KMM NC Mine Permit_Supp Doc_09202024_FINAL w roadmap

North Carolina Mine Permit
Supplemental Report
Kings Mountain Lithium Mine Project — Kings
Mountain Mine
September 20, 2024
Document No.: KM60-EN-RP-9079
Revision:
��� Albemarle

North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
CONTENTS
Introduction ............................................................................................................................1
Purposeand Content..................................................................................................................2
Regulatory Consistency.................................................................................................3
A. General Characteristics of the Mine....................................................................................6
Existing Legacy Features ..............................................................................................7
Existing Conditions and Materials..................................................................................7
ProposedFeatures......................................................................................................10
B. Maps ..........................................................................................................................14
C. Protection of Natural Resources .......................................................................................16
CurrentConditions.......................................................................................................19
Sequence of Events during Construction ....................................................................28
Sequence of Events during Operations.......................................................................31
D. Reclamation Plan ................................................................................................................67
E. Determination of Affected Acreage and Bond .................................................................72
F. Notification of Adjoining Landowners..............................................................................72
G. Land Entry Agreement........................................................................................................73
H. References ..........................................................................................................................74
Appendix A Mine and Reclamation Maps
Appendix B Permit Release Form
Appendix C Design Sheets
Appendix D 2022 Prefeasibility Study— Hydrogeology Study and Groundwater
Modeling
Appendix E Water Supply Well Mitigation Plan
Appendix F Stormwater Management Plans and Erosion and Sediment Control Plans
Appendix G Geotechnical Stability Reports, Calculations, and Cross-Sections
Appendix H 2O23 Prefeasibility Study— Baseline Geochemical Characterization
(Abridged)
Appendix I Abridged Engineering Design Reports
Appendix J Safety Data Sheets
Appendix K 2023 Prefeasibility Study: Surface Water—Water Balance Development
Report
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
Appendix L Federally and State-Listed Species Report
Appendix M Letter from City of Kings Mountain on Sewer Availability
Appendix N Visual Impact Assessment Report
Appendix O Conceptual Closure Plan
Appendix P Cross-Sections
Appendix Q Groundwater and Surface Water Sampling and Analysis Program for the
Kings Mountain Mining Project
Appendix R Albemarle Kings Mountain Mine— Blasting Impact Study
Appendix S Landowner Notifications
List of Figures (embedded)
Figure A-1: Generalized Process Plant Flow Diagram ...............................................................14
Figure C-1: Material Balance ......................................................................................................33
List of Figures (Appendix A)
Figure 1: USGS Topographic Map
Figure 2: NCDOT Highway Map
Figure 3: Kings Mountain Mine and TSF Project Location Map
Figure 4: Permitted Mine Areas Map
Figure 5: Aerial Location Map
Figure 6: Topographic Location Map
Figure 7: Legacy Mining Facilities Map
Figure 8: Surface Water Features Map
Figure 9: Wetland Delineations Overview Map
Figures 10-13: Wetland Delineations at Mine Site Map Series
Figure 14: Location of 100-Year Floodplain Limits
Figure 15: Monitoring Well Network
Figure 16: Soils Map
Figure 17: NRHP Listed for Eligible Site Map
Figure 18: USGS 2008 Geology Map
Figure 19: Location of Geotechnical Borings
Figure 20: Existing Site Conditions (LOM Phase 0)
Figure 21: Kings Mountain Mine Site Layout Overview Map
Figure 22: Proposed Pit Map and Cross-Sections
Figure 23: Map and Cross-Section Showing the Pit Geotechnical Domains and Sectors
Figure 24: Easement Map
Figure 25: Kings Mountain Site Layout and Property Buffers
Figure 26: Mine Site Layout Map with Acreage Table
Figure 27: End of Construction (End of Mining Year 0) LOM Phase 1
Figure 28: Interim Operations (End of Mining Year 5) LOM Phase 2
Figure 29: End of Operations (End of Mining Year 9.4) LOM Phase 3
Figure 30: End of Reclamation (After Mining Year 9.4) LOM Phase 4
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
Figures 31-35: Kings Mountain Mine Site Layout Series Maps
Figure 36-A: Site Location Map with Temporary Surface Water Management and Sediment
Control Features
Figure 36-B: Site-Wide Overall Stormwater Plan (Operations)
Figure 37: Surface Water Management— Detail Sheet 1
Figure 38: Surface Water Management— Detail Sheet 2
Figure 39: Surface Water Management— Detail Sheet 3
Figure 40: Surface Water Management— Detail Sheet 4
Figure 41: Phase 1 Construction Stormwater Plan
Figure 42: Phase 2 Construction Stormwater Plan
Figure 43: Kings Mountain Mine Water Balance Flowsheet
Figure 44: Kings Mountain Site-Wide Water Balance Flowsheet during Construction
Figure 45: Kings Mountain Site-Wide Water Balance Flowsheet for Closure
Figure 46: NCG02 Outfall Location Map
Figure 47: Public Lands, Recreation, and Conservation Areas Map
Figure 48: Closest Occupied Residence to Pit
Figure 49: Fuel Station Location Map
Figure 50: Adjoining Parcels Overview Map
Figures 51-56: Mine Adjoining Parcels Map Series
List of Tables
Table 1: Summary of Existing Conditions Near the Kings Mountain Mine Site ............................8
Table 2: Existing Permitted and Proposed Kings Mountain Mine Acreages.................................9
Table 3: List of Required Maps and Figures...............................................................................15
Table 4: Summary of Mining Sequence Time Periods and General Activities............................17
Table 5: Annual Mine Production Schedule................................................................................18
Table 6: Truck Trip Schedule......................................................................................................18
Table 7: Impact Summary to Proposed-Jurisdictional Resources ..............................................22
Table 8: LOM Surface Water Management and Sediment Control Activities by Mine Phase.....38
Table 9: Project Design Criteria for Surface Water Infrastructure...............................................44
Table 10: Sediment Control Ponds.............................................................................................45
Table 11: Project Discharge Outfall Locations............................................................................46
Table 12: Water Storage Basin 1 Water Quality Predictions ......................................................63
Table 13: Preliminary Permanent Seed Mix Composition and Schedule ...................................71
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Expanded Appendix "Road Map"
The following pages provide a detailed description of the contents of appendices listed in the Table of
Contents in the Supplemental Document and describes navigational aids that have been provided.
• Since many appendix documents contain subappendices, a naming convention has been
provided to uniquely distinguish each appendix and sub-appendix contained within it. For
example, F-A identifies Appendix A within major appendix F. F-A-A identifies Appendix A
contained in Appendix A, which is contained in major appendix F, etc.
• PDF files of these appendices are provided, and many are bookmarked (viewing the files in
Adobe is recommended as it will make the bookmarks visible and provide ease of navigation).
The append ix/subappendix naming convention is carried over to the appendix divider sheets in
the hard copies, and in the PDF bookmarks and/or file names in the electronic submittal. All
Appendix materials shown italicized font are subsections of PDF document and are identified
only in the bookmarks contained in that file.
Appendix A Mine and Reclamation Maps
Appendix B Permit Release Form
Appendix C Design Sheets
Appendix A- RSF and RSF-X Design Sheets (C-A)
Appendix B -WSB-1 Design Sheets (C-B)
Appendix C - Plant Flow Diagram (C-C)
Appendix D -Water Treatment Plant Block Diagram (C-D)
Appendix D Hydrogeology Study and Groundwater Modeling (SRK)
Appendix A - Hydrogeological Units per Model Layers (D-A)
Appendix B - Comparison of Simulated and Measured Water Levels (D-B)
Appendix C - Components of Pit Lake Balance as Input for Pit Lake Chemistry Modeling (D-C)
Appendix E Water Supply Well Mitigation Plan (SRK)
Appendix A - Predicted Water Level Changes at Monitoring Locations (E-A)
Appendix F Stormwater Management Plans and Erosion and Sediment Control Plans
Appendix A- Surface Water Management Report (SRK) (F-A)— note-addresses the operational
stormwater and erosion control plan for portions of the project including the mine, rock and overburden storage
facilities. Note that Appendix E(F-A-E)includes additional details for the overburden storage facilities that were
added late to the project. The operational stormwater and erosion control plan for the remainder of the site(NPI, ore
processing, etc.)can be found in Hatch document(F-C).
Appendix A - Hydrologic and Hydraulic Calculations (F-A-A)
Appendix B- Erosion Control Report (F-A-B) Note- Provided, but supplanted by F-A-D
Appendix A - Runoff Estimation for the Kings Mountain Mining Project(F-A-B-A)
Appendix B— Channel Design for the Kings Mountain Mining Project(F-A-B-B)
Appendix C—Sediment Pond Designs (F-A-B-C)
Anpendix C- Culvert Inspections (F-A-C)
Appendix D- Operational Erosion Control Plan (F-A-D)
Appendix A - Runoff Estimation for the Kings Mountain Mining Project(F-A-D-A)
Appendix B— Channel Design for the Kings Mountain Mining Project(F-A-D-B)

Appendix C—Sediment Pond Designs (F-A-D-C)
Appendix E— Stormwater Control Addendums (F-A-E)
Appendix E-1 Overburden Storage Facility SWMP(F-A-E-A)
Erosion and Sediment Control Plan Addendum (F-A-E-B)
Appendix E-IA -Runoff Estimation (F-A-E-B-A)
Appendix E-1B- Channel Design (F-A-E-B-B)
Appendix E-1 C- Sediment Pond Designs (F-A-E-B-C)
Appendix B - Construction Stormwater Management Plan (Hatch) (F-B)note- this appendix covers
the operational stormwater and erosion control plan for portion of the project including the mine, rock and overburden
storage facilities. Note that Appendix E(F-A-E)includes additional details for the overburden storage facilities that
were added late to the project. The operational stormwater and erosion control plan for the remainder of the site
(NPI, ore processing, etc.)can be found in Hatch document(F-C)
Exhibit A -Phase 1 Construction Stormwater Management Plan
Exhibit B-Phase 2 Construction Stormwater Management Plan
Exhibit C-Duke Substation Pad
Exhibit D-Erosion and Sediment Control Details
Appendix A -Frequency Analysis Results from AWA & NOAA Atlas 14 Precipitation Map (F-B-A)
Appendix B- Summary Peak Runoff Volume and Flowrate Calculations (F-B-B)
Appendix C-Proposed(Operational) Sediment Basins Sizing Calculations (F-B-C)
Appendix D-Proposed Sewer Sizing Calculations (F-B-D)
Appendix E- Channel and Culvert Capacity Analysis Results (F-B-E)
Appendix C — Preliminary Drainage Analysis report (Hatch) (F-C)
Exhibit A - Overall Stormwater Management Plan Post Development Conditions
Exhibit B-Enlarged Stormwater Management Plan—North Area of 1-85
Exhibit C-Enlarged Stormwater Management Plan—South Area of 1-85
Exhibit D- Overall Stormwater Management Plan—NPI Area
Exhibit E- Overall Stormwater Management Plan -Duke Substation Pad
Exhibit F-Detention Pond Outlet Pipes-Plans and Profiles
Exhibit G-Erosion and Sediment Control Details
Exhibit H-Drainage Outfall Protection Details
Appendix A - USGS Quadrangle Site Location Map (F-C-A)
Appendix B- USDA Soils Report(F-C-B)
Ajopendix C-Frequency Analysis Results(F-C-C)
Appendix D-Post Development Runoff Volume and Flowrate Calculations (F-C-D)
Appendix E-Hydraflow Hydrographs Runoff Volume and Flowrate Calculations (F-C-E)
Appendix F-Proposed Sewer Sizing Calculations (F-C-F)
Appendix G- Channel and Culvert Capacity Analysis Results (F-C-G)
Appendix H-Proposed Sediment Basins Stage Storage Sizing Calculation (F-C-H)
Appendix 1-FEMA Floodplain National Flood Hazard Laver FIRMette (E-C-/)
Appendix G Geotechnical Stability Reports, Calculations, and Cross-Sections
Appendix A- Geotechnical Report - Pit Stability and Modeling (SRK, Abridged) (G-A)
Appendix B - RSF Calculation Package (SRK, Abridged) (G-B)
Appendix C - WSB-1 Calculation Package (SRK, Abridged) (G-C)
Appendix H 2O23 Prefeasibility Study- Baseline Geochemical Characterization (Abridged)
Appendix A - Sample Locations and Distributions (H-A)
Appendices B- H (Abridged, available on request)

Appendix I Abridged Engineering Design Reports
Appendix A- Prefeasibility Engineering Design Report for RSFs A and X
Appendix A—RSF-A and RSF-X Site Characterization Report(not included, available on request)
Appendices B—Preliminary Design Drawing Set(not included, can be found in C-A)
Appendix C- Stability Calculation Package (not included, found in G-B)
Appendix B - Prefeasibility Engineering Design Report for WSB-1 (I-B)
Appendix A— WSB-1 Prefeasibility Site Characterization Report(I-B-A)
Appendix C - Water Treatment Plant Process Description and Block Flow Diagram (I-C)
Appendix J Safety Data Sheets
Appendix K Surface Water-Water Balance Development Report
Appendix A - Legacy Climate Data (K-A)
Appendix B- Johnson SB Probability Distribution fitting to Legacy Precipitation Records (K-B)
Appendix L Federally and State-Listed Species Report
Appendix A -Aerial Photographs Showing Historic Mining in the Project Area
Appendix B- US Fish and Wildlife Service Information (L-B)
Appendix C- North Carolina Natural Heritage Resource Report (L-C)
Appendix M Letter from City of Kings Mountain on Sewer Availability
Appendix N Visual Impact Assessment Report (ERM)
Appendix O Conceptual Closure Plan (SRK)
Appendix A - Recommended Revegetation Plan
Appendix B - Tech Memo - Surface Hydrology of Open Pit Overflow, Post-Closure 'O-B)
Appendix C - Tech Memo - Conceptual Closure Surface Water Management Plan for RSF-A (O-C)
Appendix D - Tech Memo - Conceptual Closure Surface water management plan for TSF , -D)
Appendix E- Closure Drawing Package (O-E)
Appendix P Cross-Sections
Appendix A- OSF Cross Sections (P-A)
Appendix B - GMS Cross Section (P-B)
Appendix C - RSF Cross Sections (P-C)
Appendix Q Groundwater and Surface Water Sampling and Analysis Program
Appendix R Albemarle Kings Mountain Mine- Blasting Impact Study
Appendix S Landowner Notifications

North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
Acronyms and Abbreviations
Acronym Definition
Albemarle Albemarle U.S., Inc.
amsl above mean sea level
bgs below ground surface
BMP best management practice
DEMLR Division of Energy, Mineral, and Land Resources
DMS dense media separation
E&S erosion and sediment
FA-2 FLOTIGAM EDA
FeSi ferrosilicon
GMS growth media storage
G.S. North Carolina General Statute
HDPE high-density polyethylene
I-85 Interstate 85
Gateway Trail Kings Mountain Gateway Trail
KMM Kings Mountain Mine
LIMS low intensity magnetic separator
LOM life of mine
Na2CO3 Soda ash
NaOH Sodium hydroxide
NCAC North Carolina Administrative Code
NCDEQ North Carolina Department of Environmental Quality
NCDOT North Carolina Department of Transportation
non-PAG non-potentially acid generating
NPDES National Pollutant Discharge Elimination System
NPI non-process infrastructure
NRHP National Register of Historic Places
OSF (temporary) overburden storage facility
PAG potentially acid generating
PEM palustrine emergent wetland
PFO palustrine forested wetland
Project Kings Mountain Lithium Mine Project
PSS palustrine scrub-shrub
RCRA Resource Conservation and Recovery Act
ROM run-of-mine
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Kings Mountain Lithium Mine Project
Acronym Definition
RSF rock storage facility
RSF-A (permanent) rock storage facility for non-potentially acid generating
rock
RSF-W (temporary) rock storage facility for potentially acid generating rock
RSF-X (temporary) rock storage facility for potentially acid generating rock
SHPO North Carolina State Historic Preservation Office
SRK SRK Consulting U.S., Inc
SWMP Stormwater Management Plan
Technology Center Albemarle Global Technology Center for Research and Development
TSF tailings storage facility
U.S. United States
USEPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service
USGS U.S. Geological Survey
VIA visual impact assessment
WHIMS wet high intensity magnetic separator
WSB-1 Water Storage Basin 1
WTP water treatment plant
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
Glossary
Term Definition
access roads Primary roads used to access the Kings Mountain Mine and Archdale Tailings
Storage Facility sites.
adjoining landowner A landowner's property adjoins a mine site if the landowner's property
boundary is the same as one or more of the mining permit boundaries and/or
if the landowner's land is partially covered by the mining permit.
affected acreage The surface area of land that is mined; the surface area of land associated
with a mining activity such that soil is exposed to accelerated erosion; the
surface area of land on which overburden and waste are deposited; the
surface area of land used for a processing or treatment plant, stockpiles,
nonpublic roads, and settling ponds. Affected acreage also includes
submerged lands but not undisturbed buffers. Haul roads constructed solely
for the mining operation and existing nonpublic roads upgraded for mine
operation are also considered affected acreage.
affected land The surface area of land that is mined; the surface area of land associated
with a mining activity so that soil is exposed; the surface area of land on which
material is stockpiled; and the surface area of land used for a processing or
treatment plant, stockpiles, nonpublic roads, and ponds.
Albemarle Albemarle U.S., Inc.
archaeological site The physical remains of any area of human activity, generally greater than 50
years of age, for which a boundary can be established. Examples of such
resources could include domestic/habitation sites, industrial sites, earthworks,
mounds, quarries, canals, roads, etc. Under the general definition, a broad
range of site types can qualify as archaeological sites without the identification
of artifacts.
authorization Any license, permit, approval, finding, determination, or other administrative
decision issued by an agency required or authorized under law to implement a
proposed action.
base flow The sustained flow of a stream in the absence of direct runoff, sustained
largely by groundwater.
baseline Environmental and social conditions prior to project activities.
bedrock Solid rock, overlaid in most places by unconsolidated deposits.
berm A mound or wall of earth.
best management The schedule of activities, prohibition of practices, implementation of
practice maintenance procedures, and other management practices to avoid or
minimize pollution or habitat destruction to the environment. Best
management practices can include treatment requirements, operating
procedures and practices to control runoff, spillage or leaks, sludge or waste
disposal, and/or drainage from raw material storage.
blasting The use of explosives or blasting agents to cause the fragmentation of
materials.
check dam A small, sometimes temporary, dam constructed across a swale, drainage
ditch, or waterway to counteract erosion by reducing water flow velocity.
closure The time when all mining operations cease prior to commencement of post-
closure activities.
concentrate The end products of the Project. Concentrates will contain the lithium that will
be separated from rock in the mine.
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
concentrator The concentrator will include grinding, gravity flotation, concentrate
dewatering, concentrate storage and loadout, and reagent makeup. The
concentrator will be located on the south side of Interstate 85.
construction The phase during which surface facilities and infrastructure are constructed,
which will occur between -2.5 and 0 mine years. This will include all process
and non-process infrastructure.
contact water Water that comes in direct contact with ore or waste rock or infiltrates into
tailings.
Generally, water that has come into contact with non-potentially acid
generating waste rock, potentially acid generating waste rock, filtered tailings,
pit walls and haul roads is assumed to be contact water.
contaminant A substance that pollutes air, soil, or water. It may also be a hazardous
substance that does not occur naturally or that occurs at levels greater than
those found occurring naturally in the environment.
crushing The process of reducing the size of ore by force.
cultural resources Archaeological, traditional, and built environment resources including but not
limited to buildings, structures, objects, districts, and sites.
dewatering The action of removing water from a mine pit.
discharge (Clean Water Act definition)Any addition of any pollutant or combination of
pollutants to navigable waters from any point source (40 CFR§ 122.2).
discharge (Project definition) Release of water from the Project to the environment in
accordance with applicable regulations and permit conditions; also, the water
released.
easement A grant of one or more property rights by the property owner of a portion of
land for a specified purpose and use by the public, a corporation, or other
entity.
endangered species Any species which is in danger of extinction throughout all or a significant
portion of its range.
