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HomeMy WebLinkAbout20240813_Supplemental_Report North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project — Tailings Storage Facility August 2, 2024 Document No.: KM60-EN-RP-9540 Revision: A\ Albemarle A� North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility CONTENTS Introduction ..........................................................................................................................1 Purpose ..........................................................................................................................1 A. General Characteristics of the Mine...................................................................................3 Current Existing Legacy Features................................................................................3 Existing Conditions and Materials ................................................................................3 ProposedFeatures ......................................................................................................5 B. Maps ..........................................................................................................................6 C. Protection of Natural Resources........................................................................................6 CurrentConditions.......................................................................................................9 Sequence of Events during Construction ...................................................................13 Sequence of Events during Operations......................................................................15 Erosion Control Measures to be Installed during Construction ...................................19 Erosion Control Measures to be Installed during Operations......................................20 Groundwater Effects from Pit Dewatering ..................................................................22 Tailings Storage Facility Surface Water Balance Summary........................................23 D. Reclamation Plan ..............................................................................................................32 E. Determination of Affected Acreage and Bond ................................................................39 F. Notification of Adjoining Landowners.............................................................................39 G. Land Entry Agreement......................................................................................................39 H. References ........................................................................................................................40 Appendix A Mine and Reclamation Maps Appendix B Permit Site and Tailings Storage Facility Design Sheets (Preliminary) Appendix C Archdale Stormwater Management Report Kings Mountain Mining Project North Carolin Appendix D Hydrogeological Assessment Study for Archdale Tailings Facility Kings Mountain Mining Project Prefeasibility Study Appendix E Monitoring Well Development and Q4 2023 Groundwater Monitoring Report—Archdale Site Appendix F 2023 Prefeasibility Study Kings Mountain Mining Project Baseline Geochemistry Characterization Study for the Archdale Tailings Storage Facility Appendix G Prefeasibility Engineering Design Report for Archdale Tailings Storage Facility Doc No.: KM60-EN-RP-9540 i North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Appendix H Technical Report 2023 Prefeasibility Study Surface Water: Water Balance Development Report Archdale TSF Kings Mountain Project Appendix I Technical Report 2023 Prefeasiblity Study, Kings Mountain Mining Project Archdale Tailings Storage Facility Water Quality Predictions Appendix J TSF Mobile Equipment List Appendix K Conceptual Closure Plan Kings Mountain Mining Project Archdale Tailings Storage Facility Appendix L Landowner Notifications LIST OF TABLES Table 1: Summary of Existing Conditions Near the Archdale TSF Site....................................... 4 Table 2: TSF Storage Capacity and Fill Schedule...................................................................... 7 Table 3: Scheduled Rate of Filtered Tailings Delivery to the TSF over the KMM LOM ............... 7 Table 4: Truck Trip Schedule from KMM to TSF ........................................................................ 8 Table 5: Compaction Test Results on Proposed Filtered Tailings..............................................16 Table 6: Surface Water Design Criteria.....................................................................................17 Table 7: TSF Embankment Tonnage and Lithological Composition ..........................................29 Table 8: TSF Viewshed Analysis Details for Crowders State Park Identifying Modeled Visibility Results by Acres and Percentages ...........................................................................................31 Table 9: Preliminary Permanent Seed Mix Composition and Schedule.....................................38 LIST OF FIGURES—APPENDIX A Figure 1: USGS 7.5-Minute Quadrangle Map Figure 2: NCDOT County Highway Map Figure 3: Project KMM and TSF Location Map Figure 4: Topographic Map Figure 5: Aerial Location Map Figure 6: Existing Site Conditions Map Figure 7: Legacy Mine Facilities Figure 8: Historical Mining Facilities Figure 9: Surface Water Map Figure 10: Wetland Delineation Map Figure 11: Location of 100-Year Floodplain Limits Figure 12: Monitoring Well Map Figure 13: Soil Classification Map Figure 14: Geology Map Figure 15: Geotechnical Borings Map Figure 16: Proposed Site Conditions Map Figure 17: Outfall Map Figure 18: Sequence Map: Perimeter Road and Facility Pad Grading Plan during Construction Figure 19: Sequence Map: Phase 1 Base Drain Grading Plan during Construction Figure 20: Sequence Map: End of Construction at End of KMM Mining Year 0 Figure 21: Sequence Map: Interim Conditions at End of KMM Mining Year 5 during Operations Doc No.: KM60-EN-RP-9540 ii North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Figure 22: Sequence Map: End of Operations at End of KMM Mining Year 9.4 Figure 23: Sequence Map: End of Reclamation Figure 24: Location Map of Erosion Controls and Channel Layout during Construction Figure 25: Archdale TSF Stormwater Management Details and Cross-Sections Figure 26: Archdale TSF Stormwater Basin Delineations Map Figure 27: Archdale TSF Final Stormwater Channel Layout Map Figure 28: Impervious Areas Map Figure 29: Archdale TSF Site-wide Water Balance Operational Conditions Flowsheet Figure 30: Tailings Infiltration and Runoff Flow Schematic Figure 31: TSF Buffer Map Figure 32: Archdale TSF Reclamation Plan Map and Sections Figure 33: Map and Cross-Section through the Growth Media Storage Area and "Stockpile" Figure 34: Viewshed Analysis Map Identifying Project Visibility Resources and Modeling Results Figure 35: TSF Visual Impact Assessment Photograph Simulation from Pinnacle Peak Figure 36: Public Lands, Recreation, and Conservation Areas Near the TSF Figure 37: Archdale TSF Non-Process Infrastructure Reclamation Map and Cross-Sections Figure 38: Adjoining Parcel Map Figure 39: Adjoining Parcel Overview Map for Parcels within 1000 Feet of the Permit Boundary Figure 40-43: Adjoining Parcels within 1000 Feet of the Permit Boundary Doc No.: KM60-EN-RP-9540 iii North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Acronyms and Abbreviations Acronym Definition AJD Approved Jurisdictional Determination amsl above mean sea level Albemarle Albemarle U.S., Inc. bgs below ground surface BMP best management practice CFR Code of Federal Regulations cfs cubic feet per second DEMLR Division of Energy, Mineral, and Land Resources DWM Division of Waste Management E&S erosion and sediment GMS growth media storage gpm gallons per minute 1-85 Interstate 85 KMM Kings Mountain Mine LOM life of mine (Kings Mountain Mine) NC North Carolina NCDEQ North Carolina Department of Environmental Quality NCDOT North Carolina Department of Transportation NCG02 North Carolina General Stormwater Permit for Mining Activities non-PAG non-potentially acid generating NPDES National Pollutant Discharge Elimination System NPI non-process infrastructure PAG potentially acid generating Project Archdale TSF Project PWR partially weathered rock RCRA Resource Conservation and Recovery Act SRK SRK Consulting U.S., Inc SWCA SWCA Environmental Consultants TSF tailings storage facility U.S. United States USACE U.S. Army Corps of Engineers USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey Doc No.: KM60-EN-RP-9540 iv North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Glossary Term Definition access roads Primary roads used to access the Kings Mountain Mine and Archdale Tailings Storage Facility sites. adjoining landowner A landowner's property adjoins a mine site if the landowner's property boundary is the same as one or more of the mining permit boundaries and/or if the landowner's land is partially covered by the mining permit. affected acreage The surface area of land that is mined; the surface area of land associated with a mining activity such that soil is exposed to accelerated erosion; the surface area of land on which overburden and waste are deposited; the surface area of land used for a processing or treatment plant, stockpiles, nonpublic roads, and settling ponds. Affected acreage also includes submerged lands but not undisturbed buffers. Haul roads constructed solely for the mining operation and existing nonpublic roads upgraded for mine operation are also considered affected acreage. affected land The surface area of land that is mined; the surface area of land associated with a mining activity so that soil is exposed; the surface area of land on which material is stockpiled; and the surface area of land used for a processing or treatment plant, stockpiles, nonpublic roads, and ponds. Albemarle Albemarle U.S., Inc. archaeological site The physical remains of any area of human activity, generally greater than 50 years of age, for which a boundary can be established. Examples of such resources could include domestic/habitation sites, industrial sites, earthworks, mounds, quarries, canals, roads, etc. Under the general definition, a broad range of site types can qualify as archaeological sites without the identification of artifacts. authorization Any license, permit, approval, finding, determination, or other administrative decision issued by an agency required or authorized under law to implement a proposed action. base flow The sustained flow of a stream in the absence of direct runoff, sustained largely by groundwater. baseline Environmental and social conditions prior to project activities. bedrock Solid rock, overlaid in most places by unconsolidated deposits. berm A mound or wall of earth. best management The schedule of activities, prohibition of practices, implementation of practice maintenance procedures, and other management practices to avoid or minimize pollution or habitat destruction to the environment. Best management practices can include treatment requirements, operating procedures and practices to control runoff, spillage or leaks, sludge or waste disposal, and/or drainage from raw material storage. blasting The use of explosives or blasting agents to cause the fragmentation of materials. check dam A small, sometimes temporary, dam constructed across a swale, drainage ditch, or waterway to counteract erosion by reducing water flow velocity. closure The time when all mining operations cease prior to commencement of post- closure activities. concentrate The end products of the Project. Concentrates will contain the lithium that will be separated from rock in the mine. Doc No.: KM60-EN-RP-9540 v North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility concentrator The concentrator will include grinding, gravity flotation, concentrate dewatering, concentrate storage and loadout, and reagent makeup. The concentrator will be located on the south side of Interstate 85. construction The phase during which surface facilities and infrastructure are constructed, which will occur between -2.5 and 0 mine years. This will include all process and non-process infrastructure. contact water Water that comes in direct contact with ore or waste rock or infiltrates into tailings. Generally, water that has come into contact with non-potentially acid generating waste rock, potentially acid generating waste rock, filtered tailings, pit walls and haul roads is assumed to be contact water. contaminant A substance that pollutes air, soil, or water. It may also be a hazardous substance that does not occur naturally or that occurs at levels greater than those found occurring naturally in the environment. crushing The process of reducing the size of ore by force. cultural resources Archaeological, traditional, and built environment resources including but not limited to buildings, structures, objects, districts, and sites. dewatering The action of removing water from a mine pit. discharge (Clean Water Act definition)Any addition of any pollutant or combination of pollutants to navigable waters from any point source (40 CFR § 122.2). discharge (Project definition) Release of water from the Project to the environment in accordance with applicable regulations and permit conditions; also, the water released. easement A grant of one or more property rights by the property owner of a portion of land for a specified purpose and use by the public, a corporation, or other entity. endangered species Any species which is in danger of extinction throughout all or a significant portion of its range. Endangered Species Act This act was enacted in 1973 (7 USC § 136, 16 USC § 1531 et seq.)and was designed to protect critically imperiled species from extinction as a "consequence of economic growth and development un-tempered by adequate concern and conservation."This act is administered by the U.S. Fish and Wildlife Service and the National Oceanic and Atmospheric Administration. erosion The wearing of land surface by the action of wind, water, gravity, or any combination thereof. flowsheet An illustration showing the sequence of operations, step by step, by which ore is treated in milling or concentration. flume Specially shaped, engineered structures used to measure the flow of water in open channels. Flumes are static in nature—having no moving parts—and develop a relationship between the water level in the flume and the flow rate by restricting the flow of water in various ways. fugitive dust Airborne particulate matter. This can include emissions from haul roads, wind erosion, exposed surfaces and other activities that remove and redistribute soil. groundwater The water located beneath the ground surface in soil and rock pore spaces and fractures. Doc No.: KM60-EN-RP-9540 vi North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility growth media storage An area where the surface portion of the soil that may be reused as soil is stored in large aboveground piles for later use in reclamation. haul road Internal haul roads will either be modified or newly constructed to transport material across the site. The haul roads will be connected to exit points and connect to offsite roadways for material transport offsite. Haul roads may be relocated during mining operations, as the pit expands. hazardous waste A category of waste regulated by the Resource Conservation and Recovery Act. Such waste includes solid waste listed in the Resource Conservation and Recovery Act that exhibits at least one of four characteristics (as described in 40 CFR§§261.20-261.24): ignitability, corrosivity, reactivity, or toxicity; or that is listed by the U.S. Environmental Protection Agency in 40 CFR§§ 261.31-261.33. All waste considered hazardous in accordance with Federal Resource Conservation and Recovery regulations. This term refers to all waste materials that may cause direct or indirect damage to the environment. This waste type may be liquid or solid. Hazardous waste will be identified and disposed of offsite in accordance with Resource Conservation and Recovery Act regulations. highwall Any vertical or near vertical excavation slope exceeding 10 feet in height. All highwalls must be protected by a highwall barrier. hydrogeology The study of the water below the Earth's surface and its interrelationship with geologic materials. impervious surface Hard surfaces that do not allow water to permeate the ground. infiltration Downward entry of water into soil or rock; also, the water that enters the soil or rock. landowner Any owner of a legal or equitable interest in real property that adjoins a mine site if the property boundaries are the same as the mine permit boundaries and/or if the landowner's land is partially covered by the mining permit. laydown area Area used for material and equipment storage throughout the Project. legacy mine Albemarle's current lithium mine and metal production compound, which was also previously mined by other entities beginning as far back as 1883. mine dewatering Water that is either existing or accumulates during operations that will be mechanically removed from the Project through pumping. minerals Soil, clay, coal, stone, gravel, sand, phosphate, rock, metallic ore, and any other solid material or substance of commercial value found in natural deposits on or in the earth. mining (i)The breaking of the surface soil in order to facilitate or accomplish the extraction or removal of minerals, ores, or other solid matter; (ii) any activity or process constituting all or part of a process for the extraction or removal of minerals, ores, soils, and other solid matter from their original location; or(iii) the preparation, washing, cleaning or other treatment of minerals, ores, or other solid matter so as to make them suitable for commercial, industrial, or construction use. mitigation Actions taken to reduce the likelihood of a certain adverse impact occurring. mobile equipment Nonstationary machinery that