Response to July 21 Request

ENGINEERING
PLLC
INNOVATIVE WASTE SOLUTIONS
January 19, 2022
VIA FedEx DELIVERY
Mr. Adam Parr, P.E.
Assistant State Mining Engineer
NCDEQ, Division of Energy, Mineral, and Land Resources
Department of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
RE: Hood Creek Soils Co., LLC - Response to July 21, 2021 letter
Mr. Parr,
HNA Engineering, PLLC is submitting this letter on behalf of the Hood Creek Soils Co., LLC, as a
follow-up to the comments received from your office, dated July 21, 2021. Your comments are
listed below with our corresponding response directly below each.
1. Please clearly indicate and label on the map the mine permit boundary. This mine
permit boundary also needs to match the requested permitted acreage on pg. 1 of the
mine permit application.
The mine permit boundary is outlined as the orange, dashed line, labelled as Limits
of Disturbance (LOD). We have added to the legend, Limits of Disturbance & Mine
permit boundary. We also adjusted the mine permit boundary to include the new
facility entrance/access from Hoods Creek Road and reduced the overall footprint
to avoid any impacts to the blue line stream, identified by Caldwell County's GIS
system.
2. Please clarify the acreage request between permitted acres and affected acres.
The total property is approximately 84 acres. The area that we are seeking a mine
permit for has been reduced from the previously requested 25.1 acres to 24.0
acres, as shown within the orange, dashed line limits. The affected acres would be
within, and the same as, the mine permit limits.
205 Walnut Street, Statesville, NC 28677 P: 704.464.6800

irkAAO
ENGINEERING
PLLC
INNOVATIVE WASTE SOLUTIONS
3. Please clearly indicate and label on the mine map the buffer to the mine permit
boundary.
The 25-foot property buffer, 50-foot stream buffer and 300-foot structure buffer are
all shown on the maps. We have added some additional notes to clarify these
better. Our intent with this mining operation was not to maximize the use of the
entire property but to provide sufficient, undisturbed buffers from any residences
(north and east side) and to have any disturbed areas and the associated
stormwater flowing to the south and west where we could manage stormwater in a
more effective manner. The mine permit boundary has greater than the minimum
buffer required on all sides.
4. Please clearly indicate and label on the mine map the location of the fuel tanks as
identified in the mine permit application.
We anticipate having (1) one, 500-gallon diesel fuel tank on -site that will be
relocated as the operation moves to new areas. We have added the proposed,
initial location to Sheet 5 of 12, at the upper most point of the main access road and
the proposed final location to Sheet 7 of 12, in the main operating area. The initial
fuel tank location may start lower on the site, depending on accessibility, and will
eventually be moved to the locations as shown.
5. Please provide calculations for Erosion and Sediment Control (E&SC) measures. These
calculations should provide information on basins, traps, ditch lines, pipes, conveyance
systems, etc. for each drainage area.
Calculations have been updated and provided for each US measure and are
attached to this letter. Our revised plan includes (4) sediment basins, (10)
stormwater conveyance channels, (5) culverts, sediment fence and diversion
berms. These features will be installed as the mining area moves into different
areas and prior to disturbance within those areas. Sediment Basin 1 (SB-1) is
existing from the previous land disturbance operation and will be upgraded to meet
the sizing requirements when disturbance activities occur in that drainage area.
The outfall discharge for this existing basin may also require additional upgrades
and is believed to be using the roadside ditch for drainage currently.
Hood Creek Soils Co.
July 21 Letter Responses January 19, 2022