Endangered Species Act This act was enacted in 1973 (7 USC § 136, 16 USC § 1531 et seq.) and was
designed to protect critically imperiled species from extinction as a
"consequence of economic growth and development un-tempered by
adequate concern and conservation."This act is administered by the U.S.
Fish and Wildlife Service and the National Oceanic and Atmospheric
Administration.
erosion The wearing of land surface by the action of wind, water, gravity, or any
combination thereof.
flowsheet An illustration showing the sequence of operations, step by step, by which ore
is treated in milling or concentration.
flume Specially shaped, engineered structures used to measure the flow of water in
open channels. Flumes are static in nature—having no moving parts—and
develop a relationship between the water level in the flume and the flow rate
by restricting the flow of water in various ways.
fugitive dust Airborne particulate matter. This can include emissions from haul roads, wind
erosion, exposed surfaces and other activities that remove and redistribute
soil.
groundwater The water located beneath the ground surface in soil and rock pore spaces
and fractures.
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
growth media storage An area where the surface portion of the soil that may be reused as soil is
stored in large aboveground piles for later use in reclamation.
haul road Internal haul roads will either be modified or newly constructed to transport
material across the site. The haul roads will be connected to exit points and
connect to offsite roadways for material transport offsite. Haul roads may be
relocated during mining operations, as the pit expands.
hazardous waste A category of waste regulated by the Resource Conservation and Recovery
Act. Such waste includes solid waste listed in the Resource Conservation and
Recovery Act that exhibits at least one of four characteristics (as described in
40 CFR §§ 261.20-261.24): ignitability, corrosivity, reactivity, or toxicity; or
that is listed by the U.S. Environmental Protection Agency in 40 CFR§§
261.31-261.33.
All waste considered hazardous in accordance with Federal Resource
Conservation and Recovery regulations. This term refers to all waste
materials that may cause direct or indirect damage to the environment. This
waste type may be liquid or solid. Hazardous waste will be identified and
disposed of offsite in accordance with Resource Conservation and Recovery
Act regulations.
highwall Any vertical or near vertical excavation slope exceeding 10 feet in height. All
highwalls must be protected by a highwall barrier.
hydrogeology The study of the water below the Earth's surface and its interrelationship with
geologic materials.
impervious surface Hard surfaces that do not allow water to permeate the ground.
infiltration Downward entry of water into soil or rock; also, the water that enters the soil
or rock.
landowner Any owner of a legal or equitable interest in real property that adjoins a mine
site if the property boundaries are the same as the mine permit boundaries
and/or if the landowner's land is partially covered by the mining permit.
laydown area Area used for material and equipment storage throughout the Project.
legacy mine Albemarle's current lithium mine and metal production compound, which was
also previously mined by other entities beginning as far back as 1883.
mine dewatering Water that is either existing or accumulates during operations that will be
mechanically removed from the Project through pumping.
minerals Soil, clay, coal, stone, gravel, sand, phosphate, rock, metallic ore, and any
other solid material or substance of commercial value found in natural
deposits on or in the earth.
mining (i)The breaking of the surface soil in order to facilitate or accomplish the
extraction or removal of minerals, ores, or other solid matter; (ii) any activity or
process constituting all or part of a process for the extraction or removal of
minerals, ores, soils, and other solid matter from their original location; or(iii)
the preparation, washing, cleaning or other treatment of minerals, ores, or
other solid matter so as to make them suitable for commercial, industrial, or
construction use.
mitigation Actions taken to reduce the likelihood of a certain adverse impact occurring.
mobile equipment Nonstationary machinery that will be used to perform operations.
National Historic This act (Public Law 89-665; 16 USC §470 et seq.) is legislation intended to
Preservation Act preserve historical and archaeological sites in the United States. The act
created the National Register of Historic Places, the list of National Historic
Landmarks, and the State Historic Preservation Offices. It was signed into law
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
on October 15, 1966. The act requires federal agencies to evaluate the impact
of all federally funded or permitted projects on historic properties (i.e.,
buildings, archaeological sites, etc.)through a process known as Section 106
Review.
noise Sound that interferes with speech and hearing and that is undesirable.
non-potentially acid Rock that does not generate acid during exposure to air and water.
generating
non-contact water Direct precipitation, stormwater, and surface water that has not contacted ore,
waste rock, tailings, industrial areas or activities, or surfaces disturbed by
construction activities including runoff from reclaimed surfaces and water from
adjacent watersheds diverted around a facility.
Water that has not come into contact with filtered tailings or tailings storage
facility embankment rock is assigned the least impacted water quality. This
water has only contacted vegetated or newly constructed native soil surface
and can be released to the environment with only appropriate sediment
controls. Generally, all surrounding undisturbed watersheds, and any
reclaimed surface are assumed to generate non-contact water.
operations The 9.4-year phase during which ore will be extracted and processed, water
and waste will be managed, and concurrent reclamation will occur.
overburden The soil materials that lie above the natural deposit of rock.
point source (Clean Water Act definition)Any discernible, confined, and discrete
conveyance including, but not limited to, any pipe, ditch, channel, tunnel,
conduit, well, discrete fissure, container, rolling stock, concentrated animal
feeding operation, landfill leachate collection system or vessel, or other
floating craft from which pollutants are or may be discharged (40 CFR§
122.2).
pollutant (Clean Water Act definition) Dredged spoil, solid waste, incinerator residue,
filter backwash, sewage, garbage, sewage sludge, munitions, chemical
wastes, biological materials, radioactive materials (except those regulated
under the Atomic Energy Act of 1954, as amended [42 USC. 2011 et seq.]),
heat, wrecked or discarded equipment, rock, sand, cellar dirt, and industrial,
municipal, and agricultural waste discharged into water(40 CFR § 122.2).
pond Temporary water storage for retention of runoff and sedimentation control.
post-closure The phase after mine closure. During post-closure, reclaimed areas will be
maintained, and monitoring will confirm that reclamation has been sustained
and post-closure performance criteria have been achieved.
potentially acid Rock that when oxidized by neutral and alkaline surface weathering, may form
generating acid which can then leach metals.
process The process of producing lithium concentrate from extracted spodumene
resources.
Project Kings Mountain Lithium Mine Project, which includes the offsite Archdale
Tailings Storage Facility.
reclamation The reasonable rehabilitation of the affected land for useful purposes, and the
protection of the natural resources in the surrounding area. Although both the
need for and the practicability of reclamation control the type and degree of
reclamation in any specific instance, the basic objective is to establish on a
continuing basis the vegetative cover, soil stability, water conditions, and
safety conditions appropriate to the area.
refuse All waste soil, rock, minerals, scrap, tailings, slimes and other material directly
connected with the mining, cleaning, and preparation of substances mined,
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
including all waste materials deposited on or in the permit area from other
sources.
rock The solid mineral material forming part of the surface of the Earth exposed on
the surface or underlying the soils or ocean.
runoff The portion of precipitation that flows over the ground surface to a surface
water body or Project water management structure.
safety bench A safety bench is required at the toe of the overburden cut slope and the top
of a hardrock highwall. The minimum safety bench width is 10 feet.
saprolite A soft, earthy, typically clay-rich, thoroughly decomposed rock formed in place
by chemical weathering of igneous, sedimentary, and metamorphic rock.
schist A foliated metamorphic rock, the grains of which have a roughly parallel
arrangement, generally developed by shearing.
screen A device such as a fence or planting area used to visually separate
properties.
sediment Solid particulate matter, both mineral and organic, that has been or is being
transported by water, air, gravity, or ice from its site of origin.
sediment pond A pond used for settling suspended solids.
sedimentation Process by which sediment, resulting from accelerated erosion, has been or is
being transported off the site of the land disturbing activity or into a lake or
natural watercourse.
seepage (i)Water that flows downward out of the base of an unlined engineered
feature into groundwater. (ii)The slow movement of water through natural
geologic materials into or out of surface water or groundwater.
screening Screening installed to reduce public view, dust and noise from the mine site,
and processing area. Screening methods may include, but are not limited to,
preserving existing vegetation, earthen vegetated berms, and planted trees.
spodumene A mineral containing lithium ore.
stakeholders Persons or groups who are directly or indirectly affected by a project, such as
rights holders, as well as those who may have interests in a project and/or the
ability to influence its outcome, either positively or negatively.
storm, 100-year, 24-hour The surface runoff resulting from a rainfall of an intensity expected to be
storm event equaled or exceeded, on the average, once in 100 years, and of a duration
which will produce the maximum peak rate of runoff for the watershed of
interest under average antecedent wetness conditions.
stormwater The flow of water which results from precipitation, and which occurs
immediately following rainfall or a snowmelt.
tailings Waste byproducts of lithium beneficiating processes consisting of rock
particles which have usually undergone crushing and grinding, from which the
profitable mineralization has been separated.
tailings storage facility An offsite storage facility used to store unwanted byproduct from the mineral
extraction process. This byproduct is transported by truck from the tailings
loadout area at the Kings Mountain Mine site to the offsite storage facility.
Referred to as the Archdale Tailings Storage Facility.
temporary A period of time, not to exceed a specific number of consecutive days.
undisturbed buffer No disturbances are permitted within these buffers. Undisturbed buffers are
required along nature watercourses and wetlands.
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unexcavated buffer Disturbance is allowed within these buffers, although excavating is prohibited.
Haul roads, erosion control measures, and earthen berms may be constructed
within these buffers.
unweathered bedrock This geological and hydrogeological unit typically consists of competent(hard
with relatively high rock strength) bedrock that lies at moderate to significant
depths below the ground surface that exhibits no to rare weathering effects
and decay relative to the original parent rock character.
velocity The speed at which water flows.
watershed The land area that drains water to a particular surface waterbody or point
along a stream. A ridge or drainage divide separates a watershed from
adjacent watersheds.
weathered bedrock This geological and hydrogeological unit consists of bedrock that has some
amount of decomposition from the original character of the parent rock as a
result of proximity to the surface and secondary affects typically resulting in a
less competent rock. Weathering of bedrock typically affects the
geomechanical and index properties that may include an increase in the
fracture density and a decrease in rock strength, hardness, and rock quality.
This rock type may include decomposition of silicate minerals to clay and iron-
oxide minerals as a result of hydrolysis chemical reactions from interaction
with surface and/or groundwater. Saprolite is related to moderate to high
weathering of the parent rock.
wetland An area that is inundated or saturated by surface and/or groundwater at a
frequency and duration sufficient to support a prevalence of vegetation
typically adapted for life in saturated soil conditions. Wetlands generally
include swamps, marshes, bogs, fens and similar areas.
wetland delineation The act of establishing the boundary between wetlands and uplands (or non-
wetlands) using soils, hydrology, and vegetation as indicators.
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INTRODUCTION
Albemarle U.S., Inc. (Albemarle), headquartered in Charlotte, North Carolina, is a leading global
producer of lithium-based chemicals. Albemarle currently operates a lithium compound and
metal production facility (Kings Mountain Facility) at the legacy Kings Mountain Mine (KMM)
(legacy mine) located in the city of Kings Mountain, Cleveland County, North Carolina.
Cleveland County is approximately 30 miles west of Charlotte within the United States (U.S.)
Geological Survey Kings Mountain 7.5-minute quadrangle (Figure 1: U.S. Geological Survey
[USGS] Topographic Map'). The KMM site is also located within the Broad River Basin and sub-
basin Upper Broad 8-Digid HUC03050105, which is approximately 2.5 miles from the Catawba-
Broad River divide. The KMM is divided by Interstate 85 (1-85) with the main area located on the
northern side, and a smaller area to the south. The larger northern area is bordered by South
Battleground Avenue (Highway 216), Park Grace Road, and Tin Mine Road to the west; Quarry
Road to the north; and 1-85 to the south and east (Figure 2: North Carolina Department of
Transportation [NCDOT]) Highway Map). The southern land area is bordered by 1-85 to the
north and York Road to the east. Martin Marietta also operates an active aggregate mine that
borders the KMM site to the east.
A significant portion of the Kings Mountain Gateway Trail (Gateway Trail) extends through the
site. Albemarle is committed to relocating this portion of the Gateway Trail. The other nearest
public land is Crowders Mountain State Park, which is located approximately 2 miles east of the
KMM site and southeast of 1-85 in Gaston County.
To meet current and expected demand for lithium products, Albemarle intends to reopen the
legacy mine to produce spodumene concentrate from spodumene ore, which will be extracted
by deepening and widening an existing, inactive open pit. Non-ore bearing rock generated
during operations will be managed onsite or transferred offsite under commercial agreement.
Non-potentially acid generating (non-PAG) rock will be stored onsite. All tailings will be filtered
and transported to an approved offsite tailings storage facility (TSF) called the Archdale TSF,
located approximately 3 miles southwest of the KMM (Figure 3: Kings Mountain Mine and TSF
Project Location Map), for permanent storage. The KMM and TSF together are referred to as
the Kings Mountain Lithium Mine Project, or the "Project." The Mine Permit Application for the
TSF has been submitted separately. This application is for the KMM only.
Albemarle holds two mine permits at KMM: Permit 23-01 (East Mine Permit) and Permit 23-34
(West Mine Permit) (Figure 4: Permitted Mine Areas Map). In this permit application, Albemarle
is requesting a major modification to KMM Permit 23-01 to initiate hardrock mining at the
existing facility. The primary activities included within this major modification include:
• Constructing processing facilities including a water treatment plant (WTP); non-process
infrastructure (NPI); stormwater management, water treatment, and storage systems; rock
storage facilities (RSFs); and overburden storage facilities (OSFs);
Figures are presented in Appendix A: Mine and Reclamation Maps, unless otherwise noted.
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• Reinitiating mining within the legacy pit to extract spodumene ore;
• Producing spodumene concentrate; and
• Reclaiming and closing the mine.
Albemarle also requests to be completely released from Permit 23-34, as the requested
modification to Permit 23-01 subsumes the area included in Permit 23-34. Additionally, the
60.48 acres representing the existing chemical plant, Albemarle Global Technology Center for
Research and Development (Technology Center), and the location of the proposed Duke
Energy substation are excluded from the mine permit boundary requested by the modification to
Permit 23-01. A permit release form has been submitted to the Division of Energy, Mineral, and
Land Resources (DEMLR) and is provided in Appendix B: Permit Release Form. The applicant
anticipates the requested permit releases to occur after, and only if, modification to Permit 23-01
is approved.
The permit boundary encompasses the minimum land area necessary for the Project, and the
proposed permit boundary (as shown on Figure 4: Permitted Mine Areas Map) generally follows
parcel boundaries delineated through surveys and GIS data. In some cases, the permit
boundary deviates from the existing property lines to preserve a public right-of-way or in
anticipation of state abandonment of a public right-of-way (in which case the permit boundary
encompasses the public right-of-way). The permit boundary may also deviate from parcel
boundaries to exclude facilities and land unrelated to mining.
PURPOSE AND CONTENT
The purpose of this document is to provide Project-specific details to supplement the North
Carolina Mining Permit Application. The structure of this document follows the sequence of the
application form. Pertinent documents and engineering reports have also been attached as
appendices.
Appendix A: Mine and Reclamation Maps contains figures and mine maps. Project design
sheets and drawings can be found in Appendix C: Design Sheets. Supporting documentation for
the Project can be found in Appendices D through S and include:
• A threatened and endangered species/wildlife study;
• Hydrogeology study and groundwater model;
• The abridged baseline geochemical characterization (including waste [soil and rock] and
tailings characterization);
• Geotechnical stability reports and calculations (including summaries and slope analyses for
the open pit, RSFs, and Water Storage Basin 1 [WSB-1]);
• Abridged engineering design reports;
• Cross sections;
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• Safety data sheets for proposed chemicals to be used in the spodumene concentration
process;
• Surface water balance and development information;
• Stormwater management plans (SWMPs), including the erosion and sediment (E&S) control
plans for construction and operations and supporting drainage calculations and the drainage
analysis report;
• A water supply mitigation plan;
• The Visual Impact Assessment (VIA);
• A blasting impact study;
• A conceptual closure plan;
• A letter from the city of Kings Mountain on sewer availability;
• The proposed Groundwater and Surface Water Sampling and Analysis Program; and
• Landowner notifications.
Regulatory Consistency
This application, combined with the supporting documentation, demonstrates that the proposed
reopening of the legacy mine is consistent with North Carolina mining regulations. The Project
does not meet any of the seven criteria for denial, pursuant to North Carolina General Statute
(G.S.) Article 74-51. For reference, these criteria are as follows:
1. That any requirement of this Article or any rule promulgated hereunder will be
violated by the proposed operation;
The Project will not violate any rules contained in Article 74-51 of The Mining Act of 1971, as
demonstrated by this application and supporting information.
2. The operation will have unduly adverse effects on potable groundwater supplies,
wildlife, or fresh water, estuarine, or marine fisheries;
The Project will not impact any known potable groundwater supplies, as the area is supplied by
a municipal potable water source. This has been demonstrated by the installation of
groundwater monitoring wells, analytical sampling and results that are presented in the
hydrogeology study conducted by SRK Consulting U.S., Inc. (SRK) (available in
Appendix D: 2022 Prefeasibility Study— Hydrogeology Study and Groundwater Modeling) that
evaluated public and private water supply wells within a 4-mile radius.
Additionally, a Water Supply Well Mitigation Plan has been developed (see Appendix E: Water
Supply Well Mitigation Plan), which contains mitigative contingencies in the unlikely event that a
potable water well would be impacted.
Coordination occurred with the North Carolina Wildlife Resources Commission and the U.S.
Fish and Wildlife Service (USFWS) and there are no conflicts with federal or state threatened or
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endangered wildlife species. Acoustic surveys identified the presence of the tricolored bat
(Perimyotis subflavus), which is proposed to be listed by the USFWS. Section 7 consultation
has been initiated with the USFWS. Additional acoustic surveys will be performed to determine
the presence of the tricolored bat prior to construction. All applicable USFWS rules and
guidelines will be followed to prevent adverse impacts to this species.
No fresh water, estuarine, or marine fisheries are located on the site. All regulated stormwater
and wastewater discharged from the Project will be through outfalls permitted through the
NCG02 Certificate of Coverage and will meet state water quality discharge limits through onsite
treatment prior to discharge to receiving waters. Water quality and flow will be monitored prior to
discharge. Therefore, the Project will not impact downstream water resources.
3. The operation will violate standards of air quality, surface water quality, or
groundwater quality that have been promulgated by the Department;
A minor source air permit application has been submitted to the Division of Air Quality to
construct and operate stationary sources associated with the mining process, pursuant to
requirements of 15A North Carolina Administrative Code (15A NCAC).
Surface-quality water will be managed onsite, and discharges during normal conditions, will be
routed through outfalls permitted through the NCG02, which is authorized by the U.S.
Environmental Protection Agency's National Pollutant Discharge Elimination System (NPDES)
program. PAG contact water will be treated at a WTP prior to being stored in WSB-1, which will
also be used to store non-contact water and allow suspended solids to settle out of the water
column prior to discharge. Water leaving the site will be monitored prior to release for
compliance with all applicable surface water quality discharge limits.
