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Home My WebLink AboutAppendix K - Archdale Closure_Report_Rev04_20240614 Conceptual Closure Plan Kings Mountain Mining Project Archdale Tailings Storage Facility Rev04 Report Date: June 14, 2024 Report Prepared for: A ALBEMARLE" Albemarle Corporation 4250 Congress Street, Charlotte, NC 28209 Report Prepared by $; srk consulting SRK Consulting (U.S.), Inc. 5250 Neil Road, Suite 300 Reno, NV 89502 SRK Project Number: USPR000576 Albemarle Document Number: KM60-EN-PN-9082 Authored by: Jeff Parshley, C.P.G, Corporate Consultant (Mine Closure) Reviewed by: Mark Willow, M.Sc., SME-RM, Principal (Environmental & Permitting) SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page ii Table of Contents ExecutiveSummary....................................................................................................... viii Environmental Considerations for Closure .................................................................................................ix SpatialConstraints.............................................................................................................................ix LandUse............................................................................................................................................ix OreGeochemistry..............................................................................................................................ix GrowthRegime..................................................................................................................................ix WaterTreatment.................................................................................................................................x WaterBalance.....................................................................................................................................x Wetlands .............................................................................................................................................x Climate................................................................................................................................................x ClimateChange ..................................................................................................................................x Engineering Considerations for Closure ......................................................................................................x Design Storm Event for Closure .........................................................................................................x Rock Storage Facility Configuration....................................................................................................x Surface Water Diversions ...................................................................................................................x GeotechnicalStability.........................................................................................................................xi Socioeconomic Considerations for Closure................................................................................................xi Stakeholders Impacted by Closure....................................................................................................xi Macroeconomic and Socioeconomic Impact of Closure....................................................................xi Kings Mountain Community Planning................................................................................................xi AttractiveNuisances ..........................................................................................................................xi ClosureStrategy .........................................................................................................................................xi Revegetation.....................................................................................................................................xii Stormwater Management..................................................................................................................xii Archdale Tailings Storage Facility.....................................................................................................xii TSF Non-process Infrastructure........................................................................................................xii Power Lines and Power Distribution.................................................................................................xiii WaterSupply System........................................................................................................................xiii Roads xiii Ponds xiii YardAreas ........................................................................................................................................xiii Industrial and Hazardous Waste.......................................................................................................xiii Fencing .............................................................................................................................................xlll WellAbandonment............................................................................................................................xiii Progressive Closure.........................................................................................................................xiv J V P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page iii Temporary Closure ..........................................................................................................................xiv UnplannedClosure ..........................................................................................................................xiv Post-Closure Management Plan......................................................................................................xiv Socioeconomic Transitioning....................................................................................................................xiv Post-Closure Visioning.....................................................................................................................xiv Socioeconomic Transitioning Actions...............................................................................................xv ClosureMonitoring.....................................................................................................................................xv Preliminary Mine Closure Schedule..........................................................................................................xvi 1 Introduction.................................................................................................................. 1 1.1 Project Location ..................................................................................................................................1 1.2 Regulatory Framework and Operating Approvals...............................................................................2 2 Project Description...................................................................................................... 3 2.1 Land Tenure........................................................................................................................................3 2.2 Mining History .....................................................................................................................................3 2.3 Project Overview.................................................................................................................................4 2.4 Project Layout.....................................................................................................................................4 2.5 Mining Schedule..................................................................................................................................6 2.6 Infrastructure.......................................................................................................................................6 2.7 Open Pit..............................................................................................................................................7 2.8 Mine Support Infrastructure ................................................................................................................7 2.9 Rock Storage Facilities .......................................................................................................................7 2.10 Overburden Storage Facilities ............................................................................................................7 2.11 Tailings Storage Facility......................................................................................................................8 2.12 Process Facilities................................................................................................................................8 2.13 Water Management.............................................................................................................................9 2.14 Waste Management............................................................................................................................9 2.14.1 Non-Hazardous.......................................................................................................................9 2.14.2 Recyclable or Reusable Waste...............................................................................................9 2.14.3 Hazardous Waste....................................................................................................................9 2.14.4 Special Waste .......................................................................................................................10 2.14.5 Demolition Waste..................................................................................................................10 3 Project Environmental and Social Setting............................................................... 11 3.1 Meteorology ......................................................................................................................................11 3.1.1 Temperature..........................................................................................................................11 3.1.2 Solar Radiation......................................................................................................................11 3.1.3 Precipitation...........................................................................................................................11 3.1.4 Storm Frequency...................................................................................................................12 J VP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page iv 3.1.5 Evaporation ...........................................................................................................................13 3.2 Air Quality..........................................................................................................................................14 3.3 Land Use...........................................................................................................................................14 3.3.1 Historic Land Use..................................................................................................................14 3.4 Geological Setting.............................................................................................................................15 3.5 Geochemistry....................................................................................................................................15 3.5.1 Geochemical Characterization ..............................................................................................16 3.5.2 Tailings Geochemistry...........................................................................................................17 3.5.3 Cover Material Characterization............................................................................................18 3.6 Soils 18 3.7 Groundwater.....................................................................................................................................19 3.7.1 Groundwater Chemistry........................................................................................................20 3.8 Surface Water...................................................................................................................................21 3.8.1 Surface Flow Regime............................................................................................................21 3.8.2 Surface Water Chemistry......................................................................................................24 3.9 Seismology........................................................................................................................................25 3.10 Biodiversity........................................................................................................................................26 3.11 Natural Protected Areas....................................................................................................................27 3.12 Socioeconomic Setting .....................................................................................................................27 3.12.1 Social Area of Influence ........................................................................................................27 3.12.2 Stakeholders .........................................................................................................................30 3.12.3 Government...........................................................................................................................30 3.12.4 Demographics .......................................................................................................................30 3.12.5 Education ..............................................................................................................................32 3.12.6 Economy and Industry...........................................................................................................32 3.12.7 Employment and Household Income....................................................................................32 3.12.8 Economic Vulnerability..........................................................................................................33 3.12.9 Environmental Justice and Vulnerable Communities............................................................33 3.12.10 Community Health and Safety..........................................................................................34 3.12.11 Social Infrastructure..........................................................................................................35 3.12.12 Cultural Heritage...............................................................................................................36 4 Design Basis .............................................................................................................. 37 4.1 Legal Requirements..........................................................................................................................37 4.2 Closure Objectives............................................................................................................................37 4.3 Future Use ........................................................................................................................................37 4.3.1 Further Mining Activities........................................................................................................37 4.4 Design Standards..............................................................................................................................37 J V P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page v 4.4.1 Global Industry Standard on Tailings Management..............................................................37 4.4.2 Canadian Dam Association...................................................................................................38 4.5 Environmental Considerations Affecting Closure .............................................................................38 4.5.1 Spatial Constraints ................................................................................................................38 4.5.2 Land Use...............................................................................................................................38 4.5.3 Tailings Geochemistry...........................................................................................................38 4.5.4 Growth Regime .....................................................................................................................38 4.5.5 Water Treatment ...................................................................................................................38 4.5.6 Water Balance.......................................................................................................................38 4.5.7 Wetlands................................................................................................................................39 4.5.8 Climate ..................................................................................................................................39 4.5.9 Climate Change.....................................................................................................................39 4.6 Engineering Considerations Affecting Closure .................................................................................40 4.6.1 Design Storm Event for Closure............................................................................................40 4.6.2 Surface Water Diversions......................................................................................................40 4.6.3 Geotechnical Stability............................................................................................................40 4.7 Socioeconomic Considerations Affecting Closure............................................................................40 4.7.1 Stakeholders Impacted by Closure.......................................................................................40 4.7.2 Macroeconomic and Socioeconomic Impact of Closure.......................................................41 4.7.3 Kings Mountain Community Planning ...................................................................................41 4.7.4 Attractive Nuisances..............................................................................................................42 4.8 Closure Assumptions and Design Criteria........................................................................................43 4.8.1 Design Criteria.......................................................................................................................43 4.9 Closure Materials..............................................................................................................................43 4.9.1 Available Materials................................................................................................................43 4.9.2 Material Salvage....................................................................................................................44 4.9.3 Materials Balance..................................................................................................................44 4.10 Revegetation Test Program..............................................................................................................45 4.10.1 Progressive Closure..............................................................................................................46 4.11 Worker Health and Safety.................................................................................................................47 4.12 Relinquishment .................................................................................................................................47 5 Closure Strategy ........................................................................................................ 48 5.1 Revegetation.....................................................................................................................................48 5.2 Stormwater Management..................................................................................................................48 5.3 Archdale Tailings Storage Facility.....................................................................................................49 5.3.1 TSF........................................................................................................................................50 5.3.2 TSF Drainage and Surface Water Management...................................................................51 J V P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page vi 5.3.3 TSF Non-process Infrastructure............................................................................................53 5.4 Power Lines and Power Distribution.................................................................................................53 5.5 Roads 53 5.6 Ponds 54 5.7 Yard Areas........................................................................................................................................54 5.8 Industrial and Hazardous Waste.......................................................................................................54 5.9 Fencing .............................................................................................................................................54 5.10 Well Abandonment............................................................................................................................54 5.11 Progressive Closure..........................................................................................................................54 5.12 Temporary Closure ...........................................................................................................................55 5.13 Unplanned Closure ...........................................................................................................................55 5.14 Post-Closure Management Plan.......................................................................................................56 6 Socioeconomic Transitioning................................................................................... 57 6.1 Post-Closure Visioning......................................................................................................................57 6.2 Socioeconomic Transitioning Actions...............................................................................................57 7 Closure Monitoring .................................................................................................... 59 8 Preliminary Mine Closure Schedule......................................................................... 60 9 References.................................................................................................................. 