will be used to perform operations. National Historic This act(Public Law 89-665; 16 USC §470 et seq.) is legislation intended to Preservation Act preserve historical and archaeological sites in the United States. The act created the National Register of Historic Places, the list of National Historic Landmarks, and the State Historic Preservation Offices. It was signed into law Doc No.: KM60-EN-RP-9540 vii North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility on October 15, 1966. The act requires federal agencies to evaluate the impact of all federally funded or permitted projects on historic properties (i.e., buildings, archaeological sites, etc.)through a process known as Section 106 Review. noise Sound that interferes with speech and hearing and that is undesirable. non-potentially acid Rock that does not generate acid during exposure to air and water. generating non-contact water Direct precipitation, stormwater, and surface water that has not contacted ore, waste rock, tailings, industrial areas or activities, or surfaces disturbed by construction activities including runoff from reclaimed surfaces and water from adjacent watersheds diverted around a facility. Water that has not come into contact with filtered tailings or tailings storage facility embankment rock is assigned the least impacted water quality. This water has only contacted vegetated or newly constructed native soil surface and can be released to the environment with only appropriate sediment controls. Generally, all surrounding undisturbed watersheds and any reclaimed surface are assumed to generate non-contact water. operations The 9.4-year phase during which ore will be extracted and processed, water and waste will be managed, and concurrent reclamation will occur. overburden The soil materials that lie above the natural deposit of rock. point source (Clean Water Act definition)Any discernible, confined, and discrete conveyance including, but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, landfill leachate collection system or vessel, or other floating craft from which pollutants are or may be discharged (40 CFR § 122.2). pollutant (Clean Water Act definition) Dredged spoil, solid waste, incinerator residue, filter backwash, sewage, garbage, sewage sludge, munitions, chemical wastes, biological materials, radioactive materials (except those regulated under the Atomic Energy Act of 1954, as amended [42 USC. 2011 et seq.]), heat, wrecked or discarded equipment, rock, sand, cellar dirt, and industrial, municipal, and agricultural waste discharged into water(40 CFR§ 122.2). pond Temporary water storage for retention of runoff and sedimentation control. post-closure The phase after mine closure. During post-closure, reclaimed areas will be maintained, and monitoring will confirm that reclamation has been sustained and post-closure performance criteria have been achieved. potentially acid Rock that when oxidized by neutral and alkaline surface weathering, may form generating acid which can then leach metals. process The process of producing lithium concentrate from extracted spodumene resources. Project Kings Mountain Lithium Mine Project, which includes the offsite Archdale Tailings Storage Facility. reclamation The reasonable rehabilitation of the affected land for useful purposes, and the protection of the natural resources in the surrounding area. Although both the need for and the practicability of reclamation control the type and degree of reclamation in any specific instance, the basic objective is to establish on a continuing basis the vegetative cover, soil stability, water conditions, and safety conditions appropriate to the area. refuse All waste soil, rock, minerals, scrap, tailings, slimes and other material directly connected with the mining, cleaning, and preparation of substances mined, Doc No.: KM60-EN-RP-9540 viii North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility including all waste materials deposited on or in the permit area from other sources. rock The solid mineral material forming part of the surface of the Earth exposed on the surface or underlying the soils or ocean. runoff The portion of precipitation that flows over the ground surface to a surface water body or Project water management structure. safety bench A safety bench is required at the toe of the overburden cut slope and the top of a hardrock highwall. The minimum safety bench width is 10 feet. saprolite A soft, earthy, typically clay-rich, thoroughly decomposed rock formed in place by chemical weathering of igneous, sedimentary, and metamorphic rock. schist A foliated metamorphic rock, the grains of which have a roughly parallel arrangement, generally developed by shearing. screen A device such as a fence or planting area used to visually separate properties. sediment Solid particulate matter, both mineral and organic, that has been or is being transported by water, air, gravity, or ice from its site of origin. sediment pond A pond used for settling suspended solids. sedimentation Process by which sediment, resulting from accelerated erosion, has been or is being transported off the site of the land disturbing activity or into a lake or natural watercourse. seepage (i)Water that flows downward out of the base of an unlined engineered feature into groundwater. (ii)The slow movement of water through natural geologic materials into or out of surface water or groundwater. spodumene A mineral containing lithium ore. stakeholders Persons or groups who are directly or indirectly affected by a project, such as rights holders, as well as those who may have interests in a project and/or the ability to influence its outcome, either positively or negatively. storm, 100-year, 24-hour The surface runoff resulting from a rainfall of an intensity expected to be storm event equaled or exceeded, on the average, once in 100 years, and of a duration which will produce the maximum peak rate of runoff for the watershed of interest under average antecedent wetness conditions. stormwater The flow of water which results from precipitation, and which occurs immediately following rainfall or a snowmelt. tailings Waste byproducts of lithium beneficiating processes consisting of rock particles which have usually undergone crushing and grinding, from which the profitable mineralization has been separated. tailings storage facility An offsite storage facility used to store unwanted byproduct from the mineral extraction process. This byproduct is transported by truck from the tailings loadout area at the Kings Mountain Mine site to the offsite storage facility. Referred to as the Archdale Tailings Storage Facility. temporary A period of time, not to exceed a specific number of consecutive days. transportation route Tailings will be transferred to and from the approved offsite tailings storage facility via trucks from Tin Mine Road to Dixon School Road then north to Highway 216, and west via U.S. 29/ Highway 216. undisturbed buffer No disturbances are permitted within these buffers including haul roads and sediment control measures. Undisturbed buffers are required along nature watercourses and wetlands. Doc No.: KM60-EN-RP-9540 ix North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility unexcavated buffer Disturbance is allowed within these buffers, although excavating is prohibited. Unexcavated buffer areas are required along rights-of-way. Haul roads, erosion control measures, and earthen berms may be constructed within these buffers. unweathered bedrock This geological and hydrogeological unit typically consists of competent (hard with relatively high rock strength) bedrock that lies at moderate to significant depths below the ground surface that exhibits no to rare weathering effects and decay relative to the original parent rock character. velocity The speed at which water flows. visual screening Screening installed to reduce public view of the mine site, including the processing area. Screening methods may include, but are not limited to, vegetated earthen berms, planted trees, or a combination of both. watershed The land area that drains water to a particular surface waterbody or point along a stream. A ridge or drainage divide separates a watershed from adjacent watersheds. weathered bedrock This geological and hydrogeological unit consists of bedrock that has some amount of decomposition from the original character of the parent rock as a result of proximity to the surface and secondary affects typically resulting in a less competent rock. Weathering of bedrock typically affects the geomechanical and index properties that may include an increase in the fracture density and a decrease in rock strength, hardness, and rock quality. This rock type may include decomposition of silicate minerals to clay and iron- oxide minerals as a result of hydrolysis chemical reactions from interaction with surface and/or groundwater. Saprolite is related to moderate to high weathering of the parent rock. wetland An area that is inundated or saturated by surface and/or groundwater at a frequency and duration sufficient to support a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, fens and similar areas. wetland delineation The act of establishing the boundary between wetlands and uplands (or non- wetlands) using soils, hydrology, and vegetation as indicators. Doc No.: KM60-EN-RP-9540 x North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility INTRODUCTION Albemarle U.S., Inc. (Albemarle), headquartered in Charlotte, North Carolina, is a leading global producer of lithium-based chemicals. Albemarle currently operates a lithium compound and metal production facility at the legacy Kings Mountain Mine (KMM) adjacent to an inactive "legacy mine" located in the city of Kings Mountain in Cleveland County, North Carolina (Figures 1 through 51). To meet current and expected demand for lithium products, Albemarle intends to re-open the legacy mine to produce lithium concentrate from the spodumene resource, which will be extracted by deepening and widening an existing, inactive open pit. Non-ore bearing rock generated during operations will be managed onsite at the KMM, while non-potentially acid generating (non-PAG)filtered tailings will be transported for permanent storage to an approved offsite tailings storage facility (TSF) located approximately 3 miles southwest of the KMM in Cleveland County, North Carolina. The filtered tailings will be dumped into the dry stack TSF using haul trucks and placed and compacted using dozers, front-end loaders, compaction equipment, and other mobile equipment. Albemarle requests approval for a new mine permit for construction and operation of a TSF at the Archdale legacy mica mine site (Figure 6) for the backfilling, storage, and revegetation of tailings. The TSF will receive non-PAG tailings, non-PAG rock, and possibly growth media from the KMM as described above to accomplish the following objectives: • To construct a robust perimeter rock embankment and water management system to safely and permanently store and contain the tailings from the KMM consisting primarily of fine- grained quartz, clay, mica, and feldspars similar in grain size to silty sand soil. • To establish a topography in keeping with the surrounding landscape. • To reduce public safety risks associated with an open pit and pit lake. • To eliminate long-term water management (e.g., pit lake pumping). • To reverse hydrogeologic impacts caused by a pit. The KMM will be authorized under a separate mine permit modification request. PURPOSE The purpose of this document is to provide a supplemental narrative to accompany the Archdale TSF North Carolina Mining Permit Application. The sections contained herein follow the sequence of the application form. Pertinent documents and engineering reports have also been attached as appendices to support the Archdale TSF Project ("Project"). Appendix A contains all figures and maps. Project design, construction, and operations drawings can be found in Appendix B. Supporting documentation for the Project including 1 All figures are included in Appendix A. Doc No.: KM60-EN-RP-9540 1 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility geotechnical site characterization, tailings characterization (index tests), engineering designs and specifications, water management, stormwater management, the water balance, the erosion and sediment (E&S) control plan and drainage calculations, and descriptions of final reclamation activities are provided in Appendices C through K. This Project is unique in that none of the proposed activities involve extraction of minerals, ores, or other solid matter. The purpose of the Project is to create a TSF for the permanent storage of non-PAG tailings generated from an offsite mining operation. Due to the physical distance between the TSF and the KMM, the Division of Energy, Mineral, and Land Resources (DEMLR) requested that separate mine permit authorizations be obtained for the two facilities, although the TSF and mine are related pieces of the same project. The tailings to be stored on the Project will be singularly sourced from one mining operation and will be reclaimed concomitantly with the associated KMM closure. As such, some of the questions included in this application and associated notification forms do not specifically apply to this Project as no extraction is proposed. This mine permit application addresses impacts from the Project's proposed activities. The impacts of the current conditions as described below have already been permitted. Doc No.: KM60-EN-RP-9540 2 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility A. GENERAL CHARACTERISTICS OF THE MINE The Project site is currently comprised of 143.8 acres of disturbed and undisturbed land located between Interstate 85 (1-85) and State Highway 216 / United States (U.S.) Highway 29 (South Battleground Avenue) (Figures 1 through 5). The Project will consist of the following three primary phases: • Construction; • Operations (tailings deposition and permanent storage); and • Closure/Reclamation. TSF closure and reclamation will be performed after tailings storage activities have ceased. Current Existing Legacy Features Legacy open-pit mica mining activities were previously conducted at the Project site (Figure 7). The operator partially reclaimed the site upon cessation of mining activities after 2013. Reclamation was limited to minor slope regrading, disturbed ground revegetation, and allowing several of the open pits to partially fill with fresh water through natural hydrologic processes. The water level in the pits is maintained by pumping through a discharge point identified in the current operator's North Carolina General Stormwater Permit for Mining Activities (NCG02). The current, pre-Project related activities, legacy mine site land disturbance is depicted on Figure 8. No legacy ore processing equipment or structures currently exist at the TSF site. Remaining legacy mining features include: • Access roads; • Open pits with steep slopes, several of which are currently filled with water or have been naturally reclaimed by native vegetation; • A drainage system with an active water pump; • Seven monitoring wells; and • Mica-bearing stockpiles. The existing drainage system currently discharges to an unnamed tributary, which flows south off the proposed Project site under 1-85,joining Dixon Branch. Dixon Branch flows southeast and is contiguous with Kings Creek approximately 2 miles south of the Project site. This unnamed tributary is colloquially referred to as "Archdale Creek" in technical documents and occasionally within permit applications. Existing Conditions and Materials Existing conditions at the Project site are shown on Figure 6 and have been described in more detail by SRK Consulting U.S., Inc (SRK) (SRK 2024a). Doc No.: KM60-EN-RP-9540 3 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility The documents summarized in Table 1 specifically describe the existing site conditions, resources, and materials to be used to construct the TSF embankment, which have either been appended or referenced in this document: • Meteorology and climate (see Appendix C); • Streams and wetlands (SWCA 2024a); - Figure 9 shows the Project relative to the existing watershed and streams; - Figure 10 shows the wetlands delineation map (there are no jurisdictional wetlands within the Project boundaries); - Figure 11 shows the locations of the 100-year floodplain limits map; • Hydrogeological conditions including monitoring well data (see Appendix D) with Figure 12 showing the monitoring well map; • Additional nearby well information and data (see Appendix E); • Soils classification map (Figure 13), vegetation, sensitive wildlife, aquatics, and biology (SWCA 2024b); • Cultural resources including existing land uses dominated by mining zones with a small, forested zone in the southwest part of the site (SWCA 2024c); • Geology map (Figure 14); • Geotechnical borings map (Figure 15); • Baseline geochemistry characterization study for KMM materials to be transported to the TSF including the filtered tailings and non-PAG waste rock to be used for the construction of the TSF embankment (SRK 2024d); • Baseline geochemistry characterization study for materials already present at the Archdale TSF site (see Appendix F). Table 1: Summary of Existing Conditions Near the Archdale TSF Site ReportExisting Resource Consultant (Report Appendix(Figure Number) in this Existing Site Conditions SRK (2024a) A(Figure 6) Meteorology SRK C Streams and Wetlands SWCA (2024a) - Hydrogeology SRK D Monitoring Well Data AECOM E Biology, Wildlife, and Vegetation SWCA(2024b) - Cultural Resources SWCA(2024c) - Soils SWCA (2024b) A(Figure 13) Geology SRK G and A(Figure 14) Doc No.: KM60-EN-RP-9540 4 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility AppendixExisting Resource Consultant (Report Report Site Geotechnical Conditions SRK G KMM Baseline Geochemical Conditions SRK (2024d) - TSF Baseline Geochemical Conditions