20240507_MRO Comments

Mooresville Regional office comments on ADI Response received April 9, 2024
1. The construction sequence (in the binder booklet) under II. Forney Creek approximate
Station 5+20 to 32+00 needs to be updated to provide a minimum 5' core between the new
constructed channel and the existing stream channel. The new stream does not need to tie
into the existing stream until all of the new stream work has been completed and adequate
ground cover has been provided for the disturbed areas. Once the new stream (and upland
areas)areas have been stabilized,the final core can be removed to tie the new stream into
the existing stream.
2. Need to provide adequate measures (e.g. silt fence, straw wattles, etc.) between all land
disturbance activities and live streams at all times. The plan designer can just put a note on
the plans for this requirement or it could be a modification for your approval. The current
plans have areas where there are no proposed measures between the land disturbance and
live streams.
3. The top crest width of the coffer dam for the pump around should have a minimum 3'top
crest width.
4. Need to provide adequate measures at the stream crossing for the new bridge and haul
road installation (Sheet EC4). Suggest diversion berms parallel to the stream to adequately
sized sediment traps and/or skimmer basins on each side of the stream crossing. The
current plan does not show any proposed measures in this vicinity.
5. Mine Map Sheet 1 needs to show the correct color legend for waste areas. Currently,the
waste areas (located NW& NE of the current pit) are being shown as pit areas. The mine pit
is not located in either of these two locations. Also,the legend to denote the orange berm
needs to be provided in the Legend Table (like it is shown on Mine Map Sheet 2).
6. Mine Map Sheet 2 needs to show correct color legend for the waste areas. Again,the waste
areas located NW and NE of the current pit are being shown as a pit area,which is not
correct.
7. Mine Map Sheet 3 needs to show the stream buffers being provided along the new
relocated Forney Creek. These stream buffers will need to be adhered to as the mining
operations progress into the future.
8. Mine Map Sheet 4 needs to show the correct color legends for the mine reclamation. The
two waste areas (located NW&NE of the current pit) are being shown with a dark gray
legend,which is not identified in the Legend Table. This dark legend needs to be identified
and the identification needs to correspond to the proper reclamation that will occur in
these areas. The current pit legend color does not match the color being shown in the
Legend Table. Typically,the mine pits are allowed to fill with water to become lakes. The
Legend Table shows a blue color to denote water, however,the pit area is not being shown
in blue. Do they intend to allow the pit to fill with water for the reclamation of the pit
area? If so,this area needs to be properly identified with the legend color.