61 List of Tables Table 2-1: Production Facilities and Supplies ....................................................................................................6 Table 3-1: Key Stakeholder Groups.................................................................................................................30 Table 3-2: Population Growth in the Social Area of Influence..........................................................................31 Table 3-3: Racial Breakdown in the Social Area of Influence ..........................................................................31 Table 3-4: Potential EJ Communities in the EJA Study Area (USEPA and NCDEQ)......................................34 Table 4-1: Reclamation Quantities...................................................................................................................45 List of Figures Figure1-1: Project Location Map .......................................................................................................................1 Figure 2-1: Preliminary Kings Mountain Mining Project.....................................................................................5 Figure2-2: Archdale TSF Layout .......................................................................................................................6 Figure 2-3: Archdale TSF Non-Process Infrastructure Area ..............................................................................8 Figure 3-1: Annual Precipitation and Distribution of Monthly Precipitation ......................................................12 Figure 3-2 Average Monthly Evaporation.........................................................................................................14 Figure 3-3: Existing Streamflow Network .........................................................................................................22 JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page vii Figure 3-4: Location of Kings Creek Watershed ..............................................................................................23 Figure 3-5: Archdale Surface Water Sample Locations...................................................................................25 Figure 3-7: Social Area of Influence.................................................................................................................29 Figure 4-1: Land Use Map (City of Kings Mountain)........................................................................................42 Figure 4-2: Volunteer Revegetation at Archdale..............................................................................................46 Figure 5-1: Archdale TSF Post-Closure Stormwater Flows .............................................................................49 Figure 5-2: Archdale TSF (end of operations)..................................................................................................49 Figure 5-3: Archdale TSF Section C.................................................................................................................50 Figure 5-4: Typical Section TSF Embankment Regrading...............................................................................50 Figure 5-5: TSF Closure Perimeter Channel....................................................................................................51 Figure 5-6: TSF Stormwater and Seepage Collection Detail Plan (Operations)..............................................52 Figure 5-7: TSF Stormwater and Seepage Collection Detail Plan (Closure)...................................................52 Figure 8-1: Preliminary Closure Schedule........................................................................................................60 Appendices Appendix A: Recommended Revegetation Plan Appendix B: Technical Memorandum: Conceptual Closure Surface Water Management Plan for Kings Mountain TSF Appendix C: Closure Drawing Package JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page viii Executive Summary SRK developed a site-specific conceptual closure plan for both the Kings Mountain and Archdale properties predicated on the currently proposed mine designs as well as the various studies that have been completed in support of those designs. For purposes of brevity, neither a summary description of the Project (as designed) nor findings from the individual studies will be reiterated herein, as they are provided elsewhere in this document. Rather, this section will focus on information from the other sources that is deemed essential or relevant to the understanding of closure of the Project, as proposed in this plan. The overall objectives used to inform the closure strategy include: • Ensure legal and other obligations are met. • Manage reputational impacts. • Relinquish a safe and secure site where remaining infrastructure is chemically and physically stable. • Implement closure actions that minimize impact on remaining mineral resources. • Protect and preserve remaining environment, including limiting impact on community water sources. • Implement socioeconomic transitioning measures to assist community sustainability and future development. The Project is subject to applicable regulations of the North Carolina Department of Environmental Quality (DEQ). Any mining must be carried out in accordance with the North Carolina Mining Act of 1971, G.S. 74, Article 7, and NCAC Title 15A, Chapter 5. Anyone operating a mine that affects more than one acre of surface area must obtain a permit, post a bond, and develop a reclamation program. This conceptual closure plan describes preliminary methods to close the proposed mine facilities in accordance with these legal requirements. The principal facilities considered during closure include: • Open Pit, • Rock Storage Facilities (RSFs), • Archdale Tailings Storage Facility (TSF), • Process Plant, • Mine Support Infrastructure, • Water Storage Basin 1 (WSB-1) • Water Diversions, • Water Supply, • Waste Management, and • Electricity Supply. The Project environmental and social setting, as described in the various supporting documents, were reviewed and considered during development of the conceptual closure plan. These included: • Meteorology o Temperature o Solar Radiation o Precipitation o Storm Frequency JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page ix o Evaporation • Air Quality • Land Use (Historic and Current) • Geology and Geochemistry • Site Soils • Hydrogeology and Surface Hydrology • Water Quality • Seismology • Biodiversity • Natural Protected Areas • Recreation • Socioeconomical Setting (incl. Environmental Justice) • Cultural Heritage • Health and Safety Environmental Considerations for Closure Based on the regulatory requirements, as well as the information developed within each of the aforementioned resource areas, a number of environmental considerations were identified having the potential to affect closure of the Project. Spatial Constraints The Project is spatially limited due to other development and property ownership in the surrounding areas. This presents some challenges for operational development, planning for closure reclamation slopes, and storage of reclamation materials. Land Use During preliminary meetings, local stakeholders indicated the desire to include redevelopment of the Gateway Trail system after closure. Due to the urbanization of the city and housing shortage, the land adjacent to the Kings Mountain Project in Cleveland County is in high demand to meet the housing needs. Ore Geochemistry Based on geochemical characterization results, the Kings Mountain ore material is benign and contains only minor sulfide content. Geochemical characterization and modeling work indicates that groundwater underlying the proposed TSF is predicted to be circum-neutral (pH 6.7 to 7.3), with the majority of parameters predicted to be below North Carolina Groundwater Quality Standards. The only exceptions are iron and manganese, which are elevated in existing (i.e., baseline)groundwater at Archdale. Growth Regime The climate of the region, as well as soil characteristics, have a positive impact on vegetative growth in the Project area, as evidenced by self-sustaining volunteer revegetation in previously disturbed areas from former operations. JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page x Water Treatment No water treatment will be required after closure for the Archdale TSF. Water Balance Water balance simulations conducted for the site indicate that the overall water balance of the Project is strongly positive, generating excess water from pit dewatering activities,waste rock seepage,waste rock runoff, and undiverted run-on to the facilities. Wetlands SWCA (2024) identified a total of 17.05 acres of wetlands at the Archdale site but has recommended that all these wetlands be considered non-jurisdictional. At this time the USACE has not issued a Jurisdictional Determination. If the USACE agrees with the recommendation no mitigation would be required. Climate The Project site can receive between 40 to 70 inches of rain on an annual basis. This precipitation is relatively evenly distributed throughout the year but occurs with the greatest intensity during the summer growing season in the form of thunderstorms. Hurricanes can cause periods of intense rainfall throughout the fall and winter. Climate Change A climate change analysis suggests that the region will likely become warmer and wetter as a result of climate change; however,the study predicts that this will not be reflected in the more extreme rainfall events that control PMP depths. Engineering Considerations for Closure In addition to environmental considerations potentially affecting closure, several engineering considerations were also considered: Design Storm Event for Closure All operational channels were designed to safely convey the peak flow from the 100-year, 24-hour storm event from the maximum area that will contribute to them. Any channels that will remain after closure will be reconfigured to safely convey a PMP storm event. Rock Storage Facility Configuration Based on a review of runout potential, the occurrence of a runout event is considered very low probability, and, in the unlikely event of a runout, the material is modeled to be maintained within the 100 ft setback distance to the property boundary. Surface Water Diversions At closure, all facilities will be covered with growth media and revegetated. Therefore, all runoff from the facilities will become non-contact water. Most of the surface water diversions will be removed and JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page A sediment ponds will be breached or removed. Any remaining channels will be reconfigured to safely convey a PMP storm event. Geotechnical Stability Based on preliminary design reports for the TSF,these facilities are geotechnically stable, as designed at their final overall slope angles. This applies to post-closure conditions as well. Socioeconomic Considerations for Closure A number of socioeconomic considerations also influenced the closure strategy for the Kings Mountain Project: Stakeholders Impacted by Closure Stakeholders will be affected by closure in differing ways, depending on their relationship to the mine. • Employees and their dependents • Suppliers to the Project and their employees • Shared value partners • Local, State and Federal Governments • The Eastern Band of Cherokee Indians and the Catawba Nation • Residents of Kings Mountain and surrounding areas • Vulnerable groups Macroeconomic and Socioeconomic Impact of Closure Albemarle is in the preliminary phase of assessing macro and socioeconomic impacts from the Project and closure. There will be positive and negative direct and indirect impacts associated with closure. Albemarle is working with stakeholders to optimize positive impacts, explore partnerships to develop employment opportunities and community investment programs, and identify appropriate mitigation strategies for negative impacts. Kings Mountain Community Planning Future use planning for the Project site could influence the future uses selected for the site and will be considered during development of the socioeconomic transitioning plan. Attractive Nuisances During closure and post-closure, there is the potential that conditions on the mine may attract trespassers who do not understand risks associated with accessing the areas where there are perceived attractive conditions. Closure Strategy The closure strategy involves implementation of best management strategies to bring the site to the agreed upon post-mining land use and established closure goals. Financial planning and provisioning will be provided at a later stage as mine planning progresses, but financial assurance mechanisms for closure will be in place throughout the entirety of the mine closure phase. JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page xii Revegetation The proposed revegetation plan including seeding methods, species, and any amendments in described in the Recommended Revegetation Plan (ERM, 2024a) and provided in Appendix A of the Conceptual Closure Plan (SRK, 2023a). Stormwater Management At closure, all surface water will be directed toward original flow paths to the degree possible. All of the sediment ponds constructed for operations will be breached or removed during closure.All culverts installed during construction or operations will be removed at closure and fill above the culverts will be removed and/or regraded to allow unimpeded flow toward original water courses. Remaining channels will be modified to allow them to safety pass a PMP storm event. Riprap will be placed along channels where high velocities could result in erosion. The final surface of the tailings in the TSF will be deposited, with minimal regrading, to create a mounded surface that sheds water after closure. At closure stormwater from the TSF will be managed in the diversion channels constructed at the toe of the embankment and reconfigured at closure to safely convey a PMP storm event. Once contact water flows are no longer being pumped to the WSB-1,the embankment will be breached back to original channel elevation and the pond will be allowed to free drain. The wetlands that were established during operations will be reestablished at the new water level. Archdale Tailings Storage Facility Because the tailings in the TSF will be dry stacked,the final surface of the facility will be created during deposition, and no significant regrading of the tailings surface is expected. Both the tailings surface and the embankment will be covered with two feet of growth material. The final TSF embankment slope will have an overall slope of 2.5H:1 V with slope breaks approximately every 30 vertical feet. These slope breaks are designed to reduce erosion from surface flows while vegetation is established. The surface of the tailings and the embankment will be seeded with an approved seed mix. Tree seedlings will be planted on the tailings surface, but no trees will be planted on the embankment in accordance with state dam safety regulations. TSF Non-process Infrastructure The Archdale NPI area, at the southwest corner of the TSF area, contains the contact water pond, truck shop,truck parking,office,and various support buildings and Iaydown areas needed for operation of the TSF. This area will be completely reclaimed during closure and all buildings and structures will be removed. Concrete foundations and floor slabs will be broken and placed in the contact water transfer pond void or removed from site to a licensed landfill. The soils under buildings and all disturbed areas will be inspected to identify any areas where oils or liquids may have seeped into the ground. Any areas where impacted soils are found will be sampled and tested. As needed, any impact soils will be excavated and removed to an appropriate disposal facility. Any compacted areas will be ripped. JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page xiii The surface of the entire Archdale NPI area will be regraded to convey surface flows toward culverts under I-85. One foot of growth media will be placed and the area revegetated using an approved seed mix. Some tree seedlings will be planted. Power Lines and Power Distribution Power lines and distribution systems may be required to supply energy to structures remaining to support post-closure land use. However, for purposes of this strategy, any temporary infrastructure that was installed to support operations will be decommissioned and demolished. This infrastructure will be among the last items decommissioned, with decommissioning occurring once there is no need for energy on site. Some power infrastructure will remain permanently as part of the larger City of Kings Mountain electrical utilities supply. Water Supply System All water used on site will be supplied internally. Once operations and processing cease, and water supply to the Project is no longer needed, pipes and pumps will be dismantled and removed from the site. Roads All roads that are not needed for post-closure access for monitoring and maintenance, or potential future use, will be removed during closure. All roads that will remain after closure will be narrowed to 15 feet, which should allow access by small trucks or bulldozers. Ponds After closure cover is placed, all collection and sediment ponds will be breached and discharges conveyed to drainages. Yard Areas After regrading to direct water generally into original water courses, the areas will be covered with one foot of growth media and reseeded according to the revegetation plan. Industrial and Hazardous Waste Industrial and Hazardous waste will be identified in accordance with RCRA and applicable waste regulations and disposed of off-site at an approved third-party facility. Fencing Fencing will be removed and 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. Well Abandonment Water supply wells will remain for future use at closure.Any monitor wells not needed for post-closure monitoring will be closed in accordance with state regulations. JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page xiv Progressive Closure Progressive closure is reclamation activities that take place during operations to accelerate closure of facilities for which closure can begin during operation or are no longer needed for the current operation. By performing progressive closure on areas no longer needed for operations, the proposed closure methods can be tested at field scale. Temporary revegetation of the closure material stockpiles will also provide information on the proposed revegetation approach. Temporary Closure In the event of temporary closure, the site will be placed into care and maintenance in accordance with a temporary closure plan prepared to preserve the assets at the site while maintaining compliance with all legal obligations. Unplanned Closure If the operation is closed prior to the currently planned closure date, some of the actions included in this plan may require modification appropriate to the conditions that exist at the time of closure. These modifications would be documented in a final closure plan prepared at that time. Post-Closure Management Plan The post-closure management plan will be developed at a later date, but typically include post-closure monitoring activities and vegetation monitoring and maintenance activities. Socioeconomic Transitioning In March 2023, Albemarle began community engagement regarding planning for socioeconomic transitioning at closure with a series of four initial workshops with key stakeholders to develop a vision for the future of the site. These meetings were designed to obtain stakeholder input to the closure planning process to ensure that the closure plan would be consistent with potential future uses. Continued engagement will occur throughout the mine life cycle, as the mine plan evolves and additional information is gathered. Post-Closure Visioning The post-closure visioning meetings were conducted as facilitated brainstorming sessions designed to encourage open dialog and ensure that the opinions of all those present were represented in the meeting. The specific topics included: possible desirable future uses, repurposing opportunities, types of undesirable future uses, and criteria to include or exclude future uses. A number of different ideas for future uses of the site, or portions of the site,were introduced by various stakeholders and discussed by the group. Common themes in these uses were: • Areas for unorganized recreation (e.g., trails, natural areas) • Organized recreation areas (e.g., ball fields) • Access to the pit lake for a water recreation area • Possible commercial use of the plant area • Outdoor event space • Potential use of some buildings for community (e.g., youth) programs JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page xv • Accessibility for all the public Large-scale industrial,warehousing, and commercial development were the only future uses that were generally deemed unfavorable, but deemed acceptable in portions of the site, provided that they did not conflict with surrounding land uses or the post-closure vision. Socioeconomic Transitioning Actions At this time, Albemarle plans to implement the following actions related to socioeconomic transitioning for the site after closure as part of this plan: 1) Albemarle will continue to engage with the community and key stakeholders on issues relating to post-closure vision for the site and socioeconomic transitioning with the intent of developing a comprehensive socioeconomic transitioning plan for the site during operations. 2) Develop a detailed post-closure land use plan in consultation with stakeholders to ensure that the final closure activities on the site are consistent with those land uses. This would include a land use viability assessment that defines criteria for inclusion and/or exclusion of possible future uses with the intent of developing a comprehensive plan that meets legal requirements and considers input from stakeholders. 3) Albemarle continues to participate in planning discussions with the Gateway Trail Board of Directors, the City of Kings Mountain, and Cleveland County to develop a plan for a new section of the Gateway Trail that aligns with the city's Master Plan for parks and recreation facilities, and stays committed to both preserve and enhance recreation opportunities for our community. Albemarle will continue to support engagement with the local community to gain input and ensure the best vision for the future of the trail can be realized. Currently, there is no timetable for the trail to be affected by potential mining operations at the Kings Mountain site, and the trail will continue to remain open to the public across Albemarle's property. Closure Monitoring The objective of the closure and post-closure monitoring program will be to track the recovery of the site toward the long-term post-closure land use goals, in accordance with the overall closure objectives. The monitoring program will be designed to collect information to demonstrate that the closure criteria have been achieved, revegetation and restoration objectives are met, and the site is stable. The strategy is to adopt monitoring requirements for specific environmental aspects and adapt these for closure.These activities will then be implemented through the closure and post-closure period.The monitoring that is typically required during the closure and post-closure period includes: • Surface Water—Quality monitoring of surface water to detect any changes to baseline water quality conditions, for a period that meets regulatory requirements. • Groundwater— Quality monitoring of both the shallow and deep aquifers. Aquifer recovery also typically monitored via collection of water samples to detect any changes to baseline water quality conditions, for a time that meets regulatory requirements. • Air Quality—Air quality monitoring is typically limited to the period in which significant dust is potentially generated. Once these areas have been closed, the air quality network will be decreased or totally removed. JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page xvi • Reclamation Performance Monitoring — reclamation performance monitoring consists of comparing the reclaimed areas to analogue sites where vegetation performance and soil chemical and physical properties are measured. • Biological Monitoring of aquatic and terrestrial resources in accordance with local requirements. Annual reports will be prepared to document the results of the monitoring during the closure and post- closure phases. These reports will provide important information required to manage the on-going closure activities, with the data and reports being used to: • Provide recommendations for improving subsequent reclamation activities. • Indicate where reclamation and closure activities have not been successful, requiring a potential change in design criteria. • Provide information where care and maintenance are required during the post-closure period. • Indicate if relinquishment criteria have been achieved. During closure, a phased approach in the reduction of monitoring frequency and locations typically occurs. Preliminary Mine Closure Schedule Some mine closure activities can occur concurrently as the mine operations allow. However, the availability of those areas for closure will depend on the mining schedule and availability of equipment and staff resources. Areas that could be closed concurrently include the embankment of the Archdale TSF could be ready for closure as early as Year 6 of operations. The majority of closure actions would be implemented once mining ceases in Year 9, but some post-closure monitoring and maintenance activities would continue for another 10 years. As monitoring demonstrates that the closure goals are met, monitoring requirements should decrease, and groundwater wells can be progressively abandoned. Maintenance activities could include overseeding areas where vegetation has not performed to expectations, or covers have experienced localized erosion. JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page xvii List of Abbreviations The following abbreviations may be used in this report. Abbreviation Unit or Term ABA acid base accounting AGP acid generation potential AJD approved jurisdictional determination AWA Applied Weather Associates amsl above mean sea level ANP acid neutralization potential ARDML acid rock drainage and metal leaching BCMWRORC BC Mine Waste Rock Pile Research Committee CDA Canadian Dam Association Chemetall Chemetall Foote Corp. CEUS Central and Eastern United States MID corrugated metal pipe Cyprus Cyprus Specialty Metals Co. Cyprus Amax Cyprus Amax Minerals Co. Cyprus Foote Cyprus Foote Mineral Co. DEQ Department of Environmental Quality DEHNR Department of Environment, Health and Natural Resources Division of Land Resources DHHS North Carolina Department of Health and Human Services DMS dense media separation EJ environmental justice ESA Endangered Species Act Foote Foote Mineral Company Inc. FoS factor of safety ft feet GARD global acid rock drainage GISTM Global Industry Standard on Tailings Management m gallons per minute HCT humidity cell test HDPE high density of eth lene KIM Kin s Mountain KMMP Kings Mountain Mining Project L liter LEAF leaching environmental assessment framework Mg Milligrams Mst million short tons NAG net acid generating NEPA National Environmental Policy Act NNP net neutralization potential NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System NPI non processing infrastructure NPR neutralization potential ratio OSA overall slope angle PAG potentially acid generating cf per cubic foot PET Polyethylene terephthalate PJD preliminary jurisdictional determination PMF peak design flood PMP robable maximum precipitation Project Kings Mountain Mining Project PSD prevention of significant deterioration QAQC quality assurance/quality control JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page xviii Abbreviation Unit or Term RCRA Resource Conservation and Recovery Act Rockwood Lithium Rockwood Holdings Inc RSF rock storage facility SAol Social Area of Influence SEM scanning electron microscopy SMU soil map units Solvay Solvay Process Co. SPLP synthetic precipitation leaching procedure S.U. standard units H TSF tailings storage facility USFWS US Fish and Wildlife Service UT unnamed tributary WSB-1 Water Storage Basin No. 1 XRD x-ray diffraction JVP/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 1 1 Introduction Kings Mountain Mining Project (KMMP or Project) is a open pit lithium mining operation located in the city of Kings Mountain, North Carolina, in the southeastern United States. The Project is a lithium pegmatite deposit that is currently being investigated for redevelopment by Albemarle Corporation (Albemarle) as part of a prefeasibility-level analysis. The purpose of this conceptual closure plan is to give a general overview of closure for the Project. Activities proposed as part of mining at the Project include an open pit mine, tailings storage facility (TSF), rock storage facilities (RSF), processing plant, and related infrastructure. This closure plan specifically addresses the context, basis and proposed plan for closure of the TSF facilities at the Archdale site. 1.1 Project Location Situated in Cleveland County,the mine is approximately 35 miles west of Charlotte, North Carolina. Located amidst rolling hills of the Piedmont Plateau, the Project is in a predominantly rural setting within the city of Kings Mountain. The mine site covers a significant land area, which includes both the proposed extraction areas and associated processing infrastructure. shows the location and extent of the mine. The nearby Archdale site is the location of the project TSF. - Kin s M unta'n Pra'ect i in• F -r s:a�ne Asherllle Mp°RS✓le cTme�.