021 Should you have any questions or need additional information, please contact me at our Raleigh office: (919) 380-2746, Jack. GarveVftlehighhanson.com , and you may also contact our contracted engineer, Andrew Mericle: (919) 827-0864, americle(o)daa.com . Sincerely, Jaccac'�)A:C� arvey Environmental Manager Enclosures: cc: Daren McMorris, NC Operations Manager Jerry Marker, Plant Manager Andrew Mericle, Draper Aden Associates Bob Zarzecki, S&EC, PA