SRK F KMM = Kings Mountain Mine; SRK= SRK Consulting U.S., Inc; SWCA=SWCA Environmental Consultants; TSF=tailings storage facility Proposed Features Key features that will either remain in place with modifications or be newly added are shown on Figure 16 and described in Appendix G. Project features include: • A dry stack TSF for the permanent storage of 9.2 million short tons of KMM tailings. • Surface water management infrastructure, which will include: - A contact water (i.e., waters that contact the tailings and/or embankment rock) transfer pond; - A sediment retention pond; - A seepage collection tank; - A perimeter stormwater management channel; - Two pumps (one for the TSF sump and one for the active tailings surface runoff); - One optional pump from the contact water transfer pond to the unnamed tributary to Dixon Branch at the float pond skimmer; and - Four outfalls that include three proposed culverts and one existing culvert for offsite water discharge (Figure 17). • A transportation route—tailings and non-PAG rock will be transferred to the TSF from KMM via South Battleground Avenue (Highway 216) and U.S. 29. • A growth media storage (GMS) area located on the southern end of the Project, used to store material salvaged during construction for use during reclamation (Figure 16). • Infrastructure and service facilities, also referred to as non-process infrastructure (NPI), located at the existing northern entrance (Figure 16) including: - A security gate; - A soil tracking device (to minimize soil tracked offsite by vehicles); and - Entrance parking. • NPI facilities located at the southern entrance (Figure 16) to be constructed on a graded and structurally prepared fill pad including: - A gated entrance; Doc No.: KM60-EN-RP-9540 5 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility - A parking area; - An office and canteen building for site staff with two offices and one conference/break room; - Two prefabricated/modular construction change rooms; - A lift station building; - A maintenance shop; - A heavy vehicle (truck) parking area; - A fueling pad (containing a 1,000-gallon diesel aboveground storage tank with secondary containment); - A small road base stockpile; - A truck wash area; and - A laydown area. B. MAPS Six copies of the 7.5-minute quadrangle (North Carolina Geology Survey) and county highway maps (North Carolina Department of Transportation) have been attached on Figures 1 and 2, respectively. As required for new permits, the unnumbered table in Section B of the North Carolina Mine Permit Application form includes proposed affected acreages for the Project's components. Clearly labeled, scaled mine maps depicting all mine features proposed for the life of mine (LOM) as it corresponds to the KMM mining years submitted under a separate permit document submission, including a final reclamation map, have been included as Figures 18 through 23. C. PROTECTION OF NATURAL RESOURCES 1. Describe in detail the sequence of events for the development and operation of the mine and reference the sequence to the mine map(s). Tailings generated from the KMM during operations will be hauled via over-the-highway trucks to the Archdale TSF for permanent dry stack storage. TSF construction and operations activities are described below with additional details provided in the identified appendices and representative KMM LOM sequence maps (Figures 18 through 23). Table 2 below shows the proposed annual tailings quantity fill schedule by mining year (corresponding to the KMM) and construction phase (Appendix G). The TSF fill schedule extends from KMM Mining Year 0 through KMM Mining Years 1 through 9, and embankment Doc No.: KM60-EN-RP-9540 6 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility elevations at KMM mining year end. The TSF will have the capacity to store 9,189,309 tons (7,165,153 cubic yards) of tailings (Appendix G). Table 2: TSF Storage Capacity and Fill Schedule Phase Year Elevation Elevation (tons) (cubic yards) Phase 1 (starter 0 885 0 0 embankment) Phase 2 1 905 880 809,267 631,007 Phase 3 2 920 900 1,122,958 875,601 Phase 4 3 935 915 1,120,732 873,865 Phase 5 4 950 928 1,120,732 873,865 Phase 6 5 960 939 1,071,821 835,728 6 949 1,123,803 876,260 7 959 1,120,732 873,865 8 971 1,120,732 873,865 9 988 578,532 451,097 TOTAL 9,189,309 7,165,153 Source:Appendix G amsl =above mean sea level;ft=feet;TSF=tailings storage facility Table 3 below shows the scheduled rate of tailings delivery to the TSF over the KMM LOM. Table 3: Scheduled Rate of Filtered Tailings Delivery to the TSF over the KMM LOM Date—January 1, Dry Tailings (tons/day) 2028 1,885 2029 2,615 2030 2,610 2031 2,610 2032 2,496 2033 2,617 2034 2,610 2035 2,610 2036 1,347 2037 0 Source:Appendix H KMM = Kings Mountain Mine; LOM = life of mine;TSF=tailings storage facility Doc No.: KM60-EN-RP-9540 7 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Table 4 below shows the approximate number of vehicles transporting materials and staff between the KMM and the TSF sites daily. Tailings placement will occur 355 days per year, deducting ten non-operating days due to inclement weather, holidays, safety stand-downs, and/or other potentially undefined events. The intention of the daily placement and grading work is to create a smooth, compacted surface that will promote stormwater flow to a temporary stormwater collection point while minimizing the potential for stormwater to collect and pool anywhere on the tailings' surface. Table 4: Truck Trip Schedule from KMM to TSF Proposed Land Use Daily AM Peak Hour Trips PM Peak Hour Trips Trips Tailings shipments a 278 8 8 16 8 8 16 Tailings embankment b 234 9 9 18 9 9 18 Mine deliveries 10 2 2 4 2 2 4 Mine visitors and maintenance 26 10 2 12 0 10 10 Archdale staff 24 6 6 12 6 6 12 Archdale deliveries 4 1 0 1 1 1 2 Archdale visitors and 1 1 1 1 0 0 0 maintenance TOTAL 577 37 28 64 26 36 62 Source:Albemarle 2024b 8 16 hours per day, 7 days per week b non-potentially acid generating waste rock KMM = Kings Mountain Mine; TSF =tailings storage facility Seven sequence maps, listed below, are included in Appendix A and are representative of existing conditions, construction (including two grading plans and the final construction plan), and operations related to tailings deposition and storage. • Existing conditions (Figure 6); • Perimeter road and facility pad grading plans during construction (Figure 18); • Phase 1 base drain grading plan (Figure 19); • Phase 1 at end of KMM Mining Year 0 (Figure 20); • Interim conditions at end of KMM Mining Year 5 and end of construction Phase 6 (Figure 21); • End of operations at end of KMM Mining Year 9.4 (Figure 22); and • End of Reclamation (Figure 23). All TSF design drawing sheets with cross-sections are included in Appendix B. Details of the construction grading activities are shown in separate grading plan maps in Appendix B. Doc No.: KM60-EN-RP-9540 8 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Current Conditions The proposed Archdale TSF land area has been disturbed by historical mining activities, which resulted in altered upland landscapes and man-made water features (open pits, ponds, and stockpiles). The following subsections detail the current features of the site. Topography, Surface Waters, and Surface Drainage The existing elevations of the Project reflect the site's long and dynamic history of legacy open- pit mining activities. The topographic map of the TSF site (Figure 4) illustrates a gradient that slopes southward. Elevations at the TSF site range from 750 feet above mean sea level (amsl) to 1050 feet amsl. Several legacy open pits exist on the Project site, which have steep slopes with standing surface water. Several mica stockpiles are also present, which will be removed from within the proposed excavation footprint during construction and incorporated into the base of the TSF structure (described below). Existing conditions (Figure 6) include surface and groundwater collection in three open pits from which surface water is routinely pumped (using a surface-mounted, approximately 600 gallons per minute [gpm] electric pump [SRK 2024a]) to an upper forebay pond where it is allowed to flow through a rock filter dam or gravel embankment prior to discharging offsite, as identified in the current operator's NCG02 permit. After leaving the Project site, the discharge flows south under 1-85 through a 60-inch diameter concrete culvert leading to an unnamed tributary of Dixon Branch (often referred to as "Archdale Creek" in supporting documentation). The Project will be located immediately south of the surface water divide roughly defined by South Battleground Avenue (Figure 9), and all surface waters drain south to an unnamed tributary of Dixon Branch adjacent to the Project site. The unnamed tributary joins Dixon Branch approximately 0.9 stream miles south of the Project site (Figure 9). Dixon Branch joins with Kings Creek approximately 2 miles south of the TSF site, in South Carolina, as shown on Figure 9. Wet/ands and Fioodpiains There are no U.S. Army Corps of Engineers (USACE)jurisdictional wetlands or non-wetland waterbodies within the Project, per an Approved Jurisdictional Determination (AJD) dated September 19, 2019 (SAW-2019-01131) (SWCA 2024a). A new AJD request was submitted to the USACE in January 2024, as the original has expired. Based on an updated delineation conducted in 2023, there are no USACE or North Carolina Department of Environmental Quality (NCDEQ)jurisdictional wetlands within the TSF permit boundary (Figure 10). The AJD request is pending USACE approval. The Federal Emergency Management Agency National Flood Hazard has not identified any 100-year floodplain areas within the Project site (Figure 11). The nearest identified 100-year floodplains are located approximately 1.3 miles upstream and 0.8 miles downstream of the Project. Doc No.: KM60-EN-RP-9540 9 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility $O%/S As part of the Natural Resources Conservation Service, the U.S. Department of Agriculture Soil Survey indicates the presence of seven soil unit types within the Project area (Figure 13) (SWCA 2024b; NRCS 2023). However, the mapped soils do not reflect impacts and soil homogenization resulting from historical mining activities. The soils are mostly comprised of upland soils that formed on saprolite or residuum on interfluves and hillslopes on ridges. All the soil types within the Project area are classified as well drained, nonhydric. Geology The Project will be centrally located within the Piedmont Plateau, which consists of both igneous and sedimentary rocks with various grades of metamorphism (Appendix G). Surface exposures at the Archdale TSF are limited to the area of the legacy mine. The remainder of the property is either blanketed under a deeply weathered saprolite profile, with varying degrees of preservation of the remnant structures of the protolith or overlain by legacy spoils or stockpiles. The surficial overburden/soil zone has been removed from the majority of the TSF site, exposing the saprolite. Based on regional geologic mapping by the U.S. Geological Survey (Horton 2008), the underlying bedrock geology of the Archdale TSF site consists mainly of muscovite schist and granite (Figure 14). Five primary geologic units have been identified at the Project site based on the geotechnical investigation (Appendix G). The geotechnical sonic borings conducted in 2023 are shown on Figure 15. Geological and geotechnical strength characteristics for each unit are also described in Appendix G. • Overburden Soils—Layers of remaining intact surficial soil or other material situated above the saprolite layer, where there is no historical surface disturbance, are typically identified and logged as overburden soil (residual soil). These soils are classified per the United Soil Classification System as mostly silt and dense silty sand. • Saprolite—Saprolitic soils resulting from in-situ weathering of local bedrock were identified at various thicknesses across the site. Saprolite typically consists of micaceous sandy silts and silty sands with low-plasticity clay minerals. The transition from residual native (overburden) soil to saprolite was noted in the boring logs where a distinct change in color, United Soil Classification System classification, and density were observed. • Partially Weathered Rock—The lower portion of the saprolite presents a higher stiffness and shows more features from the parent rock than can be observed in the upper soil-like zone. Closer to the weathered bedrock zone, gravel sized fragments of the parent bedrock were observed in the lower reaches of the saprolite zone. This lower zone of the saprolite is referred to as partially weathered rock (PWR). PWR at the TSF site was identified at depths ranging from 4 to 30 feet below ground surface (bgs), except when below the waste rock stockpiles and saprolite, where it was found between 120 and 150 feet bgs. The thickness of the PWR spans from 2 to 90 feet. The PWR was characterized as elastic silt, silty sand with gravel, poorly graded sand with silt Doc No.: KM60-EN-RP-9540 10 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility and gravel, and well graded gravel with sand with a trace of cobbles up to 15 percent in some locations. Gravel was often described as derived from quartz and pegmatite. The PWR is fine to coarse-grained, angular, was found in a moist condition, and has a wide spectrum of colors. Fines in PWR ranged from 14 to 87 percent. The clay percentage in selected samples was found using hydrometer testing and showed values from 7 to 15 percent. • Weathered Bedrock—Weathered bedrock was encountered at depths between 15 to 35 feet bgs, with the highest point situated at elevations between 825 and 900 feet amsl. The weathered bedrock presents as sound to highly fractured, fresh to highly weathered, and foliated. The weathered bedrock presents as very fine to coarse-grained, with quartzite veins, traces of garnets, and some pyrite. Rock quality designation values vary between 0 and 38 percent. Some samples of weathered bedrock have water content values between 7 and 18 percent. • Unweathered Bedrock—Unweathered, or competent, bedrock was encountered at depths between 30 to 179 feet bgs, with the uppermost horizon of competent bedrock encountered at elevations between 815 and 994 feet amsl. This geological unit includes diverse metamorphic rock types from the Inner Piedmont geologic unit, upper mica schist, and muscovite pegmatite. The unweathered bedrock displays sound to slight fracturing, unweathered to fresh conditions, is foliated, and is close to moderate fracture spacing. The unweathered bedrock presents as fine to medium-grained with pyrrhotite. Rock quality designation values vary between 19 and 74 percent. Hydrogeology Hydrogeology of the region around the TSF site is described in Appendix D and summarized below in Section C. 3.(C.). Existing Water Quality Existing surface water and groundwater quality data is currently being collected at the TSF site (Appendix E). Surface water samples collected onsite and from Dixon Branch meet surface water quality standards (Appendix 1). Cultural Resources A Phase 1 archaeological survey and geoarchaeological investigation was conducted in accordance with Section 106 of the National Historic Preservation Act and its implementing regulations, found in the Code of Federal Regulations Title 36, Part 800 (36 CFR Part 800) (SWCA 2024d). The Phase 1 survey was also conducted in accordance with applicable federal and state guidelines and requirements, including the North Carolina Office of State Archaeology Archaeological Investigation Standards and Guidelines (NCOSA 2023). Doc No.: KM60-EN-RP-9540 11 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Fieldwork was conducted on September 18 and 21, 2023 and consisted of visual inspections, pedestrian surveys, and shovel testing of the Project site. Shovel testing was limited to the southwestern portion of the Project where previous mining activities have not occurred. No previously recorded archaeological sites are located within the Project site. It was determined that development of the Archdale TSF will not have adverse impacts on historical properties; therefore, additional investigations are not warranted. Vegetation Land cover maps (USGS 2019) indicate that the Project consists primarily of hay/pasture (49.2%) and barren land (15.5%)with smaller portions of herbaceous forest, scrub-shrub, development, and open water (e.g., ponds, lakes, and mining pits described previously under the subsection called Wetlands and Floodplains) (SWCA 2024b). Review of the current aerial imagery and in-field assessment suggests the hay/pasture category is the barren and early successional shrubby/herbaceous land found in the historic mining areas rather than actual hay/pasture (SWCA 2024b). SWCA Environmental Consultants (SWCA) (2024b) also observed that natural regeneration of herbaceous, shrubby, and forest habitat has occurred over waste rock piles and other areas historically disturbed by mica mining. These habitats are all generally in a dense, successional stage of growth, with most trees being less than 10 years old with average widths of 5 to 8 inches diameter at breast height. Vegetation communities found in the habitats are listed below and described in detail by SWCA (2024b): • Forested upland (deciduous, evergreen, and mixed) • Herbaceous upland • Scrub-shrub. Biology and Wildlife A desktop review, in combination with field observations, was performed in September and October 2023 (SWCA 2024a, 2024b) to assess the potential occurrence of federally and state- listed species. The assessment addressed flora and fauna species protected under the Endangered Species Act of 1973, as amended, as well as North Carolina state-listed species protected as Endangered and Threatened Wildlife Species of Special Concern of the State of North Carolina (North Carolina General Statutes 