The potential for groundwater quality to be impacted by the proposed Project has been
extensively evaluated through monitoring, leachability analyses, and predicted flow path
modeling. It was concluded that groundwater contributions to surface waters will not cause an
exceedance of the North Carolina Department of Environmental Quality (NCDEQ) Class C
Water Quality Standards. Additionally, all potentially acid generating (PAG) material derived
from mining and processing activities will be temporarily stored in an area designated as RSF-X,
which will be underlain with a high-density polyethylene (HDPE) liner for the protection of
groundwater. The collection ponds associated with RSF-X will also be lined. Water from these
ponds will be pumped to the WTP and treated prior to release into WSB-1. Water treatment at
the WTP will no longer be required after all PAG materials from RSF-X have been removed and
placed in the pit as backfill during post-closure. WSB-1 would remain in place to continue to
provide passive water treatment before discharging to an unnamed tributary to Kings Creek.
Particle tracking simulations and modeling were also performed, which concluded that the
groundwater is shallow and will flow towards the open pit and/or report to Kings Creek or South
Creek located within the Project boundaries.
4. The operation will constitute a direct and substantial physical hazard to public health
and safety or to a neighboring dwelling house, school, church, hospital, commercial
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or industrial building, public road or other public property, excluding matters relating
to use of a public road;
Precautions to prevent physical hazards to neighboring properties from flyrock, excessive
airblasts, or ground vibrations will be implemented and are detailed in a blasting impact study
recently conducted for the Project. See the response to Section C.7. of this document.
Additional precautions to prevent physical hazards to neighboring properties, from flooding, air
emissions and fugitive dust are detailed in Appendix F: Stormwater Management Plans and
Erosion and Sediment Control Plans.
5. The operation will have significant adverse effect on the purposes of a publicly
owned park, forest or recreation area;
The Project will not significantly adversely affect the purposes of publicly owned parks, forests,
or recreation areas. A VIA was performed to determine the presence, type, extent, and location
of buffers to provide screening from the Project during construction, operations, and post-
closure.
The results of the study indicate that there will be no long-term visual impacts from the Project,
as the majority of the infrastructure, buildings, RSF-X, and OSFs will be reclaimed. RSF-A will
remain, although it will be graded and revegetated to match the existing contours and
appearance of the surrounding landscape. Refer to Sections C.S. and C.10. for further details.
Albemarle conducted blast and vibration analyses that indicate operations will not produce
adverse impacts at any nearby public park or recreation areas. The analysis determined that
adverse impacts will not be detectable at Patriots Park or within Crowders Mountain State Park,
which are located 0.5 miles and 2 miles from the Project boundary, respectively. The Project will
not cause increased traffic next to or through these public areas.
Due to the distance of the state park from the Project, and post-closure compatibility with the
landscape, no significant impacts are anticipated with respect to noise, vibration, dust, or traffic
generation.
6. Previous experience with similar operations indicates a substantial possibility that the
operation will result in substantial deposits of sediment in stream beds or lakes,
landslides, or acid water pollution;
Previous mine operations with the same processes occurred on the site from the 1940s to
1990s without causing any of these adverse effects.
The Project will implement E&S controls during construction and operations to prevent sediment
leaving the site or entering jurisdictional watercourses and wetlands. Appropriate permanent
and temporary best management practices (BMPs) will be installed and maintained at all times.
As mentioned in Criteria 3 above, all stormwater and wastewater will be managed onsite and
only discharged through approved NCG02 outfalls during normal conditions. PAG material will
be stored at RSF-X, which is designed to include an HDPE geomembrane liner and contact
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water collection ponds. This water will be treated by the WTP and then pumped to WSB-1 for
temporary storage prior to offsite discharge. Landslides will be avoided by instituting the
following methods, procedures, and facility design and construction methods. Permanent fill
piles will be constructed to meet the state's minimum slope requirements (2 horizontal to 1
vertical or flatter for clayey material, and 3 horizontal to 1 vertical or flatter for sandy material).
All low-strength materials in the RSF excavation footprints (foundation subgrades) will be over
excavated during construction to improve facility stability. A pit slope monitoring system will be
instituted that will include observation, inspections, and instrumentation and immediately
notifying the appropriate Project supervisor of any poorly performing pit or slope conditions. Pit
wall design strategies (that will include blasting designs, scaling, cleanup to reduce the rock fall
hazard and maximize bench performance), geotechnical pit mapping (including structural
geology to assist in ground control management), pit slope and groundwater monitoring with
defined trigger levels/thresholds and updating stability and pore pressure analyses to verify new
pit designs will be implemented. In addition, a written ground control plan will be established and
followed for safe control of highwalls, pits, and spoils banks left over from legacy mining
operations.
7. The applicant or any parent, subsidiary, or other affiliate of the applicant or parent
has not been in substantial compliance with the Article, rules adopted under this
Article, or other laws or rules of the State for the protection of the environment or has
not corrected all violations that the applicant or any parent, subsidiary, or other
affiliate of the application or parent may have committed under this Article or rules
adopted under this Article and that resulted in:
a. Revocation of a permit,
b. Forfeiture of part or all of a bond or other security,
c. Conviction of a misdemeanor under G.S. 74-64,
d. Any other court issued under G.S. 74-64,
e. Final assessment of a civil penalty under G.S. 74-614, [or]
f. Failure to pay the application process fee required under G.S. 74-54.1.
Albemarle's previous, current, and proposed operations have been consistent with Article 74-51,
and rules adopted under the Article, including those listed in a. through f. above.
A. GENERAL CHARACTERISTICS OF THE MINE
The KMM site is located at 348 Holiday Inn Drive, Kings Mountain, North Carolina. It is
comprised of approximately 1,083.43 acres of disturbed, undisturbed, and developed lands that
are bisected by 1-85 (Figure 5: Aerial Location Map).
Albemarle intends to reopen the existing KMM, which ceased operations in the early 1990s, and
re-establish production of spodumene concentrate to meet current and expected demands for
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lithium products. Current land use surrounding the Project area includes residential and
commercial developments, forested areas, and other industrial mining facilities. Existing
topography is highly variable throughout the Project site and is described in further detail below
(Figure 6: Topographic Location Map).
The Project will consist of three primary stages:
• Construction
• Operations
• Post-closure/final reclamation
Progressive reclamation of disturbed areas will occur during operations when possible, and final
reclamation will be performed after all mining and processing activities have ceased.
Existing Legacy Features
The legacy mine was reclaimed to meet closure requirements after operations ended in the
1990s. These reclamation activities included slope grading, revegetation of disturbed ground,
and allowing the open pit to fill with freshwater through natural hydrologic processes. Much of
the legacy ore processing equipment and the spodumene concentrator plant were removed,
though remnants of the mining operations still exist, including (Figure 7: Legacy Mining Facilities
Map):
• An open pit with a pit lake that filled with water from rainfall, runoff, and groundwater;2
• An excavation associated with a legacy tin mine (known as PEG-25);
• An infrequently used spur rail line;
• Two legacy TSFs where tailings from previous operations were placed into settling ponds;3
• Several RSFs where waste rock from previous mining operations was stored and remains;
• Several storage and mill ponds;
• Several repurposed mine operation support buildings;
• Access roads; and
• Radioactive mining refuse within the footprint of the Kings Mountain Facility.4
Existing Conditions and Materials
The documents summarized in Table 1 specifically describe the existing site conditions,
resources, and materials to be used in the proposed Project, which have either been appended
or referenced in this document:
2Albemarle began pumping water from the open pit in April 2024 as authorized under Permit NC0090212.
3One of the legacy TSFs is currently dry, the other retains water from continuing precipitation runoff.
4 The refuse was encased in a clay liner and buried in the legacy tailings area in 2001, in accordance with a plan
approved by NCDEQ.
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• Streams and wetlands (SWCA 2023a);
- Figure 8: Surface Water Features Map shows the Project relative to the existing
watershed and streams;
- Figures 9 through 13: Wetland Delineations show the wetlands delineation map,
including jurisdictional wetlands;
- Figure 14: Location of the 100-Year Floodplain Limits shows the 100-year floodplain
limits map;
- Figure 15: Monitoring Well Network shows the monitoring well map;
• Soils classification map (Figure 16: Soils Map);
• Cultural resources including existing land uses dominated by mining zones (Figure 17:
NRHP Listed for Eligible Site Map);
• Geology map (Figure 18: USGS 2008 Geology Map);
• Pit geotechnical characterization (Appendix A: Abridged Select Phase Geotechnical Report
- Pit Stability and Modeling of Appendix G: Geotechnical Stability Reports, Calculations, and
Cross-Sections) and borehole map (Figure 19: Location of Geotechnical Borings); other site
geotechnical characterization results have been described by SRK (SRK 2024bc, 2024c);
• Baseline geochemistry characterization study for KMM materials (Appendix H: 2023
Prefeasibility Study- Baseline Geochemical Characterization [Abridged]) to:
- Construct the proposed facilities (RSFs, WSB-1, and TSF); and
- Characterize the tailings and non-PAG waste rock to be used for the construction of the
TSF embankment.
Table 1: Summary of Existing Conditions Near the Kings Mountain Mine Site
ReportExisting Resource Consultant(Report Appendix/Figure in this
Existing Conditions Site Map This document Figure 20
Wetlands and waterbody delineation SWCA 2023 Figures 9-13
Federally and State-Listed Species Report SWCA Appendix L
for the Kings Mountain Lithium Mine
Phase I Archaeological Surveys for the SWCA 2023b; 2024 Figure 17
Proposed Kings Mountain Mining Project
Geology SRK 2024a Figure 18
Hydrogeology SRK Appendix D
Site and Pit geotechnical (characterization) Appendix G
conditions:
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ReportExisting Resource Consultant (Report Appendix/Figure in this
• RSF-A and RSF-X SRK 2024b -
• WSB-1 SRK 2024c -
• Additional open pit characterization SRK 2024a Figure 19
Terracon 2024
Plant site and roads
KMM baseline geochemical SRK Appendix H
characterization including waste rock and
tailings
KMM = Kings Mountain Mine; RSF = rock storage facility; SRK= SRK Consulting U.S., Inc;
SWCA= SWCA Environmental Consultants; USACE = U.S. Army Corps of Engineers;
WSB-1 =Water Storage Basin 1
Permitted and Ongoing Activities
Albemarle currently operates lithium compound and metal production facilities within a 16-acre
fenced area of the former mining site. The existing lithium compound production facilities
receive raw materials from other Albemarle or external suppliers and do not have the
specialized equipment required to extract lithium compounds from the mine product
(spodumene concentrate). Thus, although the existing plant will coexist with the mine, there will
be no interdependence or relationship between the two distinct facilities.
The former mine site also houses the Technology Center, which was constructed in 2012 and
houses research and development activities, plant support, and corporate functions. Together,
the existing production facilities, Technology Center, and proposed Duke Energy substation
occupy a 60.48-acre area that will be excluded from the Project and the mine permit boundary.
As previously mentioned, Albemarle holds two NCDEQ mine permits: KMM 23-01 (East Mine
Permit) and 23-34 (West Mine Permit). Affected acreages for each of the permits are depicted in
Table 2.
Table 2: Existing Permitted and Proposed Kings Mountain Mine Acreages
l�Permit Permitted Acreage Disturbed Acreage
East Mine 23-01 460.13 270.22
West Mine 23-34 161.9 95.92
Proposed modification 1,083.43 634.7
Site preparation activities have been authorized by modifications to the existing East and West
Mine permits and construction general permits and will occur prior to infrastructure construction.
Site preparation activities will include clearing and grubbing, relocation of utilities, and
construction of temporary access roads. Existing site conditions, prior to site preparation are
shown on Figure 20: Existing Site Conditions (LOM Phase 0).
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Clearing and grubbing will occur for temporary access roads for utility reroutes, at the offset
corridor for utility reroutes, and at roads along 1-85. Growth media will be salvaged and stored.
Relocated utilities will include the sewer force main line, the Dominion Energy and City of Kings
Mountain gas distribution lines, and the Rutherford and Duke Energy electrical overhead lines.
E&S control BMPs are identified in the relevant permits that authorize the work and will be
installed and maintained during site preparation. These controls will prevent unauthorized
discharge from leaving the site until the permanent stormwater management system can be
constructed.
As previously mentioned, the pit lake is being dewatered pursuant to conditions within NPDES
Permit No. NC0090212.
Proposed Features
This Project will ultimately result in reclamation of the site after both legacy and proposed
mining activities, creating an overall beneficial site use through the regulated reclamation
process. The Project will result in permanent vegetative buffers, improved public safety, and
restored topography and hydrology through the excavation and reclamation of an existing
resource that has historically been, and will continue to provide, an economic benefit to the
community. This section describes the features and activities Albemarle proposes to be
permitted by this application, not including features or activities itemized in the Permitted and
Ongoing Activities section above.
Key features that will either remain in place with modifications from the legacy mine, or will be
newly added for Project operations, are described in detail in Section C below and depicted on
Figure 21: Kings Mountain Mine Site Layout Overview Map.
• One growth media storage (GMS) area will be constructed to stockpile suitable overburden
generated during construction. This material will be temporarily stored for future use as soil
coverage to reclaim mine features.
• The footprint of the previously dewatered, legacy open pit will be expanded 900 feet to the
southwest and the pit floor will be deepened another 465 feet by drilling, blasting, loading,
and hauling to obtain and transport the lithium-bearing ore and the non-ore waste materials
(see Figure 22: Proposed Pit Map and Cross-Sections). The pit will be mined over 9.4 years
and will have final dimensions of 3,000 feet in length, 1,800 feet in width, and 800 feet in
depth (relative to the pit crest elevation), ending with pit wall heights and overall slope
angles ranging from 650 feet and 37 degrees (east wall) to 705 feet and 53 degrees (west
wall) below grade (see Figures 22 and 23: Proposed Pit Map and Cross-Sections; and Map
and Cross-Section Showing the Pit Geotechnical Domains and Sectors). The maximum
depth of the final pit excavation will be at an elevation of approximately 195 feet above
mean sea level (amsl) (the current elevation of the legacy pit floor is at 660 feet amsl).
• A run-of-mine (ROM) pad will be constructed to temporarily stockpile and manage ore mined
directly from the open pit before processing. It will be located southeast of the open pit and
northeast of the crushing and screening circuit (Figures 22, 24, and 25).
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• Some non-ore bearing rock with economic value as aggregate will be transported by haul
truck to the adjacent Martin Marietta quarry. The remainder will be stored onsite as
described below.
• Three RSFs will be built in even platforms/benches using dozers and haul trucks to store
non-ore bearing rock generated by the Project. The majority of the RSF waste rock materials
will be transported from the open pit (fragmented material from blasting) using haul trucks.
The RSF Design Sheets are included in Appendix A: RSF-A and RSF-X of Appendix C:
Design Sheets, and RSF engineering design information is detailed in Appendix A:
Prefeasibility Engineering Design Report for Rock Storage Facilities A and X of Appendix I:
Abridged Engineering Design Reports and summarized below.
- RSF-A will store non-PAG rock along with legacy tailings and coarse embankment
material removed from the legacy TSF during construction of RSF-X, and other non-
PAG materials generated in the ore sorting and dense media separation (DMS) circuits.
RSF-A will continue to grow as mining progresses, ultimately reaching a height of 380
feet above grade (and reaching 1,200 feet amsl after reclamation). RSF-A will be a
permanent stockpile.
- RSF-X will store PAG rock and other materials removed during processing that have
acid generating potential (ore sorter and DMS rejects). RSF-X will be underlain by an
HDPE geomembrane liner to allow collection of seepage and contact water for treatment
prior to offsite discharge. RSF-X will be temporary as the PAG fill material from it will be
removed and placed as backfill in the open pit as part of activities related to closure.
Design information for RSF-X can be found in Appendix A: Pre-feasibility Engineering
Design Report for Rock Storage Facilities A and X of Appendix I: Abridged Engineering
Design Reports.
- RSF-W will be used to temporarily store PAG material in a designated area at the
bottom of the open pit while construction of RSF-X is underway. Material temporarily
stored in RSF-W will be relocated to RSF-X when construction is complete.
• Three OSFs (OSF-1, OSF-2, and OSF-3) will also be constructed in even platforms/benches
using haul trucks, over the highway trucks, and dozers to store saprolite and overburden
soils excavated from under RSF-A, RSF-X, and from the legacy Archdale pit, to establish
adequate foundation conditions and stability for those storage facilities. The OSFs will be
created early in the construction process and will immediately be revegetated once no
longer needed.
• A WTP will be constructed for the treatment of PAG contact water from RSF-X for permitted,
offsite discharge and onsite reuse at the concentrator facility. The WTP will use chemical
treatment, including processes for pH adjustments and sodium hypochlorite (bleach), for
precipitating metallic compounds. The WTP will also involve ultrafiltration and primary and
secondary reverse osmosis processes prior to water being pumped into WSB-1 (see
Appendix C: WTP Process Description of Appendix I: Abridged Engineering Design
Reports). Sludge will be stored in a tank for 48 hours before being sent to a sludge thickener
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tank for clarification. Two waste streams will be generated from the WTP (see WTP Process
Flow Diagram in Appendix D: Water Treatment Plant Block Diagram of Appendix C: Design
Sheets): reverse osmosis brine that will either be disposed of through the onsite City of
Kings Mountain sewer system (if the discharge requirements are met) or at an approved
offsite facility, and filter cake waste solids generated from the WTP filter press, which will be
disposed of offsite at an approved solid waste handling facility.
Chemicals used in WTP operations will include:
- Sulfuric acid
- Caustic
- Sodium hypochlorite
- Coagulant
- Flocculant
- Anti-scalant
• WSB-1 will be created from the legacy Executive Club Lake and be used for water storage
and sediment control for the collected stormwater, treated effluent from the WTP, and pit
dewatering flow. Water will ultimately either be discharged offsite through an approved
NPDES outfall or reused (makeup water) in mining operations (Appendix B: Prefeasibility
Engineering Design Report for Water Storage Basin 1 of Appendix I: Abridged Engineering
Design Reports).
• Several ponds to retain and collect stormwater will be constructed. Some of these ponds will
provide sediment control prior to discharge into Kings Creek or South Creek. Ponds
associated with RSF-X will also be HDPE lined and will retain and collect water to be
pumped to the WTP. The remaining ponds will be used to collect stormwater that will be
pumped to WSB-1 for sediment control.
• A crushing and screening circuit will be constructed and operated through three main
stages: primary, secondary (including ore sorting), and tertiary (see Figure A-1: Generalized
Process Plant Flow Diagram, below). The circuit will be designed to reduce the size of the
ore and perform initial separation of lithium-bearing minerals from non-lithium-bearing
minerals in the ore sorting process.
• A plant feed stockpile will be constructed to store ore produced from the crushing circuit and
to serve as feed to the concentrator (this plant facility building is shown on the Mine Layout
Map on Figure 21: Kings Mountain Mine Site Layout Overview Map). The concentrator will
be a facility that further physically separates spodumene concentrate from the supplied ore
feed. The concentrator will be located on the south side of 1-85 and will consist of:
- A DMS circuit that will produce coarse spodumene concentrate product and "rejects"
(material that does not contain spodumene ore and which will be transferred to the
appropriate onsite RSF for storage) (Figure A-1: Generalized Process Plant Flow
Diagram, below). The liquid used in DMS will consist of a mix of water and ferrosilicon
Doc No.: KM60-EN-RP-9079 12

North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
(FeSi), controlled to target a slurry specific gravity that allows material lighter than the
target specific gravity to "float" and heavier material to "sink." The discharge from the
DMS cyclones will go through screens and then magnetic separators to the recovery
media (i.e., FeSi). DMS material will not have a chemical coating.