°e - North Carolina w� .. _. Shelby ^r^^ Gavonia r� - ocharloue riJil ------------- -_. o partanbuq weae wmgm Rock Hill u� Greewine Q`eaF South Carolina Source:Google Earth,2023(modified by SRK) Figure 1-1: Project Location Map J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 2 1.2 Regulatory Framework and Operating Approvals The Project is subject to applicable regulations of the North Carolina Department of Environmental Quality(DEQ).Any mining must be carried out in accordance with the North Carolina Mining Act of 1971, G.S. 74, Article 7, and NCAC Title 15A, Chapter 5. Anyone operating a mine that affects more than one acre of surface area must obtain a permit, post a bond, and develop a reclamation program. The plan identifies proposed mining and processing components and describes preliminary methods to close these facilities in accordance with the DEQ, formerly the Department of Environment, Health and Natural Resources Division of Land Resources (DEHNR)Surface Mining Manual. This conceptual closure plan includes the following information: • Description of facilities present at closure and associated plans for closure • Description of stormwater management practices and closure objectives • Description of stability objectives at closure • Public safety and access during closure and post-closure • Closure and post-closure water management • Post-mining land use • Regrading and revegetation plan • Waste disposal at closure JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 3 2 Project Description The Project ore deposit is a lithium-bearing, rare-metal pegmatite intrusion that has penetrated along the Kings Mountain shear zone, a regional structural feature known to host multiple lithium bearing pegmatites along its trend. The pegmatite field at Kings Mountain is approximately 1,500 feet (ft) wide at its widest point in the legacy pit area and narrows to approximately 400 to 500 ft in width at its narrowest point south of the legacy pit. The field has a lithium mineralization strike length of approximately 7,500 ft and is predominantly contained in the mineral spodumene. The spodumene pegmatite bodies exhibit a texture-based variation in lithium grade, spodumene grain size, mineral alteration, and rock hardness. 2.1 Land Tenure The KM Project property consists of privately held land either owned in fee simple or leased by Albemarle or one of its wholly owned subsidiaries. There are 27 fee simple parcels, totaling 1,326.71 acres, owned directly by Albemarle or one of its wholly owned subsidiaries which grant both surface access and mineral rights. There are two parcels, 12849 and 12854, totaling 20.06 acres under lease for surface access only, and one additional parcel, 47136, totaling 40.3 acres, which is under lease for both surface access and mineral rights. The Project area is located within the footprint of historic mining activity, and is adjacent to urban land used for recreation, businesses, and residential homes. 2.2 Mining History Exploration activities on the KM property started in the 1800's, with limited documentation prior to the 1950's. The 1940's provided the first records of mining activities, operated by Solvay Process Co. (Solvay)initially, and then by Foote Mineral Company Inc. (Foote).All active mining operations ceased in 1984, but no reclamation work was required or performed following cessation of mining. The Property has maintained the onsite conversion plant for converting lithium carbonate sourced from Clayton Valley and Salar de Atacama, to other lithium compounds and lithium metal to the present date. Current exploration programs include historical geological compilation, surface and bench mapping, and a multi-year exploration drilling program. Mining at KM began in 1883 with the discovery of cassiterite, a tin-bearing mineral, within the outcropping pegmatites. Subsequently, open-pit mining for tin occurred sporadically between 1903 and 1937 (ERM, 1981). Between 1943 and 1945, under the sponsorship of the US Government, Solvay established a processing plant and mined for spodumene from the outcropping pegmatites at KM (ERM, 2004). A summary of the post-1940 property history and Property operators' is as follows: • In the early 1950s, Foote, a subsidiary of Newmont Mining Corporation, purchased the property and began mining and extracting lithium from the spodumene. • In 1988, Cyprus Specialty Metals Co. (Cyprus), a subsidiary of Cyprus Mineral Co., acquired Foote and became Cyprus Foote Mineral Co. (Cyprus Foote).Which then merged with Amax Inc. in 1993 to become Cyprus Amax Minerals Co. (Cyprus Amax) (ERM, Ebensperger et al., 2005). J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 4 • In 1998, Chemetall GmbH, a subsidiary of Metallgesellschaft A.G., purchased Cyprus Foote from Cyprus Amax, and renamed the subsidiary Chemetall Foote Corp. (Chemetall). • In 2004, Rockwood Specialties Group, Inc., a subsidiary of Rockwood Holdings Inc. (Rockwood Lithium), acquired Chemetall. In 2010, Chemetall expanded operations at KM with the construction of a lithium hydroxide plant and a technical center. • In 2015, Albemarle acquired Rockwood Lithium and conducted advanced exploration programs and economic evaluations at KM during 2017 and 2018. 2.3 Project Overview After dewatering the legacy pit,the lithium deposit is to be mined using conventional open pit mining techniques. Blasting will fragment the ore and waste rock where it will be loaded and hauled to either the processing facilities (ore) or the rock storage facilities (overburden). The current plan includes mining in the existing pit and expanding the pit to the southwest (Figure 2-1). Ore would be drilled, blasted, loaded, and transported by haul truck to a new processing plant at a rate of --2.98 million tons per annum of ore (-8,150 tons per day) and processed to produce 380 to 420 thousand tons per annum of spodumene concentrate. The concentrate will be filtered to approximately 11% moisture by weight and transported off site for further refinement into lithium hydroxide monohydrate at a separate facility. Tailings from the spodumene concentrate process will be filtered to approximately 10 to 15% moisture content by weight and transported off site to a nearby facility for disposal. A portion of the waste rock with economic value as aggregate will also be transported off site for sale. 2.4 Project Layout Figure 2-1 presents the Project layout, showing the relative locations of the major components of the Project. The Project is bisected northeast to southwest by Interstate 85 (1-85). The headwaters of Kings Creek are located immediately northeast of the site, and the creek leaves the Project area to the south. The Phase 1 open pit outline is shown in the northeast area of the Project along with the ultimate (Phase 4) pit extents. Haul roads are shown connecting the pit to the RSFs: RSF-X, located south-centrally for potentially acid generating (PAG)waste rock, and RSF-A, located in the southwest for non-PAG waste rock. The haul roads will also connect to the non-processing infrastructure (NPI) (located in the northwest portion of the site) and the ore sorting area and stockpiles(located on the east side of the Project,just north of 1-85). A bridge over 1-85 will connect the ore stockpile area to the processing area, located immediately south of 1-85. South of the processing area, Water Storage Basin (WSB)-1 will collect all contact water produced within the Project area before being discharged from the site. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 5 i i ® srkconsulting .a. AALBEMARLE FIGURE 01 Figure 2-1: Preliminary Kings Mountain Mining Project Tailings from the spodumene concentrate process will be filtered to approximately 10 to 15% moisture content by weight and transported off site to the nearby Archdale TSF facility for disposal (Figure 2-2). A portion of the waste rock with economic value as aggregate will also be transported off site for sale. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 6 .IF FNTRANGE -- -- -�_ 1 W FT_ HIGH POINT PERIMETER HAUuACCESS ROAD FILTERED 7AawG //. STOPAGE UGHr VEHICLE ENTRANCE _ / r " • � / ROCK FILL EMBANKMENTS CREST 96D ELF,a 1 SEEPAGE INTERCEPTICN DRAIN l l PERIMETER ACCESS ROAD WATERAND SEWER MAIN LIGHTVEHICLE ACCESS ROAD EXISTING CULVERTS(TYP.) PROPOSEOCULVERT(iYP} SEDIMENT BASINS FUEL PAD SEEPAGE COLLECTION TANK MAINTENANCE SHOP CULVERT ABLE TO PASS PUP PROPERTY BOUNDARY - OVERHEAD POWER v / CONTACT WATER POND GROWTH MEDIA STOCKPfLE(-2DOk CY OONM AREA TRUCKPARKING PING V Figure 2-2: Archdale TSF Layout 2.5 Mining Schedule Once operational, mining from the open pit is anticipated to last for approximately 8.5 years. During the last year of mining, and a portion of the following year, some of the waste rock extracted during operations will be backfilled into the bottom of the open pit. 2.6 Infrastructure The proposed facilities are summarized in Table 2-1 and are discussed in the following sections. Table 2-1: Production Facilities and Supplies Facility Description Type Open Pit The KM open pit is a permanent facility of the project. Permanent Rock Storage RSF-A is a permanent facility of the Project. RSF-X contains PAG Permanent/ Facilities and will be segregated in a lined facility to be used as in-pit Temporary backfill. Tailings Storage The Archdale TSF will be built off site as a dry-stack tailings Permanent Facility facility and will remain after closure. Water Built to prevent natural water from inflowing to the Project Temporary/ Diversions facilities. Some will remain after closure. Permanent Process Plant Process facilities are where ore will be crushed, milled, and Temporary rocessed for lithium ore concentrate. Water Supply The water for the process will be obtained from either site water Temporary supply or surface water locations within the Project boundary. Electricity Electricity to the site is provided by transmission lines to the Temporary/ Supply property. Some installments may be permanent. Permanent Source:SRK,2023b JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 7 2.7 Open Pit Mining will occur from a single existing open pit on site, that currently has a developed pit lake. Prior to mining, the pit lake will be evacuated at a nominal rate of 2,000 gallons per minute (gpm) over several months to remove the pit lake. During operations, dewatering will occur at a typical rate of 100 to 300 gpm, although a pumping capacity of 5,000 gpm is designed in the dewatering system to address peak flows during extreme storm events. Water from the pumping system will be sent to WSB-1 via pipeline. The proposed pit is to be developed in five phases, PHO to PH4 Pits. The early pit phases advance the depth of the historic open pit to about 450 feet above mean sea level (amsl) (PHO-PH3), and pushback the East Wall toward its final position. The final PH4 pit phase comprises a push-back to form the West Wall crest and advances the pit floor to an elevation of 285 ft amsl. The overall slope heights range from 650 ft (East Wall) to 705 ft (West Wall). The proposed pit is to be excavated across an 8.5 year period. A pit lake has formed within the historic open pit with a current pit lake elevation at 785 ft amsl with two to three benches exposed above the water level. The West Wall has an overall slope angle (OSA)of about 500 and the East Wall about 400. The exposed benches are vegetated and show a higher degree of fracturing than the underlying fresh rock recovered during the drilling programs. The current ground elevation is approximately 975 ft and 850 ft amsl on the west and east sides of the historic pit, respectively. The historic pit depth is 660 ft. 2.8 Mine Support Infrastructure In addition to the open pit, mine facilities include infrastructure such as a mine office, a truck shop, a truck wash, workshops, warehouses, and ancillary facilities that will be temporarily located in the NPI area in the northwest portion of the site during the life of the operation and removed from site during closure (Figure 2-1). 2.9 Rock Storage Facilities Waste rock from the KM open pit will be placed on two RSF, located on site: RSF-A and RSF-X. RSF-A will be comprised of coarse rock material and has a capacity of 23.39 million short tons (Mst)of waste rock material (pers comm David Thompson, March 18, 2024). RSF-A will be located in the southwest area of the property and will be for non-PAG material. RSF-X will be a lined facility to store PAG material. RSF-X will be constructed south centrally,with a capacity of 15.85 Mst(pers comm David Thompson, March 18, 2024). 2.10 Overburden Storage Facilities Material excavated during construction will be stored in growth media stockpiles or overburden storage facilities (OSFs). Growth media stockpiles are located at both the Kings Mountain and Archdale sites. The growth media stockpile at Kings Mountain will be located at the NW corner of the pit. The growth media stockpile at Archdale will be located in the southwest corner of the area (Figure 2-2). There will be three OSFs located at Kings Mountain to contain the additional material that will be excavated below the top layer salvaged as growth media as shown on Figure 2-1. J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 8 2.11 Tailings Storage Facility The Archdale TSF will be located at the site of a former mica mine. Tailings from the spodumene concentrate process at KM will be filtered to approximately 10 to 15% moisture content by weight and transported off site to the proposed Archdale TSF for disposal. A portion of the waste rock mined at KM will be transported to Archdale for construction of the TSF embankment. An initial TSF embankment (i.e., starter dam) will be constructed on site to hold approximately 1 year of filtered tailings. The filtered tailings material will be placed and compacted within the TSF with mobile equipment. Over the 10-year life of the Project, the TSF embankment will be raised annually using downstream construction methods with run-of-mine (ROM)waste rock. The filtered tailings will continue to be placed until the facility reaches its full capacity.At final build-out, the TSF will contain 9.2 Mst of tailings (Albemarle, 2023a), after which it will be closed and reclaimed. Figure 2-2 shows the Archdale TSF layout. The TSF is bounded by 1-85 on the southeast and Highway 24 on the northwest. Access to the TSF will be off Highway 24 with a truck entrance and a light vehicle entrance. The site will include minor office and maintenance facilities, parking, water storage facilities, and a TSF perimeter access road (Figure 2-3). A small road base stockpile and growth media storage area are included in the site plan. ------ ------ ---- - , y PLANT SITE GRADING PLAN Figure 2-3: Archdale TSF Non-Process Infrastructure Area 2.12 Process Facilities North of 1-85 the ore will go through 3 crushing and screening stages (Figure 2-1). After secondary crushing, it will feed an ore sorting step, where high iron content waste material will be rejected. The rejects will then be hauled to RSF-X.The ore sorter product then goes through tertiary crushing and screening prior to being transported via conveyor to the south side of 1-85, where it will be temporarily stored at a covered ore storage barn. Ore will be retrieved from the ore storage barn and fed via conveyor to two parallel Dense Media Separation (DMS) modules, at each, an initial separation at a low specific gravity(SG)(2.65-2.70) will allow removal of the light waste material, which will be transported back to the north side of I- 85 and temporarily stored in bins so that they can be hauled and comingled with waste rock and stored at RSF-A. J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 9 The heavier material will then go through a second separation at a SG between 2.85 and 2.9, with the material heavier than 2.85-2.90 will be the enriched spodumene concentrate. This concentrate will need to be dried so that it can be fed to a dry magnetic stage for removal of the iron bearing waste.The magnetic concentrate will be mixed with the ore sorter rejects and sent to the north side of 1-85. The intermediate density material together with tertiary crushing/screening fines will then feed a grinding circuit, followed by desliming, magnetic separation and mica flotation, the waste streams generated during these stages will be combined and directed to a thickener and filter combination to recover process water. The pre concentrated spodumene ore will then go through a spodumene flotation stage where a final fine spodumene concentrate is produced, together with spodumene tails. Each of these two streams will be thickened and filtered separately. The spodumene tails after being filtered will be combined with the prior filters waste stream (called mica tails)for transport via conveyors back to the north side of 1-85. The fine spodumene concentrate will also be conveyed back to the north side of 1-85 after being combined with the coarse DMS spodumene concentrate. The combined spodumene concentrate will go to concentrate storage silos prior to via taken from site via railroad. 2.13 Water Management The project facilities are designed with runoff water management systems to reduce the amount of water that contacts the tailings, and to collect any contact water that does occur. 2.14 Waste Management Waste material generated at the Project(excluding sewage effluents) is classified as: 2.14.1 Non-Hazardous Solid urban and industrial wastes:this is waste that does not contain any type of dangerous material and is generated mainly in lunchrooms and offices, among others. Domestic waste consists of organic and inorganic waste (e.g., food waste, paper, bags, plastics, etc.). Domestic waste will be sent to an off-site landfill designated to accept domestic waste. 2.14.2 Recyclable or Reusable Waste Consisting of materials which, depending on their nature, can be reused in Kings Mountain or recycled outside the mine by authorized companies. This is a subgroup of non-hazardous waste which includes wood, metallic items in general, wear material, scraps, tinplate, cardboard, paper, polyethylene terephthalate (PET) packages, tires, and other related items. 2.14.3 Hazardous Waste Domestic and industrial waste considered hazardous in accordance with federal Resource Conservation and Recovery Act (RCRA) regulations. This term refers to all those waste materials that may cause direct or indirect damage to the environment.This waste type may be liquid or solid. Hazardous wastes will be identified and disposed of off-site in accordance with RCRA regulations. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 10 2.14.4 Special Waste This is waste that, according to its characteristics, requires special handling and disposal (e.g., radioactive wastes). Special wastes will be disposed of in accordance with applicable regulations at facilities designated to receive such waste. 2.14.5 Demolition Waste This is waste generated by the demolition of site facilities and will be recycled to the extent possible, and typically hauled away by the demolition contractor or stored onsite temporarily and hauled to a disposal facility that is approved to accept demolition waste. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 11 3 Project Environmental and Social Setting 3.1 Meteorology The Project is located within the Kings Mountain basin, which is a region of active weather throughout the year. The Project area is classified as Koppen climate Cfa, humid subtropical climate, which is characterized by the coldest month averaging above 32' Fahrenheit (F), at least one month's average temperature above 71.6° F, and at least four months averaging above 50' F, with no significant precipitation differences between seasons and no dry summer months. The region receives moisture from its proximity to the Atlantic Ocean, as well as being in the path of frequent jet streams, allowing fronts and areas of low pressure into the region. This can be enhanced by the warm Gulf Stream current just offshore of the North Carolina coast. The area is also topographically within the Appalachian Mountains, which can create a wide variety of climates and precipitation events within the region (Applied Weather Associates, 2022). 3.1.1 Temperature The climate of the Project vicinity is humid subtropical with hot summers and mild winters. The monthly temperature ranges from a minimum of around 3°F in January to a maximum of around 104°F in August,with an average temperature of around 60°F. Legacy data show that temperatures in the area have been increasing, with an average rise of 0.3°F per decade since 1970, or roughly 1.7°F from 1895 to 2020. Climate change is expected to further contribute to this warming trend, potentially impacting surface water conditions, such as increased evaporation rates and altered streamflow patterns. Predictive climate models suggest further warming in the future, potentially resulting in more frequent and severe heatwaves and droughts. 3.1.2 Solar Radiation The nearby city of Gastonia, North Carolina has an average annual solar radiation value of 5.37 kilowatt hours per square meter per day. Solar radiation is lowest in the months of December and January highest in June and August. (Gastonia, NC Utilities - Electricity, Natural Gas, Solar I Utilities Local). 3.1.3 Precipitation Kings Mountain experiences varying precipitation levels throughout the year. On average, the area receives between 46 to 52 inches of rainfall annually(Figure 3-1), with the wettest months typically being May through August and the driest months occurring between October and February. Precipitation is distributed relatively evenly throughout the year, without a clear wet or dry season. The region is susceptible to extreme precipitation events, such as tropical storms and hurricanes, which can bring heavy rainfall and cause flooding. Legacy data suggest that precipitation patterns may become more variable in the future, with an increase in both droughts and floods. J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 12 Distribution of Precipitation 12 so 70 m � -5w s ■o 40 2. a 30 T 4 - c E 20 - O 2 4 10 - D 0 January February March April May June July August September October November December Annual Total 2.5%SK 5%-10% ■10%-25% 025%-50% ■Median ■50%-75% 075%-90% 90%-95% 95%-97.5% Annual Precipitation as 70 r 6D 1 5D r 4D a 9D 20 ID I I 0 1925 1,20 1935 1340 1345 1550 1555 1%0 1%5 1970 1975 19 0 1995 1590 1995 2000 2005 2010 2015 2020 Source:SRK,2023a Figure 3-1: Annual Precipitation and Distribution of Monthly Precipitation 3.1.4 Storm Frequency Storms encountered at the Project vary in frequency and intensity throughout the year. For example, a 100-year, 24-hour storm event produces, on average, 7.96 inches of precipitation (National Oceanic and Atmospheric Administration (NOAA), 2023). The region experiences thunderstorms, tropical storms, and hurricanes, which can bring heavy rainfall and high winds. Thunderstorms,which are the most common type of storm in the area, see peak activity in July and August. Factors such as temperature, humidity, wind patterns, and topography influence storm occurrence. These storms can impact surface water availability and quality by causing flooding, erosion, and sedimentation. Climate change could increase the frequency and intensity of storms in the future, posing higher risks of flooding and erosion. Applied Weather Associates (AWA) completed the Site-Specific Probable Maximum Precipitation Study for Kings Mountain Mining Operations, North Carolina (AWA, 2022) for the Kings Mountain basin in North Carolina. AWA utilized a storm-based approach to derive the site-specific probable maximum precipitation (PMP) depths to update the PMP depths originally developed in hydrometeorological reports developed by the National Weather Service. Table 3-2 shows Tables 10.4 and 10.5 excerpted from AWA(2022),which show the results of the site-specific study with annual return intervals to 1:10,000 years and beyond. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan-Kings Mountain Page 13 Table 3-2 Precipitation Frequency Estimates Table 10.4: Kings Mountain basin AEP for 6-,24,stud 72-hour PMP Dings Mountain AEP Estimate PM (in) AEP ARI 6hr 28.5 2.51's 39,929,769 24hr 32.4 1.09'7 9,144,104 72hr 32.4 3.93'7 2,540,551 Tahle]0.5: Kings Mountain hAsin oierall frequenry analysis for 6,24-,and 72-huvr 1�275 Frequency Analysis 6-hour 24-hour 72-hour AEP AEP 50% 5% 95% 50% 5% 95% 50% 5% 95% 1 0.99010 9.9' 1.0 0.9 1.1 2.0 1.8 2.2 2.4 2.2 2.6 2 0.50000 5.0' 2.1 2.1 2.5 3.6 3.4 3.9 4.3 4.0 4.6 0.20000 2.0' 3.2 2,9 3.4 4.8 4.4 5.1 5.7 5.2 6.1 10 0.10000 1.0' 3.8 3.5 4.1 5.5 5.1 6.0 6.6 6.1 7.1 25 0.04000 4.0' 4.7 43 5.0 6.6 6.1 7.2 7.9 7.3 8.5 50 0.02000 2.C' 5.1 4.9 5.9 7.5 6.9 8.2 8.9 8.2 9.7 100 0.01000 1.01 6.0 5.5 6.7 8.4 7.7 9.2 9.9 9.1 10.9 200 0.00500 5.01 6.8 6.2 7.6 9.3 6.5 10.4 11.0 10,1 123 500 0.00200 2.0 3 7.9 7.1 8.9 10.6 9.6 12.1 12.6 11.4 14.3 1,000 0.00100 1.03 9.7 7.9 10.1 11.7 10.4 13.5 13.9 12.4 16.0 5,000 0.00020 2.0° 10.9 9.5 13.1 14.4 12.5 17.2 17.1 14.9 20.4 10,000 0.00010 1.01 11.9 10.3 14.5 15.7 13.5 19.1 12.6 16.0 22.6 100,000 0.00001 1.0' 15.8 13.1 20.5 20.4 16.9 26.5 24.2 20.0 31.3 1,000,000 0.000001 1.01 20.5 16.3 28.3 26.2 20.7 36.1 31.0 24.5 42.7 10,000,000 0.0000001 1.0 26.2 19.9 35.7 33.1 25.0 48.8 39.1 29.7 57A 100,000,000 0.00000001 1.0 g 33.1 24.0 52.5 41.3 29.9 65.5 42.9 35.4 77.6 1,000,000,000 0.000000001 1.09 41.4 29.6 70.7 51.2 35.3 87.4 60.6 41.9 103.5 10,000,000,000 0.0000000001 1,O in 51.4 33.9 94.7 1 63.1 41.5 116.1 1 74.7 49.2 137.5 Source:AWA,2022 3.1.5 Evaporation Evaporation rates at the Project vary based on temperature, humidity levels,wind speed, and solar radiation. Legacy data from regional climate stations provided by NOAA (NOAA, 2023) (Clemson University, SC GHCND:USC00381770, Chesnee 7 WSW, SC GHCND:US000381625, and Chapel Hill 2 W, NC GHCND:USC00311677), shows that evaporation rates are highest in summer, averaging around 6 to 7 inches per month, and lowest in winter, with around 2 to 3 inches per month (Figure 3-2). Overall, average annual potential evaporation ranges from 55 to 65 inches. Evaporation impacts surface water availability by contributing to water loss from lakes, rivers, and streams. Factors such as vegetation cover, land use practices, and soil moisture levels influence evaporation variability. Climate models predict that evaporation rates will continue to increase in the future due to warming temperatures and changes in precipitation patterns. J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 14 s 7 �6 ss • o 4 w 7- t 3 ` 9 o i 2 1 0 January February March April May June July August September October November December Clemson Univ Chesnee 7 WSW Chapel Hill 2 W — — —Average GoldSim Figure 3-2 Average Monthly Evaporation 3.2 Air Quality Albemarle has contracted with SWCA Environmental Consultants to install and operate two PM10 stations at the Kings Mountain facility. Albemarle is currently monitoring and collecting baseline data for future air quality dispersion modeling in support of an air permit and for federal National Environmental Policy Act(NEPA) planning purposes. The current PM10 monitoring stations were located based on several criteria. These criteria include: the location with respect to air quality emissions sources and prevailing wind direction, an on-site meeting with Albemarle and follow-up communications with NC DEQ, US Environmental Protection Agency (EPA-required siting criteria for Prevention of Significant Deterioration (PSD) ambient monitoring, and site security and safe access. The specific equipment specified for this site is standard within the air monitoring industry and has been approved by federal, state, and local governments nationwide for data collection. Data collected meets procedural and data output requirements for EPA and NC DEQ air quality networks. 