113-331). The U.S. Fish and Wildlife (USFWS) Information for Planning and Consultation resource identified four federally listed species having the potential to occur on the Project site: little brown bat (Myotis lucifugus), tricolored bat (Perimyotis subflavus), monarch butterfly (Danaus plexippus), and the dwarf-flowered heartleaf (Hexastylis naniflora). However, no USFWS- designated critical habitat for federally listed species is within the Archdale TSF site. Both bat species were once abundant in North Carolina, although populations have significantly declined due to white-nose syndrome. Most of the native habitat on the Project site has been highly disturbed despite being a closed mine. However, small areas with mature trees and Doc No.: KM60-EN-RP-9540 12 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility enough successional trees have regenerated, providing suitable habitat for the tricolored and little brown bat. Acoustic bat surveys have not yet occurred at the Archdale TSF site but were conducted at the KMM site approximately 3 miles east. During those surveys, only the tricolored bat was detected. However, as there is suitable habitat for both species, and as the tricolored bat was recently confirmed in the vicinity, both species have the potential to occur. The monarch butterfly and dwarf-flowered heartleaf have a low potential for occurrence due to lack of suitable habitat. The timber rattlesnake (Crotalus horridus) is the only state of North Carolina listed species that has moderate potential to occur based on suitable habitat (e.g., rock outcroppings). Species- specific surveys were not conducted due to the secretive nature of the species. However, biological surveys were conducted during the species' active period in 2023, and no timber rattlesnakes were observed. All other state-listed species had a low or very low potential to occur, primarily due to lack of suitable habitat. Sequence of Events during Construction Construction of the initial TSF embankment and stormwater management system will be conducted during KMM Mining Year 0 per the sequence listed below: • Installation of E&S control best management practices (BMPs) (see Figures 24 and 25) and buildout of separate stormwater basins (Figure 26) (additional descriptions and other maps are provided in Appendix C to manage and divert non-contact water) (Appendix G). These BMPs and stormwater basins will be installed during construction and maintained at all times during construction and operations. The BMPs include, but are not limited to, silt fences, straw wattles, earthen berms, and surface stabilization. These BMPs will also be installed during the establishment of road access from U.S. 29. The E&S plan included in Appendix C and depicted on Figure 24 are preliminary at this stage of design. However, a more formal E&S plan will be submitted a minimum of 30 days prior to land disturbance, pursuant to Chapter 4 of the North Carolina Environmental Quality Erosion and Sediment Control Planning and Design Manual (NCDEHNR 1996). • Clearing and grubbing of existing vegetation and soil salvaging at the proposed TSF location and NPI pad area (Figure 18), including the upper 1 foot of organic topsoil and growth media surface materials (consisting of the A/B soil horizon and a variable portion of the upper C horizon saprolite soils), and removal of the legacy mica stockpile materials. Salvaged soil will be stored at the GMS area located on the southern end of the Project site. Any excavated saprolite from the TSF excavation footprint that does not meet growth media requirements will be back-hauled to KMM using the same trucks that are hauling the waste rock sourced from KMM for construction of the TSF embankment. The legacy mica stockpiles will be excavated and placed at the bottom of the TSF and compacted to the material specifications. • Re-establishing access into existing legacy open pits, including construction of an unpaved, perimeter access road (see Figure 18), which will encircle the existing pit rim (Appendix B). Doc No.: KM60-EN-RP-9540 13 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Access roads shown in Figure 18 and Design Drawing Sheet 300 in Appendix B will be constructed using rock fill. This perimeter access road will also be used to construct the initial starter embankment (Figure 20). The grading plan (Figure 18) consists of excavating the existing saprolite pit floors to an average of 10 feet (and locally up to 30 feet) to provide a relatively smooth surface sloped to a single seepage collection sump at the southeastern corner of the TSF. The deepest pit floor (bottom) planned for the TSF grading activities will be 850 amsl. Based on available data (Appendix G), relatively low permeability saprolite soils are likely to be present throughout the TSF excavation footprint, which will provide a relatively low permeability surface capable of inhibiting vertical migration of collected waters and promoting lateral flow to the TSF base drain system described below. These grading and TSF base excavation activities may include limited drilling and blasting and use of explosives in the existing pit bottom, if hard bedrock is encountered. However, no blasting is currently anticipated. • Construction of the initial starter TSF embankment and perimeter berm, which will occur completely within the base of the existing pit with a 40-feet wide crest road to a Phase 1 elevation of 885 feet amsl (see Table 2, and Figures 18, 19, and 20) using non-PAG coarse- grained waste rock transported from the KMM facility. The starter embankment will include a 3-feet wide and 2-feet thick layer of crushed sand filter along the interior slope face to form a zoned sand filter and prevent migration of tailings solids through the coarse waste rock outer embankment. The embankment will be constructed with a 1.5 horizontal to 1 vertical interior side slope and a 2.5 horizontal to 1 vertical exterior side slope. If onsite materials cannot be processed to meet the necessary material specifications, non-PAG materials will be imported from an outside vendor. Temporary haul roads will be constructed as necessary within the pit and tailings placement areas for all-weather access for site haul trucks. Additional perimeter rock embankment raise construction details during operations are described below under subsection Sequence of Events during Operations. • Installation of the TSF base drain system, which will be placed over the prepared base (to be located under the placed tailings) to collect and remove infiltrating meteoric water (that will contact and infiltrate the placed filtered tailings) and any collected seepage from upwelling groundwater (Figure 19). The base drain system will consist of a series of perforated corrugated polyethylene collection pipes placed along the existing and regraded natural flow lines. It will be covered with drain rock or sand to provide a preferential flow path for the migrating waters. The base drain system will route waters collected from the interior of the TSF footprint (dominated by contact waters defined below) to a seepage and stormwater collection sump at the southeastern edge of the TSF interior (see the sump drain on Figures 20 and 21 and in Appendix B). Two drainpipes will exit the sump base and be routed under the southern embankment to the contact water transfer pond described below. The pipeline will be installed with multiple water stops to prevent seepage flow along the pipeline. There will not be a pool of water at the bottom of the TSF. The pump in the sump drain will not be relocated as tailings are deposited into the TSF. Water that is predicted to exit the filtered tailings pile via this base drain system is 144 gpm (Appendix H) excluding stormwater. No synthetic liner system is justified at the base of the TSF for the following two Doc No.: KM60-EN-RP-9540 14 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility reasons (Appendix G): drilling and sampling of the saprolite conducted within the proposed base excavation areas suggests they will provide a relatively low permeability surface capable of inhibiting vertical migration of fluids and promoting lateral flow to the TSF base drain system; and the geochemical characterization and modeling results. • Installation of the surface water management infrastructure (Figures 18 to 20, and 26 and 27). Contact water will consist of surface water runoff from the TSF (Appendices G and H) and TSF seepage contact water, which will be pumped to the contact water transfer pond as described in Section C. 2. below (SRK 2024b). Stormwater management outside the limits of the TSF will include a perimeter stormwater management channel at the toe of the slope to route collected runoff to a sediment retention basin. Stormwater generated between the northern extent of the TSF and U.S. 29 will flow within existing channels along the edge of 1-85 to the south/southwest through a system of channels and culverts and then offsite (Appendices C, G, and H). • Construction of surface infrastructure and NPI to be located at the northern and southern gate entrance areas (as described in Section A), which also includes utility installation. New onsite infrastructure will be connected to the city of Kings Mountain's utility systems at the property boundaries and with the existing Rutherford overhead power tie-in. • The utilities servicing the Project will include (Figure 16): - A 3-inch potable water line from the city of Kings Mountain extending overland from the tie-in to the NPI pad. - A 4-inch high-density polyethylene sewage line from the city of Kings Mountain extending overland from the lift station to the tie-in. - Electric power from the existing Rutherford overhead line extending to the pad. • Final conditions at the end of TSF construction will include the buildout of the starter embankment at an elevation at 885 amsl (Figure 20). Sequence of Events during Operations Operations, consisting of tailings placement, will commence in KMM Mining Year 1 in the approximate sequence listed below: • Hauling of filtered tailings from the KMM tailings loadout facility to the Archdale TSF (Figures 21 and 22). Filtered tailings index test results and mineralogical descriptions are provided in Appendix G. • Continued hauling of non-PAG waste rock from the KMM (Figures 21 and 22) to the TSF embankment to raise the working face. - Tailings placement will be either directly at the working face or within temporary stockpiles over the 9.4 years of operation (Table 2). Tailings will be spread with dozers and other mobile equipment into 12-inch-thick lifts and compacted to specified maximum proctor dry densities and optimum moisture contents (Table 5). A smooth, graded, Doc No.: KM60-EN-RP-9540 15 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility compacted surface will be created to promote stormwater flow during operations (and closure) from the implementation of the surface water management plan described below, while minimizing the potential for collection and pooling elsewhere on the TSF surface. When necessary, water will be added to achieve compaction requirements (per specifications described in Appendix G) and to contain fugitive dust. A list of mobile equipment that is anticipated to be used during the Project is included in Appendix J. Table 5: Compaction Test Results on Proposed Filtered Tailings OptimumTest Sample Maximum Dry Density (Pcf) Content Standard proctor maximum dry COMP1/2 102.6 15.9 density (ASTM D698) Modified proctor maximum dry COMP1-202303 104.6 12.5 density (ASTM D1557) COMP2-202303 102.8 12.3 COMP1/2 105.4 12.8 Source:Appendix G Additional compaction tests(proctor testing)could be conducted prior to mine startup and/or during initial tailings placement and compaction activities. pcf= pounds per cubic foot • Continued TSF embankment construction will be conducted in five additional phases (corresponding to Construction Phases 2 through 6 in Table 2), as tailings are placed and compacted over time. Raise construction will be ongoing throughout the KMM LOM. The starter embankment constructed prior to process startup (related to Phase 1 in KMM Mining Year 0) is expected to provide tailings storage capacity for the first year of TSF operation. During that first year of processing, the initial annual raise will be constructed through the fifth year of operations (Figure 21), which will provide sufficient tailings storage capacity through the ninth year of processing. The non-PAG waste rock delivered from the KMM will be placed directly in the embankment raise work area for management with TSF haul and mobile equipment. However, the TSF will not be used to store water and any collection of water will be immediately pumped out through the surface water management system. As such, the TSF is not considered a dam per the DEMLR Land Quality Section's Dam Safety Program requirements and definitions. Additional perimeter embankment construction details are described below in Section C. 6.(B.). • Implementing a surface water management plan (see Appendices C and H). Non-contact stormwater will be collected in separate surface water diversion structures, managed with appropriate E&S controls, and released to existing drainages at approved discharge points (SRK 2023b). Contact water will be separately collected in a series of channels and contact water management ponds that will be monitored before being released to an unnamed tributary (SRK 2024b). Water discharged from the TSF will not need treatment beyond the settling ponds before discharge to the unnamed tributary (Archdale Creek) to Dixon Branch. The design criteria were selected based on applicable regulations and associated guidance documents, including the North Carolina Surface Mining Manual(NCDEHNR 1996), the Doc No.: KM60-EN-RP-9540 16 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Global Industry Standard on Tailings Management (GISTM 2020) flood design criteria, and with consideration for Project-specific risks. The selected criteria and the North Carolina recommendations are shown in Table 6 below. Table 6: Surface Water Design Criteria Infrastructure Type Project Design Criteria Recommendation a Permanent channels adjacent to PMP local storm 10-year storm (temporary) the TSF 25-year storm (permanent) Permanent channels in the NPI 100-year storm 10-year storm (temporary) area 25-year storm (permanent) Culverts Probable maximum flood 25-year storm Ponds 25-year storm for all sediment 10-year storm (<20 acres) control ponds 25-year storm (>20 acres) 100 percent containment of the probable maximum precipitation storm event for TSF collection pond a Recommended by North Carolina Mining Manual(NCDEHNR 1996)and Erosion and Sediment Control Planning and Design Manual, North Carolina(NCSCC 2013). NPI = non-process infrastructure; PMP=probable maximum precipitation; TSF=tailings storage facility • Collecting contact water (Appendix G) in the base drain system to be routed to the seepage and stormwater collection sump (see Figures 20 and 21 for the sump drain location) and contact water transfer pond, including groundwater inflow from the interior of the TSF during operations (Figures 20 and 21). All runoff produced from the active tailings surface within the crest of the perimeter berm will be collected and pumped to the contact water transfer pond to avoid standing water (Appendices G and H). This pump will be sized to evacuate the probable maximum precipitation event within about 2 weeks. Anticipated ponding time is less than 2 days for a 100-year storm event (Appendix H). The non-PAG waste rock used to construct the TSF will be subject to runoff, infiltration, uptake, and percolation. Any water that percolates through the non-PAG rock will be routed to the TSF drainage system and added to the collection sump before being pumped to the contact water transfer pond. The contact water transfer pond is sized to detain contact water produced by the TSF up to the 100-year flood and to convey flow from a probable maximum flood event through an emergency spillway. If the water meets the necessary water quality criteria (see Appendix 1), it will be discharged from Outfall 002 to the existing culvert under 1-85 through a gravity pond skimmer or an optional pumping system (with a max pump flow rate of 667 gpm) (Appendix C) utilizing a floating intake. The contact water transfer pond is designed to have a 3.8-million-gallon storage capacity and will allow sediment in the ponded water to precipitate out prior to discharge (Appendix G). Additional information on TSF water management during operations is included in Appendix H and described by SRK (2024c). • Stormwater management (see Appendix C and Section C. 2. below for details), consisting of channels and culverts (Figure 27) capable of conveying a maximum flood event (100-year, 24-hour flood) around or across the site without detention. The non-contact water channels Doc No.: KM60-EN-RP-9540 17 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility will be constructed during the development of the TSF to divert flows around the infrastructure and collect surface runoff to prevent commingling with non-contact water. The channel networks will be developed in three sections associated with the identified outfall numbers on Figure 17 including the active TSF perimeter associated with Outfall 003, the NPI pad associated with Outfalls 001 and 002, and the active TSF areas associated with Outfall 001 (see Appendix C). In addition, existing Outfall 004 is related to waters in the existing legacy open pit, will be temporary, and is described below in Section C. 3.(B.). • Water from the truck wash in the southern NPI area will be collected, routed to the new sewer line, and connected to the existing sewer main along Route 29 (Figure 16). The captured truck wash water will therefore be treated at an offsite municipal wastewater treatment plant. 