- A grinding circuit that will prepare material remaining after DMS for further processing
(see Figure A-1: Generalized Process Plant Flow Diagram).
- Desliming and magnetic separation of impurities (see Figure A-1: Generalized Process
Plant Flow Diagram).
- Flotation circuits to remove mica and other materials to produce a finer grade
spodumene concentrate product, separating it from tailings, which will be thickened and
filtered to enable transport from the site (see Figure A-1: Generalized Process Plant
Flow Diagram).
- A list of proposed chemicals used in the spodumene ore sorting and DMS circuits and
the concentration plant will include (See Appendix J: Safety Data Sheets for the reagent
and chemical safety data sheets):
■ SYLFAT FA2
■ Washington Mills Duramet
■ MAGNAFLOC 10
■ FLOTIGAM EDA
■ 4-Methyl-2-pentanol
■ Soda ash (Na2CO3)
■ Sodium hydroxide (NaOH)
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
Figure A-1: Generalized Process Plant Flow Diagram
Onf ham primary
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Flns U20
Conce,*rsce o To TSF
19 To RM PRG R8F
sp.dum Mla Tall.
• A covered conveyor system will be constructed and used to transport ore and other
materials across the site, including over 1-85. Filtered tailings will be loaded onto trucks and
transferred to the offsite Archdale TSF using South Battleground Avenue, via U.S. 29 /
Highway 216.
• Two NPI areas (Figure 26: Mine Layout with Acreage Table) will be located at the KMM site
(north and south of 1-85) to support mining and processing operations. The north NPI area is
located west of the open pit, while the south NPI area is located adjacent to the process
plant. NPI will include but is not limited to, maintenance shops, storage areas, roads, offices,
fueling facilities, hazardous material storage, security gates, fencing, a power supply,
stormwater management infrastructure, water and fire systems, a septic/sewer system, and
vehicle wash areas.
• Drilling, loading, hauling, and other mine operations will require mobile equipment including
but not limited to, deck drills, hammer drills, front-end loaders, haul/maintenance/fuel trucks,
excavators, track/wheel dozers, motor graders, pressure washers, forklifts, compressors,
and backhoes.
Be MAPS
As required by the permit application, six copies (two hardcopies and four electronic copies) of
the 7.5-minute quadrangle (North Carolina Geological Survey) and county highway map (North
Carolina Department of Transportation) have been attached on Figures 1 and 2: USGS
Topographic Map; NCDOT Highway Map, respectively.
The unnumbered table in Section B of the North Carolina Mine Permit Application form includes
current and proposed affected acreages.
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
Clearly labeled, scaled mine maps with related Project facilities depicting all mine features
proposed for the life of mine (LOM) have been attached and depicted on Figures 27 through 35.
Table 3: List of Required Maps and Figures
Required Map Required Map Description Required Map Figure (or Appendix)
under Section B Referenced in this Application
a. Property lines of the tracts including . Figure 4: Permitted Mine Areas Map
easements and ROW . Figure 24: Easement Ma
b. Existing or proposed permit . Figures 1: USGS Topographic Map
boundaries with geographic controls . Figure 4: Permitted Areas Map, and
(coordinates) . Figure 25: Kings Mountain Site Layout
and Property Buffers, Figure 26: Mine Site
Layout with Acreage Table are Project
maps showing the latitude and longitude
coordinates.
• Figures 19: Location of Geotechnical
Borings and Drawing 100 in the Design
Sheets for the RSFs (Appendix A) and
WSB-1 (Appendix B)of Appendix C:
Design Sheets show the coordinates in
North Carolina State Plane NAD83 (in
U.S. feet
C. Initial and ultimate limits of clearing Figures 41 and 42: Phase 1 Construction
and grading Stormwater Plan and Phase 2 Construction
Stormwater Plan for facility areas. See
Design Sheet C4.01 (Sheet 1) and 4.02
(Sheet 3)from the Operational E&S Control
Plan Drawings in Appendix D in Appendix A:
Stormwater Management Report of
Appendix F: Stormwater Management Plans
and E&S Control Plans showing the ultimate
limits for clearing and grubbing of the
phased pit mining footprints.
d. Outline of width of buffer zones (both Figure25: Kings Mountain Site Layout and
undisturbed and unexcavated) Property Buffers
e. Outline and acreage of Figure 26: Mine Site Layout Map with
pits/excavations Acreage Table
f. Outline and acreage for stockpile Figure 26: Mine Site Layout Map with
areas Acreage Table
g. Outline and acreage for temporary and Figure 26: Mine Site Layout Map with
permanent overburden stockpile areas Acreage Table
h. Location and acreage of processing Figure 26: Mine Site Layout Map with
plants Acreage Table
i. Locations and names of streams, Figure 8: Surface Water Features Map
rivers, and lakes
j. Outline and acreage of settling and/or Figure 26: Mine Layout Map with Acreage
processing wastewater ponds Table
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
Required Map Required Map Description Required Map Figure (or Appendix)
under Section n&= Referenced in this Application
k. Outline and acreage of planned and Figure 26: Mine Layout Map with Acreage
existing access roads and onsite haul Table
roads
I. Location of planned and existing Figure 20: Existing Conditions (LOM
onsite buildings Phase 0)
M. Location and dimensions of proposed . Figures 41 and 42: Phase 1 Construction
sediment and erosion control Stormwater Plan and Phase 2
measures Construction Stormwater Plan
• Also see Figure 2.1: Temporary Surface
Water Management and E&S Control
Features Map in Appendix E in Appendix
A: Surface Water Management Report of
Appendix F: Stormwater Management
Plans and E&S Control Plans
n. Location of 100-year floodplain limits Figure 14: Location of 100-Year Floodplain
and wetland boundaries Limits
o. Names of owners of record (both Figures 50-56: Mine Adjoining Parcel Maps
public and private)of all tracts of land Series with associated owner names listed in
adjoining the mine permit boundary the table in Appendix S: Landowner
Notifications
P. Names of owners of record (both Figures 50-56: Mine Adjoining Parcels Maps
public and private) adjoining the mine Series
permit boundary that lies directly
across from several human-made or
natural features and within 1,000 feet
of the mine permit boundary
q. Map legend details All map figures
Note: Identified figures are included in Appendix A: Mine and Reclamation Maps, unless otherwise noted.
E&S =erosion and sediment control; LOM = life of mine; ROW= right of way; U.S. = United States;
SGS = U.S. Geological Survey
C. PROTECTION OF NATURAL RESOURCES
This section includes the questions included in the application form followed by detailed,
supporting information and references to specific appendices. Additional information relative to
existing site conditions has also been included where appropriate in an effort to provide concise
summaries and quick references to information that may be pertinent to the review.
1. Describe in detail the sequence of events for the development and operation of
the mine and reference the sequence to the mine map(s).
The Project has been designed to be constructed, operated, and closed in sequence over
defined periods of time as presented in Table 4 below, and within the representative LOM
sequence maps as shown on Figures 20: Existing Site Conditions (LOM Phase 0) and Figures
27 through 30. Site Preparation and Access (-3.5 years) and Site Maintenance (ongoing)
activities as included in these sequence designations have been approved by previous permit
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
modifications to the East and West Mine permits and are therefore not included in this permit
application. However, timing of these activities has been included in this narrative for clarity.
This permit application requests approval for only those activities that commence at the
construction phase, which is from Mining Year-2.5 through Mining Year 0. Construction
activities will commence after permit issuance.
Table 4: Summary of Mining Sequence Time Periods and General Activities
Mine Sequence Designation Mine Sequence Significant Activities a b c d e
(mining years)
Site Maintenance Legacy pit dewatering, excavation and sale of legacy sand tailings.
(ongoing)
Site Preparation and Access Rerouting of sewer force main, Dominion gas line, City of Kings Mountain
(-3.5 years) gas line, Rutherford electrical overhead line, and Duke electrical
overhead 44 kV distribution lines. Construction of temporary access
roads and performing geotechnical borings.
Construction Infrastructure construction: haul roads, ROM pad, crushing circuit, 1-85
(-2.5 years including Mining concentrator bridge/conveyor, Kings Creek haul road culvert, OSFs,
Year 0) RSF-W, RSF-A, RSF-X (initial phase), WSB-1, NPI, concentrate loadout,
GMS, WTP, the concentrator, initial year of open-pit mining, and
perimeter buffer development.
Operations Infrastructure in place (with the exception of the RSFs where waste
(Mining Years 1 to 9.4) materials will be added daily during operations; the later phase of RSF-X
construction will be completed within the first 2 years of operation, as
described in the Section C subsection RSF Construction). New haul
roads will be constructed, including those in and near the pit.
Concentrator facility operations will commence, and tailings will be
generated and hauled offsite to the Archdale TSF. Open-pit mining will
continue throughout.
Interim Operations Rock will continue to be stockpiled at the RSFs, concentrate produced,
(end of Mining Year 5) tailings generated and hauled offsite to the TSF. Construction of new
haul road along the rim to transport material.
Closure Mining will cease along with production of spodumene concentrate,
(after Mining Year 9.4) waste rock, and tailings.
Post-Closure/Final Removal or final reclamation of all mine facilities, and other activities
Reclamation identified in the mine closure plan. The WTP will continue to operate until
all PAG materials from RSF-X have been removed and placed in the pit
as backfill, and all ponds containing PAG contact water have been
drained and treated in the WTP.
Note:
a Stormwater management is required during all mining periods.
b Only significant activities are listed for each period.
-Blasting activities and mining from the open pit and offsite hauling will occur during the 9.4-year life of mine(e.g.,
development and production mining).
d Reclamation will occur concurrently with operations and continue into the post-closure phase.
e See accompanying mine sequence map figures for end of construction, interim operations (Mining Year 5), end of
operations, and end of reclamation.
GMS =growth media storage; kV= kilovolt; NPI = non-process infrastructure; OSF=overburden storage facility;
ROM = run-of-mine; RSF= rock storage facility; TSF=tailings storage facility; WSB-1=Water Storage Basin 1;
WTP =water treatment plant
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
Initial mining of the open pit will begin in Mine Year 0 and ramp up over time, as depicted in the
Annual Mine Production Schedule (Table 5), using conventional drill, blast, and load mining
methods. During the LOM (Mine Years 0 through 9.4), 24,505,000 tons of ore will cumulatively
be hauled to the ROM pad;17,183,000 tons of non-PAG rock and overburden to RSF-A and
OSFs; 10,563,000 tons of PAG rock to RSF-X; and 41,560,000 tons of aggregate rock offsite for
commercial use.
Table 5: Annual Mine Production Schedule
ProductionMine Year Annual
Total • Overburden Aggregate
(including Waste Waste
0 187 1,464 349 263 97
1 2,281 2,075 1,004 0 1,295
2 2,902 869 647 0 1,744
3 3,081 1,345 674 580 2,927
4 2,922 2,505 1,623 545 5,174
5 2,732 2,186 2,300 350 5,432
6 2,916 2,017 2,157 482 7,429
7 3,110 1,583 1,094 182 5,758
8 3,064 619 617 1 7,711
9 1,309 118 100 0 3,992
Total LOM 24,505 14,780 10,563 2,403 41,560
Source:Appendix A: Surface Water Management Report of Appendix F: Stormwater Management Plans and Erosion
and Sediment Control Plans
Production totals are greater or less than total value due to rounding.
LOM = life of mine; non-PAG = non-potentially acid generating; PAG = potentially acid generating
The approximate truck trip schedule is depicted in Table 6 and includes day and night peak hour
trips of material transport and staff to and from the KMM facility. Material transport will begin
when tailings are generated, which is anticipated in Mining Year 0.
Table 6: Truck Trip Schedule
ProposedDaily AM Peak Hour Trips PM Peak Hour Trips
Trips
Tailings shipments a 256 7 7 14 7 7 14
Tailings embankment b 234 6 6 12 6 6 12
Mine staff 620 204 107 311 107 204 311
Mine deliveries 10 2 2 4 2 2 4
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
ProposedDaily AM Peak Hour Trips PM Peak Hour Trips
Trips
Mine visitors and 26 10 2 12 0 10 10
maintenance
Archdale staff 24 6 6 12 6 6 12
Archdale deliveries 4 1 1 2 1 1 2
Archdale visitors and 2 1 1 2 0 0 0
maintenance
TOTAL 1,176 237 132 369 129 236 r 365
Source: Albemarle 2024a
a 20 hours per day, 7 days per week
b non-potentially acid generating waste rock
Specific sequencing relative to this permit application is described by construction and
operational details provided in later subsections. However, to better understand the potential for
adverse impacts associated with sequencing, narrative on current conditions (topography,
surface water, wetland/floodplains, soils, hydrogeology, cultural resources, vegetation, and
wildlife) is detailed in the following subsections.
Current Conditions
The proposed KMM land area has been disturbed over time by historical mining activities, which
has resulted in altered upland landscapes and human-made water features (ponds and
reservoirs).
Topography, Surface Waters, and Surface Drainage
Topography
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 Piedmont province
is characterized by rolling to hilly uplands with well-defined drainage networks consisting of
established streams and creeks and erosional channels that have incised the Piedmont Plateau.
Erosion and gullying have left narrow to broad upland ridgetops and steep slopes adjacent to
the major streams.
Elevations within the Project area range from approximately 755 to 1,074 feet amsl. Lower
elevations occur south of the Project, and higher elevations occur to the east at Crowders
Mountain State Park at approximately 1,700 feet amsl. The highest elevation to the west of the
Project area (immediately west of the existing Kings Mountain open pit) is approximately 1,000
feet amsl.
Onsite topography will be temporarily modified by the construction of the OSFs and RSF-X,
which will all be reclaimed during post-closure. RSF-A will achieve the highest elevation, 1,200
feet amsl, and is proposed to remain post closure, after being regraded and revegetated to
match the landscape of the surrounding area.
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
Surface Water and Drainage
The natural drainage network in the vicinity of KMM is heavily influenced by historical and active
mining activities. The drainage network consists of Kings Creek, South Creek, and a small creek
informally known as Mill Creek, which was impounded to form Executive Club Lake. There are
several artificially created waterbodies that previously supported legacy mine operations (see
Figure 8: Surface Water Features Map). South Creek was impounded in the 1950s to provide a
water source for mine operations, forming the South Creek Reservoir, which remains today.
Kings Creek passes through the Project boundary from northeast to southwest. Prior to entering
the site, water flows past the Martin Marietta quarry pit. Martin Marietta's quarry intermittently
pumps water from its pit into Kings Creek, with a pumping capacity of 2,500 gallons per minute.
As Kings Creek enters KMM, it is routed under the current Technology Center through a 620-
feet long, 4-feet diameter corrugated metal pipe culvert. From the culvert discharge point, Kings
Creek flows to the southwest and joins with the discharge from South Creek Reservoir before
crossing under 1-85 through three 7-feet wide by 10-feet high concrete box culverts. South of
1-85, Kings Creek joins with the discharge from Executive Club Lake before flowing out of the
Project's boundary to the southwest. The upstream headwater basin outside the Project
boundary contributing to Kings Creek is shown on Figure 8: Surface Water Features Map.
South of 1-85, Executive Club Lake (State Dam ID: CLEVE-006) discharges to Kings Creek.
Executive Club Lake was formed during previous mining operations as part of a TSF and
impoundment. An embankment (dam) was constructed to a crest elevation of 850 feet amsl with
a trapezoidal spillway constructed at elevation 845 feet amsl, which was the original control pool
elevation during legacy operations. In the early 2000s, a portion of the embankment was
removed down to 820 feet amsl to allow stormwater to flow through the original dam footprint.
Executive Club Lake collects runoff from the watershed immediately upgradient, with the current
spillway crest at 820 feet amsl allowing for storage of several feet of water. After flowing over
the rock spillway, water joins with Kings Creek approximately 1,500 feet downstream of the
lake. The area below the confluence of Kings Creek and Executive Club Lake is currently
blocked by a beaver dam, forming a large marshy area in the drainage and resulting in localized
flooding.
South Creek begins northwest of the KMM in an area of residential neighborhoods. The creek
flows generally southwards before entering South Creek Reservoir (State Dam ID:
CLEVE-007-H). South Creek Reservoir was constructed in the mid-1950s as part of historical
mining activities and was used as a water source for the former mine. The culverts discharge to
a rock energy dissipater that joins Kings Creek.
Several human-made, isolated waterbodies are within the KMM boundary, the most prominent
being the mine pit lake. The mine pit lake formed in the historical open pit and throughout its life,
no natural discharge flowed to the stream network. Water from the pit lake was sporadically
pumped from the legacy mine pit lake to the adjacent Martin Marietta aggregate quarry.
Dewatering of the lake began in April 2024 and is expected to take approximately 18 months.
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
No. 1 Mill Pond is a historical water management feature previously used to supply process and
firewater from the Kings Mountain Facility to the legacy plant. It infrequently discharges through
a culvert under the railroad spur into Kings Creek. Mud Pond 1, Mud Pond 2, and PEG-25 Pond
collect local stormwater but have no discharge capabilities.
No High Quality Waters or Outstanding Resource Waters, as defined by the NCDEQ Division of
Water Resources, are present within, immediately adjacent to, or downstream of the Project's
permit boundary. Kings Creek and the other streams onsite are Class C waters as defined by
the NCDEQ Division of Water Resources.
The Project will affect the drainage features describe above as follows:
• Isolated water bodies Mill Pond 1, Mud Ponds 1 and 2, and PEG-25 will no longer exist.
• Direct impacts to existing stream features and wetlands (discussed in wetland section).
• The elevation of Executive Club Lake will be increased, as it is converted to WSB-1.
• Kings Creek will have a slight increase in flow during operational phase based on modeling
results and predicted flows with the increases coming from the addition of pit dewater flows
and capture of flows previously contributing to a closed basin (e.g., the Kings Mountain pit
lake) (summary conclusions are included in Appendix K: 2023 Prefeasibility Study: Surface
Water—Water Balance Development Report).
Wet/ands and Fioodpiains
The Federal Emergency Management Agency National Flood Hazard map of the area depicts
approximately 21 acres of the KMM site being within Zone AE of the 100-year floodplain. These
mapped floodplain areas are located along Kings Creek (Figure 14: Location of 100-Year
Floodplain Limits). However, no facilities or infrastructure will be constructed within any portion
of the 100-year floodplain.
Wetlands and non-wetland waterbodies are present on the KMM site and are considered
jurisdictional under both North Carolina and federal regulations (Figures 9 through 13: Wetland
Delineations). Three wetland community types were identified and delineated on the KMM site.
In addition, streams and open water bodies (palustrine unconsolidated bottom) were also
identified and delineated. Wetland vegetative communities include:
• Palustrine emergent wetland (PEM): The PEM wetland communities consist of a
prevalence of hydrophytic non-woody vegetation and are generally located in open areas
without a tree canopy layer. Many of the emergent wetlands are located along pond and
stream edges, or in small depressional areas where woody vegetation has not developed. In
addition, emergent wetlands are found within maintained and mowed utility line easements.
Dominant species include giant cane (Arundinaria gigantea), bushy bluestem (Andropogon
glomeratus), lamp rush (Juncus effusus), cottongrass bulrush (Scirpus cyperinus), lesser
poverty rush (Juncus tenuis), fowl bluegrass (Poa palustris), shallow sedge (Carex lurida),
and goldenrod.
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
• Palustrine forested wetland (PFO): The PFO wetland communities consist of a prevalence
of hydrophytic woody species that are approximately 20 feet or greater in height and 3
inches or greater in diameter at breast height. Most of the forested wetlands are mature
forests with large trees along streams or within the artificially influenced flooded areas.