3.3 Land Use The current land package consists primarily of historic mining features including open pit mines, waste rock, and tailings facilities on both sides of 1-85. The land package also consists of some recreational, residential, and commercial development property. 3.3.1 Historic Land Use The site has been mined sporadically starting in 1903 for cassiterite, a tin bearing mineral, and in 1942 for lithium in support of World War 11. Production continued until low demand for lithium resulted in the shutdown of the mining operation and eventual dismantling of the processing facilities in 1994. The Archdale site has been previously mined for mica resources. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 15 3.4 Geological Setting Elevation in the Project area ranges from approximately 755 to 1,074 ft above mean sea level (amsl). Lower elevations occur to the south of the Project area and higher elevations surround the remaining Project area, including two peaks at Crowders Mountain State Park, at approximately 1,700 ft amsl. The Project area is located within the Piedmont physiographic province which extends between the Blue Ridge Mountains to the west and the Coastal Plain to the east. The Fall Line, located east of the Project area, is a boundary between the Coastal Plain region and the Piedmont region. Initially, the Piedmont was a gently sloping plain until uplift raised the region to its present elevation. Bedrock geology consists of metamorphic rocks including biotite gneiss, schist, slate, quartzite, phyllite, and amphibolite that has been physically and chemically weathered forming a reddish soil at the surface, which is underlain by soft, weathered bed rock. The geologic units run parallel along an approximate northeast-southwest strike. The Piedmont province is characterized by rolling to hilly uplands with well-defined drainage networks consisting of well-established streams and creeks along with erosional channels that have incised the Piedmont plateau. Erosion and gullying have left narrow to fairly broad upland ridgetops and steep slopes adjacent to the major streams. Soils are formed from weathered bedrock (i.e., residuum), and most are classified as Udorthents with a soil horizon profile typical of a C horizon to 80 inches below surface with a texture of sandy clay loam (SWCA, 2023a). 3.5 Geochemistry Albemarle has conducted a geochemical characterization investigation to provide an understanding of the geochemical characteristics of geological materials specific to the Kings Mountain Project and to define the potential for future mining wastes, including waste rock (including DMS and ore sorting rejects), nd tailings, to generate acid or leach deleterious constituents. Representative samples have been collected and characterized following guidelines set forth in the Global Acid Rock Drainage(GARD)Guide(INAP,2014),the MEND Prediction Manual for Drainage Chemistry from Sulfidic Geologic Materials (MEND, 2009) and the Bureau of Land Management Instruction Memorandum NV-2010-014, Nevada Bureau of Land Management Rock Characterization Resources and Water Analysis Guidance for Mining Activities. The approach for a purpose-built characterization focuses on the following aspects: • Evaluation of tailings material geochemistry to provide a prediction of contact water chemistry that may change over time and would influence the design, operation, and closure of the TSF. • Define the geochemical properties of overburden materials that will be used as reclamation cover material including alluvium and saprolite. The results of the geochemical characterization test work provide a basis for the assessment of acid rock drainage and metal leaching(ARDML)potential and supports predictions of future contact water quality. In turn, these results have been used to inform decisions on engineering designs, mine planning, and waste rock and tailings management. J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 16 The program approach and results are detailed in the Kings Mountain Geochemical Characterization Work Plan (SRK, 2022) and the results of the program have been incorporated into the Baseline Geochemistry Characterization, Kings Mountain Report (SRK, 2024b). The geochemical characterization program is currently ongoing, and the information provided herein regarding geochemistry may change as additional data are received. 3.5.1 Geochemical Characterization As part of the program, samples representative of future mine waste materials have been collected from exploration drill core for geochemical characterization testing (SRK, 2022). The geochemical test methods implemented include both static and kinetic testing that are designed to address the bulk geochemical characteristics of the samples, and to assess the potential of waste rock and ore materials to generate acid or release metals into solution. "Static testing" is a general term describing those analytical methods applied to characterize acid generation and metal leaching characteristics of material at the time of testing and does not account for temporal changes that may occur in the material as chemical weathering proceeds. Static tests provide a balance of acid generating and acid consuming reactions at an end point and may be used to determine the potential magnitude of metals leaching from a given material. Static testing is distinguished from "kinetic tests", which evaluate the rate of sulfide oxidation and metal release over time. Static testing provides a conservative approximation of acid generation and trace metal release potential, which is used to determine whether more comprehensive kinetic testing is warranted. Materials that exhibit uncertain or highly variable geochemical behavior in the static tests may require further characterization using kinetic test methods to determine the rates and character of longer-term leaching. The geochemical test methods for the Project have been selected to determine the total acid generating or neutralizing potential of the samples and assess the concentration of constituents in leachates that could be derived from the material. Static and kinetic testing methodologies include the following: • Multi-element analysis using four-acid digestion followed by Inductively Coupled Plasma Mass Spectroscopy (ALS Chemex Method ME-MS61 m). • Measurements of paste pH. • Acid Base Accounting (ABA) using the modified Sobek method (Sobek et al., 1978) with sulfur speciation by hydrochloric acid or sodium carbonate (NaCO3). • Net Acid Generating (NAG)testing that reports the final NAG pH and final NAG value after a two-stage hydrogen peroxide (H2O2)digest (Miller et al., 1997). • Synthetic Precipitation Leaching Procedure (SPLP) testing (US EPA, 1994) and analysis of leachate. • Leaching Environmental Assessment Framework (LEAF) testing using the EPA 1313, 1314 and 1316 methodologies (US EPA, 2012a;b; US EPA, 2017a). • Mineralogical analysis, including optical microscopy, Scanning Electron Microscopy (SEM), X-Ray Diffraction (XRD), QEMSCAN and TIMA. The potential for material to generate acid is defined by the balance of acid generation potential (AGP) to acid neutralization potential (ANP). Determining if a material has a potential to generate J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 17 acid is typically done by looking at the ratio of ANP to AGP,which is referred to as the neutralization potential ratio (NPR), or the difference of ANP and AGP, which is referred to as the net neutralization potential (NNP). 3.5.2 Tailings Geochemistry Static testing was completed on samples representative of future tailings material and process waste streams to assess the balance of acid generating and acid neutralizing minerals for these materials (SRK, 2022). The ABA results indicate that overall, the sulfide sulfur content was low or below detection for the flotation tailings and DMS rejects. In comparison, the OSR and MSR samples have higher sulfide sulfur content than other waste streams and as such higher potential for acid generation, with some samples indicating a potential for net acid generation despite the generally low sulfide contents (<1%). Despite the presence of sulfides within the OSR and MSR material, these materials still show an overall low potential for acid generation. Based on the current HCT data, the two OSR HCTs have maintained neutral conditions throughout the test despite the ABA and NAG results that indicated these samples have a potential for acid generation. The two HCTs representative of flotation tails have also maintained neutral conditions as predicted by the static test data. Metal(loid)s chemistry shows enrichment is associated with the higher sulfide contents in the OSR, but overall concentrations are still relatively limited by comparison to crustal abundance. TSF porewater samples obtained from lysimeters installed in the historical TSFs are circum-neutral, which is consistent with the static and kinetic test program. Metals concentrations are also low in the porewater, with many parameters below analytical detection limits. The results showed concentrations of a few parameters that were higher in comparison to the leach test results of future tailings (e.g., copper and manganese). SRK has undertaken water quality predictions to assess future contact water quality associated with the Archdale TSF (SRK, 2024e). The base-case water quality predictions use a mass balanced approach, whereby the tailings, waste rock, and groundwater source terms are mixed in the proportions provided in the water balance to provide a mass balanced chemistry at the various water quality prediction points. This is considered a conservative approach, as mineral precipitation and trace element sorption processes (i.e., processes that may remove trace elements from solution) are not accounted for that will likely occur in nature. A sensitivity analysis has been undertaken to evaluate the effect of incorporating mineral equilibration and sorption on the resulting water chemistry. The results show that predicted water quality in the contact water pond and upper tributary of Dixon Branch (herein referred to as Archdale Creek) is circum-neutral (pH 6.7 to 7.4 s.u.), with all parameters predicted to be below North Carolina Surface Water Standards. Post-closure, the contact water pond will no longer be operational. Groundwater underlying the proposed TSF is also predicted to be circum-neutral (pH 6.7 to 7.3 s.u.), with the majority of parameters predicted to be below North Carolina Groundwater Quality Standards. The only exceptions are iron and manganese, which are elevated in existing (i.e., baseline) groundwater at Archdale. The results of the equilibration sensitivity analysis show that the equilibrated chemistry is similar to the mass balanced chemistry; however predicted concentrations of iron, manganese, aluminum J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 18 and antimony are slightly lower for the equilibrium chemistry sensitivity, reflecting the precipitation of ferrihydrite, alunite, MnHPO4 and SbO2, with the latter including additional sorption processes onto iron oxides. 3.5.3 Cover Material Characterization Static geochemical laboratory testing has been conducted on eight samples of alluvium/overburden and 10 samples of saprolite to assess the potential for acid generation and metal leaching from the future cover material (SRK, 2024e).A suite of static tests was completed on the samples, including ABA, NAG and multi-element analysis. These results have been supplemented with multi-element data from the Albemarle exploration database. The results can be summarized as follows: • Most of the alluvium and saprolite samples are characterized by low sulfur contents (<0.01 wt%) and are classified as non-PAG based ABA and NAG test results. • Paste pH of the 10 saprolite samples is circum-neutral (ranging between pH 5.2 and 7.9), with three samples that were less than pH 6.The paste pH results for the alluvium samples are similar to the saprolite samples. The alluvium and saprolite samples are typically characterized by lower paste pH values compared to the waste rock(core) samples from the geochemical characterization program. These lower pH values relate to the removal of primary neutralizing minerals by weathering processes, leaving behind iron and aluminum oxide minerals. SPLP testing was initiated on three samples of alluvium and three samples of saprolite to assess the leaching behavior of potential future cover materials. For the alluvium and saprolite samples, the leachate pH was neutral to alkaline (pH 5 to 8.3). For the majority of the alluvium and saprolite samples, element release was low or at the limit of detection under neutral conditions. One sample of alluvium has been included in the HCT program. This cell has exhibited slightly acidic conditions but overall low metal release. No parameters have been leached at concentrations that exceed the surface water or groundwater standards. The results of the characterization program indicate that there are no significant geochemical differences between the alluvium and saprolite material. Both the alluvium and saprolite material are considered suitable for use as cover material and can be used interchangeably for reclamation purposes 3.6 Soils Most of the soils within the Project area are classified as well drained, and none of the major components of soil map units (SMU)s are considered hydric soils. Two of the minor components of SMUs(the Chewacla soil series and the Dorian soil series)are classified as hydric. Hydric soils are soils that are saturated or inundated with water long enough to have a higher likelihood of supporting wetland conditions. Many of these soils have water table depths that allow the soil component to range from hydric to nonhydric depending on the location of the soil within the landscape as described in the map unit. Therefore, caution must be used when comparing the list of hydric components with soil survey maps. Soil profiles were remarkably similar regardless of SMU, geology, or slope position. The following horizons were generally present at Kings Mountain: JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 19 • A: Mineral soil with organic matter accumulation, loss of iron, aluminum, clay. This horizon was poorly developed across the Project area, being generally 1 to 2 inches thick. • B: Subsurface accumulation of clay, iron, aluminum, humus. This horizon was marked by the accumulation of organic matter and a blocky structure, and generally thin. • C: Little pedogenic alteration. In the case of Kings Mountain soils, this horizon is marked by greater clay components and the accumulation of iron oxides. • Cr: Weathered bedrock. In many locations, both the A and B horizons were generally thin and present as an A/B horizon, with dominantly A horizon characteristics but with some B horizon characteristics. The weathered bedrock (C horizon)was consistent regardless of the parent material, as these were mostly felsic (i.e., igneous rocks that are relatively rich in silicon, aluminum, calcium, and sodium that form feldspars and quartz) and weathered very similarly. Soil characteristics in relation to revegetation and reclamation are discussed in Section 4.9.1. 3.7 Groundwater The conceptual hydrogeological model for the site subdivides the groundwater system around the pit into two main components, namely, surficial deposits, and bedrock system. Surficial deposits are made up of a mix of overburden rock, saprolite, and weathered bedrock. These units have relatively higher hydraulic conductivities than the deeper bedrock. Groundwater inflow to the pit through the surficial deposits is believed to be substantial in the current condition and expected to be a major contributor during the initial stages of mining. However, their relative contribution to pit inflow and pore pressure is expected to decrease rapidly in time, as the surficial units become dewatered through pit excavation and in-pit sump dewatering. In contrast, the underlying bedrock groundwater system is expected to be the most important component in terms of pit inflow and pore pressure distribution during mining. This system is understood as bedrock units with low hydraulic conductivity and storage parameters decreasing with depth. The main flow pathways in this system occur through fracturing and weathering of the bedrock, which is more pronounced in the upper parts of the system,just underneath the surficial deposits. Saturated fracture networks and faults in the bedrock will be the main source of pit inflow and could control pore pressures through compartmentalization of different blocks, as discontinuities could act as either flow conduits or barriers at the local scale. Additional to these components, hydraulic testing in the area indicates that there are two major water-bearing corridors in the bedrock, at geological contacts east and west of the Kings Mountain pit. The contact between amphibole gneiss-schist and upper mica schist on the western side, as well as the contact between silica mica schist and schist-marble on the eastern side have been identified as major water-bearing features when intercepted by drillholes. Packer testing along these contacts also indicates higher hydraulic conductivities, even at depths approximately between 200 and 600 ft below ground surface. These corridors have been labeled as "Shear Contacts" in corresponding hydrogeological reports. Even though they are expected to affect the regional groundwater system, the current pit shells do not intercept these contacts at depth, and thus they are not anticipated to be a direct contributor to inflow or pore pressures distribution at the pit slopes. This, however, might change if pit shells are re-designed in the future. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 20 Groundwater inflow to the system occurs mainly through recharge from precipitation.As it reaches the surface, a fraction of the precipitation infiltrates the surficial deposits, and percolates through the different units until it recharges the groundwater system. In the bedrock system, this occurs mainly through fractures and the weathered areas among the intact rock. By regional and local estimates, the amount of groundwater recharge around the Kings Mountain pit area is expected to be between 10% and 20% of mean annual precipitation, depending on the local soil conditions and level of urbanization. The main groundwater outflow from the system occurs through regional flow and as discharge to the creeks and streams. In the area of pit lake, groundwater generally flows from the northwest to the southeast. Around the Kings Mountain and Martin Marietta pits, groundwater contours have been affected by historical mining, forming a concentric flow towards the excavations. In terms of the Kings Mountain pit, it currently holds a pit lake that has been increasing in lake elevation through the past decade (recorded), by direct precipitation and groundwater flow. The following sections describe current water levels and the flow regime around this pit in more detail (SRK, 2023a). 3.7.1 Groundwater Chemistry KM info is included as it provides good representative information for the general area and the TSF site specifics.A total of 96 groundwater samples(including two duplicates)were collected from the site during pumping tests and regular quarterly sampling events during May 2022 and June 2023 and were submitted to ACZ Laboratories in Steamboat Springs, Colorado. Typical quality assurance/quality control (QA/QC) checks were performed, including the following: • Calculation of cation-anion balances • Comparison of total versus dissolved measurements • Comparison of duplicate sample results • Evaluation of blank sample results The water quality data have been assessed against three different sets of water quality standards: • North Carolina Department of Environmental Quality Groundwater Standards • North Carolina Department of Environmental Quality Surface Water Quality Standards for Class C Waters Based on this assessment, groundwater within the Project area does not meet the North Carolina groundwater standards for iron and manganese, which exceed the standards in most of the wells. Other constituents that are elevated above groundwater standards for one or more wells include antimony(five wells), arsenic(six wells), lead (2 wells), nickel (1 well), sulfate(three wells)and zinc (2 wells). Manganese is also commonly elevated in groundwater above the most restrictive surface water standards. Other constituents that are elevated in groundwater above the Class C surface water standards in one or more wells include arsenic(two wells), cadmium(one well), copper(four wells), mercury (three wells), and zinc (three wells). Radioactive elements (gross alpha and gross beta, radon 222, radium 226/radium 228, and uranium) are detected in a few of the wells, but at low concentrations that are below the water quality standards. The only exceptions to this are gross alpha and gross beta concentrations for JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 21 seven wells (SNKM22-420, SNKM22-438, RTKM22-399, RTKM22-401, RTKM22-403 and RTKM22-412)that exceed the North Carolina groundwater standard. The highest gross alpha and gross beta concentrations are observed for KMMW-001, which are an order of magnitude higher than observed for the other wells with elevated gross alpha and gross beta concentrations.All other groundwater locations have gross alpha and beta, radium 226 and 228, and uranium below the water quality standards (SRK, 2023b). At Archdale, a total of 11 groundwater samples (including one duplicate and one field blank) were collected from Archdale site during the quarterly sampling event in December 2023. Monthly groundwater water quality monitoring has continued since this initial sampling. The groundwater in the Archdale area is mainly characterized by a neutral pH and sodium/potassium-bicarbonate type geochemical signature. Groundwater water quality data have been compared to groundwater standards. Based on this assessment, the groundwater within the Archdale area meets the water quality standards with the exception of iron and manganese that are above the groundwater standards in all nine wells. Lead was also slightly above the groundwater standard in one well (SNKM23-531A). The Dixon Branch water samples meet all groundwater water quality standards. Radioactive elements (gross alpha and gross beta, radium-226/radium-228, and uranium) were detected in most wells, but did not exceed North Carolina groundwater standards with the exception of well SNKM23-531A. This well had gross alpha levels elevated above groundwater standards. SNKM23-531A also contained the highest levels of gross beta, along with radium 226 and 228. This well also exhibited the highest amount of Total Suspended Solids (TSS). 3.8 Surface Water 3.8.1 Surface Flow Regime KM info is included as it provides good representative information for the general area and the TSF site specifics. The natural drainage network in the vicinity of the Project is heavily influenced by historical and active mining activities. The contributing watersheds to the Project area are roughly defined by Battleground Avenue to the north, Tin Mine Road to the west, Church Road to the south and east, and Cardio Hill, a legacy waste dump, to the northeast. The drainage network consists of two main drainages and several constructed water bodies, as shown in Figure 3-3. Kings Creek passes through the Project area from northeast to southwest but is intercepted by the Marin Marietta Quarry Pit (a.k.a., Kings Mountain Mica Company Lake) upstream of the Project area. Water intercepted by the Martin Marietta Quarry Pit is pumped out on a regular basis and discharged into Kings Creek. The pumping system was recently upgraded to 2,500 gpm capacity. As Kings Creek enters the Project area, it is routed under the current Albemarle Research Building in a 620 ft, 4 ft diameter corrugated metal pipe (CMP) culvert. Discharging from the culvert, King Creek flows to the southwest and joins with the discharge from the South Creek Reservoir before crossing under 1-85 in three, 7 ft wide x 10 ft high concrete box culverts. Flowing south, Kings Creek joins with the discharge from WSB-1 before flowing off the Project area to the southwest. J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 22 A pit lake is formed in the historical Kings Mountain Pit and does not discharge to the stream network. The current pit lake elevation is approximately 800 ft amsl and will need to rise at least 50 ft before discharging into Kings Creek. There are several small, man-made ponds in the Project area which generally contribute to the Kings Creek drainage system. The most notable of these ponds is Mill Pond #1, a legacy water management structure used by the existing industrial activities to manage stormwater runoff from the Project area. Mill Pond #1 collects water from the site and infrequently discharges through a culvert under the railroad spur into Kings Creek Reservoir. WSB-1 is formed by the historical South Legacy Tailings Impoundment south of 1-85. Post-mining, the embankment was breached down to elevation approximately 820 ft amsl, and the lake freely discharges over a rock spillway,joining with Kings Creek approximately 1,500 ft downstream of the lake. Urnnr Vau n A1i� { I \, wI Source: USGS 2023 and SRK 2023b Figure 3-3: Existing Streamflow Network The Archdale site sits immediately south of a surface water divide roughly defined by South Battleground Avenue. On the site, surface water drains south to Archdale Creek. Dixon Branch joins with Kings Creek approximately two miles south of the site in South Carolina (Figure 3-4). To the north of the site, surface water flows north into an unnamed tributary of Long Branch. The site is heavily influenced by the legacy mining activities of the former mica mine. Existing conditions result in local surface water collection in the open pits, which is pumped as part of operations to an upper pond (shallow open pits)where it is allowed to flow through a rock filter dam J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 23 before leaving the property and flowing south under 1-85 in a 60-inch-diameter concrete culvert. Additional culverts crossing under 1-85 are located at 500-to 800-ft intervals,with diameters ranging from 18 to 60 inches, discharging the drainage swale collecting runoff against the northern side of the highway or drainages bypassing the legacy pits. These culverts typically discharge 20 to 35 ft below the highway surface into Archdale Creek. 