20220901_ADI_Response

August 26, 2022
Mr. Adam Parr, PE; Assistant State Mining Engineer
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
CC by email to [e-mail]
RE: Parker Mine
Boulder Associates LLC
Mining Application No. 84-06
Stanly County
Yadkin River Basin
Please find below comments copied from your review letter date August 10, 2022, and our responses [in bold typeface]
indicating how the comment has been satisfied. Revised versions of the following plan sheets are also submitted:
• Cover Sheet, with Sheet index and Site Overview
• SP1 Site Preparation Plan
• LU 1 Land Use Map [Phase I]
• RI Reclamation Map [Phase 1]
• R2 Reclamation Map [Phase 2]
1. Reclamation sheets for Phase 1 and Phase 2 are both labeled as sheet "Rl". Please provide unique
names for your map sheets.
The reclamation plan for Phase 2 was properly identified as R2 in the Sheet Index on the cover sheet. The sheet
label has been corrected on Sheet R2.
2. The water elevation shown in cross section A -A' for both phase 1 and phase 2 reclamation shows
Maximum Lake Elevation 645'. The elevation of the stream buffer near SB 1 is approximately 635'
and the elevation of the stream buffer near SB2 is approximately 625'. Please clarify the discrepancy
between the elevation of maximum water levels and elevation of stream buffers.
The emergency spillway for the reclamation pond has been shown on sheets R1 and R2 with an elevation of
approximately 625 feet. This will control the water level in the lake.
August 26, 2022 Response to comments letter dated August 10, 2022. Page 1

3. Please verify no activity will occur on phase 2 until a future modification is submitted to the
Department.
This is verifiable in the text provided on the cover sheet of the plans set under the heading "Site Overview", in
which we lay out the general sequence of events for site development, and which included the following statements:
The plans for Phase 2 will be submitted for approval before site development proceeds beyond the activities
described and shown for Phase 1. However, in general terms, it is expected that the initial pit will be
expanded westward in Phase 2 to encompass a larger area and will increase in depth, so that the pit will
provide substantial water storage capacity. Phase 2 is also contingent upon authorization for impacting
streams and wetlands located within the proposed permit boundary.
It is recognized that modification of the mining permit, as well as additional authorizations for direct impacts to
streams or wetlands, are required. The text of the "Site Overview" was originally submitted in our letter dated
April 13, 2022, and it was added to the cover sheet of the plans set to facilitate your review. No activity will occur
on phase 2 until a future modification is authorized by the Department. This was discussed with Adam Parr on
August 19 and considered sufficient to address this comment. Please refer to the full text of the Site Overview for
additional information.
4. Please provide construction sequence for the overburden storage and perimeter berms shown on LUI.
Please provide details and clearly label on the mine map any Erosion and Sediment Control (E&SC)
Measures that will be put in place during the construction of the areas to mitigate offsite sediment
before they are stabilized.
The construction sequence and installation of controls are described on the cover sheet of the plans set under the
heading "Site Overview" and are shown on the Site Prep sheet [SPl]. In particular, please note the following:
For Phase 1 activities, drainage from overburden storage will not be directed into the diversion ditches or
basins. For the overburden storage areas, rock dams will be installed across natural swales as shown on the
Site Prep sheet [SPl], and silt fence will be installed on contours in multiple rows as needed to limit the
drainage area to 0.25-acres per 100 feet of silt fence. A continuous berm will be built of overburden
material on the upslope side of the silt fencing placed along the perimeter and riparian buffers, so that silt
fencing controls runoff from the outslope of the berm until it is stabilized with respect to erosion. Areas
below the ditches will thus be controlled with a combination of silt fence and berms.
The ground will be prepared for overburden placement by clearing and grubbing. Overburden will be
placed in small lifts [approximately 1-ft thick] and compacted with a bulldozer or similar heavy equipment.
To the extent practical, topsoil will be segregated for future reclamation use, and will also be stored within
overburden storage areas. The ESC measures are shown on the Site Prep sheet [SPl], with additional
related information on the Erosion Control sheets [EC1-EC3] and the Land Use sheets [LUI and LU2].
Overburden will be placed in the Overburden Storage Areas by working upslope from the berms, so that
runoff from overburden placement is primarily controlled by the berms, and with the upslope face of the
overburden used to retain runoff. The 'Typical Overburden Storage Detail' on the plan sheets shows the
overburden will be placed to slope back into the site and away from streams or the site perimeter. In Phase
1, only a 100-ft wide segment in the outer [southernmost] portion of the overburden storage area will be
utilized. In future phases, overburden storage will proceed upslope to the point that it meets the diversion
ditch, so that all runoff from the disturbed areas is directed to basins or captured in the pit.
These controls were discussed with Adam Parr and Kenny Llywelyn on August 23 and considered sufficient to
address this comment. Please refer to the full text of the Site Overview for additional information.
August 26, 2022 Response to comments letter dated August 10, 2022. Page 2

5. The perimeter berm along the southern edge, shown on SP 1, crosses several natural swales and would
prevent natural stormwater drainage. Please clarify how ponding and the potential to overtop and erode
the berm will be mitigated during a storm event.
The following measures are shown on the Site Prep Sheet SPl and will mitigate the potential to overtop and erode
the berm that will be installed along the southern edge of the Phase 1 activity:
a. The existing drainage area above each swale will be reduced by diversion ditches as shown on the Site
Prep Sheet SPl.
b. "Rock dams" will be installed in the natural swales as shown on the Site Prep Sheet SP1.
This was discussed with Adam Parr and Kenny Llywelyn on August 23 and considered sufficient to address this
comment. This text has been added to the Site Overview on the Cover Sheet.
6. Please clarify where the outfall from SB3 will discharge. The mine map shows a berm below the spill
way that would prevent the basin from draining.
The perimeter berm directly below SB3 has been removed from the Phase 1 plans on Sheet LUL The area between
the diversion ditch 1-SB3 and the perimeter buffer zone is shown on the plans as undisturbed in Phase 1. No
perimeter berm is needed in this area.
Contact information:
James Shaad
Mine Manager for Boulder Associates LLC
j amesschad3000*gmail.com
August 26, 2022 Response to comments letter dated August 10, 2022. Page 3