Smaller forested wetlands are generally associated with the emergence of groundwater on
hillsides adjacent to streams and likely do not have year-round surface water. Several
forested wetlands are located along the edges of lakes and ponds that may be periodically
inundated after large storm events. The tree strata are dominated by red maple (Acer
rubrum), American sycamore (Platanus occidentalis), water oak (Quercus nigra), sugarberry
(Celtis laevigata), American elm (Ulmus americana), and sweetgum.
• Palustrine scrub-shrub wetland (PSS): The PSS wetland communities consist of a
prevalence of hydrophytic woody vegetation less than 20 feet tall. Most of the scrub-shrub
wetlands in the Project area are located in linear depressional areas along the Gateway
Trail or within portions of the Executive Club Lake wetland complex that are subject to
periodic flooding. Most of these wetlands occur as dense thickets dominated by only a few
scrub-shrub species and have a sparse herbaceous layer. The scrub-shrub strata are
dominated by brookside alder (Alnus serrulata), American sycamore, black willow (Salix
nigra), Chinese privet (Ligustrum sinense), and red maple.
The development of facilities and infrastructure will affect several wetlands, watercourses, and
waterbodies through the removal of vegetation, infilling of wetlands and waterbodies, or
construction of dams, diversions, or culverts affecting the form and function of the waterbodies
and/or watercourses. Impacts are quantified in Table 7
Table 7: Impact Summary to Proposed-Jurisdictional Resources
Area Description Impacts
mm�
1 North NPI 0.3 1,303 x
2 South Creek road crossing x 384 x
3 OSF-1 0.5 1,598 x
4 RSF-A 0.02 1,736 x
5 Kings Creek haul road x 116 x
6 ROM pad 0.3 561 x
7 WSB-1 dam 0.26 226 0.14
8 WSB-1 inundation 3.58 x 10.93
9 Concentrator plant 0.36 x 0.04
10 Mine pit expansion x 446 x
Total 5.32 6,370 11.11
ac= acre;ft=feet; NPI = non-process infrastructure; OSF =overburden storage facility; ROM = run-of-mine;
RSF= rock storage facility; WSB-1 =Water Storage Basin 1
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North Carolina Mine Permit Supplemental Report
Kings Mountain Lithium Mine Project
soils
The U.S. Department of Agriculture Soil Survey maps 16 soil unit types and three non-soil units
within the Project area. The majority of the soils are classified as well drained with 2 percent
(Chewacia loam, 0 to 2 percent slopes) composition of hydric units (Figure 16: Soils Map). The
site 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).
Mapped soils unit types will not be impacted by the Project, although some areas may be
homogenized during closure as a result of reclamation. Overburden and growth media will be
stockpiled during operations to minimize the need to bring in offsite material.
Geology
The Project is located within the Kings Mountain mining district and is centrally located within
the Piedmont Plateau. The Piedmont Plateau ranges from 750 to 1,050 feet amsl and consists
of both igneous and sedimentary rocks with various grades of metamorphism and weathering.
The metasedimentary rocks include assemblages of gneissic and schistose rocks.
North Carolina's tin-spodumene belt lies within the Inner Piedmont terrane, an orogenic core
formed during the Devonian-Mississippian, Acadian-Neoacadian orogeny of the southern
Appalachians. The Inner Piedmont stretches for approximately 435 miles strike length from
Winston-Salem in North Carolina to the Coastal Plain in Alabama, bound between the Brevard
Fault Zone to the northwest and the Central Piedmont Suture to the southeast
(Merschat et al. 2012). Rocks of the Eastern Inner Piedmont, the Cat Square terrane, are
unconformably abutted against the exotic peri-Gondwanan Carolina super terrane along the
Central Piedmont Suture. Spodumene pegmatites hosted by rocks of the Cat Square terrane,
occur along the reactivation of this major tectonic boundary called the Kings Mountain Shear
Zone.
The Kings Mountain Shear Zone is a zone of ductile mylonitic deformation that extends for at
least 37 miles, no more than a few hundred feet wide, and provides a boundary between two
terranes within the Piedmont Plateau including the Kings Mountain and Inner Piedmont Belts.
The proximity of spodumene pegmatite dikes to the Kings Mountain Shear Zone and the
development of deformational fabrics constrained through Rb-Sr age dating, suggest that the
zone controlled their emplacement (Horton 1981). Spodumene pegmatites throughout the Kings
Mountain Shear Zone exhibit sheared or mylonitized textures and are parallel in trend, oriented
northeast-southwest.
In the Kings Mountain area, Horton (2008) has mapped three stratigraphic groups consisting of
intrusive, Cat Square terrane (Eastern Inner Piedmont Layered Metamorphic rocks), and Kings
Mountain Belt (Carolina Terrane). In the Carolina Terrane, the Neoproterozoic Blacksburg
Formation is dominantly a metasedimentary sequence of schist and phyllite with interlayered
marble, amphibolite, calc-silicate rocks, and micaceous quartzites; these are conformably
divided from the Battleground Formation by the Kings Creek Shear Zone. The Cat Square
terrane is composed of Cambrian or Neoproterozoic amphibolites and mica schist.
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Mississippian aged intrusions consisting of Cherryville Granite, granite pegmatite, and
spodumene pegmatites intrude the mica schist and amphibolite units of the Cat Square terrane
along the Kings Mountain Shear Zone.
The geology map on Figure 18: USGS 2008 Geology Map identifies the previously identified
formations, intrusive rocks (including spodumene pegmatite), and surface materials and shows
the permit boundaries for the Project. Rocks from the Blacksburg formation are exposed on the
surface where the proposed southern NPI infrastructure and WSB-1 will be located.
Spodumene pegmatites, averaging up to 20 percent spodumene, vary in thickness and overall
extent. Hundreds of these spodumene pegmatite dikes occur in the Kings Mountain area, with
most less than 10 feet thick while the largest dikes are approximately 400 feet thick and 3,300
feet long.
The Kings Mountain deposit is a lithium-bearing rare-metal pegmatite intrusion that has
penetrated along the Kings Mountain Shear Zone. The pegmatite field at Kings Mountain is
approximately 1,500 feet wide at its widest point in the historical pit area and narrows to
approximately 400 to 500 feet in width at its narrowest point south of the historical pit. The
pegmatite field has a strike length of approximately 7,500 feet. Lithium mineralization is
predominantly contained in the pyroxene group mineral spodumene. Minor lithium
mineralization is also hosted in lithium-bearing alteration assemblages replacing primary
spodumene and includes muscovite. The spodumene pegmatite bodies exhibit a texture-based
variation in lithium grade, spodumene grain size, mineral alteration, and rock hardness.
Surface exposures on the Kings Mountain property are limited to areas of historical mine
workings. The remainder of the property is either blanketed under a deeply weathered saprolite
profile based on recent geotechnical investigations, rarely preserving any remnants of the
protolith, or overlain by historical spoils or stockpiles. Units of Cat Square terrane dominate the
property and host the spodumene pegmatite deposits. The eastern limit of the former open-pit
mine on the property coincides with the Kings Mountain Shear Zone and as a result the units
belonging to the Blacksburg formation are largely observed in borehole cuttings and drill core.
Five primary geologic units were identified at the Project site by geotechnical investigations
conducted in 2022 and 2023 and are described below (SRK 2024b, 2024c). Geological and
geotechnical strength characteristics for each unit from the pit to help with slope stability
assessments are also described in SRK's Factual Report, Kings Mountain Mining Project(SRK
2024a) and in Appendix A: Abridged Select Phase Geotechnical Report - Pit Stability and
Modeling of Appendix G: Geotechnical Stability Reports, Calculations, and Cross-Sections and
are based on geotechnical boreholes presented on Figure 19: Location of Geotechnical Borings.
• Overburden soils: Layers of remaining intact surficial soil or other material situated above
the saprolite layer where there is no historical surface disturbance are typically identified and
logged as overburden soil (residual soil). These soils were classified per the United Soil
Classification System as silt and dense silty sand.
• Saprolite: Saprolitic soils resulting from in-situ weathering of local bedrock were identified at
various thicknesses across the site. Saprolite typically consists of micaceous sandy silts and
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Kings Mountain Lithium Mine Project
silty sands with low-plasticity clay minerals. The transition from residual native (overburden)
soil to saprolite was noted in the borehole logs where a distinct change in color, United Soil
Classification System classification, and density were observed. Saprolite was found
between ground surface and approximately 20 feet below ground surface (bgs) in the 2022
and 2023 to 2024 investigations associated with the prefeasibility site characterization
studies (SRK 2024b; 2024c).
• Partially weathered rock: The lower portion of the saprolite presented a higher stiffness
and showed more features from the parent rock than could be observed in the upper soil-
like zone. Closer to the weathered bedrock zone, gravel sized fragments of the parent
bedrock were observed in the lower reaches of the saprolite zone. This lower zone of the
saprolite is referred to as partially weathered rock.
Partially weathered rock was identified at depths varying from 16 to 100 feet bgs, with the
uppermost layer between 812.5 and 748 feet amsl.
• Weathered bedrock: Weathered bedrock was encountered at depths from 64 to 143.5 feet
bgs, with the highest point situated at elevations between 771 and 702 feet amsl.
The weathered bedrock presented as sound to highly fractured, fresh to highly weathered,
foliated, and very fine to coarse-grained, with quartzite veins, traces of garnets, and some
pyrite. Rock quality designation values varied between 0 and 38 percent. Some samples of
weathered bedrock had water content values between 7 and 18 percent.
• Unweathered bedrock: Unweathered bedrock was encountered at depths between 90 to
152 feet bgs, with the uppermost horizon between 757 and 690 feet amsl This geological
unit included diverse metamorphic rock types from the Inner Piedmont geologic unit, upper
mica schist, and muscovite pegmatite.
The unweathered bedrock displayed sound to slight fracturing, unweathered to fresh
conditions, was foliated, and showed close to moderate fracture spacing. The unweathered
bedrock presented as fine to medium-grained with pyrrhotite. Rock quality designation
values varied between 19 and 74 percent.
The characteristics of the regional geography are the impetus for this mining project. Long-term
impacts to the geology will be mitigated through reclamation during post-closure.
Hydrogeo%gy
The Project site's groundwater system is divided into two main components, surficial regolith
and deeper bedrock. The surficial regolith, composed of overburden, saprolite, and weathered
bedrock, is considered the high hydraulic conductivity component of the system. Both
historically and in future mining, most of the hydraulic drawdown from mining is understood to
occur in the surficial regolith. The historical recovery of the pit lake is believed to be mainly
through recharge and flow in the surficial regolith (Appendix D: 2022 Prefeasibility Study—
Hydrogeology Study and Groundwater Modeling). In contrast, hydraulic testing in the bedrock
suggests low to medium hydraulic conductivity ranging from 0.002 to 3 feet per day, which
decreases with depth. Flow in the bedrock is expected to be largely controlled by fractures,
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Kings Mountain Lithium Mine Project
which are mostly present at shallow depths close to the weathered zone. Mining operations are,
therefore, likely to affect water levels in the deep bedrock component to a lesser extent than in
the overlying regolith.
Groundwater flow in the region generally follows topography. Local to the Kings Mountain site,
groundwater flows toward the existing open pit or the creeks as shown on Figure 6-2 in
Appendix D: 2022 Prefeasibility Study— Hydrogeology Study and Groundwater Modeling.
Water level changes are predicted to be close to the proposed pit due to the low permeability of
the rock, which decreases in permeability with depth. Water level changes at the end of mining
can also be viewed on Figure 7-2 in Appendix D: 2022 Prefeasibility Study— Hydrogeology
Study and Groundwater Modeling). Figure 7-2 depicts the drawdown caused by maintaining a
dewatered open pit (in blue) and the mounding that will occur due to the presence of the raised
topography of RSF-A (in red). The difference in head between the surrounding groundwater
system and the pit bottom should increasingly drive water toward the pit. However, as the pit
progresses in depth, the reduction in permeability will cause a reduction in groundwater flow into
the pit. This has been verified through historical observation, as well as packer and aquifer
testing.
Cultural Resources
Historic architecture and archaeological surveys were conducted in the Project area under
consultation with the North Carolina State Historic Preservation Office (SHPO).
• Architectural: The architectural survey included the entire Project boundary and the Area of
Potential Effect, which is defined as the geographic area where the proposed mining
operations will directly or indirectly cause alterations in the character or use of historic
properties. As part of the survey, properties within the Project boundary were evaluated as
potentially considered eligible for listing on the National Register of Historic Places (NRHP).
A map showing a summary of the NRHP eligible and ineligible sites is in Figure 17: NRHP
Listed for Eligible Site Map.
However, after discussion with SHPO, it was determined that only two properties located
within the Project boundary were eligible for listing. Two additional eligible properties were
identified within the Area of Potential Effect, as well as one already listed property (Margrace
Mill Village Historic District). SHPO provided their concurrence and concluded that the
proposed Project has the potential to adversely impact these five properties, due to possible
impacts from blasting, and visual impacts. The Project will require the demolition of both
onsite NRHP eligible properties.
• Archaeological: The survey identified no archaeological resources within the Project
boundary, and SHPO provided concurrence.
Vegetation
Historical mining resulted in heavy disturbance of the endemic vegetative communities at the
site. Agricultural disturbance and urban development have also impacted vegetation since at
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least the 1950s. Most of the currently persisting vegetative communities have developed from
ecological regeneration and natural recruitment within the historical mining areas. Outside the
mining areas and mine tailing landings, most of the Project area consists of deciduous forest
and mixed deciduous-pine forests in various stages of forest succession.
Six upland land use /vegetative communities were mapped within the Kings Mountain site
including:
• Developed
• Forested upland deciduous
• Forested upland evergreen
• Forested upland mix
• Herbaceous upland
Vegetation will be impacted in some areas due to the construction of the facilities and
infrastructure associated with the mining operations. However, much of the mature forested
areas will remain and/or be enhanced with native plantings to reduce visibility from neighboring
properties and roads.
Biology and Wildlife
Field surveys and a desktop review for biology and wildlife were performed in September and
October 2023 (Appendix L: Federally and State-Listed Species Report), to assess the potential
occurrence of federally and state-listed species. The assessment addressed flora and fauna
species protected under the Endangered Species Act of 1973, as amended, as well as North
Carolina state-listed species protected as Endangered and Threatened Wildlife Species of
Special Concern of the State of North Carolina (G.S. 113-331).
The desktop review identified five federally listed species having the potential to occur on the
Project site: northern long-eared bat (Myotis septentrionalis), little brown bat (Myotic lucifugus),
tricolored bat, and the dwarf-flowered heartleaf(Hexastylis naniflora). The survey included the
monarch butterfly (Danaus plexippus), which is currently a candidate for listing under the
Endangered Species Act. However, there is no USFWS-designated critical habitat for federally
listed, or candidate species within the KMM site.
All three bat species were once abundant in North Carolina, although populations have
significantly declined due to white-nose syndrome. Most of the native habitat on the Project site
has been highly disturbed despite there being a closed mine. Acoustic bat surveys were
performed in June 2022 across 15 locations within the suitable roosting habitat of approximately
736 acres at the KMM site. It was determined that northern long-eared bat and little brown bat
calls were not detected; however, the tricolored bat was detected. Most detections occurred
near waterbodies, suggesting this species is using the KMM site for foraging. Since the northern
long-eared bat was not detected in the surveys, and the KMM site is outside the 2023 revised
geographic range, the potential for this species to occur is considered very low. However, as the
little brown bat has similar foraging habitat to the tricolored bat, it has the potential to occur even
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Kings Mountain Lithium Mine Project
though it was not detected. The tricolored bat is not currently listed, but USFWS has proposed
listing this species as endangered. Development within the Project area would impact forested
habitat used by this species and other bats during the summer season. Section 7 consultation
has been initiated with USFWS.
The monarch butterfly has a low potential to occur due to lack of suitable habitat. Neither the
monarch butterfly nor the dwarf-flowered heartleaf were directly observed during the field
surveys.
State-listed species are those listed as endangered, threatened, and/or of special concern and
are protected by the North Carolina Wildlife Resources Commission via the North Carolina
Endangered Species Act of 1987. The North Carolina Wildlife Resources Commission list of
state-listed species for Cleveland County was reviewed to assess whether the species have
potential to occur in the Project area. Based on desktop review and field surveys from 2022 to
2024, the timber rattlesnake (Crotalus horridus), American bittersweet (Celastrus scandens),
and smooth sunflower (Helianthus laevigatus) have potential to occur in the Project area due to
presence of suitable habitat. However, surveys in 2022 and 2023 did not find American
bittersweet or smooth sunflower to be present. Surveys were not conducted for timber
rattlesnake due to lack of predictive survey areas within the Project (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 during various
seasons from 2022 through 2024, and no timber rattlesnakes were observed; therefore, it is
unlikely for this species to be encountered during Project activities. All other state-listed species
have a low or very low potential to occur, primarily due to a lack of suitable habitat.
Sequence of Events during Construction
The sequence of events during construction and operations are described in more detail in the
following subsections. Activities contain herein can be reviewed relative to the current conditions
previously described.
Initial Construction Activities
Prior to construction activities, vegetation will be cleared, and growth media salvaged and
stored in growth media stockpiles. Diversion ditches will be installed to intercept non-contact
(defined below in Section C.3.(A)) surface water drainage and convey it to existing drainage
outlets. Silt fences, or other BMPs and erosion control measures, will be installed downstream
to prevent release of sediment to the environment and to control surface and stormwater runoff.
BMPs will receive scheduled maintenance to achieve performance expectations. The sequence
of BMP installation is described in detail in Section C.2. below.
Perimeter Berm and Buffer Zone Development
Various buffer types will be established throughout the KMM consisting of a combination of
naturally vegetated, planted vegetated, vegetated berms, enhanced evergreen, and undisturbed
buffers. Widths will vary depending on the location of infrastructure relative to property
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Kings Mountain Lithium Mine Project
boundaries and jurisdictional watercourses/wetlands (Figure 25: Kings Mountain Site Layout
and Property Buffers). Additional details are provided in Sections C.5.(A) and (B).
Plant, Infrastructure, and Facility Construction
Construction of the concentrator and associated Project infrastructure including the crushing
circuit, RSFs, OSFs, WSB-1, WTP, haul roads, access roads, 1-85 bridge, NPI areas,
concentrate and tailings loadouts, railway, stormwater management system, and supporting
utilities will be completed in an anticipated 2-year period after receipt of regulatory approvals.
General Construction
Construction of the concentrator plant, WTP and related facilities is expected to occur over
approximately 18 months. Open-pit mining will commence during the first year of construction to
acquire suitable materials for facility development and initial ore feed for concentrator
commissioning and subsequent ramp up.
It is anticipated that broken, weathered bedrock and competent bedrock will be suitable for use
as general fill to construct the mine facilities. It is also assumed that some lower portions of the
residual soil unit may be suitable for construction bulk fill use. A soil specialist or licensed
engineer may be asked to characterize and assess the excavated soil and bedrock conditions to
determine their suitability for general fill purposes.
The construction schedule has been developed and is assumed to include initial mining
operations in the open pit, concentrator, ROM pad, crushing circuit, south NPI, north NPI, 1-85
concentrator bridge or conveyor, Kings Creek haul road culvert, OSFs, RSF-W (temporary—in
place for 2 years), RSF-X (temporary to be used during operations), RSF-A, and concentrate
and tailings loadout areas.
The generalized sequence of construction activities will be as follows:
• Implement E&S control measures (see sequence of BMP installation details in
Section C.3.(A) below).
• Execute clearing and grubbing activities—stockpile vegetation and soil separately in
designated areas.
• Build vegetated berms and establish buffer zones.
• Develop access roads, temporary site service roads, and laydown areas.