122)-- 124—c 11260— 12800cc 130— _ N • 2i6\ �\ 8 BAS r ��U��i•�+:::/f,•`r K Main White Plains u f t.o 1IIIiI I MeCurn L11111111111M� 0 y8 3760 ` ai(✓ /ir e Feet I Af 111 ! 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Surface water chemistry is being collected onsite and compiled into quarterly reports for review and analysis to determine background conditions. Surface water samples are collected quarterly from a number of facilities on the site and a few locations on the pit lake at varying depths. Each sampling event monitors field parameters and includes field blanks sent to the laboratory. Samples are submitted to either Waypoint Analytical or ACZ Laboratories in Steamboat Springs, Colorado, depending on analytical hold times. Typical QA/QC checks were performed, including the following: • Calculation of cation-anion balances. • Comparison of total versus dissolved measurements. • Comparison of duplicate sample results. • Evaluation of blank sample results. The water quality data have been assessed against three different sets of water quality standards: • North Carolina Department of Environmental Quality Groundwater Standards. • North Carolina Department of Environmental Quality Surface Water Quality Standards for Class C Waters. Preliminary results show that water quality is generally below Class C surface water quality standards with the following exceptions: • Residual chlorine for most surface water samples and pit lake samples. • Dissolved oxygen in several surface water and pit lake samples were below standard. • A few samples had pH outside of the standard range. At Archdale, six surface water samples(including one duplicate and one field blank)were collected during the quarterly sampling event in December 2023. Monthly surface water quality monitoring has continued since this initial sampling. In addition, surface water samples were collected from four locations in the Dixon Creek watershed located south of the TSF. Surface water and locations are shown in Figure 3-5: The groundwater in the Archdale area is mainly characterized by a neutral pH and sodium/potassium-bicarbonate type geochemical signature.Surface water samples at the Archdale site generally display a similar major ion geochemical signature and are characterized as sodium/potassium-bicarbonate type waters. Sample ADSW-3 shows slightly different major ion signature with mixed anions (i.e., bicarbonate/chloride). Surface water samples from Dixon Branch are characterized as calcium+sodium-potassium/bicarbonate type waters. Based on current assessment, the surface water within the Archdale area meets the Class C surface water quality standards with the exception of iron and manganese that are above the standards in all four surface water sample locations. The Dixon Branch water samples meet all Class C surface water quality standards. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 25 ADSW-1-2023.1211 r -' AUSW-2-24231 11 - ADSYY-4:�10231211 AD-+W-3-20231 11 . • UT-Dixon-20240118 40 id re US-Dixon-2D24D118 Confluence-2D24D118 RPM on-2D 4D118 SURFACE WATER SAMPLING LdCATIONS 2023 SurFace Water 0 300 600 900 1200 1500 Samples Property Boundaries Feet Dixoncreek Figure 3-5: Archdale Surface Water Sample Locations 3.9 Seismology The Central and Eastern United States (CEUS) is part of a broad mid-plate compressive stress province that also includes most of Canada. Over this large region, the stress field is orientated with a relatively uniform east-northeast direction of maximum horizontal compression. This compression direction corresponds well to the direction of absolute plate motion of the North American Plate, which suggests that a far-field tectonic source such as ridge-push or basal drag at the Mid-Atlantic Ridge may be the primary source of stress in the mid-plate region. This stress J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 26 regime, along with the structural features developed through the geologic history described above controls the occurrence and localization of seismicity in the region. Seismicity and consequent hazard in the CEUS is largely controlled by pre-existing zones of weakness that are favorably orientated in the modern stress field. Earthquakes in the region are rare but can be significant. The most significant earthquake near the site occurred in 1886 in Charleston, South Carolina, which was a 7.1 magnitude earthquake. More recently a M 5.1 event occurred in 2020 near Sparta, North Carolina. The New Madrid earthquake sequence of 1811-1812 in southeastern Missouri/northeastern Arkansas are also significant at long-period ground motions. This sequence, which was felt as far away as the East Coast, consisted of three principal events on 16 December 1811, 23 January 1812, and 7 February 1812 —referred to as NM1, NM2, and NM3. The magnitudes of the New Madrid earthquakes are highly uncertain but appear to range from M 7.0 to 7.6 (GeoVision, 2023). For a 2,475-year return period (2% exceedance probability in 50 years), the latest 2018 NSHMs indicate hard rock PGA and 1.0 sec SA of 0.118 and 0.068 g, respectively, for the site(Petersen et al., 2020). The site-specific hard rock PGA and 1.0 sec SA computed in this study are 0.088 g and 0.059 g for the 2,475-year return period. The differences 35% and 15%, respectively, and may be due to differences in GMMs and possibly in the characterization of the Charleston RLME. Which is not considered to be significant(Lettis, 2023). 3.10 Biodiversity The Project area lies within the Piedmont EPA Level III Ecoregion. This ecoregion consists of a transitional area between the mostly mountainous ecoregions of the Appalachians to the northwest and the relatively flat coastal plain to the southeast. Once largely cultivated, much of this region is planted pine or has reverted to successional pine and hardwood woodlands. The historical oak-hickory-pine forest was dominated by white oak, southern red oak, post oak, and hickory,with shortleaf pine, loblolly pine, and to the north and west, Virginia pine (SWCA, 2023a). The Project area is dominated by forested upland vegetation (69.3%), and 13.5% is disturbed/developed. Jurisdictional and non-jurisdictional wetlands and streams are present and detailed in the Wetland and Waterbody Delineation Report for the Albemarle Kings Mountain Lithium Mining Project, Cleveland County, North Carolina(ERM, 2022a). SWCA submitted both an Approved Jurisdictional Determination (AJD) and Preliminary Jurisdictional Determination (PJD) request to the US Army Corps of Engineers (USACE) in February 2023. This will determine the final wetland acreage and linear feet of streams that are jurisdictional. No federally listed species have been identified within the Project area. The northern long-eared bat was not detected during acoustic surveys, and the site is on the extreme southeastern edge of its range.Although suitable habitat is present,the dwarf-flowered heartleaf was not identified during presence/absence surveys.The potential monarch butterfly habitat within the Project area is mostly low quality, and there is very little milkweed present to support this species. Tricolored bat was detected throughout the Project area during acoustic surveys. This bat is not state or federally listed, but the US Fish and Wildlife Service (USFWS) has proposed listing this species as endangered under the Endangered Species Act(ESA). JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 27 Timber rattlesnake, American bittersweet, and smooth sunflower are state-listed species that have potential to occur based on suitable habitat. However, American bittersweet and smooth sunflower were not present during biological surveys. Surveys were not conducted for timber rattlesnake due to the lack of predictive survey areas within the Project area (e.g., rock outcrops)and the secretive nature of the species. However, numerous biological surveys were conducted throughout a diversity of habitats (e.g., forests, floodplains) in the Project area and no timber rattlesnakes were observed. All other state-listed species have a low or very low potential to occur, primarily due to lack of suitable habitat (SWCA, 2023b). 3.11 Natural Protected Areas Site redevelopment will impact the Gateway Trail system that was put into place in 2009. However, the features on this trail consist of mining components, such as a rock storage facility, and are therefore not considered natural protected areas. The Project is within close proximity to the Crowders Mountain State Park boundary to the south. Some visual impacts may be anticipated by visitors to the park during active operations; however after reclamation and closure, visual impacts will be minimized to the extent practical. Foote Trail currently traverses the KM Project area. Figure 3-6 shows a map of the Gateway Trail system. 3.12 Socioeconomic Setting The Project is located within the United States of America, in the State of North Carolina. Within North Carolina, there are 100 counties, each of which are governed by county commissioners that make up a county board. The Project is located in two different counties: Cleveland County and Gaston County, though the majority of the Project area is located in Cleveland County (Albemarle, 2023). Key informants were identified by ERM as part of baseline data collection and consisted of 23 community members from Kings Mountain and surrounding areas. The key informants were made up of residents, City Councilmembers, recreational representatives, business owners, School and Social Services Administrators and Chiefs, as well as other strategic development partners in the area. 3.12.1 Social Area of Influence A Social Area of Influence (SAoI) is established to facilitate the understanding of current socioeconomic conditions in the Project area, including conditions of the economy, local communities, social infrastructure, recreational activities, cultural heritage, and community health. The Project's SAoI is further divided into a Direct Social Area of Influence (Direct SAoI)' and an 1 The Direct SAoI encompasses the geographic area where the Project is located (in this case, the city of Kings Mountain and TSF), as well as those areas reasonably expected to experience primary impacts because of the Project. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 28 Indirect Social Area of Influence (Indirect SAol)2 to guide the understanding of baseline socioeconomic conditions in relationship to the Project (Figure 3-7). For this Project, the Direct SAol has been defined as the city of Kings Mountain, associated residential areas,3 and areas near the TSF (see purple polygon on Figure 3-4). This includes the mine and related facilities, which are located within the city of Kings Mountain. The Indirect SAol includes the cities of Shelby, Gastonia, and Bessemer City (Figure 3-7). The Direct SAol and Indirect SAol together encompass the full SAol. The definition of the SAol is based on the current understanding of the Project and the socioeconomic context of the area. The SAol may be refined or updated as more information on the Project becomes available. Data on Cleveland County and Gaston County have been included in this report where relevant for additional context. 2 The Indirect SAol encompasses areas that could experience secondary impacts from Project activities(for example, housing Project workers in nearby communities outside of Kings Mountain). 3 A small number of residential areas in the eastern portion of Kings Mountain fall within Gaston County, rather than Cleveland County. While these residential areas have a Kings Mountain address, they are technically not part of the city of Kings Mountain, nor Cleveland County, and are therefore not eligible to attend schools in Kings Mountain. However,for the purposes of this baseline,they are considered part of the Direct SAol, as they may still experience direct impacts because of the Project. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 29 rgi.a o CC\g^ oN odoE P-nicct Lonatian leigh N� QC - C.ps: M-1 mom * site tneaden 0 Direct Social Area of Influence(Direct SAo1) Lincoln C°un(y O Indired Social Area of Influence pndirect Gaston County Shl) C.-ty s—dary QSlake Boundary Q`N� Roads P�O' v� � —kolerslsle LP.Route NO Raule 0 --'�Shel.by '—ti ' O' Bessemer City, 1 � -CZ_ Kings Gastonia Mountain North Carolina 1 inch-2.5 mi when printed 11.17 l Souih Carolina Social Area of Influence Kings Mountain Lithium Mine Albemarle Kings Mountain Cleveland County. S\� Norlh Carolina \ Source: ERM,2023 Figure 3-6: Social Area of Influence J P/M W Archdale_Closure_Report_USPR000576_Rev04.dc cx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 30 3.12.2 Stakeholders Several stakeholder groups have been identified with the Project. Table 3-1 identifies these stakeholder groups. Table 3-1: Key Stakeholder Groups Stakeholder Role Employees and their dependents Employees working at the mine and their dependents. Suppliers to the Project and their Contractors/suppliers who supply the mine with good and employees services. This includes stakeholders that have been part of Albemarle's Shared value partners Benefit Sharing Projects, or who may have received funding or support from Albemarle during operations. Local, state, and federal Government officials and regulators in Kings Mountain and governments surrounding areas. Indigenous peoples who have lived on their ancestral lands in The Eastern Band of Cherokee this area of North Carolina. The Catawba Nation owns a casino Indians and the Catawba Nation adjacent to the mine, and the Project is located in the historical territory of the Cherokee. Residents of the City of Kings Residents in the surrounding community including immediate Mountain and surrounding areas neighbors of the mine,who will presumably continue to live in that locationpost-closure. This stakeholder group includes vulnerable people who may be Vulnerable groups more adversely affected by, or less able to adapt to the adverse impacts from the Project compared to other stakeholder groups. 3.12.3 Government Cleveland County has several citizens' boards and committees. Individuals can complete an application for selection by the commissioners. Members of the board and various committees serve to guide county decision-makers toward choices that reflect the voice of the county residents and promote resident wellbeing. Kings Mountain is governed by a Manager-Council form of government with a mayor, two At-Large Councilmembers, and a Ward-Elected Councilmember for each of its five wards. According to stakeholders, Ward One is a "majority minority ward," which was created in the 1960s to give a voice to minority populations in Kings Mountain. Ward One has expanded since the 1960s to include additional neighborhoods and communities. Much of the Project is located in Ward One and Ward Three, but it will also extend beyond city limits (Albemarle, 2023). 3.12.4 Demographics Population Kings Mountain, also referred to in this report as "the city", spans two counties. The eastern-most portion is in Gaston County, and the larger, western portion of the city is in Cleveland County (UNC Chapel Hill, 2022). The population of Kings Mountain was 11,409 in 2021, with a population density of approximately 830 people per square mile (U.S. Census Bureau, 2021). The population in Kings Mountain grew from 10,296 in 2010 to 11,409 in 2021, representing a 10.8 percent increase. In 2021, the total population in Cleveland County was 100,359, with a population density of 214.7 people per square mile. Both Cleveland and Gaston counties are located west of the Charlotte metropolitan area, and, according to the North Carolina Rural Center, Cleveland County is considered a rural county, while Gaston County JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan-Kings Mountain Page 31 is considered a regional city and suburban county (NC Rural Center, 2022). Population growth in the SAol is shown in Table 3-2. Table 3-2: Population Growth in the Social Area of Influence Percent Population Females Area 2010 20a Growth Density(People Males N Population Population Since 2010 per Square Mile (/O� Kings Mountain 10,296 11,409 10.8 830.4 46.1 53.9 Shelby 20,323 21,947 8.0 982.3 43.9 56.1 Gastonia 71,741 81,161 13.1 1,555.9 47.0 53.0 Bessemer City 5,340 5,507 3.1 1,038.9 54.8 54.2 Charlotte 731,424 879,709 20.3 2,836.9 48.0 52.0 Cleveland County 98,078 100,359 2.3 214.4 48.9 51.1 Gaston County 206,089 230,856 12.0 640.71 48.41 51.6 North Carolina 9,535,483 10,551,162 10.7 214.71 49.91 51.1 Source: U.S.Census Bureau,2021 In Kings Mountain, approximately 56.8 percent of the population is of working age, or between ages 16 and 64 (U.S. Census Bureau, 2021).Almost 30 percent of the population in Kings Mountain is over 60 years of age. Of the cities in the SAol, Bessemer City has the youngest median age of 35.3 years and a mode age between ages 25-29 (10.6 percent of the population). Race and Ethnicity Most residents in Kings Mountain identify as either White (65.2 percent) or Black/African American (27.3 percent). Approximately 3.7 percent of Kings Mountain residents identify as two or more races, 1.6 percent identify as Asian, and 2 percent as Hispanic/Latino. Within the full SAol, most residents identify as White, followed by Black/African American and Hispanic. Gastonia has the highest proportion of individuals who identify as Hispanic/Latino at 10 percent. The full breakdown is shown in Table 3-3 (below). Table 3-3: Racial Breakdown in the Social Area of Influence Race Kings Shelby Gastonia Bessemer Cleveland Gaston Mountain City County County White alone 65.2% 57.8% 55.6% 75.9% 71.8% 70.4% Black or African American alone 27.3% 31.7% 29.4% 12.4% 20.2% 16.9% American Indian and Alaska Native alone 0.0% 0.0% 0.1% 0.0% 0.1% 0.2% Asian alone 1.6% 0.9% 1.3% 0.0% 0.9% 1.7% Native Hawaiian and Other Pacific 0.0% 0.3% 0.0% 0.0% 0.1% 0.1% Islander alone Some other race alone 0.1% 0.0% 0.2% 0.2% 0.2% 0.2% Two or more races 3.7% 5.2% 3.3% 1.9% 2.8% 2.9% Hispanic or Latino 2.0% 4.2% 10.0%1 9.6%1 3.9% 7.7% Source: ERM,2021a In Kings Mountain, English is the most widely spoken language among residents ages 5 years and older (ERM, 2021a). Ninety-seven percent of the population in Kings Mountain speak English, while 1.6 percent speak Spanish, and 1.7 percent speak Asian and Pacific languages. Within the SAol, JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 32 English is also the most widely spoken language; however, both Bessemer City and Gastonia have sizable Spanish speaking populations at 8.8 percent and 8.3 percent, respectively. 3.12.5 Education Within Kings Mountain, there are four elementary schools, one intermediate school (fifth and sixth grade), one middle school, and one high school. During the 2020-2021 school year, Kings Mountain High School was ranked first in Cleveland County high schools and Kings Mountain High School is ranked 145/686 for all North Carolina high schools (U.S. News, 2023). Approximately 42 percent of the students enrolled in Kings Mountain High School are economically disadvantaged (ERM, 2022b). There are two community colleges within the SAol: Gaston College and Cleveland Community College. Cleveland Community College is tightly aligned with workforce development and invests in vocational programs including manufacturing trades, industrial systems, mechanical drafting, plumbing, information technology(IT), and electric systems(ERM,2018).The College recently opened a new Advanced Technology Center which includes 45,000 square feet of space, high-bay training spaces, and a crane for industry training (ERM, 2021 b). Gardner-Webb is the closest four-year college to Kings Mountain, less than 20 miles west of the city (ERM, 2022c). 3.12.6 Economy and Industry According to stakeholders, the economy in Kings Mountain stalled after the loss of the textile manufacturing industry during the implementation of the North American Free Trade Agreement (NAFTA) in 1994, as manufacturers began to relocate their factories to Mexico in the mid-1990s (ERM, 2022d). This resulted in the loss of an entire sector of jobs within Kings Mountain, and stakeholders reported that family members who lost factory jobs had difficulty being re-skilled for other lines of work. However, businesses and other industries are starting to return to the area, including Utz, Coca-Cola, and Walmart. In Kings Mountain, 59.2 percent of the population ages 16 years and older are in the labor force, compared to 62.4 percent statewide in North Carolina (ERM, 2021 a). Within the SAol, labor force participation is lower in Shelby(55.9 percent)and Cleveland County(56.7 percent), but higher in Gastonia(64.3 percent), Bessemer City(60.5 percent)and Gaston County(62.4 percent). Over 31 percent of Kings Mountain residents are employed in production, transportation, and material moving occupations (U.S. Census Bureau, 2021d). In both Cleveland and Gaston counties, most residents are employed in management, business, science, and arts occupations. The largest industries in Kings Mountain are manufacturing (24 percent), educational services and health care and social assistance (18 percent), and retail trade. 3.12.7 Employment and Household Income The median household income in Kings Mountain is $42,336 (ERM, 2021a). The median household income in Gastonia is the highest out of all the towns in the Project's SAol at $52,990, though this is still lower when compared to the Gaston County median income ($56,819) and the state median income($60,516).The mean household income in Kings Mountain is$56,360, substantially lower than the Gaston County median of$75,999 and the state's median of$84,888. The unemployment rate in Cleveland County (7.1 percent) is higher than both North Carolina (5.3 percent) and the national average (5.3 percent). The percentage of people whose income from JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 33 2020 to 2021 is below the poverty level in Cleveland County is 14.6 percent, higher than the state average of 12.9 percent. Cleveland County's average per capita income of$24,505 is lower than the North Carolina income per capita average of$34,209; however, Gaston County's average per capita income of $30,607 is more closely aligned with the state average. The Cleveland County median household income at $45,646 is also lower than the North Carolina ($60,516) and U.S. averages ($64,994) (ERM, 2021a). There are stark differences in per capita income by race in the SAol. On average, individuals who live in Kings Mountain and identify as White have a per capita income of$25,074, nearly 80 percent higher than individuals who identify as Black or African American, with a per capita income of$14,010 (U.S. Census Bureau, 2020). In Shelby, individuals who are White have a per capita income of $31,677, 1.5 times more than individuals who are Black or African American, with a per capita income of $12,963. Individuals who live in Kings Mountain and identify as"some other race" have the lowest per capita income at $11,743, followed by individuals in Shelby who identify as Asian at $11,896 (ERM, 2021a). 3.12.8 Economic Vulnerability Kings Mountain and Shelby have the highest poverty rates in the SAol,at 20.7 percent and 19 percent, respectively(ERM, 2021a). Kings Mountain also has the highest unemployment rate in the SAol at 8.1 percent, followed by Bessemer City at 6.4 percent. The poverty rate and unemployment rate for Cleveland County is 14.6 percent and 7.1 percent, respectively. In Cleveland County, the poverty rate of all people is 18 percent, and 17.2 percent of households are receiving Food Stamps or Supplemental Nutrition Assistance Program(SNAP)benefits.Within the SAol,the percentage of individuals receiving Food Stamps or SNAP benefits ranges from 19.5 percent in Bessemer City to 22.9 percent in Kings Mountain (ERM, 2021a). Over 47 percent of children in Kings Mountain are in single parent families, and 11.4 percent of people are uninsured. According to stakeholders, two of the most common barriers to employment are transportation and childcare (ERM, 2022). There are no public transit options in the SAol, and many individuals lack reliable transportation to get to work, particularly if they do not own cars. Community members told ERM that childcare is insufficient both at the regional level and within the city of Kings Mountain. These barriers with transportation and childcare force many parents to stay home and take care of children rather than having the opportunity to join the workforce (ERM, 2022). 3.12.9 Environmental Justice and Vulnerable Communities ERM identified potential communities with Environmental Justice(EJ)concerns,or communities which may disproportionately feel impacts from Albemarle's operations. According to the USEPA, EJ is the "fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies" (USEPA, 2013). In 2021, approximately 13.3 percent of households in North Carolina were in poverty (ERM, 2021 a). In Kings Mountain, 21.1 percent of households were below the poverty level in 2021, a higher proportion than those below the poverty level statewide in North Carolina (ERM, 2021a). Most individuals in Kings Mountain identify as White alone (65.2 percent), followed by those who identify as Black of African American (27.3 percent)and two or more races(3.7 percent).The unemployment rate J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan-Kings Mountain Page 34 in Kings Mountain in 2020 was 8.1 percent, higher than the Cleveland County rate of 7.1 percent(U.S. Census Bureau, 2021 da. Most of the census block groups (CBGs) surrounding the Project are potential EJ communities because of the prevalence of low-income populations. Most of these low-income communities identify as white, low-income, minority populations, and linguistically isolated homes in the EJ Study Area. Potential Communities with EJ Concerns ERM identified potential communities with EJ concerns using the USEPA EJScreen Tool, the NCDEQ Community Mapping tool, and the U.S. Census Bureau. The following CBGs were identified as potential communities with EJ concerns as shown in Table 3-4 (below). Table 3-4: Potential EJ Communities in the EJA Study Area (USEPA and NCDEQ) Census Block Group(CBG) Total Minority Percent Below Poverty Linguistically Isolated CT 9504 BG 1 45.7% 12.4% 1.5% CT 9504 BG 2 38.1% 25.5% 0.0% CT 9504 BG 3 14.3% 29.7% 0.5% CT 9504 BG 4 21.7% 20.3% 0.0% CT 9504 BG 6 47.8% 2.7% 1.4% CT 9505 BG 1 53.9% 15.4% 0.0% CT 9505 BG 3 27.0% 38.0% 0.0% CT 9506.01 BG 1 27.6% 18.4% 4.2% CT 9506.01 BG 2 39.4% 14.5% 0.0% CT 9506.01 BG 3 19.6% 38.1% 0.0% CT 9506.04 BG 1 5.4% 30.9% 0.6% CT 316 BG 2 41.4% 10.4% 0.0% CT 317.05 BG 2 23.2% 15.2% 0.0% CT 317.06 BG 1 37.5% 15.8% 0.0% Source: ERM,2021a, U.S.Census Bureau,2021a Note: Percentages indicative of potential EJ concerns are highlighted in gray These CBGs have been identified as potential communities with EJ concerns, but should not be considered "EJ Communities." The communities highlighted in this section provide a starting point for further discussion on potential vulnerable communities and will be discussed at later stages of the Project. 