NCG020943_No Snow Camp Mine Reponse Letter_20190620

NO NoSnowCampMine
Chapter of the Blue Ridge Environmental Defense League
SNOW CAMP PO Box 721
MINE Snow Camp, NC 27349
Ms. Judy Wehner
Assistant State Mining Specialist
Division of Energy, Mineral and Land Resources
Department of Environmental Quality
1612 Mail Service Center
Raleigh NC 27699-1612 6/20/2019
Dear Ms. Wehner;
The Snow Camp Chapter of the Blue Ridge Environmental Defense League (BREDL)
has reviewed Alamance Aggregate's (AA) response to the DEQ's request for additional
information and have found the response wholly inadequate. Additionally, Northwest
Geoscience in High Point, NC, a leader in environmental and engineering geoscience
has reviewed AA's response and has found it, along with the included Hydrogeological
and Groundwater Monitoring reports prepared by Robert Reinhardt to he. wholly
inadequate and insufficient. As a result, we are requesting that the mining permit be
denied as it is clear that AA has no intention of complying with reasonable requests
from the DEQ and other relevant state agencies. Below we have enumerated the
specific deficiencies in the AA response to the requests from DEQ. The numbers below
correspond to those in the letter from the DEQ requesting additional information from
AA dated December 21, 2018. We request that the DEQ also carefully review the
attached report from Northwest Geoscience that explains the deficiencies in the Hydro -
geologic and Groundwater Monitoring Reports from Robert Reinhardt in detail.
1. You requested that AA provide letters from both Duke Energy and Colonial
Pipeline indicating that they had reviewed the plan, especially blasting, and were
comfortable with the project moving forward. They did not include a letter from
Colonial Pipeline and the Duke Energy letter indicated that there were no
specifications for the access road crossing easements for both companies. This
information is critical as the pipelines are only buried 24 inches deep.
2. No comments, other than to remind the DEQ that the proposed life of this mine is
50 years, accentuating the importance of making a sound decision on this project
that protects the safety of affected citizens and the Snow Camp Community.
3. You requested that AA provide a detailed site specific hydrogeologic study
including a copy of the report from Carolina Geological Services that was referred
to in the initial application. Instead, they provided a Preliminary Hydrogeological
Investigation that mentions the previous study, but does not provide a copy. Our
question is: How can you provide a preliminary report when it mentions a detailed
study that has been completed previously, but for some reason has not been
1

shared? A request was also made for a revised Groundwater Monitoring Plan and
finally a survey of wells. Please carefully review the attached report provided by
Northwest Geoscience that lists the deficiencies in the reports provided by AA.
In regards to a request for an adverse impact letter with a plan to correct any well
water loss due to dewatering, even though DEQ provided a sample letter
specifically outlining corrective actions, AA response does not include language
recommended by the DEQ. The DEQ request specifically stated that the applicant
should state how the mine would rectify the situation, while the proposed letter
only states that the situation would be rectified without any specifics or
commitments. This provides very little legal protection for residents who are
affected.
In addition, the report contains a number of inaccuracies for example the report
lists the depth of the mine as 200 feet when the application lists the depth as 325
feet. This error could have serious effects on any calculations used to determine
the effects on local wells.
4. Your request asks for a "thorough geological investigation of the site". What was
submitted does not specifically address the site geologic characteristics and is
based on assumptions from other locations. (soo report from Northwest
Geoscience)
5. The requested permit was not attached and the Notice of Intent is not a sufficient
response to the request. A mining permit should not be issued until the requested
NPDES permit is obtained, which is what your request asks for. Additionally, we
believe because of the risks and proximity of streams that feed a regional drinking
water source, an individual NPDES permit should be required rather than a
general permit.
6. NCDEQ requested that AA "Provide additional information to this office that
clearly addresses the amount of free silica dust and radon that will be released as
a result of the proposed operation". Alamance Aggregates did not provide this
information.
7. AA was requested to provide proof that they obtained the necessary 401/404
approvals/certifications needed. No approvals and certifications were provided
due to their premise that they would not need them due to lack of impact on
streams and wetlands. Please see the report from Northwest Geoscience.
8. No Comments
9. The blasting report submitted again relies on assumptions and is not site specific.
It does not take into account the actual geological make-up of the site or the age
and depth of the pipeline. In the blasting report by Dyno Nobile, they assume that
blasting will always occur at a free face, negating any concerns about block
motion. This does not address the absence of a free face during mine startup and
initial blasting. Initial blasting will likely start on level ground and if so, will result in
block motion. DEQ had suggested test blasting to determine actual effects and I
support a blasting study specific to the proposed site.

10.AA did not respond in the affirmative or otherwise to the question from the Wildlife
Commission about limiting tree clearing between May 15 and August 15 to reduce
the effects on the bat population. This should be addressed, including a proposed
clearing sc:hedulP that shows that clearing will not be. performed during this time
11. The recommendation from the Wildlife Commission that the area be reclaimed as
a wetland due to the shallow basin is not addressed in the affirmative or
otherwise. There is no indication in the reclamation plan that AA plans to follow
this recommendation. If Alamance Aggregates does not think it is possible to
follow this recommendation, they should state so and provide a justification based
on the geology, topography, or hydrology at the site.
12. No Comments
We find Alamance Aggregates response disturbing as they have had six months to
provide this information and failure to do so should be grounds for denial of this permit.
In your letter to Alamance Aggregates dated December 21, 2018, you stated:
"...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 on the
information currently in the Department's files at the end of the 180-day period."
We are unaware of any request for extension being requested and granted.
We believe that the lack of information also meets several of the seven reasons that are
grounds for the State to deny a permit including:
(d)(2) That the operation will have unduly adverse effects on potable groundwater
supplies, wildlife, or fresh water, estuarine, or marine fisheries;
(d)(6) That previous experience with similar operations indicates a substantial
possibility that the operation will result in substantial deposits of sediment in stream
beds or lakes, landslides, or acid water pollution;
(d)(7) That the applicant or any parent, subsidiary, or other affiliate of the applicant or
parent has not been in substantial compliance with this Article, rules adopted under this
Article, or other laws or rules of this State for the protection of the environment or has
not corrected all violations that the applicant or any parent, subsidiary, or other affiliate
of the applicant or parent may have committed under this Article...
Thank you for your attention to this matter. Based on the information provided, we do
not see any other possible outcome other than denial of this permit.

Sincerely;
NoSnowCampMine Chapter of the Blue Ridge Environmental Defense League
Gary R. Ulicny Ph
Chapter Representative
gruhealthcare(a)-gmail.com
cc: Winston Salem Regional Office DEQ