2. Describe specific erosion control measures to be installed prior to land disturbing activities and during mining to prevent offsite sedimentation (include specific plans for sediment and erosion control for mine excavation(s), waste piles, access/mine roads, and process areas), and give a detailed sequence of installation and schedule for maintenance of the measures. Locate and label all sediment and erosion control measures on the mine map(s) and provide typical cross- sections/construction details of each measure. Engineering designs and calculations are required to justify the adequacy of any proposed measures. Appropriate erosion control measures and BMPs will be installed and maintained during construction and operations to prevent discharges of sediment and turbid waters offsite. Concurrent reclamation and/or stabilization of disturbed areas with unconsolidated soils will occur during construction where possible. Disturbed areas created from the construction of haul roads, ditches, embankment faces, and the disturbed perimeter of facility footprints will be stabilized after final grades have been established. A preliminary, site-specific construction and operational TSF erosion control plan has been attached in Appendix C. As part of new site construction and commissioning, a formal E&S plan will be developed using furthered design and operational details, in compliance with the specific requirements of the Erosion and Sediment Control Planning and Design Manual (NCSCC 2013). The final plan will be approved prior to commencement of land disturbance activities. Ongoing BMPs will be provided over the life of the facility by constructing a sediment control pond that will receive non-contact water flows from disturbed and undisturbed natural ground collected by the perimeter channels. The majority of the sediment controls will be implemented during TSF construction, while ongoing tailings placement, embankment raises, and concurrent reclamation will require ongoing sediment controls over the life of the facility. Hydrologic and hydraulic modeling and a description of the methodology and summary of calculations for sizing the channels, determining the required erosion protection, and for sizing the sediment control pond are included in Appendix C. Doc No.: KM60-EN-RP-9540 18 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Channel networks (Figure 27) will be developed in three sections: the TSF perimeter, the NPI pad, and the TSF (see Section C.3.(B.) below and Appendix C for details). Each will be designed with a different stormwater management approach. Erosion protection for the channels was selected based on the maximum tributary catchment for the duration of the Project and the expected velocities during flood events. Most of the proposed channels are grass-lined, although those with steeper gradients will be lined with riprap. One sediment control pond will be situated downstream of the TSF perimeter channels to manage non-contact water from the active TSF perimeter corridor before discharging into the unnamed tributary to Dixon Branch. The sequence of installation and maintenance of BMPs is described below. BMPs will be visually inspected for stability and operation on an inspection schedule that will be outlined in an approved Stormwater Pollution and Prevention plan. Erosion Control Measures to be Installed during Construction The TSF E&S plan and map showing erosion controls that will be employed during construction are shown on Figures 24 and 25 and described in detail in Appendix C; the stormwater channel layout is on Figure 27; and sections and details showing BMPs are shown on Figure 25. Sediment control measures will be appropriately installed prior to soil disturbance. The TSF BMPs will be installed when road access is established from U.S. 29, to control and divert non- contact water. Proposed BMPs may include, but are not limited to, staked silt fences, straw wattles, earthen berms, culverts, check dams, riprap and diversion channels, sediment ponds, skimmer and riser sediment basins, outlet stabilization, typical operational paved flumes, and surface stabilization (Appendix C; NCSCC 2013). The perimeter channel around the TSF will use a composite channel design with a low-flow triangular channel section adjacent to the TSF perimeter berm and a minimum 5-foot perimeter roadway sloping towards the low-flow channel at 2 percent grade. The low-flow portion of the channel will be designed to convey flow from the 100-year, 24-hour storm event and utilize the 50-feet wide roadway to convey higher flows to the probable maximum precipitation event. Freeboard for the low-flow channel will be provided by the additional 1 foot of flow available on the roadway, and a minimum 18-inch safety berm will provide freeboard above the roadway surface at the probable maximum precipitation design flow. A typical section through the perimeter channel and haul road is shown on Detail 1 of Figure 25 (also see Appendix C). A skimmer sediment pond will de-sediment the water before discharging it under 1-85 through an existing 60-inch reinforced concrete pipe culvert to the unnamed tributary to Dixon Branch. The maintenance plans and schedule for the sediment pond include removing sediment when accumulation reaches 50 percent of the available storage. Floating trash and debris will be removed. Vegetation at the top and faces of the embankment will be removed. Outlet structures from the sediment pond will be inspected for clogging and/or structural damage. Debris will be removed, and needed repairs will be done immediately. Outflow locations will be inspected to make sure discharge from the pond is not impeded by tailwater conditions. Doc No.: KM60-EN-RP-9540 19 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Accumulated sediment will be removed from behind the check dams before reaching 50 percent of the dam height. Dislodged or washed-out check dams will be restored to their original configuration. Ditches and channel areas will be repaired where excessive downcutting or side scour have occurred. If significant erosion is observed between dams, a protective turf reinforcement mat or section of riprap liner will be installed in that portion of the channel. Rock weirs will be replaced when filtering capacity is reduced by one-half. Erosion Control Measures to be Installed during Operations Surface water will be managed per the site-wide water balance (Appendix H) to provide sufficient storage to prevent the undesirable release of impacted water from the Project. The water balance provides water storage from the TSF with sufficient detention to allow monitoring before offsite release without treatment. 3. A) Will the operation involve washing the material mined, recycling process water, or other wastewater handling? If yes, briefly describe all such processes including any chemicals to be used. No. Tailings processing will occur at the KMM concentrator prior to being transported to the TSF. Water may occasionally be added to the deposited filtered tailings using a water truck after arrival and placement in the TSF to achieve compaction requirements for dry stack tailings. 3. B) Will the operation involve discharging fresh or wastewater from the mine or plant as a point discharge to the Waters of the State? If yes, briefly describe the nature of the discharge and locate all proposed discharge points (along with their method of stabilization) on the mine map(). Yes. The operation will involve discharging water from the Project from four discharge points to the Waters of the State, which is identified as the unnamed tributary (Archdale Creek) to Dixon Branch. Please refer to the TSF Outfall map (Figure 17) showing the locations of the planned outfalls. Three of the outfalls will include culverts to be installed within the Project boundaries (Outfalls 001, 002, and 003) and are shown on Figures 16 and 17. One outfall (Outfall 004) that exists under the current owner and operator (Imerys S.A.), is described below, and will be transferred to a new NCG02 issued to Albemarle and related to this Project. The three new culverts that will be installed during construction and used during operations include (from south to north): • A 24-inch diameter culvert (related to discharge Outfall 001) that will discharge non-contact water from the southern NPI building pad area. • A 30-inch diameter culvert (related to discharge Outfall 002) that will discharge contact water from the contact water pond after the sediment has dropped out. • An 18-inch diameter culvert (related to discharge Outfall 003) that will discharge non-contact water with ongoing sediment control. Doc No.: KM60-EN-RP-9540 20 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility These three new culverts will be removed during reclamation (see Section D below). Outfall 004, an existing outfall, will be temporary and currently conveys non-contact groundwater and precipitation stormwater pumped from the legacy open pit to an existing sediment pond (referred to as forebay pond). The discharge of the sediment pond drains either through an existing constructed rockfill berm or by overflowing the berm, and currently passes through existing Outfall 004 before flowing into an existing 60-inch diameter culvert under 1-85 and then into the unnamed tributary to Dixon Branch. Preliminary designs for surface water management are described in Appendices B, C, and H. All surface water from the Project will be discharged to the unnamed tributary to Dixon Branch at one of the three existing culverts described below (Figure 6): • A 36-inch diameter culvert that will discharge non-contact water from stabilized surfaces using BMPs, revegetated surfaces in the southern NPI building pad (including discharges from Project Outfall 001), and offsite areas. • A 30-inch diameter culvert that will discharge non-contact water generated from the southern NPI building pad area and from offsite areas, as well as contact water from the transfer pond (including discharges from Project Outfall 002). • A 60-inch diameter culvert that will discharge non-contact water from the southern NPI building pad (including discharges from Project Outfall 003), the perimeter channel corridor, and from offsite areas. This culvert will also receive discharged waters from the reclaimed TSF perimeter during post-closure. Surface water discharged from the Project site will be categorized into three different types (Appendices G and H; SRK 2024b): • Contact water, including water that has contacted the tailings or embankment wall, which DEMLR will regulate as mine dewatering/wastewater; • Non-contact water with ongoing sediment control (i.e., runoff from the TSF perimeter corridor including waters from reclaimed and revegetated slopes, haul roads, perimeter access roads, and offsite contributing areas that are collected in two perimeter channels around the TSF leading to the sediment retention basin; and water discharged from the legacy open pit), which DEMLR will regulate as stormwater; and • Non-contact water from stabilized surfaces (i.e., waters from revegetated areas, offsite areas, and the NPI areas that will contain impervious surfaces [Figure 28] or gravel surfaces that will not require sediment controls other than BMPs). The portion of this water that contacts the NPI area is regulated as stormwater. Water will be collected in the contact water pond and will not require further treatment prior to discharge but will be monitored to ensure NCG02 water quality standards are met. Water will be released through a floating skimmer to the 30-inch culvert discharge point. An emergency culvert spillway capable of conveying the probable maximum precipitation event will discharge to the existing 30-inch culvert discharge point. Doc No.: KM60-EN-RP-9540 21 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Non-contact water will be controlled by perimeter channel corridors around the TSF and will collect runoff from the haul roads, perimeter access roads, cut slopes, reclaimed slopes, and offsite contributing areas. A spillway capable of passing the probable maximum precipitation event will also be discharged to the existing 60-inch culvert. A stream stability study (see Appendix Cl: UT to Dixon Branch Stability Assessment of Appendix C) that included desktop hydraulic modeling using HEC-RAS Version 6.1.0 software (USACE 2021) was conducted to evaluate the impacts of discharging water from the proposed TSF site into the unnamed tributary to Dixon Branch, including evaluation of changes in flow rate and physical structure. The results of the stream modeling study indicate that the slight increase in flows associated with the Project are expected to be minimal and not result in increased instability. 3. C) Will any part of the proposed mine excavation(s) extend below the water table? If yes, what impact, if any, will mine dewatering have on neighboring wells? Locate all existing wells on the mine map(s) that lie within 500 feet of the proposed excavation area. Provide data to support any conclusions or statement made, including any monitoring well data, well construction data, and current water withdrawal rates. Indicate whether the proposed mine locale is served by a public water supply system or private wells. Three of the legacy open pits that contain existing pit lakes (see Figure 6) extend below the groundwater table. The proposed TSF Project will also extend below the groundwater table. Currently no groundwater pumping is being conducted at the TSF site by the current operator, other than groundwater that collects in the existing pit lakes and is pumped to the forebay pond (Figure 6). The pumping capacity of the existing pump is estimated at approximately 600 gpm (SRK 2024a). The estimated average groundwater discharge under current conditions is estimated at 59 gpm (Appendix D). The estimated amount of groundwater entering the filtered tailings pile during operations (e.g., tailings deposition and pit backfill) is 144 gpm excluding stormwater (Figure 29; Appendix H). Groundwater Effects from Pit Dewatering A hydrogeological model (Appendix D) was developed based on knowledge of the surface water drainage system, groundwater level measurements, and bathymetry for the three existing pit lakes on the site. The hydrogeological model identified the major hydrogeological units based on lithology, alteration, and hydraulic testing and modeling, mechanisms of groundwater recharge and discharge, water levels and direction of groundwater flow, and potential changes to current hydrogeological conditions due to the proposed tailings deposition and subsequent post-depositional conditions. The model simulated recharge from precipitation, interaction with surface water bodies, dewatering of existing pit lakes and tailings deposition, and water level rise in the tailings over time, and was calibrated to water level measurements and estimates of base flow in the nearby upper tributary to Dixon Branch. Accordingly, the model effectively replicates present conditions. Doc No.: KM60-EN-RP-9540 22 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility The model evaluated the impact of proposed pit dewatering and mining /TSF operations on groundwater levels surrounding the Project. The maximum extent of the 5-foot drawdown contour related to the proposed TSF dewatering activities is shown to be confined to within a small area located inside the southeastern corner of the TSF permit area (Appendix D). Groundwater drawdown due to pit lake dewatering is limited due to the short duration and relatively low permeability of the saprolite beneath the pit lakes. The maximum drawdown occurs a few months into tailings deposition (early in operation), after which water levels begin to rise due to the removal of the pit lakes as sinks. Modeling predicts no impacts to neighboring wells, the nearest of which is approximately 2,000 feet away (Appendix D). Currently, there are no existing streamflow monitoring points within or outside the TSF Project footprint in Archdale Creek, so no baseflow has been identified (Appendix C). The nearest existing flow monitoring station to the Project is on Kings Creek in Blacksburg, South Carolina (U.S. Geological Survey identification number 02153590) approximately 2.3 miles downstream of the discharge from this Project. During the January 2024 SRK site visit, water from the forebay pond was observed to be overtopping the rock berm with a total approximate Archdale Creek flow rate of 1.5 cubic feet per second (cfs) located at the 1-85 culvert location (SRK 2024a). Other flow rates from different locations along Archdale Creek recently collected by AECOM from January 25 to May 13, 2024, range from 0.61 to 20.95 cfs (Albemarle 2024d). The desktop hydrologic analysis for Archdale Creek estimated 1-year, 2-year, and 100-year peak water discharges of 110.4, 164.2, and 608.8 cfs, respectively (Appendix Cl: UT to Dixon Branch Stability Assessment of Appendix C). The total estimated water discharge flow rate from the three Project outfalls into Archdale Creek during Project operations is 276 gpm (Figure 29; Appendix H). Monitoring wells at the TSF site are shown on Figure 12. Water level data was collected from newly installed wells, historical wells, and accessible surface water bodies using a combination of water level meters, survey equipment, and data logging pressure transducers. The field data were used to develop the hydrogeological model and numerical groundwater flow models. The proposed Archdale TSF will be served by a public water supply system from the city of Kings Mountain (Figure 16 and Appendix B). No groundwater will be extracted to support operations at the site. Tailings Storage Facility Surface Water Balance Summary A site-specific water balance model (Figure 29 and Appendix H)was developed using the commercial software package GoldSim (GoldSim 2021). The conceptual model of the mine water balance was incorporated into a site-wide dynamic water balance simulation (the model) designed to simulate the physical processes identified for each component (Figure 30) and transfer water between the facilities according to the operations flowsheet (Figure 29). The model forms an electronic analog of how the mine water management system at the TSF site is expected to behave and allows for simulations to explore the behavior of the system under typical, historical, projected, and extreme conditions. Doc No.: KM60-EN-RP-9540 23 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility The water balance model is a simulation of the mine water management system that incorporates dynamic aspects of the mining activities, specifically: • Groundwater inflows to the TSF during and after operations; • Surface runoff from the active TSF during operations; • Infiltration into the TSF during and after operations; • Storage of stormwater and seepage water volumes within the contact water transfer pond system; and • Simulation of mine closure activities, including covering the tailings and reducing seepage produced by the tailings. All model input parameters, calculations, and sensitivity values are included in Appendices D and G. Overall, the model indicates the system will be able to manage stormwater and seepage flows in a controlled manner. For all cases analyzed, the proposed TSF water infrastructure and water balance system were able to manage the TSF contact water within the design constraints with an overall positive water balance. The model is relatively sensitive to the amount of groundwater inflow entering the TSF while percolation and infiltration parameters had less impact. 