irkAAO
ENGINEERING
PLLC
INNOVATIVE WASTE SOLUTIONS
6. Please show all E&SC measures on the mine map including diversion ditrches to direct
surface flow to basins.
E&SC features are shown in detail on Sheet 5 of 12, along with Tables for each
feature. Diversion berms have been added and labelled near each of the (4)
sediment basins. Culverts have also been added to direct flows under the access
roads and into these basins.
7. Please provide construction drawings and maintenance requirements for all E&SC
measures including but not limited to silt fence, construction entrance, stilling basins,
energy dissipators, etc.
Construction details and maintenance requirements are shown on Sheets 11 and
12 with seeding schedule on Sheet 10.
8. Please provide a reclamation map that clearly shows the post mining use of the site.
This map should reflect contours at the site post mining. Items in section D of the mine
permit application in italics should also be included on the reclamation map.
The Reclamation Map shown on Sheet 9 has been revised for reforestation as the
primary reclamation activity and includes the proposed final grade contours. Plans
for hiking/biking trails may be added at a later date if the City of Lenoir or Caldwell
County are interested in developing additional park areas. At this time our
reclamation plans are to return the site to a natural state by reforestation and
establishing native vegetation in areas that have been disturbed.
9. Please provide construction detail for the hiking trail shown on the reclamation map.
This would include E&SC measures, stabilization, etc.
The hiking trail has been eliminated at this time.
10. Please provide cross sections of excavations and cross sections of reclamation area.
Cross sections are included on Sheet 8 of 12.
Hood Creek Soils Co.
July 21 Letter Responses January 19, 2022

HN
ENGINEERING
PLLC
INNOVATIVE WASTE SOLUTIONS
11. Please provide proof of application for the NCG02 permit.
The NOI for this permit has been prepared and submitted on January 19, 2022. The
application forms for the NOI are included as proof with this submittal package.
12. Please clearly indicate and label on the mine map the road access from Bryant Road.
Road access onto Bryant Road has been blocked and will no longer be used for
access. The new facility entrance will be on Hoods Creek Road as permitted by the
NCDOT #D112-014-21-00002. The former access road onto Bryant Road has been
added to Sheet 3 of 12 for reference only.
13. Please clarify the use of explosives at this site. It was indicated that the materials mined
are soil and rock, specifically clay liner for a nearby landfill with a proposed depth of 20
feet.
We have included a sample blasting plan, for blasting of rock to achieve the
proposed base grades and to produce rock materials for use on and off -site. To
simplify the overall grading design plans, we have shown final base grades at
approximate Elevation 1160 with 2:1 maximum slopes on the north, west and east
sides. Our plan remains the same for the primary purpose of mining the site for
clay liner materials. The 20-foot depth is approximate and will follow existing
grades on a maximum 2:1 slope. Total estimated depth from original grade to
design bottom elevation will be approximately 75-feet. There will be no "pit"
created as part of this mining operation.
14. Please provide a proposed estimated life of the mine as seen on pg. 4 and pg. 14 of the
mine permit application. This estimate is used for calculating the reclamation surety.
We are estimating the removal of 300,000 cubic yards of material annually and have
estimated the volume of material to be removed from within the Mining Permit
Limits to be a total of 1,200,000 cubic yards. This would equate to approximately 4
years of full scale, daily operations. Our timing for construction projects will be
primarily driven by the construction events at the nearby landfill which we
anticipate will be every 2 to 3 years. Active life of this facility is anticipated to be
approximately 8-12 years based on the off -site landfill requirements for soils.
Hood Creek Soils Co.
July 21 Letter Responses January 19, 2022

HN `
ENGINEERING
PLLC
INNOVATIVE WASTE SOLUTIONS
15. Basin 2 in Area 4 appears that it may be located on top of a blueline stream according to
Caldwell County GIS. Impact to a blueline stream would require 401/404 certification.
Please provide a delineationor Jurisdictional Determination to clarify whether this basin
will impact a blue line stream.
We have added this blueline stream to our drawings from the Caldwell County GIS
and have adjusted the limits of disturbance to avoid any impacts to this stream. We
will contract a wetland/stream consultant to verify and confirm any
streams/wetlands located on the property and within our proposed mining limits of
disturbance prior to operations within each Drainage Area. Basin 2 is now labelled
Sediment Basin 4 and has been moved to the east of this stream location and
outside of the 50-foot stream buffer limits.
We appreciate your time in reviewing and commenting oo these documents and if you have any
questions or require additional information, please let us know. We look forward to working with
you on completing this permitting project.
Sincerely,
Raymond Hoffman, P.E.
President - HNA Engineering, PLLC
Cc: Dan Wall - Hood Creek Soils Co., LLC
Chris Anderson - Hood Creek Soils Co., LLC
Hood Creek Soils Co.
July 21 Letter Responses January 19, 2022