• Excavate unsuitable saprolite and overburden beneath facilities where required.
• Remove legacy tailings and embankment materials within the RSF-X excavation footprint
and construct the liner.
• Mining fleet will begin moving bulk waste rock filling areas on the north side of 1-85 between
Kings Creek and other facility locations.
• Commence grading to bulk cut and fill requirements. Place fill and install permanent
drainage systems and erosion control structures (ROM pad wall).
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• Develop utilities infrastructure.
• Develop permanent haul roads.
• Initiate development mining in the open pit.
• Construct permanent infrastructure.
Rock Storage Facility Construction
RSF construction will begin within the deconstruction of the legacy TSF and occur throughout
the LOM. Excavation of saprolite and overburden materials beneath both RSF footprint
locations will be performed and stored in the OSFs.
The stored sand tailings and non-PAG embankment rock will be moved to RSF-A and used
during initial construction. RSF-A will expand as mine operations progress, reaching an ultimate
height of 385 feet above existing grade. PAG material that will ultimately be stored in RSF-X will
temporarily be stored in RSF-W during the first year of open-pit mining, prior to the
commissioning of the concentrator. An 80-mil double-sided, textured, HDPE liner will be
installed within RSF-X and the contact water management pond footprint (Appendix A: Abridged
Prefeasibility Engineering Design Report for Rock Storage Facilities A and X of Appendix I:
Abridged Engineering Design Reports). The subgrade foundation of RSF-X will be graded to
achieve a positive drainage slope of approximately 2 percent to a perimeter drainage
conveyance system, and a contact water pond to collect waters contacting the PAG material will
be built. RSF-X will be constructed in two phases, Phase 1 (southwest) and Phase 2
(northeast), and construction will extend into the initial years of operations. RSF-X will grow as
mine operations progress, reaching an ultimate height of 210 feet above existing grade.
A set of RSF engineering drawings is included in Appendix A: RSF-A and RSF-X of Appendix C:
Design Sheets.
Water Storage Basin 1 Construction
WS13-1 will be constructed within the footprint of Executive Club Lake, which was previously
used as a tailings impoundment. Construction will involve removing legacy tailings and some
coarse rock from the existing embankment to allow reconstruction of the existing concrete-lined
spillway, construction of a gravel blanket drain along the downstream face of the embankment,
and construction of a compacted fill buttress to improve stability (Appendix C: Abridged WSB-1
Calculation Package of Appendix G: Geotechnical Stability Reports, Calculations, and Cross-
Sections). The WSB-1 embankment will consist of suitable fill materials sourced from the
Project. Once completed, the crest of WSB-1 will reach an elevation of 850 feet amsl and will
have downstream and upstream slopes of approximately 2.5 horizontal to 1 vertical incline. A
spillway will be constructed at the northern abutment at an invert of 843 feet amsl. The existing
concrete-lined spillway channel will be replaced with a new concrete channel that will follow the
same alignment. A set of WSB-1 engineering drawings is included in Appendix B: WSB-1 of
Appendix C: Design Sheets, and a map showing the status of the site-wide mine facilities at the
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Kings Mountain Lithium Mine Project
end of construction is shown on Figure 27: End of Construction (End of Mining Year 0) LOM
Phase 1.
Sequence of Events during Operations
During general mine operation, the KMM open pit footprint will be expanded to the southwest by
first removing the suitable growth media, which will then be transported to the GMS area. After
drilling and blasting, the ore will be hauled by truck to the ROM pad where it will be managed to
provide consistent grade feed to the concentrator plant.
Production mining and processing of ore at the plant facility are associated with operations that
will commence after construction of the mine facilities (and after the initial year of development
open-pit mining that will occur during construction) and will continue for approximately 8.4 years
(during Mining Years 1 through 8.4) per the annualized mining schedule presented in Table 4.
Representative maps showing the evolution of the five pit excavations over the 9.4-year LOM
are illustrated on Figure 21: Kings Mountain Mine Site Layout (map and cross-sections of the
five pit phases). In addition, representative sequence map figures showing the evolution of the
open-pit excavation include: the pit after construction is complete after Mining Year 0 (Figure 27:
End of Construction [End of Mining Year 0] LOM Phase 1), in interim operations after Mining
Year 5 (Figure 28: Interim Operations [End of Mining Year 5] LOM Phase 2), and at the end of
operations (end of Mining Year 9.4) on Figure 29: End of Operations (End of Mining Year 9.4)
LOM Phase 3.
The proposed mine plan will expand the legacy open pit by 900 feet to the southwest and
deepen the pit floor another 465 feet (the maximum depth of the planned excavation) to an
approximate elevation of 195 feet amsl (the elevation of the maximum depth of excavation). The
overall slope heights and angles range from 650 feet and 37 degrees at the east wall to 705 feet
and 53 degrees at the west wall, respectively. At the end of operations, the pit excavation will be
3,300 feet long, 1,800 feet wide, and 800 feet deep (relative to the pit crest elevation) (see map
sequence on Figure 29: End of Operations [End of Mining Year 9.4] LOM Phase 3).
During operations, a haul road built and used during construction that extends along the current
rim of the open pit will ultimately be consumed by the pit expansion in approximately Mine
Year 5. As such, a replacement haul road and related BMPs and safety berms will need to be
constructed during operations.
During operations, PAG waste rock originally placed within the RSF-W pit, along with coarse
reject materials from the ore sorting and magnetic separation waste from the DMS circuits, will
be temporarily stored in RSF-X. Some DMS rejects will also be permanently stored in RSF-A.
Filtered non-PAG mica and spodumene tailings generated from concentrator plant operations
will be conveyed to the tailings loadout facility and loaded onto trucks to be transported offsite to
the Archdale TSF for permanent storage. Spodumene concentrate will be conveyed from the
concentrator plant to the concentrate load out facility and transported offsite primarily by rail.
The plant facilities will commence ore processing at the start of operations and will take
approximately 5.3 months of ramp up time before the plant is fully commissioned. Ore from the
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ROM pad will be fed through a three-stage (primary, secondary, and tertiary) crushing system to
reduce size and facilitate continued removal of non-spodumene rock. Ore leaving the tertiary
crusher will be conveyed to the plant ore stockpile located next to the process plant located
south of 1-85 next to the concentrator.
The process plant is a DMS and flotation facility that uses a water process to separate and
refine the ore as summarized on Figure C-1: Material Balance, below. Materials finer than 0.85
millimeters will bypass the DMS circuit and will be sent directly to the grinding (mill) circuit. The
DMS circuit will receive feed sized to -6.3 millimeters to +0.85 millimeters from the crushing
circuit. The two stage DMS circuit will produce a coarse spodumene product that will be dried
prior to a dry magnetic separation stage that will produce the final coarse spodumene
concentrate. The DMS circuit will also produce a coarse reject that will be conveyed to the DMS
magnetic concentrate rejects bin for disposal to the ore sorting pad. The middlings from the
DMS circuit will be combined with the fines from the crushing circuit to feed the rest of the
circuit.
The grinding circuit will consist of a ball mill in closed circuit with fine vibrating screens. The
grinding circuit will be sized so that the milled product is 100 percent passing 300 microns, with
a target P80 of 212 microns. Two stages of desliming will precede mica flotation to remove mica
present in the ore. The mica removed from the ore will be sent to a thickener and filtered before
being conveyed to the mica concentrate and lithium tails stockpile. After mica removal, two
more stages of desliming will follow as well as high intensity conditioning prior to final
spodumene flotation, which will then be thickened and filtered and sent to the concentrate
stockpile. The spodumene concentrate will be conveyed across 1-85 by a covered conveyor for
loading into railcars and transported to an offsite conversion plant for further refinement into
lithium hydroxide monohydrate.
Reject streams from the plant will be comprised of ore sorter rejects, DMS rejects, DMS
magnetite concentrate, lithium flotation tails, and mica concentrate. Ore sorter and DMS rejects
will be conveyed by bin and trucked to the RSFs for disposal. The mica concentrate and
spodumene (lithium) tails will be thickened and filtered, and the final cake will be transported via
a conveyor north across the bridge to a covered tails stockpile located at the tailings loadout
area. Front-end loaders will transfer the tailings filter cakes from the stockpile to trucks for
transport offsite to the TSF.
Material will be moved within the site per the material balance flow chart (Figure C-1: Material
Balance, below). In summary, overburden materials excavated during clearing and grubbing will
either be stored within the GMS area, or within the OSFs. Legacy non-PAG tailings and
embankment materials within the facility excavation footprints will be stored in RSF-A. Waste
rock generated from the open pit during construction and operations will be classified as non-
PAG or PAG using a waste rock management and geochemical analysis plan (to be
developed). PAG waste rock will be temporarily stored at RSF-W, which will be located inside
the pit while RSF-X is being constructed. Non-PAG waste rock mined from the pit will be used
for facility construction, hauled to the Archdale TSF for building the embankment, or stored in
RSF-A. Some commercially valuable, non-spodumene bearing material will be transported to
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the Martin Marietta quarry for potential aggregate sale. Some overburden materials from the
construction of the Archdale TSF will be hauled to and stored at the KMM OSFs.
Figure C-1: Material Balance
iOverburden Stockpile % Rock Storage Facilities `� ^ Civil Earthworks i
i Facilities I I I
RSF-W I I Fill �
-------------�
�.------Le I
Growth i I OVB gac y I
I KM GM I I Media RSF-X I I TSF ,
I Stk OSF-2 RSF-A
Sand I
�- -- ----- .....................
.._•--- -- ----------
Archdale TSF .................. .....{.. on- Pit
Embank
PAG Backfill
I
I 1.:.....................• PAG I ---------
\`\ .......... OVB I �` Martin f�
OVB , "•i" Kings Mtn I Marietta I
TSF I Ore AGG Mine Pit �� Mine Pit
Mica I `---- ------------ ----
Growth Archdale i ----- -----�N
I` Media GM Stkp �I ( Rejects
`------------------~
I Tailings I @Q�D Saprolite:Weathered bedrock
OVB
Offsite I Concentrate I Overburden
Processing I i A"s Non-potentially acid generating rock
Facility Concentrator I PAG Potentially acid generating rock
`——————————————I
AGG Rock meetingsaleable aggregate material specs.
Ore Spodumen bearing rock with economic value
Rejects Concentrator rejects,not i net.floatat ion tailings
Although not related to operational sequencing, it is important to note that the site will be
equipped with emergency generators and emergency overflows, which will be used in the event
of power loss caused by an unforeseen event. A contingency plan that will include the locations
of tie in points and/or emergency pumps to address the containment of PAG contact water
onsite will be developed and in place prior to start of operations.
2. Describe specific erosion control measures to be installed prior to land
disturbing activities and during mining to prevent offsite sedimentation
(include specific plans for sediment and erosion control for mine
excavation(s), waste piles, access/mine roads, and process areas), and give a
detailed sequence of installation and schedule for maintenance of the
measures. Locate and label all sediment and erosion control measures on the
mine map(s) and provide typical cross-sections/construction details of each
measure. Engineering designs and calculations are required to justify the
adequacy of any proposed measures.
The objectives of the water management system include minimizing potential impacts on the
downstream environment by managing water within the Project footprint such that water quality
and water quantity objectives are achieved and limiting the loss of production due to damage
from storm events. The principal philosophy of the Kings Mountain Water Management Plan is
to separate clean, non-contact water from water that has come into contact with mining
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activities. Temporary and permanent E&S control measures were designed in accordance with
the North Carolina Erosion and Sediment Control Planning and Design Manual(2013). All E&S
measures will be installed at the onset of construction and maintained throughout mine
operations and through post-closure and reclamation. The type of BMPs selected were based
on drainage basin area delineations and calculations included in Appendix B: Construction
Stormwater Management Plan of Appendix F: Stormwater Management Plans and Erosion and
Sediment Control Plans (pages 9 to 10). Temporary sediment traps will be installed that serve
areas of less than 5 acres for less than 1 year. The storage capacity of these sediment traps will
be at least 1,800 cubic feet and will meet the 10-year, 24-hour storm event criteria included in
the North Carolina Surface Mining Manual(1996). Additionally, the temporary channels will be
designed to contain a minimum of the 10-year, 24-hour storm event. Some of the BMPs
installed during Phase 2 of construction will be permanent and remain in place through
operations and post closure. Specifically, Sediment Pond 1A will serve as future Operational
Pond M11, Sediment Pond 2A will serve as future Operational Pond M12, Sediment Pond 2B
will serve as future Operational Pond C01, and Sediment Pond 3B will serve as future
Operational Pond M81.
Stormwater calculations and hydraulic and hydrologic analysis results for sizing BMPs have not
been included in Appendix F: Stormwater Management Plans and Erosion and Sediment
Control Plans due to size. However, this information will be made available upon request.
Construction-related E&S controls and BMPs will be temporary (see Appendix B: Construction
Stormwater Management Plan of Appendix F: Stormwater Management and Erosion and
Sediment Control Plans), and construction and/or operations related BMPs will be permanent
(see Figures 36-A: Site Location Map with Temporary Surface Water Management and
Sediment Control Features and 36-B: Site-Wide Overall Stormwater Plan [Operations]) and
related to closure and post-closure. Temporary E&S controls will be implemented during
different Project phases and may be used during one or more phase. These temporary controls
will be removed when no longer needed.
Temporary Controls— Construction
• During the construction phase, E&S controls will include but are not limited to:
• Silt fences
- Sediment fences will be placed around disturbed surfaces during construction to
minimize sediment entering the stormwater channels. Sediment fences are anticipated
during:
- Clearing and construction;
- Construction of haul roads, stormwater diversion channels, sediment ponds, and other
mine infrastructure; and
- Construction of the process area and non-process area sites.
• Rock construction entrances
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- To be installed at various construction access points to reduce the amount of material
leaving the site on vehicle tires.
• Diversion berms
- Will be used to direct flow to the stormwater collection system away from disturbed,
unconsolidated areas.
• Compost filter socks and sediment fences
- Filter socks comprised of flocculant will be used to filter sediment from sheet or
channelized flow.
• Erosion control blankets
- Will be used to temporarily stabilize disturbed areas to prevent sediment transport during
rainfall events.
• Pumps / pumped water filter bags
- Will be used during dewatering to trap sediment.
• Temporary sediment ponds
- Have been designed to receive stormwater flows from disturbed and undisturbed ground
collected by perimeter channels. Sediment ponds will provide retention time for
suspended particles to settle out of the water column.
- Will be installed to service areas of less than 5 acres, for up to 1 year. The storage
capacity of the traps will be at least 1,800 cubic feet of storage per disturbed acre of
drainage area.
• Temporary seeding
- The application of seed mixtures will be used to stabilize disturbed areas. Operational
stockpiling of growth media will occur throughout the life of the Project as mine facilities
are developed or incrementally expanded. Where suitable growth media can be
harvested from the surfaces during facility development, the growth media will be
stockpiled in designated areas. The stockpiled growth media will be used during
concurrent closure and final closure activities, as described below. As the stockpiles
achieve their ultimate shape, the surfaces will be temporarily vegetated to minimize
erosion.
Sediment basin outlet structures will be equipped with skimmers. Skimmer surface drains will
float on the surface of the sediment basin as it fills and drains, releasing the clean water in the
basin rather than draining from the bottom, as is the case with conventional outlets. The
skimmer will drain the basin slowly over several days and at a constant rate to maximize
settling.
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Temporary Controls- Operations
During the operations phase, E&S controls may include controls used during construction, and
will include but are not limited to:
• Pit perimeter ponds
- Seepage collection ponds: In addition to the stormwater sediment control ponds,
wastewater runoff and seepage from RSF-A and RSF-X will be collected in wastewater
channels and routed to collection ponds associated with each RSF.
■ RSF-A: RSF Collection Pond 61
■ RSF-X: RSF Collection Pond 51
• Rock dam sediment trap
- WSB-1 will include a sediment forebay consisting of a coarse rock dam to encourage
larger sediment particles to drop out in the upstream portion of the basin to simplify
cleanout.
• Grass-lined channels
- Temporary stormwater diversions channels will be constructed to route stormwater
through the Project area. Where calculations indicate that grass-lined channels will have
adequate erosion resistance, these channels will be stabilized and revegetated as part
of channel construction.
- Riprap-lined channels: Temporary wastewater channels along the perimeter of the RSFs
will route runoff and seepage flows to the individual wastewater ponds associated with
each mine facility before being transferred to the WTP or WSB-1.
- Outlet protection level spreader: WSB-1 will discharge into a tributary of Kings Creek
through a vertical riser pipe. The outlet pipe will use a level spreader at the discharge
point into the tributary to minimize erosion.
• Paved flume
- The emergency spillway from WSB-1 will discharge on the right abutment of the dam
and has been sized to convey the probable maximum flood over natural ground to a
tributary of Kings Creek. The descent down to the tributary will be paved to minimize
erosion of the hillside and the tributary in the unlikely event the spillway is discharging.
Permanent Controls
The various E&S control measures to be used during operations include:
• Sediment control ponds
• Grass-lined channels
• Permanent stormwater diversion channels will be constructed to route stormwater flow
through the Project area. Where calculations indicate that grass-lined channels will have
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adequate erosion resistance, these channels will be stabilized and revegetated as part of
channel construction.
• Riprap-lined channels
- Permanent wastewater channels along the perimeter of the RSF will route runoff and
seepage flows to the individual wastewater ponds associated with each mine facility
before being transferred to WSB-1 or the WTP.
• Outlet protection level spreader
- Outlet level spreaders will be used on all permanent sediment control ponds that
discharge to the environment, including Sediment Pond 1, South Creek Reservoir,
Sediment Ponds 61 through 63, and Pond CO2.
- Permanent pond Sediment Pond 1 will discharge into Kings Creek using a skimmer as
well as an emergency spillway. The outlet pipe from the skimmer as well as the
discharge from the emergency spillway will both use level spreaders at the discharge
point into Kings Creek to minimize erosion.
- The existing South Creek Reservoir outlet structure includes a riprap rock down chute
that functions as a level spreader to minimize erosion as it discharges into Kings Creek.
Closure
As part of closure, controls will include but are not limited to:
• Surface grading
- Final RSF surfaces will be constructed at an overall slope of 2.5 horizontal to 1 vertical,
although some operational slopes will be a mix of angle of repose faces and horizontal
catch berms. Angle of repose surfaces remaining at closure will be regraded to 2.5
horizontal to 1 vertical. Where Project infrastructure has been demolished and removed,
the surface will be regraded to provide positive drainage.
• Surface topsoiling, roughening, and revegetation
- Surfaces that will remain at closure, including regraded mine facilities and removed
infrastructure, will be covered with a minimum of 2 feet thickness of growth media
stockpiled during the development and operational stages of the mine. The surfaces will
be roughened prior to permanent seeding using a vegetation plan developed and
validated during the operational phase of the mine.
• Riprap-lined channels
- Additional channels may be required to convey water from closed surfaces, which will be
developed during the closure plan design; this will include the final outlet from the Kings
Mountain pit, which will form a lake that is predicted to fill the pit and overtop around the
year 2090. Based on post-mining topography, a channel will be designed and
constructed to discharge the probable maximum flood from the pit lake overtop to the
adjacent Kings Creek.
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Specific BMPs are depicted on Figures 36 to 42 to control erosion from leaving the site.
A preliminary site-specific construction and operational E&S control plan and a grading plan
have been attached in Appendices B: Construction Stormwater Management Plan and C:
Preliminary Drainage Analysis Report for the NPI, Ore Mining and Process Areas— Operations
of Appendix F: Stormwater Management Plans and Erosion and Control Plans, respectively. As
part of new site construction and commissioning, design and operation details will be used to
prepare a stand-alone E&S control plan tailored to final site conditions. Both temporary and
permanent controls will be included in the E&S plan to be implemented at different phases.
