20240124_ADI_Reply

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113 Edmbmgh South Dye
SWCASuite 120
W Cory,North C..h.o 27511
9 19.29.292.2200
ENVIRONMENTAL CONSULTANTS www.swca.com
2136 Sound Science.Cnsatm Solution.'
January 23, 2024 ?� receiV
State of North Carolina o�(
Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Mining Program
Archdale Building, Fifth Floor
512 N Salisbury Street
Raleigh, NC 27604
Attn: Corey Clayton
RE: Mine Permit Modification Response to ADI_01.18.024
Kings Mountain Mine-West
Albemarle U.S., Inc.-Cleveland County, NC
Mining Permit No. 23-34
We are in receipt of the ADI dated January 18, 2024 for the referenced permit application modification. The
enclosed Attachment(Attachment 1) provides responses to your request for additional information.The revised
Mine Map drawing set is being sent under separate cover.
Should you have any questions or require additional information, please contact me at 352.818.8995 or via e-mail
at steve.adamseswca.com.
Sincerely,
SWCA
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Steve Adams
Project Manager
Cc: John Kuhn-Albemarle U.S., Inc.
Attachments:Attachment 1 Response to ADI (2 copies)
Mine Map Set(2 copies) (Submitted under separate cover)

Attachment 1
Response to ADI_2019.01.18
1. Verify that impact to the tricolored bat,a proposed endangered species detected on the site,
will be mitigated by avoiding tree clearing during their active season(April 1-November 14)as
recommended in your Federal and State-listed report.
Response:The tricolored bat is a proposed endangered species,and as such,there are no
permit requirements for this species and the U.S. Fish and Wildlife Service(FWS) has not yet
issued guidance on conservation measures that may be required. When guidance is made
available,Albemarle will consult with the FWS to determine an appropriate conservation plan
that will conform with the guidelines.
In the meantime,Albemarle,in a good faith effort,will avoid tree clearing during the active
season(April 1-November 14)as much as possible.Tree clearing that would occur during this
time frame,will be kept to a minimum. In addition,as warranted based on the extent of
clearing, bat emergence surveys will be conducted on those trees proposed to be cleared to
determine occupancy.
2. Drill location HAC-013 appears to have the straw waddle on the uphill side of the drill pad.
East of that location a drainage flow arrow is flowing uphill against the contours. Please
update mine map with the correct arrow directions and/or contour lines.
Response:The revised Mine Map set(submitted under separate cover) has been revised to add
erosion and sediment control devices to the uphill side of drill pad HAC-013 and correct the
drainage flow arrows.
3. The sewer reroute enters the wetlands buffer several times.Please confirm that the wetlands
will be unaffected by the installation of the sewer line reroute.
Response:The sewer line reroute will not impact wetland resources. Portions of the reroute will
occur within the buffer areas designated on the Mine Maps.These buffers are voluntary,as
there are no buffer requirements for the Broad River basin,Cleveland County,or the City of
Kings Mountain.Appropriate erosion and sediment control devices will be utilized construction
to avoid any secondary impacts,such as sedimentation,into wetland resources.
4. Please provide a right-of-way buffer on the mine maps for the sections of the Norfolk
Southern railway within the permit boundaries.

Response:The Norfolk Southern railway shown on the Mine Map is a spur line for the exclusive
use of Albemarle.There are no other users of this spur.Albemarle has a lease on this spur line
that provides them with the exclusive use of the line and the ability to conduct activities
adjacent to the tracks.This is much like the internal road network that Albemarle uses to access
locations within the site where no buffers to these roadways are required.There for no buffers
to the railroad are necessary.
S. Please add the 100-year floodplain limits to the mine map or confirm that the mine is not
within the 100-year floodplain.
Response:The 100-year floodplain limits are shown on Sheets 2.2 and 4.2 of the revised Mine
Map set submitted under separate cover.
6. On the mine map please provide the names of owners of records,both public and provide,of
all tracts of land that are adjoining the mining permit boundary.
Response:Sheet 8.0 has been added to the Mine Map set(submitted under separate cover)
which shows adjacent property owners to the West Mine permit boundary.