3.12.10 Community Health and Safety Health data in North Carolina is available at the state and county levels. This section relies on health data from the following public health sources: • North Carolina Department of Health and Human Services (DHHS) • Cleveland County Public Health Department • County Health Rankings and Roadmaps Where baseline data were not available at the community level, data at the county level were used to determine health indicators within the SAol. The data are used to understand health status in the SAol at the most local level possible. To understand the health rankings of each county, health outcomes' ' Health outcomes are calculated based on data about the length of life and quality of life. Source: https://www.countyhealthrankings.org/sites/default/files/media/document/CHR2022 NC O.pdf JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 35 are calculated using data on quality of life and length of life. Health factors2 are calculated considering data on health behaviors and physical environment. Cleveland County falls in the 0 to 25th percentile for health outcomes and ranks in the lower-middle range of counties for health factors, scoring in the 25th to 50th percentile (ERM, 2022b). Conversely, Gaston County ranks in the higher-middle range of counties in North Carolina for health outcomes, falling between the 50th and 75th percentile. For health factors, Gaston County is ranked in the lower- middle range of counties, falling between the 25th and 50th percentile (ERM, 2022b) Cleveland and Gaston County both have a higher percentage of the population who experience poor or fair health (23 percent and 21 percent, respectively) than the state average (18 percent for North Carolina) (ERM, 2022b) Cleveland County and Gaston County have fewer healthcare professionals and hospital beds per person than the state of North Carolina. When compared to state-level data, Cleveland County has higher rates of diseases of the heart (260.2 vs. 181.9 per 100,000), cancer of all types (252 vs. 191.6 per 100,000), and chronic lower respiratory diseases (84.6 vs. 52.1 per 100,000). The leading causes of death in Cleveland County include diseases of the heart, cancer (all types), chronic lower respiratory diseases, and cerebrovascular disease (ERM, 2022b), Emergency Services Currently, the fire department responds to approximately four to five calls per day, with calls ranging from minor to serious events (ERM, 2022a). According to stakeholders, the Kings Mountain Fire Department has a good relationship with both Shelby and Gastonia Fire Departments, both of which will respond to Kings Mountain, if needed.There is a general lack of infrastructure and overall capacity in terms of fire response for Kings Mountain, as key informants said they did not believe the fire department would be able to adequately respond to an increase in emergencies (ERM, 2022a). 3.12.11 Social Infrastructure Housing Market In recent years, Kings Mountain has experienced a growth in population as the Charlotte metro area continues to expand further west toward Cleveland County. Kings Mountain has proposed plans for new subdivisions that are currently undergoing an approval process. The City Council established a Housing Committee to evaluate housing inventory to address the growing demand. One development goal identified by the city is to continue to diversify housing options. Currently, all apartments in Kings Mountain are either Section 8 or tax credit housing. For this reason, the Housing Committee will also consider Fair Housing Act concerns, minimum housing standards, and code enforcement to meet the city's housing goals (ERM, 2022c). Like the housing market at the national level, housing prices in Kings Mountain have increased dramatically in 2021 and 2022. 2 Health factors are calculated taking using weighted averages of health behaviors(30 percent), clinical care (20 percent),social and economic factors (40 percent)and physical environment(10 percent). Source: https://www.countyhealthrankings.org/sites/default/files/media/document/CHR2022 NC O.pdf JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 36 Transportation Airports Air service to North Carolina is provided by three international airports: Charlotte/Douglas International Airport (CLT), Raleigh-Durham International Airport (RDU), and Piedmont Triad International Airport (GSO). Road Networks Kings Mountain aims to create a City Transportation Plan that is aligned with the city's overall strategic plan and economic development plan. The City Transportation Plan would include development of pedestrian and biking transportation and connectivity with trails and downtown. The Plan is to be developed over a 3-to-5-year period and would pull from nearby Morganton and Burke County's pilot bus transportation program as a best practice (City of Kings Mountain, 2018). During fieldwork, ERM found that the exit off 1-85 into Kings Mountain (towards town) presented a complex intersection, with a high volume of traffic and multiple types of vehicles, including heavy construction vehicles (ERM, 2022a). In addition, the exit off Highway 74 into town presented some complexities, such as left turns into fast-moving traffic (ERM, 2022a). 3.12.12 Cultural Heritage Project Based Archaeological Survey Information Albemarle completed a National Historic Preservation Act (NHPA) compliant phase I archaeological and geoarchaeological survey for the Project area in consultation with the North Carolina State Historic Preservation Office(SHPO).The survey was conducted between June 6 and August 22, 2022(SWCA, 2023).A total of 24 archaeological sites were recorded; however,only two sites on the eastern property (31 CL180 and 31 CL185)were determined to be potentially eligible for inclusion on the NRHP. SWCA has recommended avoidance of these site locations from subsurface disturbance, but if they cannot be avoided, the sites will require further study to determine their potential cultural value. In addition, some floodplain areas could possibly have deeply buried archaeological sites. If those areas are disturbed, additional testing is recommended. The North Carolina SHPO issued full concurrence on SWCA's report. Historic Places and Cemeteries Cleveland County has 22 historical landmarks listed on the NRHP, some of which are located in or near the SAol. Some landmarks are listed because of architectural and engineering significance,while others are areas where an important event took place and are used today for educational purposes (Cleveland County North Carolina, 2018). J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 37 4 Design Basis 4.1 Legal Requirements The Project site will be subject to mining regulations in accordance with the North Carolina Mining Act of 1971 —G.S. 74, Article 7 and NCAC Title 15A, Chapter 5: Mining: Mineral Resources. 4.2 Closure Objectives Overall objectives that have informed the closure strategy include: • Ensure legal and other obligations are met. • Manage reputational impacts. • Relinquish a safe and secure site where remaining infrastructure is chemically and physically stable. • Implement closure actions that minimize impact on remaining mineral resources. • Protect and preserve remaining environment, including limiting impact on community water sources. • Implement socioeconomic transitioning measures to assist community sustainability and future development. 4.3 Future Use Upon closure of the Project, the site would be available for further mining activities or recreational use. The post-closure land use(s) has yet to be fully determined. 4.3.1 Further Mining Activities The current mine life is anticipated for 8.3 years.At the end of mine life,there may be additional mineral resources which could lead to future mining activities in the Project area. 4.4 Design Standards 4.4.1 Global Industry Standard on Tailings Management The Global Industry Standard on Tailings Management (GISTM) strives to achieve the ultimate goal of zero harm to people and the environment with zero tolerance for human fatality. It requires operators to take responsibility and prioritize the safety of tailings facilities, through all phases of a facility's lifecycle, including closure and post-closure. It also requires the disclosure of relevant information to support public accountability. GISTM provides a framework for safe tailings facility management while affording operators flexibility as to how best to achieve this goal. For auditing and certification purposes, the standard includes the Preamble, the Requirements, the Glossary, and Annexes. Unless otherwise specified, the Requirements of the Standard are directed to the operator. The Requirements apply to individual facilities and are all intended to apply and be auditable. Conformance with the standard does not displace the requirements of any specific national, state, and/or local governmental statutes, laws, regulations, ordinances, or other government directives. Operators are expected to conform with the Requirements of the Standard not in conflict with other provisions of law. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 38 4.4.2 Canadian Dam Association The Canadian Dam Association (CDA) established a set of design Guidelines specifically for mining dams (CDA, 2014). This guide establishes the design earthquake to be considered according to the consequences of dam failure and the stage of the project(construction, operation, closure, or passive care). Since the criterion is developed according to the consequences of failure on society and the environment, it can be generalized to waste rock storage facilities and slopes. 4.5 Environmental Considerations Affecting Closure 4.5.1 Spatial Constraints The Project is spatially limited due to other development and property ownership in the surrounding areas. This presents some challenges for operational development, planning for closure reclamation slopes, and storage of reclamation materials. 4.5.2 Land Use Currently,the extreme growth of the city poses a problem from a housing perspective; as of 2019, only 10.9% of people who worked in Kings Mountain also lived there. Due to the urbanization of the city and housing shortage, the land adjacent to Kings Mountain in Cleveland County is in high demand to meet the housing needs (Albemarle, 2023). 4.5.3 Tailings Geochemistry Based on geochemical characterization and modeling work, SRK determined that groundwater underlying the proposed TSF is also predicted to be circum-neutral (pH 6.7 to 7.3), with the majority of parameters predicted to be below North Carolina Groundwater Quality Standards. The only exceptions are iron and manganese, which are elevated in existing (i.e., baseline) groundwater at Archdale (SRK, 2024e). 4.5.4 Growth Regime The climate of the region, as well as soil characteristics, have a positive impact on vegetative growth in the Project area, as evidenced by self-sustaining volunteer revegetation in previously disturbed areas from former operations. Revegetation of the site will be achievable with available materials,with few exceptions, such as alluvial and wetland materials (SWCA, 2023a). 4.5.5 Water Treatment No water treatment will be required after closure for the Archdale TSF. 4.5.6 Water Balance The model simulates climate using values based on legacy climate records from the nearby long-term climate station of Shelby 2 NW (NOAA, 2023). The climate record was infilled with values from the Daymet gridded climate dataset (NASA, 2023) and was used to develop deterministic climate scenarios that include constructed time series for climate forcing. The data set was also used to develop a synthetic climate generator based on the WGEN climate model (Richardson, 1984). This model produces stochastic daily climate time series that allow the model to perform probabilistic J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 39 modeling simulations using the Monte Carlo simulation approach. The model includes climate change predictions. The model simulates runoff, evaporation, direct precipitation, infiltration, seepage, moisture uptake in the waste rock, and consumption in processes to estimate gains and losses to the system. Water is transferred between facilities and stored in the ponds, reservoirs and lakes to simulate the management of water in the Project and predict the excess or shortfall of water for the Project. Model simulations, both forced (synthetic series designed to stress the system)and probabilistic,were performed to examine the model response to climate variability and mining activities. The simulations indicate that the overall water balance of the Project is strongly positive, generating excess water from pit dewatering activities,waste rock seepage,waste rock runoff, and undiverted run-on to the facilities. 4.5.7 Wetlands Aquatic resource delineation at Archdale was performed by SWCA in 2023 (SWCA, 2024). SWCA determined that the following are the extent of wetland resources at Archdale: • Palustrine scrub-shrub (PSS): 7.63 acres • Palustrine unconsolidated bottom (PUB): 9.42 acres SWCA has recommended that all these wetlands are considered non-jurisdictional but have not received a Jurisdictional Determination from the USACE yet. 4.5.8 Climate The Project site can receive between 40 to 70 inches of rain on an annual basis. This precipitation is relatively evenly distributed throughout the year but occurs with the greatest intensity during the summer growing season in the form of thunderstorms. Hurricanes can cause periods of intense rainfall throughout the fall and winter. Average annual temperatures vary within a relatively narrow range for a temperate climate, between 540 and 650 Fahrenheit per year. An average of 230 frost-free days can be expected per year, ranging between 185 and 275 days in any particular year. North-south latitude is the primary determinant of climate in this region and the secondary determinant is elevation (SCWA, 2023a). 4.5.9 Climate Change A climate change analysis was performed for the site (AWA, 2022) based on the AR6 climate change projections(IPCC, 2023)and incorporates the National Aeronautics and Space Administration (NASA) Earth Exchange Global Daily Downscaled Projections(NEX-GDDP)data set(NCEP 2023), to provide site-specific climate change projections. Median climate change predictions were incorporated for both the reasonable expected Shared Socioeconomic Pathway(SSP)4.5 as well as the more conservative SSP8.5. The projections indicate that while the precipitation frequency is largely variable due to modeling projections, overall, the median of the 26 models used for the Kings Mountain basin show an increase in mean annual temperature and mean annual precipitation. These results indicate that, most likely, the region will likely become warmer and wetter as a result of climate change; however, the study predicts that this will not be reflected in the more extreme rainfall events that control PMP depths. J P/M W Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 40 4.6 Engineering Considerations Affecting Closure 4.6.1 Design Storm Event for Closure All operational channels were designed to safely convey the peak flow from the 100-year, 24-hour storm event from the maximum area that will contribute to them. Any channels that will remain after closure will be reconfigured to safely convey a PMP storm event. 4.6.2 Surface Water Diversions The conceptual surface water management drainage plan during operations consists of a number of non-contact water channels designed to divert run-on to the site around and through the Project area to sediment ponds around the site before discharging (SRK, 2024f). Contact water channels are designed to intercept runoff from the active facilities and route contact water flows into the contact water management infrastructure. At closure, all facilities will be covered with growth media and revegetated. Therefore, all runoff from the facilities will become non-contact water. Most of the surface water diversions will be removed and sediment ponds will be breached or removed. Any remaining channels will be reconfigured to safely convey a PMP storm event. 4.6.3 Geotechnical Stability Based on the preliminary design reports for the TSF (SRK, 2024e), these facilities are geotechnically stable, as designed. Because each of these facilities was designed and the stability analyzed at their final overall slope angles, this applies to post-closure conditions as well. 4.7 Socioeconomic Considerations Affecting Closure 4.7.1 Stakeholders Impacted by Closure Stakeholders will be affected by closure in differing ways, depending on their relationship to the mine. A brief description of stakeholders that will be impacted by closure is provided below. Albemarle will continue to add to, update, and refine this stakeholder list throughout the lifecycle of the Project. Employees and their dependents: Employees working at the mine will be directly affected by closure, as most contracts will be terminated when mining activity declines and ultimately ceases. Their dependents may also be impacted by the closure. Cessation in pay and benefits may cause a greater level of unemployment in the area, or cause workers to move from the area in search of other employment opportunities. Suppliers to the Project and their employees: Contractors/suppliers will lose their contracts as mining operations cease. This may cause an economic downturn in the area, since there would be a reduction in demand for local goods and services,which will impact local and regional businesses and employees. Shared value partners: Groups or stakeholders who may have received funding or support from Albemarle during operations will receive a reduction or cessation of funding may occur as a result of mine closure. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 41 Local, State and Federal Governments: Government officials and regulators are integral to closure planning and may assume certain responsibilities post-closure, as agreed during closure planning. This may cause an additional burden on government resources. During development of the socioeconomic transitioning strategy, the capacity of the government to support future use of the site during post-closure would be evaluated. The Eastern Band of Cherokee Indians and the Catawba Nation: Indigenous peoples will be impacted by closure of the mine which may result in decreased traffic to the Casino, as contractors and employees leave the area. Residents of Kings Mountain and surrounding areas: Residents in the surrounding community will be affected by closure in positive and/or negative ways. Impacts may include changes to resources, visual impacts, and loss of jobs or economic benefits to the community post-closure. Redevelopment of portions of the Gateway Trail system during closure will provide ongoing recreational opportunities for the community and allow continuation and expansion of the currently successful trail system. Vulnerable groups: Vulnerable people may be more adversely affected by closure, or less able to adapt to the adverse impacts from closure compared to other stakeholder groups. These groups may be adversely affected economically from loss of jobs, benefits, or access to community services. 4.7.2 Macroeconomic and Socioeconomic Impact of Closure Albemarle is in the preliminary phase of assessing macro and socioeconomic impacts from the Project and closure. There will be positive and negative direct and indirect impacts associated with closure. Albemarle is working with stakeholders to optimize positive impacts, explore partnerships to develop employment opportunities and community investment programs, and identify appropriate mitigation strategies for negative impacts. 4.7.3 Kings Mountain Community Planning Future use planning for the Project site could influence the future uses selected for the site and will be considered during development of the socioeconomic transitioning plan. Figure 4-1 shows pattern of uses anticipated and/or desired in the years ahead, and the character contexts in which uses occur as defined in the City of Kings Mountain Comprehensive Plan 2040.3 The plan indicates the use that is expected to predominate in areas where land is currently undeveloped or, in previously developed areas, based on what is already on the ground and will likely remain or possibly evolve. Transitions in use could occur through redevelopment of previously built sites, "infill" construction on a vacant parcel amid existing built sites or repurposing of an existing structure for another use without significant site changes. 3 https://www.cityofkm.com/617/Comprehensive-Plan-2040 JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 42 KM Land Use With Parcels May 24, 2022 (Iteration 5) Legend city❑init� ®Catawba Indian Nation - - MET] W Parcel outline _ Iteration 5 'Autrurban{Au) o Recreatanal Community rI "' IRu al(Rd) o5em urban u i MSuburban(;R) o hu< q � a11 ll the,ralues> Figure 4-1: Land Use Map (City of Kings Mountain) The City of Kings Mountain Land Use Map (Figure 4-1) is a graphical representation of the policies and goals in this plan. These designations and their placement are specifically designed to promote the ideals of character found in each district(ERM, 2022c). 4.7.4 Attractive Nuisances During closure and post-closure, there is the potential that conditions on the mine may attract trespassers who do not understand risks associated with accessing the areas where there are perceived attractive conditions. Attractive nuisance conditions may include the following at the Kings Mountain Project. • Recreational users seeking to use the pit lake for swimming and/or fishing. • Trespassers perceiving that there is economic value in the various residue deposits and damaging covers to access the remaining minerals. In situations where pit lakes exist, the attractiveness of these kinds of areas may result in large numbers of trespassers on the mining site. While preventing access in a context such as exists at the mine is not feasible, measures will be required to at least make access difficult and limit inadvertent access, such as fencing and berms. While having limited effectiveness, these measures can be supplemented with education programs to inform the communities of the dangers of accessing mining areas. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 43 4.8 Closure Assumptions and Design Criteria This closure strategy has been developed based on preliminary available information including environmental data. A number of assumptions were made about general conditions, and closure and rehabilitation of the facilities at the mine to develop the proposed closure actions. As additional information is collected, these assumptions will be reviewed and revised as appropriate. 4.8.1 Design Criteria Assumed design criteria for closure stormwater management are preliminary and may include the following: • PMP design storm for critical infrastructure (SRK calculated a 6-hr PMP storm depth of 28.5 inches for the site using site-specific analysis (AWA, 2022). • Erosion of closure stormwater controls will be minimized through placement of protective liners (i.e., riprap),where appropriate. • Sediment remobilized during establishment of vegetation will be managed through sediment ponds, rock check dams, and other management practices. 4.9 Closure Materials Various cover materials are required during the closure process. This includes: • Growth medium which in this context is the final layer of materials placed onto a facility during reclamation or closure and refers to the material that will provide a growth medium for the vegetation established. • Cover material which refers to the material placed onto a facility to act as a lower permeability layer as distinct from soil which acts as clay layer. 4.9.1 Available Materials Soil properties are consistent across the property regardless of SMU, geology, topography, and land use. Of the soil forming processes, climate appears to have the greatest influence, leaching nutrients and base cations (i.e., calcium, magnesium, potassium, sodium) out of the A/B horizons and accumulating in the C horizon. As such, all soils across the Project area, including those identified as either fill or mine waste, can be generally handled similarly for reclamation. This is made evident by good regrowth and revegetation on mine waste associated with the former operations, indicating that revegetation at the Project area will be achievable with the available soil medium and plant growth material. The areas to be avoided for salvaging include areas identified as alluvial or delineated as wetland. The materials on-site can be divided into the following units for the purpose of reclamation: • The A/B horizon, despite having a poorly defined A horizon, still maintains decent nutrient value and can be salvaged as plant growth medium for reclamation. • The C horizon is strongly acid from a soils perspective and would require amendments such as lime and/or organic matter if it were to be used as plant growth medium. Additionally, the presence of iron oxides will likely bind nutrients such as phosphorus and may require additional fertilization for successful plant growth. The clay loam texture of this horizon may make it suitable as cover material during reclamation. Further geotechnical analysis is required to assess the value of this horizon as cover material. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 44 • The weathered bedrock (horizon Cr) has generally low soil fertility, although phosphorus and potassium values are acceptable likely from the weathering of minerals that contain these elements. Fine grained micas were common in these materials and a likely source of potassium. Apatite mineral is the likely source of phosphorus, although none was observed during sampling. This material is suitable for general fill material (SWCA, 2023a). The A and B horizons form a combined A/B horizon with dominantly A horizon characteristics and generally thin, with some thicker areas locally. The C horizon was fairly consistent regardless of the underlying bedrock. All of the horizons are slightly acidic, with pH values from 5.4 to 6.5 s.u. The A/B horizon, although poorly defined with a broad range of pH, has decent nutrient value. It should function as a suitable plant growth medium but will be difficult to salvage independently with the large mechanical equipment available for soil salvage. The C horizon is at the lower end of the pH range and may require amendments such as lime and/or organic matter if used alone as a growth media. Also, iron oxides could complex with nutrients such as phosphorus. However, the clay loam texture should make it a suitable cover material for reclamation. 4.9.2 Material Salvage The A/B and a portion of the C horizons will be salvaged and stockpiled during construction for future use in reclamation. Because salvage will be performed using larger earthmoving equipment such as scrapers, one foot is the minimum layer thickness that can be reliably salvaged. Therefore,the top one foot of material will be removed and stockpiled separately. This material will comprise the A/B horizon and a variable amount of the C horizon. At least two additional feet of C horizon will be removed from beneath the major facilities and other areas where additional excavation is required for geotechnical stability purposes. Because space for reclamation material storage is limited at the site, the stockpiles may be thicker than optimal and require amendments when used during closure. The need for and types and quantity of plant growth amendments will be assessed during progressive closure of some facilities. However, given the pervasive voluntary revegetation present on historic mine facilities at the site, only minimum, if any, amendments may be required. At Archdale, during construction of the TSF, some of the mica stockpile will be placed in the growth media stockpile at Archdale and the rest will be removed from the site. This stockpile will contain the required growth media volume of material required for closure of the TSF.The underlying"cover"layer comprising C-horizon material will be sourced from one of Albemarle's other nearby properties. Growth media and cover stockpiles will be reseeded temporarily during operations to stabilize them and enhance the nutrient content.There will be two growth media stockpiles for the project,one located near the northwest corner of the pit at KM and one west of the TSF NPI at Archdale. However, some growth media may be stockpiled in segregates portions of the OSFs at KM. Cover material (C-horizon) material will be stockpiled in the OSFs and sourced from them during closure. 4.9.3 Materials Balance There is an appropriate amount of suitable material available for growth media at the site. There are approximately 0.91VI cubic yards(cy)of growth media and minimum of 0.35M cy of saprolite(C-horizon) JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan-Kings Mountain Page 45 material available for reclamation material.Additional saprolite material may also be excavated during construction. These quantities are adequate for currently estimated growth media and cover requirements for closure. Sufficient rock can be acquired from RSF-A at KM for all riprap needs during closure. The quantities estimated for reclamation are listed in Table 4-1. Table 4-1: Reclamation Quantities Approximate Growth Approximate Cover Growth Media Cover Required for Riprap for Description Media Salvage Salvage Required for Closure Closure Channels C C C C C RSF-A 115,000 172,500 125,000 125,000 15,100 RSF-X 103,199 154,799 110,000 110,000 OSF-1 23,499 24,474 OSF-2 54,851 56,205 OSF-3 10,138 10,677 Growth Media Stockpile 9,261 9,261 TSF(incl.mica stockpile) 663,000 280,000 14,400 WSB-1 14,100 21,150 Roads 92,000 92,000 Yards 15,000 15,000 Building Areas 225,000 225,000 Diversion Ditches - - Ponds 3,0001 3,0001 - TOTALS 895,299 348,449 950,617 235,000 29,500 4.10 Revegetation Test Program Observations of the current site conditions demonstrate that the area will not be difficult to revegetate at closure. Following historic mining operations at the site, no planned reclamation occurred. Despite this lack of intentional reclamation, nearly every area disturbed by the previous operation has revegetated without human intervention (Figure 4-2). Therefore, the ability of Albemarle to revegetate the site is not in question. Instead, reclamation of the site will focus on accelerating the process and better managing the types of vegetation and ecosystems to be consistent with the final uses of the site. This is likely to require varied vegetation across the site. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 46 4 k. r I, i y F �"fF j t Figure 4-2: Volunteer Revegetation at Archdale 4.10.1 Progressive Closure Albemarle will use the opportunity to progressively close some portions of the site during operations to test the effectiveness of the proposed methods and types of closure activities, specifically cover and growth media, surface water management, and revegetation performance. By performing progressive closure on areas no longer needed for operations,the proposed closure methods can be tested at field scale. Temporary revegetation of the closure material stockpiles will also provide information on the proposed revegetation approach. One area upon which progressive closure could occur is the embankment of the TSF, albeit only in the last years of operation. Depending on availability of equipment and staff, progressive closure would occur on this area during operations. If monitoring of the progressive closure indicates alternatives to JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 47 currently proposed methods are required, those approaches could be tested and modifications to the plan made, as needed. 4.11 Worker Health and Safety The closure health and safety hazards are likely to be similar to those encountered during operations. Typical hazards associated with mining operations, such as heavy vehicle traffic, highwall, falls, electrical, chemical, air quality, and water hazards, will also exist during the closure and post-closure periods because many of the same activities will continue after operations. During closure, some additional hazards from closure-specific activities will be present. These include material handling hazards associated with demolition activities, such as suspended overhead loads, and movement of processing chemicals and hazardous wastes. The presence of a pit lake will represent additional water bodies that will require monitoring and access restriction. The operational health and safety program may require modification to identify these hazards and train remaining site staff accordingly. During the post-closure period, the types of activities that represent health and safety hazards will be similar to some of those present during operations. These include ongoing rockfall hazards in the pits or falling on slopes on waste rock for anyone accessing these after closure. 4.12 Relinquishment Mine closure is the result of all activities required to attain site relinquishment/surrender. This includes reclamation, closure, and decommissioning works.A completed mine has progressed to a state where mining lease ownership can be relinquished, and responsibility accepted by the next land user. Final relinquishment will depend on all stakeholders being comfortable that rehabilitation will not fail at some time after mine closure and that rehabilitation performance is aligned to the agreed criteria across the entire Project area. In order to demonstrate to authorities and other stakeholders that the closure objectives have been achieved, and the mine has undertaken closure actions satisfactorily, relinquishment criteria are developed. Relinquishment criteria are a combination of specifications, measurements, or other requirements,which are used to assess whether the closure activities have been successful in meeting the closure objective. During the development of the closure plan for the mine, once further studies have been completed, data gaps filled and detailed engineering undertaken, it will be necessary for Albemarle to develop a suite of relinquishment criteria that can be used to demonstrate the success of the closure actions. Typical items included in relinquishment criteria include: • Surface Water& Groundwater • Stormwater Controls • Air Quality • Soil Quality • Land Productivity • Erosion • Slope Stability • Vegetation JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 48 5 Closure Strategy The closure strategy involves implementation of management strategies to bring the site to the agreed upon post-mining land use and established closure goals. Financial planning and provisioning will be provided at a later stage as mine planning progresses, but financial assurance mechanisms for closure will be in place throughout the entirety of the mine closure phase. 5.1 Revegetation In accordance with the North Carolina Application for a Mining Permit, the reclamation plan must include plans for year-round seeding, including the time of seeding and the amount of seed, type of seed, fertilizer, lime, and mulch per acre. The recommendations must include general seeding instructions for both permanent and temporary revegetation. Selection of any tree species is recommended to be similar to existing tree species occurring on the Project area or adjacent to the Project area. The proposed revegetation plan including seeding methods, species, and any amendments in described in the Recommended Revegetation Plan (SWCA, 2024a) and provided by in Appendix A. Any amendment recommendations will consider the previous success of volunteer regrowth observed on the site. Seed would be procured from Ernst Conservation Seeding or other approved seeding contractor. Wildlife habitat is typically established by creating ecosystems of native species, and reshaping landscapes to create suitable habitat. Monitoring and measurement criteria for vegetation and wildlife success will be developed as mine plans progress. 5.2 Stormwater Management At closure, all surface water will be directed toward original flow paths to the degree possible (). Because all stormwater from surface facilities will be non-contact water after cover and/or growth media has been placed on all disturbed areas, and revegetated surfaces should generate minimal sediment, all of the sediment ponds constructed for operations will be breached or removed during closure. All culverts installed during construction or operations will be removed at closure and fill above the culverts will be removed and/or regraded to allow unimpeded flow toward original water courses. Where practicable, surface grading will be performed to direct flows to natural water courses without engineered channels. Remaining channels will be modified to allow them to safety pass a PMP storm event. Coarse riprap will be placed along channels where high velocities could result in erosion. The final surface of the tailings in the TSF will be deposited, with minimal regrading, to create a mounded surface that sheds water after closure (Figure 5-1). At closure stormwater from the TSF will be managed in the diversion channels constructed at the toe of the embankment and reconfigured at closure to safely convey a PMP storm event. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 49 LEGMD N,.,............... . — r 4 - - _- ._ T11 Figure 5-1: Archdale TSF Post-Closure Stormwater Flows 5.3 Archdale Tailings Storage Facility The Archdale TSF embankment will be constructed with downstream raises at a final slope of 2.5H:1 V (Figure 5-2). The last raise will be constructed during the fifth year of operations. Sao ��Iuinngl -- ---- -~- -r --- -- I T - I . ❑ rr ` I I A \� `\` P,Cal,ry louN6M1Y sEEPEWUE�o., N t G , _— - s,N ,vENr �„sro„�NON�roas��P, sau�Y � �°E:S,�N��Ew�NNNlN. FINAL TSF GRACING PLAN Figure 5-2: Archdale TSF (end of operations) JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 50 5.3.1 TSF Because the tailings in the TSF will be dry stacked, the final surface of the facility will be created during deposition (Figure 5-2), and no significant regrading of the tailings surface is expected. Both the tailings surface and the embankment will be covered with two feet of growth material, probably originating from the stockpile of material currently located on the north side of the area that will be removed during construction (Figure 5-3). This stockpile has been naturally revegetated without any intentional revegetation efforts and should function as an acceptable growth medium. 1150 1150 1100 - 1100 S OCKPI TO BE REMOVED 2Fr.O GRO H MED - 1050 ___ 1050 LL i EL.991.' F NAL TS SURFA E Z 1000 J SEEPAGE 1000 / NTERCEPTION 950 _ __ -/ DRAIN 950 w 900 __ 900 1 __ __ "' 850 p�ERIMETER ACCESS ROAD AND STARTER EMBANKMENT ` 850 800 EXISTI 800 0+00 1+00 2+00 3+00 4+00 5+00 6+00 7+00 6+00 9+00 10+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 19+00 20+00 21+00 STATION(FT.) Figure 5-3: Archdale TSF Section C The final TSF embankment slope will have an overall slope of 2.5H:1 V with slope breaks approximately every 30 vertical feet (Figure 5-4).These slope breaks are designed to reduce erosion from surface flows while vegetation is established (). 2 FT.THK CLOSURE COVER LAYER (1 FT.OF GROWTH MEDIA OVER 1 FT.OF COVER MATERIAL) 2 TYPICAL CLOSURE COVER 100 2,5 16 FT. 30 FT. GLOBAL SLOPE OF TSF REGRADED (BEFORE CLOSURE COVER LAYER) SLOPE(TYP.) 2 r RUNOFF INTERCEPTION BENCH(TYP.) 1 CLOSURE REGRADING DETAIL SCALE: 1"=40' Figure 5-4: Typical Section TSF Embankment Regrading The surface of the tailings and the embankment will be seeded with an approved seed mix. Tree seedlings will be planted on the tailings surface, but no trees will be planted on the embankment in accordance with state dam safety regulations. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 51 5.3.2 TSF Drainage and Surface Water Management The channel along the toe of the embankment will be widened to accommodate a PMP storm event (Figure 5-5). Riprap will be placed in the channel where flows or velocities could result in erosion of the channel such as the northwest corner of the channel where velocity and the change of direction could result in erosion of the channel. 2 FT.THK.RIPRAP LAYER WITH 12-IN. DIA.D50,(PLACED AS SHOWN BY HATCHING IN PLAN VIEW) POST-CLOSURE TSFCLOSURE ROAD COVER CLOSURE RIPPED SURFACE WITH _ PERIMETER 1 FT.GROWTH MEDIA CHANNEL rL ______ 5 FT. y� 15'MIN. 2.5 -...................... 1 ==_=_= PERIMETER ROAD 5 T OCK FILL EXISTING GROUND \ f� CLOSURE PERIMETER CHANNEL SECTION (TYP.) 3 SCALE: 1"=20' Figure 5-5: TSF Closure Perimeter Channel The beehive drop inlet and the four culverts (Figure 5-6) will be removed and replaced with a Swale that allows vehicular access after closure. The adjacent sediment pond will be breached to allow surface water to flow to the culvert that conveys water under 1-85 (Figure 5-7). JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 52 LIGHT VEHICLE AC S ROAD 60 SUMP DRAIN 18"0 CULVER 00• 29 % 337.5' 8 \O I I I I 3 BEEHIVE 500 DROP INLET SEEPAGE INTERCEPTION DRAIN 500 CONTACT WATER EMERGENCY 30"0 CULVERT F II I I 300 SEEPAGE —�; GE COLLECTION TANK --- a1e aT :1Ej', T1,G CULVERT l I SEDIMENN INS ---�-- ° i --- PMP EMERILL 25 STORAGE AND ABLE TO PASS PMP SPILLWAY ING PLAN — _--- so'mExisTINGCUL r7;2777�----------------- Figure 5-6: TSF Stormwater and Seepage Collection Detail Plan (Operations) PROPERTY BOUNDARY o 2.5:1 HEADNlALL 0 -�- f1 %IN CONTACTWATER ND /R"—�—/ WlSWALECUT MATERI-------- ------------ , a I I I I I I I I I I i I I I I ; I I' ----------- -------------� r —seD mEN — ——— �— EXISTING CULVERT EXISTING CULVERT -- P�NTSI'IE2��-- - so 0 EXISTING CULVERT Figure 5-7: TSF Stormwater and Seepage Collection Detail Plan (Closure) The seepage collection tank that collects shallow groundwater from the seepage interception drain during operations will be removed at closure(Figure 5-6). 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. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 53 The perimeter road will be narrowed to 15 feet by ripping the outer portion of the road. The reclaimed portion of the road will be covered with one foot of growth media (Figure 5-5). 5.3.3 TSF Non-process Infrastructure The Archdale NPI area, at the southwest corner of the TSF area, contains the contact water pond, truck shop,truck parking,office, and various support buildings and laydown areas needed for operation of the TSF (Figure 2-3). This area will be completely reclaimed during closure and all buildings and structures will be removed. As closure approaches, inventories of any materials used in the area will be managed to minimize quantities at closure. Any remaining consumables will be sold or returned to suppliers. All equipment will be removed from the buildings for resale or recycling. Buried pipelines will be capped and left in place. Power transmission infrastructure will be removed. Buildings will be demolished. and any recyclable materials removed from site. Concrete foundations and floor slabs will be broken and placed in the contact water transfer pond void or removed from site to a licensed landfill. The soils under buildings and all disturbed areas will be inspected to identify any areas where oils or liquids may have seeped into the ground. Any areas where impacted soils are found will be sampled and tested. As needed, any impact soils will be excavated and removed to an appropriate disposal facility. Any compacted areas will be ripped. Once the covers have been placed on the TSF and revegetated, and the stormwater channels have been reconfigured for closure, the contact water pond will no longer be needed and will be reclaimed. The pond liner will be removed. The pond void will be backfilled, and the culverts located east and west of the contact water transfer pond will be removed, along with the fill above the culverts, to re- establish the original surface water flow paths toward 1-85 (Figure 5-7). Removed fill may be used to fill the pond void or used to regrade the surface of the area to convey water to original flow paths. The surface of the entire Archdale NPI area will be regraded to convey surface flows toward culverts under 1-85. One foot of growth media will be placed and the area revegetated using an approved seed mix. Some tree seedlings will be planted. 5.4 Power Lines and Power Distribution Power lines and distribution systems may be required to supply energy to structures remaining to support post-closure land use. However, for purposes of this strategy, any temporary infrastructure that was installed to support operations will be decommissioned and demolished. This infrastructure will be among the last items decommissioned, with decommissioning occurring once there is no need for energy on site. Some power infrastructure will remain permanently as part of the larger City of Kings Mountain electrical utilities supply. 5.5 Roads All roads that are not needed for post-closure access for monitoring and maintenance, or potential future use, will be removed during closure. All roads that will remain after closure will be narrowed to 15 feet, which should allow access by small trucks or bulldozers. Figure 5-1 shows the roads that will be removed, and those that will remain, after closure. Roads to be removed will be regraded or ripped and, depending on the substrate material, one foot of growth media will be placed. Remaining roads will be narrowed by ripping the excess road width. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 54 All culverts conveying water under roads will be removed, and road fill material removed and/or regraded down to the original water courses. Culverts in roads that will remain will be replaced with a swale to allow vehicles to cross the water course. Reclaimed road segments will be reseeded with an approved seed mix and some areas will be planted with tree seedlings. The timing of road abandonment during closure activities will be determined based on access requirements during closure, and the schedule of other closure activities adjacent to the roads. 5.6 Ponds After closure cover is placed, all collection and sediment ponds will be breached and discharges conveyed to the drainage as shown on Figure 5-1. 5.7 Yard Areas Yards and laydown areas are generally flat areas used to store materials or the pad areas remaining after buildings are removed. These flat areas will require a minimal amount of grading to blend them into the surrounding topography. After regrading to direct water generally into original water courses, the areas will be covered with one foot of growth media and reseeded according to the revegetation plan. 5.8 Industrial and Hazardous Waste Industrial and Hazardous waste will be identified in accordance with RCRA and applicable waste regulations and disposed of off-site at an approved third-party facility. 5.9 Fencing Fencing will be removed and 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. 5.10 Well Abandonment Water supply wells will remain for future use at closure.Any monitor wells not needed for post-closure monitoring will be closed in accordance with state regulations (15A NCAC 02C.0113). The wells will be permanently abandoned by filling portions of the holes in bedrock with cuttings or gravel ending 10 feet below the top of the bedrock and then grouted to the surface. Any holes constructed in unconsolidated material or broken bedrock will be permanently abandoned by filling the entire length with grout. All holes will have a minimum five-foot top plug of cement-type grout. 5.11 Progressive Closure Progressive closure is reclamation activities that take place during operations to accelerate closure of facilities for which closure can begin during operation or are no longer needed for the current operation. Observations of the current site conditions demonstrate that the area will not be difficult to revegetate at closure. Following historic mining operations at the site, no planned reclamation occurred at the site. Despite this lack of intentional reclamation, nearly every area disturbed by the previous operation has JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 55 revegetated without human intervention. Therefore, the ability of Albemarle to revegetate the site is not in question. Instead, reclamation of the site will focus on accelerating the process and better managing the types of vegetation and ecosystems to be consistent with the final uses of the site. This is likely to require varied vegetation across the site. To test the effectiveness of the proposed methods and types of closure activities, specifically cover and growth media, surface water management, and revegetation performance. By performing progressive closure on areas no longer needed for operations, the proposed closure methods can be tested at field scale. Temporary revegetation of the closure material stockpiles will also provide information on the proposed revegetation approach. One area on which progressive closure could occur is the embankment of the TSF, albeit only in the last years of operation. Depending on resource availability, progressive closure would occur on this area during operation. If monitoring of the progressive closure indicates alternatives to currently proposed methods, those approaches could be tested and modifications to the plan made as needed. 5.12 Temporary Closure In the event of temporary closure, the site will be placed into care and maintenance in accordance with a temporary closure plan prepared to preserve the assets at the site while maintaining compliance with all legal obligations. The content of any temporary closure plan depends on the objective of the plan. If temporary closure is contemplated primarily in response to depressed commodity prices, then the closure period is likely to be longer than if the objective is to shut down for a short time to optimize an operation, implement productivity improvements, address legal or license issues, or provide a basis for re-evaluating contracts and resourcing requirements. As future price movements cannot be predicted with certainty, temporary closure planning due to reduced commodity prices must take into account the uncertain (i.e., indefinite)period for closure. The overarching objective of the closure plan is to preserve the future value of the asset for all stakeholders. The difference between the long-term and mid-term plans is that the mid-term plans utilize a strategy that assumes that prices will recover reasonably quickly (i.e., within a year or two). However, as mentioned above, commodity price movements cannot be accurately predicted with any certainty. Therefore, even with the mid-term closure scenario, it is prudent to plan for the possibility that prices do not quickly recover and that long-term closure may eventually be the best option going forward. While some temporary closure actions may be similar to life-of-mine (LOM)closure actions, others will be different based on the objective of maintaining the mine operation in a state suitable for resumptions of operations at a later date. 5.13 Unplanned Closure If the operation is closed prior to the currently planned closure date, some of the actions included in this plan may require modification appropriate to the conditions that exist at the time of closure. These modifications would be documented in a final closure plan prepared at that time. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 56 5.14 Post-Closure Management Plan The post-closure management plan will be developed at a later date, but typically include post-closure monitoring activities and vegetation monitoring and maintenance activities. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 57 6 Socioeconomic Transitioning In March 2023, Albemarle began community engagement regarding planning for socioeconomic transitioning at closure with a series of four initial workshops with key stakeholders to develop a vision for the future of the site. Albemarle conducted two workshops with community members (March and June 2023), one with employees (May 2023), and with Kings Mountain High School students (May 2023). These meetings were designed to obtain stakeholder input to the closure planning process to ensure that the closure plan would be consistent with potential future uses. Continued engagement will occur throughout the mine life cycle, as the mine plan evolves and additional information is gathered. 