3. D) If you answered yes to any of the above questions, provide evidence that you have applied for or obtained the appropriate water quality permit(s) (i.e., non-discharge, NPDES, Stormwater, etc.) from the Stormwater Program. In addition, the applicant is required to register water use with the Division of Water Resources, Ground Water Management Branch, if the operation withdraws more than 10,000 gallons per day and needs a capacity use permit from the Division of Water Resources, Ground Water Management Branch, if the operation lies in a capacity use area and withdraws more than 100,000 gallons per day. An NCG02 for water discharges associated with this Project has been submitted to DEMLR concurrently with this application. Although groundwater withdrawals from pit dewatering will not change significantly from the current case, a water withdrawal registration will be completed and submitted before permitted operations begin. 4. A) Will the operation involve crushing or any other air contaminant emissions? If yes, indicate evidence that you have applied for or obtained an air quality permit issued by the Division of Air Quality or local governing body. Operations at the TSF will not involve crushing. There are no emission sources associated with the Project that will require an air quality permit. During operations, the filtered tailings will contain 10 to 15 percent moisture and will not typically generate fugitive dust. A mobile crusher owned and operated by a contractor may be temporarily used during construction to generate sand; all air permits would be acquired by the mobile crusher owner. 4. B) How will dust from stockpiles, haul roads, etc., be controlled? Doc No.: KM60-EN-RP-9540 24 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Dust will be controlled using water from the contact water pond, if required. Water will be added to the tailings during compaction, if required, to the specified moisture content levels identified in Table 5 above. Haul roads will be constructed with coarse gravel (imported road base) compacted to create a nearly impervious surface (Figure 28). This will inherently reduce the generation of fugitive dust (see Appendix G). Additionally, haul roads and other access roads will be sprayed with water via water trucks, as needed, to control fugitive dust and maintain visibility. 5. A) A buffer will be required between any mining activity and any mining permit boundary or right-of-way. It may be an unexcavated buffer (no excavation, but roadways, berms, and erosion & sedimentation control measures may be installed within it), an undisturbed buffer (no disturbance within the buffer whatsoever), or a combination of the two, depending upon the site conditions. Note that all buffers must be located within the mining permit boundaries. How wide a buffer will be maintained between any mining activity and any mining permit boundary or right-of-way at this site? A minimum buffer of 25 feet is recommended, although a wider buffer may be needed depending on site conditions. Show all buffer locations and widths on the mine map(s). Figure 31 shows all proposed buffer locations and widths. A 25-feet wide buffer will be maintained throughout the Project even though no mining is proposed. The buffers will not consist of surface disturbance maintained between the Project permit boundaries or the rights- of-way at the TSF site or areas containing surface disturbance for the proposed Project activities. 5. B) A minimum 50 foot wide undisturbed buffer will be required between any land disturbing activities within the mining permit boundaries and any natural watercourses and wetlands unless smaller undisturbed buffers can be justified. Depending on site conditions, a buffer wider than 50 feet may be needed. How wide an undisturbed buffer will be maintained between anv land disturbing activities within the mining permit boundaries and any natural watercourses and wetlands at this site? Show all buffer locations and widths on the mine map(s). There are no natural watercourses or jurisdictional wetlands at the TSF site; therefore, internal buffers are not required for the protection of water resources. 6. A) Describe methods to prevent landslide or slope instability adjacent to adjoining permit boundaries during mining. Minimum 2 horizontal to 1 vertical slopes or flatter for clayey material and minimum 3 horizontal to 1 vertical slopes or flatter for sandy material are generally required unless technical justification can be provided to allow steeper slopes. No removal of minerals, ore extraction, or open-pit or underground mining is proposed as part of this Project other than excavation and grading of material that has accumulated in the legacy pit where the TSF will be constructed. There will be no surface disturbance in the buffer zone adjacent to the permit boundary as identified in Section C. 5.(A.) above. Doc No.: KM60-EN-RP-9540 25 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Weaker zones of saprolite within the TSF footprint may need to be excavated to stronger foundation soils/bedrock to improve the stability of the facility. If required, the foundation will be excavated at safe slope angles and the stability of the excavation will be analyzed and monitored by a geotechnical engineer to ensure adequate factors of safety at all times. Stability measures to improve excavation stability may include buttressing with rockfill and/or other ground improvement techniques. The design case for the TSF includes removal of the weak saprolite layer below the toe of the proposed facility, to an average depth of approximately 10 feet and to a maximum depth of approximately 30 feet in localized areas along the southern perimeter. With the proposed removal of unsuitable material, stability analyses resulted in acceptable static factors of safety for overall facility slopes of 2.5 horizontal to 1 vertical, as is currently planned. The TSF embankment will be constructed with a 1.5 horizontal to 1 vertical interior side slope and a 2.5 horizontal to 1 vertical exterior side slope. The contact water pond will be approximately 15 feet deep with side slopes of 2.5 horizontal to 1 vertical and constructed without a base liner to facilitate periodic sediment cleanout. The stability of the proposed TSF was evaluated at one representative geological/analytical cross-section labeled B-B' and included factors of safety and established stability criteria for all stability runs (Appendix G). A detailed description of site subsurface conditions is also available in Appendix G. Limit equilibrium stability analyses were performed for static factors using circular and non- circular failure surfaces. Stability evaluations were performed using SLOPE/W software by Geostudio, a two-dimensional slope stability program using the limit equilibrium analysis method. The Applicant will establish and follow a written ground control plan for safe control of all highwalls, pits, and spoils banks which need to be consistent with prudent engineering design and that will provide safe working conditions. Landslides will be prevented by observational monitoring and possible instrumentation methods that will include monitoring for and documenting (e.g., mapping and photographing) any fill material instabilities (e.g., rock falls, sluffs, water ponding, ground movement, etc.) and tension cracks on the surface adjacent to the edges of the existing legacy open pits and/or excavations, and immediately notifying the appropriate Project supervisor. 6. B) Provide a cross-section on the mine map(s) for all fill slopes (berms, waste piles, overburden disposal areas, etc.), clearly indicating the intended side slope gradient, installation of any benches and/or slope drains (with supporting design information) if needed, and the method of final stabilization. Cross-sections through the tailings waste pile area, including the perimeter rock embankment, during construction and operations are provided in Appendix B, and during reclamation on Figure 32. The construction and details of the tailings pile slopes have been described above in Section C. 6.(A.) and in Appendix G. Doc No.: KM60-EN-RP-9540 26 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Raise construction of the perimeter rock embankment will be conducted annually through the first 6 years of the facility's life (Table 2) using centerline lift construction methods from the toe up to and over the crest with suitable run-of-mine TSF excavation and KMM waste rock. The crest width will be maintained at 40 feet (including safety berms and travel ways)for each raise. The waste rock used for the starter embankment and annual raise construction is anticipated to be very coarse. Waste rock clasts larger than 12 inches will not be incorporated into the rock embankment. The rock embankment materials will be spread using a dozer into lifts that are as thin as possible (generally no more than 24 inches thick) and compacted using three to four passes with heavy equipment to maximize compaction to create a stable structure. Each new lift placed against an existing embankment slope will be keyed in by cutting into the existing slope about 24 inches laterally, placing and spreading the new lift, and then compacting the new surface layer as one layer to provide structural stability. The rock embankment design will include a 3-feet wide (approximately 2-feet thick) layer of crushed and graded filter sand (processed at the TSF site or imported) along the interior slope face to form a zoned sand filter and prevent migration of tailings solids through the coarse waste rock outer embankment. Crushed pilot testing will be performed as part of facility construction to develop grain size distribution relationships for each component of the interior side slope design to facilitate Terzaghi filter calculations and ensure that the different material types will be both internally stable and compatible for use in a layered sand filter design. The annual embankment raise construction targets will aim to provide a minimum freeboard above the highest tailings level of 4 feet. Based on the operational methods, actual storm storage capacity will be much greater as the tailings surface will be sloped to manage stormwater at a surface collection sump. Reclamation of the tailings pile including the final cover design is described below in Section D. 1. and in Appendix K. Final stabilization of the reclaimed tailings pile will be achieved by maintaining the designed overall slope of 2.5 horizontal to 1 vertical ratio, controlling erosion on the reclaimed slopes, implementing the surface water management plan by regrading and installing BMPs until permanent vegetation is established, and providing a natural looking landscape similar to native slopes. One cross-section through the growth media stockpile is provided on Figure 33. If natural revegetation is not successful to promote temporary stabilization of the GMS pile, revegetation of the TSF growth media stockpile may occur after its construction to enhance nutrient content and is described further in Section D. 6. C) In excavation(s) of unconsolidated (non-rock) materials, specify the angle of all cut slopes including specifications for benching and sloping. Cross-sections for all cut slopes must be provided on the mine map(s). As previously discussed, no mineral extraction or open-pit mining is planned for the Project. Unconsolidated non-rock materials consisting of overburden soils and growth media materials will mostly be mined in the upper 1 foot of the surface, and will not, therefore, require engineered design cut slopes or benching. Some localized excavation and backfilling of softer Doc No.: KM60-EN-RP-9540 27 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility overburden/saprolite may be required to improve the strength of the foundation for the TSF. Where allowable, these soils will be excavated at safe slope angles consistent with the recommended safe slope angles described in Section C. 6.(A.) above. Where not allowable due to space restrictions, an engineered plan will be developed to steepen the excavation using appropriate engineering solutions, including buttressing the slope with rockfill or other ground retention systems. Unconsolidated saprolite underlying the overburden soils at the base of the TSF interior will, on average, be excavated during construction grading to a depth of 10 feet and locally up to a depth of 30 feet. It will be shaped to roughly mirror existing topography and provide a relatively smooth surface (Appendix G). As discussed previously, when working around the legacy open pit, the Applicant will establish and follow a written ground control plan for safe control for unconsolidated (non-rock) and overburden slopes which need to be consistent with prudent engineering designs to provide safe working conditions. When benching is necessary, the width and height will be based on the type of material being excavated and the equipment used for cleaning of benches or for scaling of walls, banks, and slopes. 6. D) In hardrock excavations, specify proposed bench widths and heights in feet. Provide cross-sections of the mine excavation clearly noting the angles of the cut slopes, widths of all safety benches and mine benches, and the expected maximum depth of the excavation. Not applicable. No planned hardrock excavations are associated with the Project. 7. Describe other methods to be taken during mining to prevent physical hazard to any neighboring dwelling, house, public road, or public, commercial or industrial building from any mine excavation. Locate all such structures on the mine map if they are within 300 feet of any proposed excavation. The Project site will have two gated entrance points from U.S. 29 to prohibit public access. In addition, The TSF perimeter embankment will form a major barrier to most of the planned mobile equipment activities occurring in the legacy open pit during construction and operations. The construction plans do not currently anticipate the need to use explosives in the construction phase. However, if it is determined that blasting will be required to remove bedrock, the charges will be relatively small and will be modeled to ensure blast vibration, overpressure, and flyrock generation do not exceed regulatory thresholds. 8. Describe what kind of barricade will be used to prevent inadvertent public access along any high wall area and when it will be implemented. Vegetated earthen berms, appropriate fencing and adequate boulder barriers may be acceptable high wall barricades. A construction detail/cross-section and location of each type of barricade to be used must be indicated on the mine map(s). No highwalls will be constructed for the Project. Public access into the TSF will be severed by construction of a perimeter embankment, which will be fenced in entirety. The embankment raise will be constructed over much of the life of the facility and will reach a maximum elevation of 960 feet amsl (see Table 1). Cross-sections through the tailings waste pile area during Doc No.: KM60-EN-RP-9540 28 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility construction are provided on the SRK Design Drawing Sheets in Appendix B. Cross-sections during reclamation are provided on Figure 32, and further detail is provided in Appendix K. In addition, an 18-inch compacted earthen soil berm will be constructed on the outside edge of the perimeter haul road for safety. A cross-section of the of the perimeter haul road and safety soil berm are shown on Figure 32, and further detail is provided in Appendix C. 9. Are acid-producing minerals or soils present? If yes, how will acid water pollution from the excavation, stockpiles, and waste areas be controlled? The materials transported to the TSF from the KMM facility, including the filtered tailings and the waste rock to construct the embankment have been characterized as non-PAG (see Appendix F). In addition, overburden soil, alluvium, saprolite, and legacy waste rock to be excavated during construction and salvaged for TSF reclamation have been geochemically characterized as non-PAG (see Appendix F). Table 7 identifies the non-PAG Iithologies that will be used to construct the TSF embankment including their estimated mass (in million short tons units) and relative proportion (percent). Muscovite pegmatite bedrock and pit wall rock excavated from the TSF site during construction could be used as general fill in reclamation and have been characterized as non-PAG (see Appendix F). Mica schist bedrock and pit wall rock excavated from the TSF during development may have relatively high sulfide sulfur content (0.81 to 1.0 weight percent) and could be considered potentially acid generating (PAG) (see Appendix F). However, there is no evidence of acid rock drainage from historical mining activities (Appendices F and H). Table 7: TSF Embankment Tonnage and Lithological Composition Lithologic Unit Mass in TSF Embankment Proportion (mst) Embankment Amphibole Gneiss-Schist 0 0 Chlorite Schist 0 0 Mica Schist 1.57 35.8 Muscovite Pegmatite 0.01 0.3 Overburden 0.74 16.8 Pegmatite 0.008 0.2 Schist—Marble 0.04 0.9 Shear Schist 0.92 21.0 Silica Mica Schist 1.00 23.0 Spodumene Pegmatite 0 0 Upper Mica Schist 0.09 2.0 Pyrrhotite Mica Schist 0.003 0.1 TOTAL 4.37 100 Source:Appendix I non-PAG = non-potentially acid generating; mst= million short tons; TSF=tailings storage facility Percent totals are greater or less than 100 percent due to rounding. Doc No.: KM60-EN-RP-9540 29 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Even though the bulk of the materials at the TSF site have been characterized as non-PAG, the applicant plans to implement an operational acid-base accounting testing program during construction similar to the one being implemented at the KMM facility, to identify any PAG materials in real time so they can be managed accordingly. Any PAG materials found at the TSF that exhibit PAG qualities will be routed back to the KMM through the established truck route moving material between the two sites. Once the PAG material has arrived at the KMM facility, it will be placed in the PAG-designated rock storage facility. 