Prior to surface disturbance construction activities, non-contact surface water channels will be
constructed to divert flows around the mine infrastructure. A network channel will be installed in
phases during the LOM (Table 8). Non-contact water will be diverted over undisturbed ground
into perimeter channels and collected in several sediment control ponds. Most sediment
controls will be implemented during construction and will be required throughout the life of the
facility. All permanent channels and culverts have been designed to accommodate a 100-year
rain event, and all sediment ponds to accommodate a 25-year, 24-hour storm event
(Appendix B: Construction Stormwater Management Report of Appendix F: Stormwater
Management Plans and Erosion Control Plans), which is consistent with and exceeds criteria
required by NCDEQ (Table 9). Post development peak runoff volume and flowrate calculations
that are part of the Preliminary Drainage Analysis Report for the NPI, Ore Mining and Process
Areas— Operations (Appendix C of Appendix F: Stormwater Management Plans and Erosion
and Sediment Control Plans) have not been included with this application due to their size.
However, this data will be made available upon request.
Installation of stormwater controls will coincide with construction over the course of 2.5 years.
The drainage areas and stormwater management controls for construction are depicted as
Phase 1 and Phase 2 of the Construction Stormwater Management Plan (Appendix B of
Appendix F: Stormwater Management Plans and Erosion Control Plans). Phase 1 construction
will commence at LOM -2.5 years and continue for approximately 9 months. Phase 2 will begin
with the remainder of civil works directly following completion of Phase 1. The SWMP for Phase
1 supports earthmoving and disturbance activities. The SWMP for Phase 2 supports both
temporary and operational stormwater management facilities.
Table 8: LOM Surface Water Management and Sediment Control Activities by
Mine Phase
Mine Phase Water Management Activities
End of 2.5 years of construction . Construction of sediment control pond Sediment Pond 1 and
(pre-mining) OSF sediment control ponds
(Year 0) • Construction of sediment control BMPs
• Construction of seepage control and other water collection
ponds
• Construction of water conveyances from collection ponds to
WSB-1
• Construction of WS13-1
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Mine Phase Water Management Activities
• Construction of haul roads and associated non-contact and
contact water channels around RSF-A and RSF-X
• Commence pit dewatering to WS13-1
• Water quality monitoring
Pit Phase 1 (operations) Operations and maintenance, sediment control, water quality
monitoring
Pit Phase 2 (operations) Operations and maintenance, sediment control, water quality
monitoring
Pit Phase 3 Operations and maintenance, sediment control, water quality
(operations) monitoring
• Construction of sediment control BMPs below Pit Phase 3
• Construction of Phase 4 haul roads and associated non-contact
and contact water channels below the ultimate pit footprint
Pit Phases 4 and 5 (operations) Operations and maintenance, sediment control, water quality
monitoring
End of mining operations Operations and maintenance, sediment control, water quality
monitoring
Post-closure and final reclamation Implementation of sediment control BMPs during closure
• Decommissioning of sediment ponds and seepage ponds
• Rerouting of catchments that can drain by gravity into pit to
maximize pit inflow
• Rerouting of reclaimed/restored RSF surface runoff into the non-
contact water channels
Source: SRK 2024b
Note: See Appendix K: 2023 Prefeasibility Study: Surface Water—Water Balance Development Report for a
description of the pit phases
BMP= best management practice; OSF=overburden storage facility; RSF= rock storage facility;
WSB 1=Water Storage Basin 1
The surface water management report for operations (Appendix C: Preliminary Drainage
Analysis Report for the NPI, Ore Mining and Process Areas— Operations of Appendix F:
Stormwater Management Plans and Erosion and Sediment Control Plans) includes hydrologic
and hydraulic modeling, stormwater runoff calculations for each onsite drainage basin, a
description of the methodology and summary calculations for channel and sediment control
pond sizing, and proposed BMPs.
Other temporary and permanent ditch and channel design criteria are included in Appendices A:
Surface Water Management Report and B: Construction Stormwater Management Plan of
Appendix F: Stormwater Management Plans and Erosion and Sediment Control Plans. The
water balance flowsheet is shown on Figure 43: Kings Mountain Water Balance Flowsheet. The
site-wide water balance flowsheets for construction (predevelopment and development),
operations, and closure are on Figures 44 and 45: Kings Mountain Site-Wide Water Balance
Flowsheet during Construction; Kings Mountain Site-Wide Water Balance Flowsheet for
Closure, respectively. The design intent of the SWMP (Appendix F: Stormwater Management
Plans and Erosion and Sediment Control Plans) is to separate clean, non-contact runoff from
contact runoff during mining activities.
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3. A) Will the operation involve washing the material mined, recycling process
water, or other wastewater handling? If yes, briefly describe all such
processes including any chemicals to be used.
Yes, the operation will involve the washing of mined material, recycling process water, and
wastewater handling. The process plant facility will use water in the DMS ore sorting circuit, in
the "wet" magnetic separator circuit, in the wet grinding circuit, and throughout much of the
concentrator facility (see Figure A-1: Generalized Plant Process Flow Diagram, in Section A
above) including the mica and spodumene flotation circuits; separate lithium, concentrate, and
tailings thickeners; in the lithium and mica concentrate and spodumene (lithium) tails dewatering
circuits; and in the WTP (see WTP Block Diagram in Appendix D of Appendix C: Design
Sheets). Water (and air) and other chemicals and reagents will be added to the ores to make
slurries in many of the process circuits to help separate the lithium minerals from the waste
minerals, and a brief description (Hatch 2023c) is provided below. The anticipated reagents and
chemicals that will be mixed with water and used at the plant include: SYLFAT FA2 (makes
minerals hydrophobic), Washington Mills Duramet (used for heavy density separation),
MAGNAFLOC 10 (also referred to as F-100 dispersant reagent, below; a flocculant and
coagulant to aid in mineral recovery), FLOTIGAM EDA (a flotation collector to aid in mineral
recovery; also referred to as FA-2 in the description, below), 4-methyl-2-pentanol (also referred
to as methyl isobutyl carbinol), Na2CO3, and NaOH (See Appendix J: Safety Data Sheets for
reagents and chemical safety data sheets). Additional details about where water and other
chemicals and reagents are mixed and used in the WTP are provided below (Hatch 2023c).
The WTP will employ an ultrafiltration system followed by reverse osmosis. Additional details on
where water and other chemicals and reagents are mixed and used in the WTP are described
below and are available in Appendix C: WTP Process Description of Appendix I: Abridged
Engineering Design Reports.
The DMS circuit will pump a mixture of water and FeSi and magnetite (FeSi media) to a dense
media cyclone that will separate particles based on their density relative to the specific gravity
cutoff criteria. Water will be added to the FeSi mixing tank and to the FeSi media until the
required medium density is achieved. Water will also be added to the pump box from both the
DMS rougher and cleaner circuits, and the slurry will then be pumped to the magnetic
separators by the dilute pump.
Water will also be added to the low intensity magnetic separator (LIMS) and the wet high
intensity magnetic separator (WHIMS). Milling fine screen underflow will gravitate into the
desliming cyclone feed pump box where controlled quantity of water will be added. The
attritioning and desliming process will occur prior to wet LIMS/WHIMS and mica flotation and will
also use water and other reagents. The mica scavenger flotation underflow is pumped to the
attrition feed densifying cyclone cluster by a variable speed pump. Cyclone underflow is
combined and gravitated to the attritioning cells which clean the surface of the material under
high energy attritioning conditions. The pH will be regulated by the addition of caustic solution
(NaOH) and a dispersant F-100 reagent. Water will be added to other reagents in the
spodumene (lithium) rougher and cleaner scavenger flotation circuit. The second deslime
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cyclone underflow slurry will gravitate into the agitated lithium rougher conditioning tank#1.
Here the slurry will be conditioned at high energy intensity prior to being gravitated into the
lithium rougher conditioning tank#2. The slurry is further conditioned at high energy while the
FA-2 collector reagent is also added at a controlled rate. On overflowing from Conditioning Tank
#2, the slurry pH is reduced by the controlled addition of dilute Na2CO3 and diluted with a
controlled quantity of water. Separate lithium flotation water is used within the lithium flotation
circuit in order not to mix the reagents with those within the mica flotation process. A filter feed
tank, two filters, a filtrate tank, and a filter wash water tank will also be included within the mica
concentrate filtration facility and at the lithium tails filtration facility. Thickened mica concentrate
slurry from the mica concentrate thickener will be gravitated to the agitated mica concentrate
filter feed tank. Slurry is then pumped to the mica concentrate filters by one of three mica
concentrate filter feed pumps. Solids are filtered out of the filter plate cloth forming a tails solids
cake.
To support the processing circuits identified above, water pumping and distribution will include:
WSB-1, a mica process water tank, a fire water tank, a clean/makeup water tank, and a potable
water tank. Lithium process water will be included in the lithium concentrate dewatering area.
Mica concentrate thickener overflow will be discharged into the mica process water tank. In the
event of a shortfall, the level in the tank is maintained either by the addition of water pumped by
one of two pumps from the WSB-1 or alternatively sourced from local municipal services. The
mica process water will then be distributed throughout the concentrator, except for the lithium
flotation circuit, by the process water pumps number 1 and number 2. If the plant is process
water positive, excess mica process water will overflow to the WTP to discharge externally.
Sulfuric acid and caustic will be added intermittently in the WTP after the WTP Feed Pumps to
adjust pH as necessary to within the target pH range. Sodium hypochlorite will also be injected
after the WTP Feed Pumps and upstream of the aeration tank to oxidize metals to promote
precipitation out of the WTP influent flow stream. Coagulant and flocculant (or polymer) will also
be added to the inlet water flow stream and automatically dosed to the Reaction Tank based on
the feed flow rate and inlet turbidity. A clarifier will facilitate the settling of solids and clarification
of the liquid. The clarified effluent water will flow over the notched effluent weir around the
perimeter of the clarifier and into the effluent launder where it will be directed to the clarified
water tank for storage and further treatment. The clarified water tank will store clarified water
flowing by gravity out of the clarifier.
An ultrafiltration system in the WTP will consist of three skids and will be used to remove
residual total suspended solids from the clarification stage. The ultrafiltration membranes will
allow water to pass through and suspended solids to increase in concentration on the retained
side of the membrane. The retentate from the ultrafine equipment will be routed to the sludge
storage tank for further processing. The filtrate from the ultrafine equipment will go to the
reverse osmosis system. Backwash water will be supplied to each ultrafine skid backwash
pump from the treated water tank for regular ultrafine membrane backwashes, typically for 30 to
60 seconds in duration. Filtrate from the ultrafine will feed the reverse osmosis system.
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The reverse osmosis WTP system equipment is sensitive to the formation of scale; therefore, a
chemical feed skid will dose a small amount of anti-scalant ahead of the reverse osmosis
equipment. The reverse osmosis system will be operated to achieve approximately 75 percent
recovery of the inlet flow stream as water, which will flow to the treated water tank. A 25 percent
brine will leave the reverse osmosis equipment for further treatment. A second reverse osmosis
system will be used to recover more water from the brine or reject stream. Permeate from the
reverse osmosis systems will be routed to a treated water tank. The sludge storage tank
receives clarifier waste sludge from the magnetic drum separator and retentate from all three
ultrafine skids. Sludge from the sludge storage tank will be thickened/concentrated in the sludge
thickener, a solids clarifier that will consist of a rapid mix section, a polymer and flocculation
section, and a lamella style clarifier. Supernatant from the sludge thickener and the filtrate from
the filter press will flow by gravity to a process sump. The process sump will be located in the
floor of the water treatment building near the filter press. Flow will be pumped out of the process
sump intermittently back to the WTP feed tank for recycle back into the system. An outdoor
process sump will be installed to collect any accumulated liquid in the WTP containment area
and discharge it to the WTP feed tank with a set of pumps.
As part of the site water balance flowsheet (Figure 43: Kings Mountain Mine Water Balance
Flowsheet), the concentrator plant will require a minimum of 200 gallons per minute of relatively
clean water for gland seal water and reagent use. The minimum water stream results in a net
positive water balance at the processing plant. Any excess process water is routed through the
WTP, and effluent from the WTP may be reused in the concentration process as clean makeup
water (see Section 3.43 of Appendix K: 2023 Prefeasibility Study: Surface Water—Water
Balance Development Report).
Clean water will be mixed with flocculant dry powder within the flocculant mixer for use in the
following areas: lithium concentrate thickener, lithium tails thickener and mica concentrate
thickener via running/standby variable speed flocculant dosing pumps. Soda ash will be
discharged when required in the agitated soda ash mixing tank which will be pre-filled with a
known quantity of clean water. The Na2CO3 solution is then dosed at a controlled rate via
peristaltic variable speed dosing pumps to the various locations within the lithium flotation
circuit. Fresh water will need to be mixed with the F-100 reagent for use in the attritioning circuit.
Reagent makeup spillage will be collected within the bunded area and periodically removed by
reagent area sump pump to a haulage truck for offsite disposal.
Recovered water from the WTP may be reused in the concentration process, with excess stored
in WSB-1, as previously described. The water treatment process employs reverse osmosis,
which will generate a wastewater brine that will either be disposed through the onsite City of
Kings Mountain sewer system (see Appendix M: Letter from City of Kings Mountain on Sewer
Availability for approval letter for sewer availability for the KMM plant) if the discharge
requirements are met, or at an approved offsite facility. In addition, supernatant from the WTP
sludge thickener and the filtrate from the filter press will flow by gravity to a process sump. The
process sump will be located in the floor of the water treatment building near the filter press.
Flow will be pumped out of the process sump intermittently back to the WTP feed tank for
recycle back into the system. An outdoor WTP process sump will be installed to collect any
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accumulated liquid in the WTP containment area and discharge it to the WTP feed tank with a
set of pumps. Filter cake waste solids generated from the WTP filter press will be dropped into a
roll-box that will be disposed offsite at an approved solid waste landfill facility. Figure 43: Kings
Mountain Mine Site-Wide Water Balance Flowsheet
3. B) Will the operation involve discharging fresh or wastewater from the mine or
plant as a point discharge to the waters of the State? If yes, briefly describe
the nature of the discharge and locate all proposed discharge points (along
with their method of stabilization) on the mine map(s)_
The Project will result in the discharge of treated water through permitted outfalls. A surface
water management system has been developed to achieve water quantity and quality
objectives, to reduce potential effects on the downstream environment, and to limit damage to
infrastructure during storm events. The primary objective of the Kings Mountain Water
Management Plan is to separate clean, non-contact water from water that has come into contact
with mining activities. Non-contact stormwater will be collected in separate, surface water
diversion structures, managed with appropriate E&S controls, where required, and released to
existing drainages at or near predevelopment discharge points. Contact water (wastewater) will
be collected and conveyed in dedicated surface water diversion structures, which will convey
water to WSB-1. WSB-1 will be the Project's centralized contact water collection point. It will be
built over the existing Executive Club Lake and will serve multiple functions, including makeup
process water storage, sediment control, and combining treated wastewater sources into a
single discharge point.
A diagram showing how water within the Project site will be managed is provided on Figure 43:
Kings Mountain Mine Water Balance Flowsheet. This diagram shows how water will be
collected and diverted around the main Project facilities, including the open pit, RSFs, and
OSFs. It depicts water management components including ponds, flow paths, culverts, the
WTP, and outfalls. Surface water within the Project area will be managed as three types, which
are distinguished in the diagram. The three types, presented in order of least impacted to most
impacted are:
• Non-contact water, which does not come into contact with mining activities. It traverses
vegetated or newly constructed native soil surfaces. Generally, all surrounding undisturbed
watersheds, and any revegetated surface are described as generating non-contact water.
Depending on activities within the catchment areas, this water is classified as either
unregulated or stormwater discharges according to DEMLR guidance.
• Non-process contact water, which does come into contact with mining activities. Although,
it is expected to meet water quality standards prior to discharge post treatment for
suspended solids and sediment. Generally, water that has come into contact with non-PAG
waste rock, pit walls, and/or haul roads is defined as non-process contact water (SRK
2024b), and if it were directly discharged, it would be classified as stormwater by DEMLR,
except for pit dewatering, which would be classified as wastewater.
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• PAG contact water, which interacts with PAG waste and will be treated by the WTP prior to
transferring into WSB-1. If it were directly discharged, PAG contact water would be classified
as wastewater by DEMLR guidance.
A complete description of these water management systems is provided in the Kings Mountain
Surface Water Management Report, which is included in Appendix A of Appendix F: Stormwater
Management Plans and Erosion and Sediment Control Plans and is summarized below.
Design criteria for Project surface water controls were selected to meet or exceed the
requirements of the North Carolina Surface Mining Manual(NCDEHNR 1996) and the North
Carolina Erosion and Sediment Control Planning and Design Manual(NCSCC 2013). Project
design criteria for the surface water infrastructure are summarized in Table 9.
Table 9: Project Design Criteria for Surface Water Infrastructure
Infrastructure Type 24-hour Recommended by NCDEHNR(1996)and
Project Design NCSCC (2013)
Criteria
Permanent or temporary 100-year storm 10-year storm (temporary)
channels 25-year storm (permanent)
Culverts 100-year storm 25-year storm
Ponds (all pond sizes) 25-year storm 10-year storm (< 20 acres)
10-year storm (> 20acres)
Source:Appendix A: Surface Water Management Report of Appendix F: Stormwater Management Plans and Erosion
and Sediment Control Plans
NCDEHNR= North Carolina Department of Environment, Health, and Natural Resources
NCSCC= North Carolina Sedimentation Control Commission
Permanent sediment basins are designed to serve areas larger than 5 acres and function for
longer than 1 year, however ponds with contributing areas of less than 5 acres are proposed.
Eleven dedicated sediment basins have been designed for the site (Table 10), which capture
site runoff and allow sediment to settle. WSB-1, while not designated a sediment control pond,
does provide some sediment control in the forebay area and is therefore included here for
completeness. The 11 dedicated sediment basins, in addition to WSB-1, include:
• Sediment Pond 1 will manage flows from the pit perimeters, haul roads, NPI areas, and
OSF2. Water will be conveyed to Kings Creek through Outfall 010 as stormwater.
• Sediment Ponds 62, 63, and 64 will manage stormwater runoff from OSF-1 and OSF-3.
Water will be conveyed to South Creek through Outfalls 062, 063, and 064, respectively.
• Ponds C01 and CO3 will collect water from the ore processing area south of 1-85. Water
collected in these three ponds will be conveyed to WSB-1.
• Pond CO2 will collect water from a small portion of the South NPI area and provide sediment
control prior to release to Kings Creek at Outfall 005.
• Ponds M11 and M12 will collect water from the ore processing area north of 1-85. Water
collected in these two ponds will be conveyed to WSB-1.
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• Pond M81 will collect water from the northern NPI area. Water from this pond will be
pumped to Sediment Pond 1.
• WSB-1 will collect runoff from the WSB-1 watershed, in addition to water conveyed from
Ponds M 11, M 12, C01, and CO3, and water from the WTP. Water will be released to Kings
Creek through Outfall 003 as wastewater.
Characteristics of the sediment control ponds are provided in Table 10. Figure 43: Kings
Mountain Mine Water Balance Flowsheet shows the connections between sediment control
ponds, water sources, and their discharge points.