6.1 Post-Closure Visioning The post-closure visioning meetings were conducted as facilitated brainstorming sessions designed to encourage open dialog and ensure that the opinions of all those present were represented in the meeting. The specific topics included: possible desirable future uses, repurposing opportunities, types of undesirable future uses, and criteria to include or exclude future uses. A number of different ideas for future uses of the site, or portions of the site,were introduced by various stakeholders and discussed by the group. Common themes in these uses were: • Areas for unorganized recreation (e.g., trails, natural areas) • Organized recreation areas (e.g., ball fields) • Access to the pit lake for a water recreation area • Possible commercial use of the plant area • Outdoor event space • Potential use of some buildings for community (e.g., youth) programs • Accessibility for all the public Large-scale industrial,warehousing, and commercial development were the only future uses that were generally deemed unfavorable, but deemed acceptable in portions of the site, provided that they did not conflict with surrounding land uses or the post-closure vision. 6.2 Socioeconomic Transitioning Actions At this time, Albemarle plans to implement the following actions related to socioeconomic transitioning for the site after closure as part of this plan: 1) Albemarle will continue to engage with the community and key stakeholders on issues relating to post-closure vision for the site and socioeconomic transitioning with the intent of developing a comprehensive socioeconomic transitioning plan for the site during operations. 2) Develop a detailed post-closure land use plan in consultation with stakeholders to ensure that the final closure activities on the site are consistent with those land uses. This would include a land use viability assessment that defines criteria for inclusion and/or exclusion of possible future uses with the intent of developing a comprehensive plan that meets legal requirements and considers input from stakeholders. 3) Albemarle continues to participate in planning discussions with the Gateway Trail Board of Directors, the City of Kings Mountain, and Cleveland County to develop a plan for a new section JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 58 of the Gateway Trail that aligns with the city's Master Plan for parks and recreation facilities, and stays committed to both preserve and enhance recreation opportunities for our community. Albemarle will continue to support engagement with the local community to gain input and ensure the best vision for the future of the trail can be realized. Currently, there is no timetable for the trail to be affected by potential mining operations at the Kings Mountain site, and the trail will continue to remain open to the public across Albemarle's property. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 59 7 Closure Monitoring The objective of the closure and post-closure monitoring program will be to track the recovery of the site toward the long-term post-closure land use goals, in accordance with the overall closure objectives. The monitoring program will be designed to collect information to demonstrate that the closure criteria have been achieved, revegetation and restoration objectives are met, and the site is stable. The strategy is to adopt monitoring requirements for specific environmental aspects and adapt these for closure.These activities will then be implemented through the closure and post-closure period. The monitoring that is typically required during the closure and post-closure period is summarized below: • Surface Water—Quality monitoring of surface water to detect any changes to baseline water quality conditions, for a period that meets regulatory requirements. • Groundwater — Quality monitoring of both the shallow and deep aquifers. Aquifer recovery also typically monitored via collection of water samples to detect any changes to baseline water quality conditions, for a time that meets regulatory requirements. • Air Quality—Air quality monitoring is typically limited to the period in which significant dust is potentially generated. Once these areas have been closed, the air quality network will be decreased or totally removed. • Reclamation Performance Monitoring — reclamation performance monitoring consists of comparing the reclaimed areas to analogue sites where vegetation performance and soil chemical and physical properties are measured. • Biological Monitoring of aquatic and terrestrial resources in accordance with local requirements. Annual reports will be prepared to document the results of the monitoring during the closure and post- closure phases. These reports will provide important information required to manage the on-going closure activities, with the data and reports being used to: • Provide recommendations for improving subsequent reclamation activities. • Indicate where reclamation and closure activities have not been successful, requiring a potential change in design criteria/ • Provide information where care and maintenance are required during the post-closure period. • Indicate if relinquishment criteria have been achieved. During closure, a phased approach in the reduction of monitoring frequency and locations typically occurs. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 60 8 Preliminary Mine Closure Schedule Some mine closure activities can occur concurrently as the mine operations allow. However, the availability of those areas for closure will depend on the mining schedule and availability of equipment and staff resources. Areas that could be closed concurrently include the embankment of the Archdale TSF could be ready for closure as early as Year 6 of operations. Figure 8-1 shows a schedule of closure activities by at Archdale in the context of the current overall schedule. Facility Year Operations/Progressive Year 9 Year 10 Year 11 Year 12 Year 13 Year 14 Year 15 Year 16 Year 17 Year 18 Year 19 Year 20 Archdale TSF begin in Year 6 Roads Yards Infrastructure Buildings Ponds Well Abandonment Waste Disposal Monitoring and Maintenance Figure 8-1: Preliminary Closure Schedule The majority of closure actions would be implemented once mining ceases in Year 9, but some post- closure monitoring and maintenance activities would continue for another 10 years. As monitoring demonstrates that the closure goals are met, monitoring requirements should decrease, and groundwater wells can be progressively abandoned. Maintenance activities could include overseeding areas where vegetation has not performed to expectations or covers have experience localize erosion. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 61 9 References Albemarle, (2023). Socioeconomic Baseline. Environmental Review and Permitting Support Document. Kings Mountain Project. May 2023. Albemarle, (2023a). Phase 1 Base Case Infill PAG Mine Plan. Kings Mountain Project. September 11, 2023. Version 02.2. Applied Weather Associates (AWA), (2022). Site-Specific Probable Maximum Precipitation Study for Kings Mountain Mining Operations, North Carolina, Applied Weather Associates, September 2021, KM60-EN-RP-9431. BC Mine Waste Rock Pile Research Committee, (1991). Guidelines for Mine Waste Dump and Stockpile Design. ERM, (1981) Horton and Butler, 1981 ERM, (2004) Garrett, 2004 ERM, (2005) Ebensperger et al., 2005 ERM, (2018) Cleveland County North Carolina, 2018 ERM (2021a) U.S. Census Bureau, 2021 ERM (2021 b)The Star, 2021 ERM, (2022) ERM, (2022a) NC Rural Center, 2022 ERM, (2022b) County Health Rankings & Roadmaps, 2022 ERM, (2022c) City of Kings Mountain, 2022 ERM (2022d) UNC Chapel Hill, 2022 ERM (2024a) SWCA, (2024). Recommended Revegetation Plan, (In preparation). GeoVision, (2023). Seismic Investigation Kings Mountain Mine. Kings Mountain, North Carolina. Prepared for SRK Consulting. Prepared By GEOVision Geophysical Services. Corona, California. January 2023. INAP. (2014) GARD Guide Global Acid Rock Drainage Guide. Mine Water and the Environment. Lettis, (2023). Development of Site-Specific Seismic Design Ground Motions for the Kings Mountain Mine Development, North Carolina. Prepared by Lettis Consultants International. Concord, California. 24 April 2023. MEND, (2009). Prediction Manual for Drainage Chemistry from Sulphidic Geologic Materials. December 01, 2009. NASA, (2023). Daymet: Daily Surface Weather Data on a 10km Grid for North America, Version 4 R1 from their website at https://doi.org/l0.3334/ORBLDAAC/2129 NOAA. (2023). NOAA Atlas 14 Point Precipitation Frequency Estimates: North Carolina. National Weather Service, 2023. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Page 62 Richardson, C.W., (1984).WGEN : a model for generating daily weather variables. [Washington, D.C.] U.S. Dept. of Agriculture, Agricultural Research Service. SRK, (2022). Kings Mountain Geochemical Characterization Work Plan. Prepared for Albemarle U.S., by U.S., by SRK Consulting (U.S.), Denver, Colorado. SRK, (2023a). Conceptual Report Closure Plan Kings Mountain Mining Project, prepared for Albemarle Corporation, by SRK Consulting (U.S.) Inc., September 15, 2023. SRK, (2023b). Pit Stability and Modeling Kings Mountain Mining Project North Carolina, USA. prepared for Albemarle U.S., by SRK Consulting (U.S.),Inc. Michael Bierwagen, Fei Wang, Denver, Colorado, April 2023. SRK, (2024a). Select Phase Preliminary Engineering Design Report for Water Storage Basin 1 Kings Mountain Mining Project, prepared for Albemarle Corporation, by SRK Consulting (U.S.) Inc., SRK, (2024b). Technical Report 2022 Prefeasibility Study Baseline Geochemical Characterization Kings Mountain Mining Project, prepared for Albemarle Corporation, by SRK Consulting (U.S.) Inc., February 19, 2024. SRK, (2024c). Technical Report 2022 Prefeasibility Study, Geochemistry Water Quality Predictions Kings Mountain Mining Project, prepared for Albemarle Corporation, by SRK Consulting (U.S.) Inc., April 15, 2024. SRK, (2024d). Technical Report Select Phase Rock Storage Facilities A and X Preliminary Engineering Design Report Kings Mountain Mining Project, prepared for Albemarle Corporation, by SRK Consulting (U.S.) Inc., April 3, 2024. SRK, (2024e). SRK, (2024). Archdale Filtered Tailings Storage Facility DRAFT Select Phase Preliminary Engineering Design Report Kings Mountain Mining Project, prepared for Albemarle Corporation, by SRK Consulting (U.S.) Inc., March 29, 2024. SRK, (2024f). Archdale Storm Water Management Report Kings Mountain Mining Project North Carolina, prepared for Albemarle Corporation, by SRK Consulting (U.S.) Inc., April 15, 2024. SWCA, (2023a). Baseline Soil Sampling and Analysis for the Albemarle Kings Mountain Lithium Mining Project Cleveland County, North Carolina, prepared for Albemarle U.S., by SWCA Environmental Consultants, Kelley House, Andrew Harley Broomfield, Colorado, April 2023. SWCA, (2023b). Biological Resources Summary Report for the Kings Mountain Lithium Mine, Cleveland County, North Carolina Interim Draft, prepared for Albemarle U.S., by SWCA Environmental Consultants, Colorado, April 2023. SWCA (2024). Wetland and Waterbody Delineation Report for the Kings Mountain Archdale Tract, Cleveland County, North Carolina, prepared for Albemarle U.S., Inc. by SWCA Environmental Consultants, January 2024. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Appendices Appendices JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Appendices Appendix A: Recommended Revegetation Plan Appendix A was not available at the time of this report's finalization. JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 c� A 113 Edinburgh South Drive SWC Suite 120 Cary,North Carolina 27511 Tel 919.292.2200 ENVIRONMENTAL CONSULTANTS www.swca.com 2136 Sound Science.Creative Solutions MEMO April 19, 2024 To: Jeff Parshley, SRK-Via Emailjparshley@srk.com Jeff Osborn, SRK-Via Emailjosbom@srk.com From: Steve Adams, SWCA RE: Recommended Revegetation Planting Plan The following provides our recommendation for revegetation of disturbed areas at the Kings Mountain Lithium Mine which includes both the Kings Mountain Tract and Archdale Tract. The purpose of the revegetation plan recommendations is to provide soil stability and vegetative cover for all disturbed areas after final grading has been completed. Those areas that have not been disturbed are to remain in their natural vegetated state. • Seed Bed Preparation 1. Loose rocks, roots, and other obstructions shall be removed from surface for seedbed preparation. 2. Areas to be seeded will be ripped and available growth media (topsoil or equivalent)will be uniformly spread. 3. If soil test taken, apply fertilizer and lime per soils report. 4. If no soil test taken, provide fertilizer and lime per seeding recommendations (Recommendation: Lime-2000 Ibs/acre, Fertilizer-1000lbs/acre of 8-8-8 or 10-10-10). 5. Lime and fertilizer shall be applied uniformly and mixed with soil during seedbed preparation. • Seed Specifications Seed Type Mix Seeding Dates Seeding Rates NC Steep Slope Mix (ERN MX-310) All Dates 20lbs/acre Native Habitat Strip Mine Mix (ERNMX-111) All Dates 20lbs/acre Native Steep Slope w/annual rye (ERNMX-181-1) Feb 15-Aug 15 60lbs/acre Native Steep Slope w/grain rye (ERNMX-181-2) Aug 15-Feb 15 75lbs/acre • Mulch 1.2000 Ibs/acre small grain straw. 2. Mulch to be tacked or mechanically tied down within two (2) days after mulch spread. SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Appendices Appendix B: Technical Memorandum: Conceptual Closure Surface Water Management Plan for Kings Mountain TSF JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 SIR srk consulting 999 Suite Consulting ,Inc. 999 17th Street,Suite 400 Denver,CO 80202 T:+1 303 985 1333 F:+1 303 985 9947 denver@srk.com www.srk.com Technical Memorandum To: Claudio Andrade and Morgan Warren, Date: April 17, 2024 Albemarle Corporation Company: Albemarle Corporation From: Gary Hurban, David Hoekstra, Jeff Parshley Copy to: Jeff Osborn, SRK Reviewed by: N/A Subject: Conceptual Closure Surface Water Project#: USPR000576 Management Plan for Kings Mountain TSF Albemarle TBD Revision#: 01 Document Number: 1. Introduction SRK Consulting U.S. Inc(SRK)has prepared this memo for Albemarle Corporation (Albemarle)to document the closure surface water management plan for the Tailings Storage (TSF), as part of the Kings Mountain Pre- feasibility Study (Project), located in Clevleland County, North Carolina. The objective of this assessment is to identify conceptual level designs and/or stormwater management measures to mitigate the potential for erosion from the TSF slopes in mine closure. Following cessation of original mining activity in the 1950s, reclamation, regrading and revegetation were not performed on the original TSF and rock storage facilities. The benched configurations of these facilities were retained and a closure cover layer was not placed on the surface. Currently, diversion and dense vegetation now cover the original faciltiies and nominal erosion has been observed. This is interpreted due in large part to the operational benches of the facilities which intercepted runoff before erosive velocities of were generated. 2. Design Criteria Through coordination between Albermarle and SRK, the design criteria for closure surface water management from the slopes of the TSF are listed below. a) Maintain the designed overall slope of 2.5H:1V. b) Control erosion on the reclaimed slopes of TSF. c) Provide a natural looking landscape similar to native slopes. To meet the above criteria,the plan for surface water management on the reclaimed TSF includes a combination of regrading and placement of robust best management practices (BMPs) to stabilize the soil until robust vegetation is established. GH/DH/JP USPR000576_KM_ClosureSurfWtr TSF_Memo_Draft01.docx April 2024 SRK Consulting(U.S.), Inc. Page 2 For this pre-feasibility study, a 2-foot-thick closure cover layer is proposed to be placed on the regraded surface and consists of 1 foot of growth media and 1 foot of"closure cover",. The "closure cover"will be designed in the next phase of study to have the optimal properties for evaporation/transpiration and vegetation growth. 3. Closure Slope Regrading The proposed approach is to include a small bench to interecept sheet flow before shallow concentrated flow is generated. The TSF will be constructed with a perimeter embankment constructed of waste rock. It will be constructed in lifts with continuous slopes (not benched) and will be revegetated following construction of the final lift (i.e., concurrent reclamation). To intercept sheet flow before shallow concentrated flow develops and and rilling erosion begins, a 16' flat "runoff interception bench" is proposed (Figure 1) for each 30-foot of height of embankment. The bench will be parallel to contour with no longitudinal slope. Slope lengths from toe to crest of the 2H:1 V slopes will be approximately 67 feet which is less then the estimated maximum sheet flow distance of 100 feet(National Engineering Handbook(NEH), Chapter 15, 2010). Over time, sediment will work its way down the slope and deposit at the toe of the 2H:1V regraded slope. A positive draining slope will develop outward across the bench and more runoff and less infiltration of precipitation over the TSF slope will occur over time. This coupled with dense vegetation will make the benches blend with the slopes over time. Thus,the runoff interception bench approach will meet design criteria"C" (refer Section 2). 2'THK CLOSURE COVER LAYER ('I'OF GROWTH MEDIA OVER 1-OF COVER) 2-5 RUNOFF INTERCEPTION BENCH(TYP) GLOBAL SLOPE OF WASTE ROCK 30.0' EMBANKMENT(BEFORE CLOSURE 18-0' 1 COVER LAYER) REGRADED SLOPE(TYP) 2 Figure 1: TSF Typical Closure Slope Regrading Section 4. Discussion of Approach The climate at the site is humid subtropical with hot summers and mild winters.The monthly temperature ranges from a minimum of around YF in January to a maximum of around 104°F in August,with an average temperature of around 60°F. Average monthly precipitation varies between 3 and 5 inches. Average annual precipitation is 42 inches, with an even distribution of rainfall throughout the year and an average annual snowfall of 4 inches. Surface soils are fertile (high in organic content) and the vegetation is robust and dense. The vegetation is the primary factor that controls erosion on native slopes. As noted in the Erosion and Sediment Control Design and Planning Manual for North Carolina (NCSCC, 2013) "Appropriate vegetation cover affords excellent erosion protection.... is relatively inexpensive, and is typically GH/DH/JP USPR000576_KM_ClosureSurfWtr TSF_Memo_Draft01.docx April 2024 SRK Consulting(U.S.), Inc. Page 3 the only practical, long-term solution to erosion control of disturbed sites in North Carolina". For these reasons, vegetation is the proposed primary erosion control measure in mine closure. Establishing robust vegetation as quickly as possible will be the key to successful erosion control of the TSF slopes. The soil is most susceptible to erosion immediately following grading activities and BMPs provide a "bridge"to establishment of mature vegetation and is discussed further below. 4.1 Revegetation and BMPs Once the cover layer is placed it will be cast seeded with an appropriate seed mix and seedlings will be planted at an appropriate spacing, both to be determined in future phases of study. Robust BMPs will be installed immediately following closure regrading and placement of the closure cover layer. This will include hydro-seeding and coir matting (aka coconut blankets) coupled with straw wattles across the slope. 4.2 Observation and Monitoring Observation and monitoring of slope revegetation and performance of BMPs will be employed to identify areas that require repair or modification before erosion deteriorates. Areas not performing will be addressed with additional BMPs. GH/DH/JP USPR000576_KM_ClosureSurfWtr TSF_Memo_Draft01.docx April 2024 SRK Consulting(U.S.), Inc. 2024 Conceptual Closure Plan—Kings Mountain Appendices Appendix C: Closure Drawing Package JP/MW Archdale_Closure_Report_USPR000576_Rev04.docx April 2024 LEGEND 2 FT. THK CLOSURE COVER LAYER e \ (1 FT. OF GROWTH MEDIA OVER 1 FT. OF COVER MATERIAL) \ 1000 CONTOUR 25' (EXISTING) 2 TYPICAL CLOSURE COVER d 100\ CONTOUR 5' (EXISTING) _ ° ° g • ° \ � 1000 CONTOUR 25' (PROPOSED) �_ cal 1 FT. GROWTH MEDIA ` 5 w � 9SO \ CONTOUR 5' (PROPOSED) 2.5 ❑ \ e � 0 \ PROPERTY BOUNDARY 7 0 RAILWAY16 a S 0 150 300 6000� o s° \\ PAVED ROAD 30 FT. \ GLOBAL SLOPE OF TSF FEET ° DIRT ROAD (BEFORE CLOSURE COVER LAYER) f� REGRADED EDGE OF WATER SLOPE (TYP.) 2 EXISTING 1 FT. COVER C - FENCE �r RUNOFF INTERCEPTION BENCH (TYP.) GROUND ° n CULVERT EXISTING ° P°o liw[ i+l}FH+IF �o CLOSURE PERIMETER —> > FLOW PATH -- 15 FT. POST-CLOSURE ROAD oo n CHANNEL(TYP.) 1 CLOSURE REGRADING DETAIL TYPICAL COVER AND PERIMETER CHANNEL 950 v SCALE: 1"=40' ® ° ° (REFER DETAIL 3) 9so ------------ 950 950 o L .8J I I I I I I a 925 < 5 < < < < 8s 0 �- 950 u gy0 950 FLOW PATH (TYP.) ° CULVERT REMOVED O II 'v � 9So POST-CLOSURE ROAD 3 TYPICAL COVER 2 �� AND PERIMETER CHANNEL MAX. EL: 992.00 300 300 '� 2 FILL IN CONTACT WATER POND v I s°s � 300 TYPICAL COVER 1100 C 1100 WITH SWALE CUT MATERIAL•` A a v < _ 1050 1 1050 4 ° CLOSURE REGRADING DETAIL CULVERT REMOVED — — v _ �� <f�f�� 1000 300 1000 z 950 — — — ♦/ 3 POST-CLOSURE ROAD 950 I — — — — — — — — 300 AND PERIMETER CHANNEL v � Q 900 900 PROPERTY BOUNDARY w 850 — — — 850 —'— 16 FT. FLAT BENCH (TYP.) �� w I I (REFER DETAIL 1) v \ 800 EXISTING GROUND 800 v szs I 0+00 1+00 2+00 3+00 4+00 5+00 6+00 7+00 8+00 9+00 10+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 19+00 20+00 21+00 soo sso � STATION (FT.) \ SECTION C-C o ` <� <� s2s 9 8 5 < < ms \ V 900 < < < FLOW PATH (TYP.) (SCALE: 1"=200') 875 <�— <"� K < o rn POST-CLOSURE ROAD 3 2 875 ' <� <—� TYPICAL COVER AND PERIMETER CHANNEL 300 300 B ---RIPRAP LAYER 1100 1100 CULVERT REMOVED (REFER DETAIL 3). 960 -- — __ 1050 1 1050 CLOSURE REGRADING DETAIL DROP INLETS AND CULVERTS 1000 300 1000 REMOVED AND REPLACED BY EXISTING CULVERTS (TYP.) =-_ 950 3 POST-CLOSURE ROAD 950 10-FT. WIDE SWALE z — 300 AND PERIMETER CHANNEL 900 1 ` — —r 900 Q — > 850 — — — — 850 w w 800-_ EXISTING GROUND 800 PERIMETER ACCESS ROAD 750 750 I I I C I I FINAL TSF GRADING PLAN 0+00 1+00 2+00 3+00 4+00 5+00 6+00 7+00 8+00 9+00 10+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 19+00 20+00 (SCALE: 1"=300') STATION (FT.) SECTION B-B (SCALE: 1"=200') POST-CLOSURE ROAD 3 AND PERIMETER CHANNEL 300 A 1150 - 1150 1100 1 CLOSURE 1100 REGRADING TYPICAL COVER 300 2FT. OF GROWTH MEDIA 3 POST-CLOSURE ROAD DETAIL 300 AND PERIMETER CHANNEL 1050 1050 300 1000 1 ` — _ 1000 z0 950 —— _— `/ — — — — 950 Q 900 — — — ` — — — 900 LU 850 ` — — — 850 w EXISTING GROUND 800 800 750 750 0+00 1+00 2+00 3+00 4+00 5+00 6+00 7+00 8+00 9+00 10+00 11+00 12+00 13+00 14+00 15+00 16+00 17+00 18+00 19+00 20+00 21+00 22+00 23+00 24+00 25+00 26+00 27+00 28+00 29+00 30+00 31+00 32+00 33+00 34+00 35+00 36+00 37+00 38+00 39+00 40+00 41+00 42+00 43+00 44+00 45+00 46+00 47+00 48+00 49+00 50+00 STATION (FT.) SECTION A-A (SCALE: 1"=200') 2 FT. THK. RIPRAP LAYER WITH 12-IN. DIA. D50, (PLACED AS SHOWN BY HATCHING IN PLAN VIEW) POST-CLOSURE TSF CLOSURE ROAD COVER CLOSURE RIPPED SURFACE WITH PERIMETER 1 FT. GROWTH MEDIA CHANNEL 5 FT. 15'MIN. _ 2.5 -_-_-_-_- - 1 PERIMETER ROAD DESIGN:JS/RBB REVIEWED: RBB PREPARED BY: DRAWING TITLE: ISSUE: - 5 T OCK FILL REVISIONS REV. DESCRIPTION DATE DRAWN: APPROVED: RBB JS/ML/NM PRELIMINARY consultirr TSF RECLAMATION MAP PLAN AND DATE: A SUBMITTED FOR CLIENT REVIEW 09.04.2024 COORDINATE SYSTEM: 30.05.2024 B ISSUED FOR PRE FEASIBILITY 19.04.2024 SECTIONS NC STATE PLANE NAD83 FT SRK PROJECT NO.: REVISION: EXISTING GROUND C RE-ISSUED FOR PERMITTING 30.05.2024 PREPARED FOR: PROJECT: USPR0005576 C \\, KINGS MOUNTAIN MINE DRAWING NO. URE PERIMETER CHANNEL SECTION (TYP.) .�' A B E MA R E Operated by: RECLAMATION PLAN ))=CALE- =20, IF THE ABOVE BAR Albemarle-Lithium KINGS MOUNTAIN MINE PROJECT 300 DOES NOT MEASURE 1 INCH, FILE NAME: USPR000576-REC03_TSF.dwg THE DRAWING SCALE IS ALTERED C:\Users\jsames\SRK Consulting\NA USPR000576 Albemarle Corporation Kings Mountain 2022 Pre Feasibility Study-Internal\0800_TSF\040_Drafting\Task-800_Reclamation\USPR000576-REC03_TSF.dwg o Q J d PROPERTY BOUNDARY I <� <� < o Q FLOW PATH (TYP.) 15FT WIDE POST <� ri < < LEGEND CLOSURE ROAD (TYP.) i000- CONTOUR 25' (EXISTING) - - - - - v ° CONTOUR 5' (EXISTING) 1000 CONTOUR 25' (PROPOSED) CONTOUR 5' (PROPOSED) HEA WALL ° PROPERTY BOUNDARY RAILWAY PAVED ROAD Y I DIRT ROAD EDGE OF WATER FILL IN CONTACT WATER OND v W/SWALE CUT MATERI ° N FENCE --________ I CULVERT EXISTING ° o � Y I v I I ° v _ - - - - - - - - - - v I CULV RT REMOVED I I 950 I CULVERT RE VED I ' 925 � I——————————— N J V 900 < < < < <� <� J <— <� < 900 CULVERT REMOVE - - -— BR NCH SEDIMENT IND 875 < 0 50 100 200 ago 36"0 EXISTING CULVERT m v sus FEET v ar3n 900 E STING CULVERT 8js DROP INLETS AND CULVERTS REMOVED 0 PLANT SITE GRADING PLAN 60"0 EXISTING CUL 960 940 940 FILL IN CONTACT WATER POND 950 920 W/SWALE CUT MATERIAL z 920 _ - 900 N 900 900 _ - - - - - - 900 z 880 j � 880 GRADE SWALE/DITCH ' 15, 5 w 860 - - _ I w TO REINSTATE FLOW TO � 850 860 EXISTING CULVERT w 840 850 820 -0+50 0+00 0+50 1+00 1+50 2+00 2+50 3+00 3+50 4+00 4+50 5+00 5+50 6+00 6+50 7+00 7+50 8+00 STATION (FT.) -0+50 0+00 0+50 1+00 1+50 SECTION A-A STATION (FT.) (SCALE: 1"=60') SECTION C-C (SCALE: 1" = 60') 940 980 960 920 z 950 -� 900 900 -- 940 `= z 880 z 920 - O O - - - - - - - H 0.5% 900 _� - _ - _ - - - - - - - 900 w 860 / - 850 III 5.2% - � - - - w 840 w 880 - GRADE SWALE/DITCH - 860 TO REINSTATE FLOW TO _ 820 EXISTING CULVERT -850 -0+50 0+00 0+50 1+00 1+50 2+00 -0+50 0+00 0+50 1+00 1+50 2+00 2+50 3+00 3+50 4+00 4+50 5+00 5+50 6+00 6+50 STATION (FT.) STATION (FT.) SECTION D-D SECTION B-B (SCALE: 1" =60') (SCALE: 1"=60') REVISIONS DESIGN:JS/RBB REVIEWED: RBB PREPARED BY: DRAWING TITLE: ISSUE: REV. DESCRIPTION DATE DRAWN: APPROVED:RBB PRELIMINARY A SUBMITTED FOR CLIENT REVIEW 09.04.2024 JS/ML/NM k COORDINATE SYSTEM: consulting PLANT SITE RECLAMATION MAP DATE: B ISSUED FOR PRE FEASIBILITY 19.04.2024 SITE PLAN AND SECTIONS 30.05.2024 C RE-ISSUED FOR PERMITTING 30.05.2024 NC STATE PLANE NAD83 FT PREPARED FOR: SRK PROJECT NO.: REVISION: PROJECT: USPR000576 C J\ ALBEMARLE KINGS MOUNTAIN MINE RECLAMATION PLAN DRAWING NO. Operated by: IF THE ABOVE BAR Albemarle-Lithium DOES NOT MEASURE 1 INCH, KINGS MOUNTAIN MINE PROJECT 400 FILE NAME: USPR000576-REC04_PLANT.dwg THE DRAWING SCALE IS ALTERED C:\Users\jsames\SRK Consulting\NA USPR000576 Albemarle Corporation Kings Mountain 2022 Pre Feasibility Study-Internal\0800_TSF\040_Drafting\Task-800_Reclamation\USPR000576-REC04_PLAN I dwg