10. A) Describe specific plans (including a schedule of implementation) for screening the operation from public view such as maintaining or planting trees, bushes, or other vegetation, building berms or other measures. Show the location of all visual screening on the mine map(s) and provide cross-sections through all proposed berms or proposed spacing, sizes and species for tree plantings. A visual impact assessment report was completed for the Project (ERM 2024) to address potential impacts to the surrounding areas relative to Project visibility and includes nearby key observation points (defined as a viewpoint from which the public may view the Project). The viewshed analysis categorized the visibility of the Project facilities and structures and considered areas up to 10 miles from the proposed Project. The results of the viewshed analysis categorize the visibility of the TSF facility and structures into the following four general tiers: • No visibility: none of the Project structures would be visible. • Limited visibility: 25 percent or less of the Project structure's height would be visible. • Moderate visibility: between 25 and 75 percent of the Project structure's height would be visible. • High visibility: 75 percent or more of the Project structure's height would be visible. The TSF viewshed visibility map in Figure 34 shows the modeled visibility results in the area around the TSF. The results indicate that a majority (99.93 percent) of the proposed TSF Project would not be visible from elevated viewpoints in Crowders Mountain State Park located east of the TSF (Table 8). In addition, 99.98 percent of the trails (including Ridgeline, Pinnacle, and Backside Trails) within Crowders Mountain Park would not have views of the TSF based on the visual impact assessment results. Pinnacle Peak (Key Observation Point 16) in Crowders Mountain State Park is located 4.6 miles east of the TSF (Figure 34). Boulder Overlook in Crowders Mountain State Park is located 2.5 miles east of the TSF (Figure 34). A visual impact assessment photographic simulation of Key Observation Point 16 at Pinnacle Peak from Crowders Mountain State Park (Figure 35) shows how the final TSF facilities will be viewed with installed (e.g., with mitigation) and uninstalled (e.g., no mitigation) visual barriers, vegetation growth, and planted vegetation and trees. Doc No.: KM60-EN-RP-9540 30 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Table 8: TSF Viewshed Analysis Details for Crowders State Park Identifying Modeled Visibility Results by Acres and Percentages Site Feature Acres Percentage Not Visible 5123.57 99.93 Low Visibility 1.26 0.02 Moderate Visibility 0 0.00 High Visibility 2.08 0.04 TOTAL 5126.90 100.00 Source: ERM 2024 1-85= Interstate 85 Percent totals are greater or less than 100 percent due to rounding. Acres totals are greater or less than the total value due to rounding. A combination of screening techniques is planned to reduce public view of the Project including a perimeter embankment berm, vegetative buffers, and maintenance of mature trees along the property boundaries (where feasible) combined with possible tree planting. The proposed perimeter berm construction will act as a barrier to most of the tailings placement activities in the TSF during operations and is shown on several mine maps (see Figures 20 to 22 for berm raise construction as shown on the SRK Design Drawing Sheets in Appendix B, and Figures 23 and 32 for final berm construction after reclamation). Building the perimeter berm will start during construction. After Phase 1 the top of the embankment will be at 885 feet amsl and will continue to be raised in six phases during operations to a final elevation of 960 feet amsl (lower than the existing legacy mica waste rock pile maximum elevation of 1,040 feet amsl) to minimize the visibility of the tailings placement activities at the TSF structure. The embankment berm slope will also be revegetated to minimize visual impacts. The planned reclamation efforts, including regrading and recontouring to pre-mining topography in the NPI areas, will help the TSF better blend into the regional landscape by mimicking existing forms and colors. 10. B) Could the operation have a significantly adverse effect on the purposes of a publicly owned park, forest, or recreation area? If so, how will such effects (i.e., noise, visibility, etc.) be mitigated? The Project will have no adverse effects on nearby publicly owned parks, forests, or recreation areas. Public lands, recreation, and conservation areas located near the Project are illustrated on Figure 36. Kings Mountain National Military Park is the closest national park and is located approximately 2 miles southeast of the Project. Crowder's Mountain State Park is the closest state or local park and is located approximately 2.1 miles southeast of the Project. Due to the distance from the parks to the Project, no impacts are anticipated. As a comparison, the maximum elevation of the final reclaimed tailings pile will be 992.0 feet (see Figure 23) and the maximum elevation of the TSF embankment will be 960 feet (Table 2); whereas, the maximum elevation of the existing mica waste rock stockpile (that will be removed during construction of the TSF Project) is approximately 1,040 feet (see Drawing Sheet 300 in Appendix B). Doc No.: KM60-EN-RP-9540 31 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility 11. Will explosives be used? If yes, specify the types of explosive(s) and describe what precaution(s)will be used to prevent physical hazard to persons or neighboring property from flying rocks or excessive air blasts or ground vibrations. Depending on the mine's location to nearby structures, more detailed technical information may be required on the blasting program (such as a third-party blasting study). Locate the nearest offsite occupied structure(s) to the proposed excavation(s) on the Mine Map and indicate its approximate distance to the proposed excavation. Blasting is not proposed. 12. Will fuel tanks, solvents, or other chemical reagents be stored onsite? If yes, describe these materials, how they will be stored and method of containment in case of spill. Indicate the location(s) of all storage facilities on the mine map(s). Diesel fuel, lubrication oils, hydraulic oils, anti-freeze, and parts cleaners will be stored onsite in double walled tanks or within a containment area located near the southern NPI pad in the maintenance shop (Figure 16). A 1,000-gallon diesel fuel aboveground storage dual containment tank will be located at the southern part of the site on the fueling pad. This fuel tank will contain secondary containment. All components will be stored onsite for the duration of the tailings storage activities including construction, operations, and closure. A Spill Prevention, Control, and Countermeasure plan will be developed per the requirements of the NCG02 and will be kept onsite. D. RECLAMATION PLAN 1. Describe your intended plan for the final reclamation and subsequent use of all affected lands and indicate the sequence and general methods to be used in reclaiming this land. This must include the method of reclamation of settling ponds and/or sediment control basins and the method of restoration or establishment of any permanent drainage channels to a condition minimizing erosion, siltation, and other pollution. This information must be illustrated on a reclamation map and must correspond directly with the information provided on the mine map(s). In addition, design information, including typical cross-sections, of any permanent channels to be constructed as part of the reclamation plan and the location(s) of all permanent channels must be indicated on the reclamation map. Reclamation of the Project will commence after the KMM concentrator has ceased operations and all filtered tailings have been delivered to and compacted at the TSF. The reclamation plan includes closure and post-closure activities that are subject to applicable NCDEQ regulations in accordance with the North Carolina Mining Act of 1971, G.S. 74, Article 7, and North Carolina Administrative Code Title 15A, Chapter 5. The tailings pile and TSF embankment will be reclaimed and remain onsite after closure. Other disturbed areas will be completely reclaimed to pre-mining topography, or existing conditions prior to the start of the TSF Project. The final reclamation plan is described in Appendix K and Doc No.: KM60-EN-RP-9540 32 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility shown on the final reclamation maps on Figures 23 and 32. Cross-section details for final reclamation are shown on Figures 32 and 37. The surface water management plan on the reclaimed TSF combines regrading and placement of robust BMPs to stabilize the soil until vegetation is established. Growth media will be placed on most of the disturbed surfaces after regrading and filling activities. The GMS area will store approximately 230,000 cubic yards of growth media (Albemarle 2024c), salvaged during construction, for use during the TSF reclamation activities and closure. Approximately 280,000 cubic yards of growth media material will be required for reclaiming and closing the TSF (Appendix K). Any additional growth media that may be needed to reclaim the TSF during closure will be sourced from KMM (Albemarle 2024c). Remaining growth media not used for TSF closure will be either added as additional TSF cover fill or removed from the TSF GMS area and transported back to the KMM facility for reclamation use. The stockpiled growth media will be used as the main cover fill material on the filtered tailings pile and to reclaim areas where the TSF NPI buildings, seepage collection tank, pond areas, some roads, and the yard were located. Interim stabilization for the GMS area and pile during operations will be provided by natural revegetation, and, if necessary, application of a temporary seed mix to stabilize and enhance the nutrient content. After all growth media, overburden, soils bank, and base materials have been removed during closure, disturbed native ground in these areas will be exposed and scarified and revegetated with an approved seed mix. In addition, 14,400 cubic yards of riprap will be installed to reclaim the TSF channels (Appendix K). Most closure actions will be implemented in the ninth mining year once mining ceases (Table 2), although some post-closure monitoring and maintenance activities may continue for another 10 years (see Appendix K). As monitoring demonstrates that closure goals are met, monitoring requirements will likely decrease. Groundwater wells will be progressively abandoned, and maintenance activities may include overseeding areas where vegetation has not performed to expectations, or covers have experienced localized erosion. A detailed post-closure land use plan will be developed in consultation with stakeholders to confirm final closure activities on the site have been conducted in the past and will continue to be consistent with the envisioned post-closure land uses in the future (see Appendix K). Final reclamation activities will include: • Turning off and dismantling the two pumps (located at the base drain sump and the tailings surface stormwater collection sump) and removing them from the site immediately after the operations (tailings placement activities) and minor tailings surface regrading activities described below cease, and after closure activities commence. • Minor regrading of the compacted tailings surface to create a mounded surface that drains waters to the TSF perimeter channel. Regrading is expected to be minimal, as the final surface of the TSF will be mostly created during operations. Both the tailings surface and embankment will be covered with a minimum of 2 feet of growth material sourced from the GMS area and placed in loose lifts with a final maximum elevation of 992 feet amsl. The final TSF embankment will be constructed with downstream raises at a final overall slope of Doc No.: KM60-EN-RP-9540 33 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility 2.5 horizontal to 1 vertical with slope breaks approximately every 30 vertical feet for runoff interception. These 16-feet wide slope breaks are designed to reduce erosion from surface flows while vegetation is established. • Installing BMPs immediately following closure regrading and placement of the closure cover layers. Stormwater berms and channels will be installed as necessary to control stormwater flows off the closed surface and safely route them into the perimeter stormwater management system. These BMPs will include hydroseeding and coir matting (i.e., coconut blankets) coupled with straw wattles across the slopes. Observation and monitoring of slope revegetation and BMP performance will identify areas that require repair or modification before erosion deteriorates. Areas not performing will be addressed with additional BMPs. • Cast seeding of the surface of the tailings and the embankment with an approved permanent seed mix (see Table 8 below for the approved seed mix compositions). This will allow runoff from the facilities to become non-contact water. Tree seedlings will be planted on the tailings surface and some reclaimed roads, but no trees will be planted on the embankment in accordance with state dam safety regulations. • Identification of industrial and hazardous waste in accordance with the Resource Conservation and Recovery Act (RCRA), which will be disposed of per applicable waste regulations at an approved third-party facility. • Removal of all remaining consumables by selling or returning to suppliers. • Removal of all buildings and structures on the NPI area in the southwest corner of the TSF and complete reclamation of the land surface. Removed equipment will either be sold or recycled and hauled offsite. Concrete foundations and floor slabs will be broken and placed in the contact water transfer pond void or moved offsite to a licensed landfill. The soils under the buildings and disturbed areas will be inspected to identify impacted areas where oils or liquids may have seeped into the ground. Areas containing impacted soils will be sampled, tested, excavated, and removed to an appropriate disposal facility, as needed. Recyclable materials will be removed from the site. • Regrading of the surface of the entire NPI area to re-establish pre-existing topography to convey surface water flows toward culverts under 1-85. One foot of growth media will be placed, and the area revegetated using an approved seed mix for permanent conditions. • Breaching and removal of all collection and sediment ponds after closure cover to allow discharges to be conveyed to existing drainages (and existing culverts that convey water under 1-85) prior to removing the culverts that were installed for the Project. • Removal of the seepage collection tank that collects shallow groundwater from the interception drain. The void will be backfilled with rock, and the surface of the area graded to direct flow to the culvert that conveys water under 1-85. • Directing stormwater toward its original flow path to the greatest extent possible. Stormwater from the TSF will be managed in the diversion channels constructed at the toe of the embankment (see Figures 23, 24, 25, and 32) to convey a probable maximum precipitation Doc No.: KM60-EN-RP-9540 34 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility storm event. Riprap will be placed along channels where high water velocities could result in erosion. Channel reconfiguration details are in Appendix K and shown on Figure 32. • Once the cover has been placed on the TSF, revegetation has occurred, and the stormwater channels have been reconfigured for closure, the contact water transfer pond will be reclaimed. The pond liner will be removed, and the void will be backfilled. • The culverts located east and west of the contact water transfer pond will be removed and/or regraded to re-establish the original surface water flow paths towards 1-85. The other culverts and the drop inlet installed near the sediment basin during construction will be removed and replaced with a swale that allows vehicular access after closure. • Abandonment and closure of wells that are not needed for post-closure monitoring in accordance with state regulations. • Decommissioning and demolition of temporary infrastructure installed to support operations. Power lines and distribution systems may be required to supply energy to structures remaining to support post-closure land use. This infrastructure will be among the last items decommissioned and removed from the site, occurring once there is no need for energy onsite. • Capping of buried pipelines to be left in place. Dismantling and removal of pipes and pumps once water supply to the Project is no longer needed. • Removal of roads not needed for post-closure access for monitoring and maintenance, or potential future use. A 15-feet wide post-closure road and closure perimeter channel will be constructed (Figure 32). Removed roads will be graded or ripped, and depending on the substrate material, 1 foot of growth media will be placed. As the TSF perimeter road is narrowed along the toe of the facilities, and as the surface water channels are widened, the outer side of the road will be ripped. The timing of road abandonment during closure activities will be determined by access requirements during closure, and the schedule of other closure activities adjacent to the roads. The entrances to the TSF site will be barricaded to prohibit public access. • Development of a post-closure management plan in conjunction with the NCDEQ to include monitoring surface water quality, groundwater quality, air quality, reclamation performance, and wildlife habitat in accordance with local requirements. These programs will be based on baseline studies (see Appendix I for water quality) and data collected during operations . The landscapes will be reshaped to help promote suitable areas for wildlife habitat use. Monitoring and measurement criteria for vegetation and wildlife success will be developed as the closure plans are updated. • Post-operational monitoring will occur until such time as the TSF site is certified as fully reclaimed and bonding release milestones are met, or as determined in the post-operational monitoring program. Doc No.: KM60-EN-RP-9540 35 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility • Preparation of annual reports to document the results of monitoring during closure and post- closure phases and to manage ongoing closure activities. During closure, a phased reduction in monitoring frequency and locations typically occurs. • Continued engagement with the community and key stakeholders about issues relating to the post-closure vision for the site and the development of a comprehensive socioeconomic transition plan for the site. • Removal of fencing, which will be sent to a scrap metal facility or an appropriate waste disposal facility once closure is complete and appropriate exclusionary berms have been placed at the site. 2. Is an excavated or impounded body of water to be left as part of the reclamation? If yes, illustrate the location of the body(s) of water on the reclamation map and provide a scaled cross-section(s) through the proposed body(s) of water. The minimum water depth must be at least 4 feet, measured from the normal low water table elevation, unless information is provided to indicate that a shallower water body will be productive and beneficial at this site. No excavated or impounded bodies of water will be left as part of the TSF reclamation, as shown on Figures 23 and 32. The three culverts installed as part of the Project near the southern NPI area will be removed during reclamation. Will the body(s) of water be stocked with fish? If yes, specify species. No standing bodies of water will remain in post-closure. Therefore, there will be no stocked fish. 3. Describe provisions for safety to persons and to adjoining property in all completed excavations in rock including what kind of permanent barricade will be left. Acceptable permanent barricades are appropriate fencing, large boulders placed end-to-end, etc. Construction details and locations of all permanent barricades must be shown on the reclamation map. The Project does not include any mining or excavations on bedrock. In addition, the overall objective of the closure plan (Appendix K) is to relinquish a safe and secure site where remaining infrastructure is chemically and physically stable. At closure, the legacy pit will be fully filled with tailings. Barricades or barriers will be installed at the site entrances to prohibit the public from entering the tailings facility (Figure 23). 4. Indicate the method(s) of reclamation of overburden, refuse, spoil banks or other such onsite mine waste areas, including specifications for benching and sloping. Final cross- sections and locations for such areas must be provided on the reclamation map. At the end of construction and in early operations, the TSF GMS area and pile will allow natural revegetation and, if required, application of a temporary seed mix to stabilize and enhance the nutrient content. All growth media, overburden, soils bank, and base materials at the Project will be removed and used to reclaim the TSF, TSF embankment, NPI areas, ponds, and roads that are not needed in post-closure. After the growth media, overburden, soils bank, and base materials are removed, disturbed native ground in these areas will be exposed and will be Doc No.: KM60-EN-RP-9540 36 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility scarified and revegetated with an approved seed mix. Refuse will be removed during reclamation and properly disposed of offsite. A cross-section through the GMS area is shown on Figure 33 (Albemarle 2024c). The GMS area covers approximately 5.7 acres, will be approximately 26 feet in average height, and will have 2 horizontal to 1 vertical side slopes (Albemarle 2024c). No benches or slope drains are necessary. Reclamation methods and maps and cross-sections through the TSF facility and the NPI areas have been described above. 5. A) Describe reclamation of processing facilities, stockpile areas, and onsite roadways. No processing facilities are associated with the Project. The planned reclamation activities for the TSF and the NPI sites have been described above (Appendix K). Roads that are not needed for post-closure monitoring access or potential future use will be removed during closure. The roads that remain after closure will be narrowed to 15 feet by ripping the outer portion of the road which should allow access by small trucks or bulldozers. The reclaimed portion of the road will be covered with 1 foot of growth media as identified on Figure 32. Additional road closure details have been described above. 5. B) Will any onsite roadways be left as part of the reclamation? If yes, identify such roadways on the reclamation map and provide details on permanent road and ditch line stabilization. A 15-feet wide perimeter road will remain around the TSF as shown on Figure 23. The closure perimeter section type showing the channel and the adjacent road are depicted on Figure 27. The outside surface of the reclaimed flat road surface will be ripped, and 1 foot of growth media will be placed and revegetated with an approved seed mix. The outer 2.5 horizontal to 1 vertical perimeter road rock fill slope will have already been permanently revegetated and stabilized with an approved seed mix; however, additional hydroseeding and permanent revegetation with an approved seed mix may still be required. The existing reclaimed road will consist of a 2-feet thick layer of riprap with 12-inch diameter D50 (where 50 percent of the rocks by weight have an equivalent spherical diameter greater than or equal to this diameter) rock materials, as shown in the closure perimeter channel section on Figure 32. 6. Describe the method of control of contaminants and disposal of scrap metal, funk machinery, cables, or other such waste products of mining. (Note definition of refuse in The Mining Act of 1971.) No offsite generated waste shall be disposed of on the mine site without prior written approval from the NC Department of Environmental Quality, Division of Energy, Mineral, and Land Resources and either the Division of Waste Management (DWM) or local governing body. If a disposal permit has been issued by DWM for the site, a copy of said permit must be attached to this application. All temporary and permanent refuse disposal areas must be clearly delineated on the mine map(s) and reclamation map, along with a list of items to be disposed in said areas. Doc No.: KM60-EN-RP-9540 37 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Industrial and hazardous waste will be identified in accordance with RCRA and applicable waste regulations and disposed of offsite at an approved third-party facility. Other waste products will be removed and transferred to an appropriate waste disposal facility once closure is complete. 7. Describe your plan for revegetation or other surface treatment of the affected areas. This plan must include recommendations for year-round seeding, including the time of seeding and the amount and type of seed, fertilizer, lime and mulch per acre. The recommendations must include general seeding instructions for both permanent and temporary revegetation. Revegetation utilizing only tree plantings is not acceptable. All areas receiving growth media will be revegetated using an approved seed mix. Table 9 includes a preliminary seed mix and schedule for permanent revegetation (Appendix K). Table 9: Preliminary Permanent Seed Mix Composition and Schedule Seed Mix Type Seeding Dates Seeding Rates North Carolina Steep Slope Mix All dates 45 Ibs/acre (ERNMX-310) Native Habitat Strip Mine Mix All dates 20 Ibs/acre (ERNMX-111) Native Steep Slope w annual rye Feb 15—Aug 15 60 Ibs/acre (ERNMX-181) Native Steep Slope w grain rye Aug 15—Feb 16 75 Ibs/acre (ERNMX-181-2) Source:Appendix K Ibs = pounds Temporary cover species for erosion protection and temporary revegetation on exposed cut slopes, road embankment slopes, the GMS area, and earthen berms during construction and operations will include: • Brown top millet—February 15 to August 15, 20 pounds/acre; and • Annual rye grain—August 15 to February 15, 30 pounds/acre. Temporary mine features will all be removed or modified during final reclamation. Permanent revegetation seeding on the TSF embankment may commence as early as KMM Mining Year 6 (Table 2), as long as the TSF embankment slope is regraded to meet the closure slope requirements of 2.5 horizontal to 1 vertical with slope breaks approximately every 30 feet. Seed will be procured from an approved seeding contractor. No fertilizer or lime applications are recommended at this time due to the success of volunteer regrowth seen during site visits. Mulch consisting of small grain straw is recommended to be applied at an application rate of 2,000 pounds per acre and will be tacked or mechanically tied down within 2 days after application (Appendix K). Doc No.: KM60-EN-RP-9540 38 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Tree seedlings will be planted on the tailings surface, but no trees will be planted on the TSF embankment in accordance with state dam safety regulations. E. DETERMINATION OF AFFECTED ACREAGE AND BOND The affected acreage for the TSF Project totals 109.1 acres. Albemarle has provided DEMLR with a $1 million bond for all permitted mining activities (including the TSF and the KMM site) which is the maximum allowed by North Carolina law. F. NOTIFICATION OF ADJOINING LANDOWNERS Notification to adjoining landowners, and landowners within 1,000 feet of the permit area as a courtesy, has been performed in accordance with North Carolina Mining Permit Application requirements. The affidavit and landowner list table are included in Appendix L. Parcel maps are included on Figures 38 through 43 in Appendix A. G. LAND ENTRY AGREEMENT Included in the Mine Permit Application form. Doc No.: KM60-EN-RP-9540 39 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility H. REFERENCES Albemarle. 2024a. Equipment list for KMM and TSF Projects. Excel file name: Equipment List 20231214.xlsx Albemarle. 2024b. Archdale TSF Truck Count Details. Albemarle 2024c. Map and Cross-section through the TSF Growth Media Storage Area. Email from Albemarle dated July 11, 2024. Albemarle. 2024d. Flow Rates from Archdale Creek Collected from January 25 to May 13, 2024. Measured by AECOM. Email from Albemarle on July 12, 2024. ERM 2024. Visual Impact Assessment Report— Kings Mountain Lithium Mine. Report prepared for Albemarle U.S., Inc. Report date: June 14, 2024. Global Industry Standard on Tailings Management (GISTM). 2020. World-wide Tailings Management Guidance. Initiative of International Council on Mining and Metals, the Principles for Responsible Investment, and the United Nations Environment Programme. August 5, 2020. GoldSim. 2021. GoldSim, Version 14.0. GoldSim Technology Group. November 2021. Horton, J.W., Jr. 2008. Geologic Map of the Kings Mountain and Grover Quadrangles, Cleveland and Gaston Counties, North Carolina, and Cherokee and York Counties, South Carolina. Scale 1:24:000. U.S. Geological Survey Scientific Investigations Map 2981. U.S. Geological Survey. National Aeronautics and Space Administration (NASA). 2023. "Daymet: Daily Surface Weather Data on a 1-km Grid for North America Version 4 R1." ORNL DAAC Distributed Active Archive Center for Biogeochemical Dynamics. Accessed: [January 2023]. Retrieved from: https://doi.org/10.3334/ORNLDAAC/2129 Natural Resources Conservation Service (NRCS). 2023. "2023 Web Soil Survey." U.S. Department of Agriculture, Washington, D.C. Accessed: November 13, 2023. Retrieved from: http://websoilsurvey.nres.usda.gov/app/WebSoilSurvey.asi) North Carolina Department of Environment, Health and Natural Resources (NCDEHNR). 1996. Surface Mining Manual. February 1996. North Carolina Office of State Archaeology (NCOSA). 2023. Archaeological Investigation Standards and Guidelines. North Carolina Department of Natural and Cultural Resources, Raleigh. North Carolina Sedimentation Control Commission (NCSCC). 2013. Erosion and Sediment Control Planning and Design Manual. May 2013. SRK Consulting U.S., Inc. (SRK). 2024a. Technical Memorandum—Archdale January 2024 Site Visit. Memorandum submitted to Albemarle Corporation. February 5, 2024. Doc No.: KM60-EN-RP-9540 40 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility SRK. 2024b. Memorandum. Discharges from Archdale Property. Memorandum submitted to Albemarle Corporation. March 25, 2024. SRK. 2024c. Technical Report— Water Supply Well Mitigation Plan, Kings Mountain Mining Project. Report prepared for Albemarle Corporation. April 12, 2024. SRK. 2024d. Technical Report— 2023 Prefeasibility Study Baseline Geochemical Characterization, Kings Mountain Mining Project. Report prepared for Albemarle Corporation. April 17, 2024. SWCA Environmental Consultants (SWCA). 2024a. Wetland and Waterbody Delineation Report for the Kings Mountain Archdale Tract, Cleveland County, North Carolina. Report prepared for Albemarle U.S., Inc. January 2024. SWCA. 2024b. Federally Listed and State-Listed Species Report for the Albemarle Kings Mountain Archdale Tract, Cleveland County, North Carolina. Report prepared for Albemarle U.S., Inc. January 2024. SWCA. 2024c. Phase 1 Archeological Survey for the Proposed Kings Mountain Mining Project, Archdale Tract, Cleveland County, North Carolina. Report prepared for Albemarle, U.S., Inc. January 24, 2024. United States Army Corps of Engineers (USACE). 2021. HEC-RAS. Version 6.10 hydraulic modeling software. U.S. Geological Survey (USGS). 2019. National Land Cover Database (NLCD). Retrieved from: https://www.usgs.gov/data/national-land-cover-database-nlcd-2019-products. Accessed November 2023. Doc No.: KM60-EN-RP-9540 41 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility APPENDIX A MINE AND RECLAMATION MAPS Doc No.: KM60-EN-RP-9540 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility APPENDIX B PERMIT SITE AND TAILINGS STORAGE FACILITY DESIGN SHEETS (PRELIMINARY) Doc No.: KM60-EN-RP-9540 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility APPENDIX C ARCHDALE STORMWATER MANAGEMENT REPORT KINGS MOUNTAIN MINING PROJECT NORTH CAROLIN Doc No.: KM60-EN-RP-9540 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility Doc No.: KM60-EN-RP-9540 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility APPENDIX D HYDROGEOLOGICAL ASSESSMENT STUDY FOR ARCHDALE TAILINGS FACILITY KINGS MOUNTAIN MINING PROJECT PREFEASIBILITY STUDY Doc No.: KM60-EN-RP-9540 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility APPENDIX E MONITORING WELL DEVELOPMENT AND Q4 2023 GROUNDWATER MONITORING REPORT - ARCHDALE SITE Doc No.: KM60-EN-RP-9540 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility APPENDIX F 2023 PREFEASIBILITY STUDY KINGS MOUNTAIN MINING PROJECT BASELINE GEOCHEMISTRY CHARACTERIZATION STUDY FOR THE ARCHDALE TAILINGS STORAGE FACILITY Doc No.: KM60-EN-RP-9540 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility APPENDIX G PREFEASIBILITY ENGINEERING DESIGN REPORT FOR ARCHDALE TAILINGS STORAGE FACILITY Doc No.: KM60-EN-RP-9540 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility APPENDIX H TECHNICAL REPORT 2023 PREFEASIBILITY STUDY SURFACE WATER: WATER BALANCE DEVELOPMENT REPORT ARCHDALE TSF KINGS MOUNTAIN PROJECT Doc No.: KM60-EN-RP-9540 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility APPENDIX I TECHNICAL REPORT 2023 PREFEASIBLITY STUDY, KINGS MOUNTAIN MINING PROJECT ARCHDALE TAILINGS STORAGE FACILITY WATER QUALITY PREDICTIONS Doc No.: KM60-EN-RP-9540 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility APPENDIX J TSF MOBILE EQUIPMENT LIST Doc No.: KM60-EN-RP-9540 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility APPENDIX K CONCEPTUAL CLOSURE PLAN KINGS MOUNTAIN MINING PROJECT ARCHDALE TAILINGS STORAGE FACILITY Doc No.: KM60-EN-RP-9540 North Carolina Mine Permit Supplemental Report Kings Mountain Lithium Mine Project—Tailings Storage Facility APPENDIX L LANDOWNER NOTIFICATIONS Doc No.: KM60-EN-RP-9540