Table 10: Sediment Control Ponds
Name Contri Design Design Depth Skimmer WaterSource Water DEMILR
buting Storage Surface (ft) Size Destination Classification
ii0 00i Orifice)
Sediment 112 417 52.5 11 8/6.5 Pit perimeter 010 Stormwater
Pond 1 ponds, haul
roads, NPI
areas, and
OSF-2
Sediment 9.3 417 52.5 11 3/3 OSF-1 062 Stormwater
Pond 62'
Sediment 30.6 20.4 20.7 4 6/5 OSF-1 063 Stormwater
Pond 63'
Sediment 13.3 57 22.6 6 6/3.5 OSF-3 064 Stormwater
Pond 64'
Pond C012 13.4 111.3 25.5 6 - South NPI Internal N/A
Pond CO22 2.7 - 5.9 6 - South NPI 005 Stormwater
Pond C032 38.5 - 58.2 6 - Concentrator Internal N/A
Pond M112 4.7 80.5 17.9 6 - Concentrator Internal N/A
loadout
Pond M122 27.6 345.5 70.6 6 - ROM Pad Internal N/A
Pond M812 22.2 371.6 18.8 6 - North NPI Internal N/A
WSB-1' 281 4289.8 - 30 - WSB-1 003 Wastewater
watershed,
Ponds M11,
M12, C01,
CO2, and CO3,
WTP
' Source:Appendix A: Surface Water Management Report of Appendix F: Stormwater Management Plans and
Erosion and Sediment Control Plans
2 Appendix C: Preliminary Drainage Analysis Report for the NPI, Ore Mining and Process Areas—Operations of
Appendix F: Stormwater Management Plans and Erosion and Sediment Control Plans
-=data unavailable; ac=acre; DEMLR= Division of Energy, Mineral, and Land Resources;ft=feet;ft2=square
feet;ft3=cubic feet; in = inches; N/A= not applicable; NPI = non-process infrastructure; OSF =overburden storage
facility; ROM = run-of-mine; WSB-1 =Water Storage Basin 1; WTP=water treatment plant
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All regulated surface water from the Project site will be discharged to one of eight permanent
and four temporary outfalls on Albemarle's KMM property. The four temporary outfalls will be
used during the Project's construction phase only. Water will be discharged into an unnamed
tributary to Kings Creek, Kings Creek, or South Creek, which eventually flows into King's Creek.
Water from two RSF-A run-on catchment areas will only be exposed to undisturbed areas,
therefore runoff from these two sites is not regulated.
An additional zone in the eastern portion of the north NPI area will collect stormwater in a small
temporary sediment pond before it discharges to ground to the east. This discharge will not
enter the natural surface water system. Discharged water will infiltrate to the groundwater
system, therefore this water is unregulated.
The NCDEQ's Stormwater Program and "Guidance Document for determination of NPDES
regulatory status of various discharges on a mine site" were referenced for the determination
and classification of stormwater and wastewater discharges.
The proposed outfall locations are shown in Table 11 and illustrated on Figure 46: NCG02
Outfall Location Map.
Table 11: Project Discharge Outfall Locations
Outfall Water Origin Water Type Receiving Water Notes
Number
003 Outlet from WSB-1 dam Wastewater Kings Creek Combined outlet of all the
discharges going into WSB-1,
including water from the
WTP, open pit, ore storage
and processing area ponds,
Collection Pond 61, and
contributing catchments.
Includes both stormwater and
wastewater.
005 Pond CO2 Stormwater Kings Creek Stormwater from south NPI
area, initially from temporary
sediment pond then Pond
CO2 once it is constructed.
010 Sediment Pond 1 Stormwater Kings Creek Stormwater from Sediment
Pond 1, which captures water
from OSF-3, pit perimeter
ponds, and contributing
catchments. Downstream of
Technology Center, near
other stormwater discharge
locations. May flow into the
wetland area and thence to
Kings Creek.
062 Sediment Pond 62 Stormwater South Creek Stormwater from Sediment
Pond 62, which captures
runoff from OSF-1.
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Outfall Water Origin Water Type Receiving Water Notes
Number
063 Sediment Pond 63 Stormwater South Creek Stormwater from Sediment
Pond 63, which captures
runoff from OSF-1.
064 Sediment Pond 64 Stormwater South Creek Stormwater from Sediment
Pond 64, which captures
runoff from OSF-2.
067 Haul road and railroad Stormwater South Creek Stormwater originating in haul
watershed road and railroad watersheds.
201* Temporary sediment pond, Stormwater Kings Creek Temporary (construction
then Pond M11 only)outfall. Stormwater from
south NPI (north of 1-85).
202* Temporary sediment pond, Stormwater Kings Creek Temporary (construction
then Pond M12 only)outfall. Stormwater from
south NPI (north of 1-85).
203* Temporary sediment pond, Stormwater Kings Creek Temporary (construction
then Pond C01 only) outfall. Stormwater from
south NPI (south of 1-85).
204* Temporary sediment pond Stormwater South Creek Temporary (construction
only)outfall. Stormwater from
north NPI.
*= Outfall is temporary and will only be used during the Project's construction phase.
1-85= Interstate 85; NPI = non-process infrastructure; OSF=overburden storage facility; Technology Center=
Albemarle Global Technology Center for Research and Development; WSB-1 =Water Storage Basin 1;
WTP =water treatment plant
3. C) Will any part of the proposed mine excavation(s) extend below the water
table? If yes, what impact, if any, will mine dewatering have on neighboring
wells? Locate all existing wells on the mine map(s) that lie within 500 feet of
the proposed excavation area. Provide data to support any conclusions or
statement made, including any monitoring well data, well construction data,
and current water withdrawal rates. Indicate whether the proposed mine locale
is served by a public water system or private wells.
The existing open-pit excavation extends below and through the water table. Additional
excavation will occur below the aquifer. The pit lake is being dewatered prior to construction, as
authorized by NPDES Permit No. NC0090212. Impact assessments for continued mine pit
dewatering were performed by SRK, and the results predict that impacts to neighboring wells
(none of which are within 500 feet of the pit) are unlikely. As shown on Figure 7-2 in
Appendix D: 2022 Prefeasibility Study— Hydrogeology Study and Groundwater Modeling, there
are only three known wells that are within the 5-foot drawdown curve outside the Project
boundary. It is unclear if any of these wells are used for drinking water, as the area where they
are located is served by the City of Kings Mountain's water supply system. Nonetheless, a
Water Supply Well Mitigation Plan has been developed for the Project and contains an action
plan and mitigation efforts should it be determined that there is an impact to a private well
(Appendix E: Water Supply Well Mitigation Plan).
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No extractive wells will be on the site to dewater the mine pit or for use as a water source for
mine operations. The mine itself and the areas immediately surrounding it, are served by a
public water system (from the City of Kings Mountain). The City of Kings Mountain will provide
potable water for mine facilities, but there is no other need to use city water for mine operations.
3. D) If you answered yes to any of the above questions, provide evidence that
you have applied for or obtained the appropriate water quality permit(s) (i.e.,
non-discharge, NPDES, Stormwater, etc.) from the Stormwater Program. In
addition, the applicant is required to register water use with the Division of
Water Resources, Ground Water Management Branch, if the operation
withdraws more than 10,000 gallons per day and needs a capacity use permit
from the Division of Water Resources, Ground Water Management Branch, if
the operation lies in a capacity use area and withdraws more than 100,000
gallons per day.
Albemarle has submitted an NCG02 permit application / Notice of Intent to the Stormwater
Program to authorize all water discharges from the KMM.
The KMM is not in a capacity use area and will not require a capacity use permit, but a water
withdrawal registration will be filed with the Division of Water Resources at the appropriate time
for continued pit dewatering.
4. A) Will the operation involve crushing or any other air contaminant emissions?
If yes, indicate evidence that you have applied for or obtained an air quality
permit issued by the Division of Air Quality or local governing body.
The Project involves crushing and will generate air emissions. A minor source air permit
application has been submitted to the Department of Air Quality to construct and operate
stationary sources associated with the mining process, pursuant to requirements of 15A NCAC
02Q.
4. B) How will dust from stockpiles, haul roads, etc., be controlled?
The mining operations will employ enclosed conveyors and dust extraction systems (dust
plants) using bag filters at various transfer locations in the primary and secondary crushing
circuits to reduce fugitive dust. One such dust extraction system will include the ROM tip dust
collection system in the primary crusher that also services the sacrificial conveyor discharge to
dampen dust at its discharge chute. Dust will also be extracted at various points within the
secondary crushing process and filtered within a dust plant. The dust plant includes a scalping
screen, secondary crusher feed bin, and secondary crusher feed/discharge.
Dust will also be extracted at various points within the sizing and sorting process and filtered
within a dust plant. This will include coarse and fine ore sorting bins, coarse and fine belt sorting
belt feeders, coarse and fine sorting machines, and product/discharge chutes. A separate sorter
bypass conveyor dust plant will collect dust from the sorter bypass conveyor discharge chute.
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Dust will be extracted at various points within the tertiary crushing process and filtered within a
dust plant. The dust plant will include a sorting sizing screen and tertiary crusher
feed/discharge.
The plant feed stockpile will be in an enclosed building and include a dust plant to minimize dust
generation during material handling processes. This process will not require water treatment.
The dust plants at the primary crusher, secondary crusher, tertiary crusher, and plant feed
stockpile will include filtering the dust by periodically discharging it onto the respective
conveyors, with clean air being discharged to the atmosphere.
Watering of ore and waste during mining, on the ROM pad stockpile, and in various waste piles
(RSFs, OSFs, and GMS area) to prevent wind erosion and minimize dust dispersion will be
routinely conducted to reduce airborne dust. Concurrent reclamation of stockpiles will further
reduce the amount of bare earth surfaces, minimizing potential sources of dust generation.
Water trucks will routinely spray water on the haul truck routes to effectively suppress dust
emissions. Water spraying from the water trucks will be focused along roads and at critical
points where dust is likely to be generated, such as at intersections and high-traffic areas. Dust
control water will be supplied by either the pit dewatering force main prior to entering WSB-1, or
directly from WSB-1 (Appendix A: Surface Water Management Report of Appendix F:
Stormwater Management Plans and Erosion and Sediment Control Plans).
Other controls for dust may include treatment with magnesium/calcium chloride and speed and
traffic controls.
5. A) A buffer will be required between any mining activity and any mining permit
boundary or right-of-way. It may be an unexcavated buffer (no excavation, but
roadways, berms, and erosion & sedimentation control measures may be
installed within it), an undisturbed buffer (no disturbance within the buffer
whatsoever), or a combination of the two, depending upon the site conditions.
Note that all buffers must be located within the mining permit boundaries.
How wide a buffer will be maintained between any mining activity and any
mining permit boundary or right-of-way at this site? A minimum buffer of 25
feet is recommended, although a wider buffer may be needed depending on
site conditions. Show all buffer locations and widths on the mine map(s).
Various buffer types will be implemented to mitigate potential offsite impacts throughout the
KMM consisting of a combination of unexcavated naturally vegetated buffers, unexcavated
planted vegetated buffers, unexcavated vegetated berms, unexcavated enhanced evergreen
buffers, and undisturbed buffers. Widths will vary depending on the location of infrastructure
relative to property boundaries and jurisdictional watercourses/wetlands (Figure 25: Kings
Mountain Layout and Property Buffers). Buffer types and sizes were developed based on a VIA
that was performed in 2024 by a visual resource specialist and modified through consultation
with the City of Kings Mountain (Appendix N: Visual Impact Assessment Report).
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Potential native species that are well-suited for visual screening, rapid growth, and providing
habitat include evergreen trees such as eastern red cedar, loblolly pine, and white pine, as well
as shrubs like American beautyberry and wax myrtle. It is estimated that over 900 trees will be
planted to meet the minimum requirements of the City of Kings Mountain's ordinance (Figure 25:
Kings Mountain Site Layout and Property Buffers).
The following is a brief description of the locations of each buffer type:
• Undisturbed naturally vegetated property buffer—This buffer type is currently forested
and will remain forested during for the life of the Project as a property buffer to mitigate
visual, noise, and dust impacts (depicted in bright green on Figure 25: Kings Mountain Site
Layout and Property Buffers). These areas have a minimum width of 50 feet and a
maximum width of 1,050 feet. This buffer type is primarily located on either side of 1-85,
along the majority boundary of the parcel south of 1-85, along the north/south boundary of
the western boundary, and in the northeast corner of the property.
• Undisturbed planted vegetated buffer—This buffer type is not currently vegetated but will
be planted with appropriate vegetative species consistent with the required zoning
ordinance(s) (depicted in dark green on Figure 25: Kings Mountain Site Layout and Property
Buffers) to mitigate visual, noise, and dust impacts. These areas have a minimum width of
50 feet and a maximum of 100 feet and will be located intermittently along the boundary
described above to augment the areas that are not naturally vegetated.
• Vegetated berm—This buffer type will consist of a 50-feet wide, 6-feet high berm with a 4 to
1 slope on the front side and a 3 to 0 stop of the back side (depicted in blue on Figure 25:
Kings Mountain Site Layout and Property Buffers) providing a gentle slope for public
viewing. It will be planted to enhance the effectiveness of the berms in providing visual
screening and habitat and native vegetation along the slopes of the berms consistent with
the applicable zoning ordinance(s). These areas will be in two areas adjacent to RSF-A and
along the entire northeastern property boundary.
• Undisturbed enhanced evergreen buffer—This buffer type consists of currently forested
areas that will be augmented by planting additional evergreen species to improve screening
during leaf-off season (depicted as dark green slashes on Figure 25: Kings Mountain Site
Layout and Property Buffers). These areas will have a minimum width of 50 feet and be
located in two areas adjacent to RSF-X and on the northern end of OSF-1. Planting cross-
sections and plan view details are also depicted on Figure 25: Kings Mountain Site Layout
and Property Buffers.
• No buffer—No buffers are proposed where an existing or proposed easement or
ingress/egress area is located (depicted in dark gray on Figure 25: Kings Mountain Site
Layout and Property Buffers). The areas with no buffers are located around the southeast
property boundary corner extending south around the concentrator facilities, along the
northern NPI area, and in several smaller areas perpendicular to the western property
boundary.
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• Undisturbed buffer—This buffer type will consist of a 50-foot area between disturbed areas
and jurisdictional wetlands and waterbodies (depicted as an orange line on Figure 25: Kings
Mountain Site Layout and Property Buffers) to prevent secondary impacts or improper
staging of materials and equipment.
5. B) A minimum 50-foot-wide undisturbed buffer will be required between any
land disturbing activities within the mining permit boundaries and any natural
watercourses and wetlands unless smaller undisturbed buffers can be
justified. Depending on site conditions, a buffer wider than 50 feet may be
needed.
How wide an undisturbed buffer will be maintained between any land
disturbing activities within the mining permit boundaries and any natural
watercourses and wetlands at this site? Show all buffer locations and widths
on the mine map(s).
See previous response (Section C.5.(A)).
6. A) Describe methods to prevent landslide or slope instability adjacent to
adjoining permit boundaries during mining. Minimum 2 horizontal to 1 vertical
slopes or flatter for clayey material and minimum 3 horizontal to 1 vertical
slopes or flatter for sandy material are generally required unless technical
justification can be provided to allow steeper slopes.
Several of the proposed mine facilities located adjacent to the mine permit boundaries including
RSF-A, OSF-1, OSF-3, and the open pit will either include excavations and/or store fill materials
and have been designed to prevent landslides or slope instability. All permanent fill piles for the
Project will ultimately be constructed to meet the stated minimum slope requirements
(2 horizontal to 1 vertical or flatter for clayey material, and minimum 3 horizontal to 1 vertical or
flatter for sandy material). The initial slopes for RSF-A (a permanent facility), and the slopes for
RSF-X (a temporary facility)will be constructed at steeper angles consisting of 2.5 horizontal to
1 vertical ranging from 20 to 26 degrees (see Drawings 300 and 400 in Appendix A: RSF-A and
RSF-X of Appendix C: Design Sheets). These RSF slopes will be constructed steeper than the
general requirements for sandy materials (18.43 degrees); however; most of the materials to be
stored in the RSFs will consist of fragmented coarse-grained partially weathered rock and
competent bedrock that have geomechanical index (strength) properties that are typically
stronger than the finer-grained clayey and sandy soil materials. In addition, limit equilibrium
stability analyses results show the temporary steeper 2.5 horizontal to 1 vertical RSF slopes will
be stable under static and pseudo-static conditions and are described in detail below.
RSF-A will be constructed over gently sloping terrain (5 to 15 degrees), founded atop in-situ
saprolite and partially weathered rock, and have a total height of approximately 280 feet. It will
have maximum slopes of 2.5 horizontal to 1 vertical (22 to 26 degrees) with a benched profile as
specified in Section 5.1: RSF Design in Appendix A: Prefeasibility Engineering Design Report
for Rock Storage Facilities A and X of Appendix I: Abridged Engineering Design Reports. All the
materials that will be stored in RSF-A will need to be comingled at a mix ratio that does not
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negatively affect the strength governed by the coarse rock component. Placement of the
materials into RSF-A will need to be carefully managed and inspected by the mine operators
through even spreading/distributing of material across the crest widths with mobile equipment
(haul trucks and dozers).
Temporary RSF-A slopes will be regraded between lifts to 2 horizontal to 1 vertical
(26.6 degrees) to satisfy reclamation requirements as shown on Detail 1: Closure Regrading
Detail on Drawing 100 from Appendix D: Closure Drawing Package of Appendix O: Conceptual
Closure Plan. Progressive reclamation of the regraded RSF-A lifts during their construction is
possible since RSF-A will be constructed from the bottom up and will include 16-foot slope
breaks that will remain at the top of each lift to reduce erosion from surface flows while
vegetation is established for long-term stability (see Detail 1 on Drawing 100 from Appendix D:
Closure Drawing Package of Appendix O: Conceptual Closure Plan).
RSF-X will be founded on saprolite and partially weathered rock and will have a total height of
approximately 200 feet. It will be constructed with temporary maximum slopes of 2.5 horizontal
to 1 vertical (20 degrees).
RSF-A and RSF-X subgrade foundations will need to be carefully excavated and constructed
prior to the construction of the overlying dump platforms to make stable facilities. This is
discussed in detail in Section C.6.(C) below. The subgrade will be prepared in accordance with
the lines and grades as shown on the RSF Design Sheets (see Appendix A: RSF-A and RSF-X
of Appendix C: Design Sheets), including regrading and compaction with selected engineering
materials. Weaker zones of unsuitable saprolite within the RSF excavation footprints will need to
be excavated to stronger foundation soils/bedrock to improve stability especially around the toes
of the proposed facilities.
The RSF foundation bases will be excavated at safe slope angles as identified above, based on
the material type, and if required, the stability of the excavation will be analyzed and monitored
by a geotechnical engineer to maintain adequate factors of safety at all times. Stability
measures to improve excavation stability may include buttressing with rockfill and/or other
ground improvement techniques.
The RSF slopes will be constructed in flat and level lifts of maximum 30-feet thickness and
dumped at a 1.4 horizontal to 1 vertical lift face angle (generally the angle of repose for waste
rock). There will be no areas of an RSF where adjacent lifts have more than a two-lift thickness
difference. Where applicable, construction of the RSFs will follow a dump-and-push method,
where the load is dumped onto the lift and dozer-pushed to form the crest. Equal load
distribution across the entire active dump reduces the potential for slope instability by reducing
the pressure applied to the foundation materials and the resulting pore pressure increase. The
quality of the waste rock materials will be managed by geotechnically trained personnel during
RSF construction and especially during initial lift placement.
The stability of the proposed RSFs at different subgrade excavation depths was evaluated using
GeoStudio Slope/W software, which is a two-dimensional slope stability program. Stability was
analyzed at three representative geological/analytical cross-sections labeled RSF-A BX-BX',
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RSF-X I-I', and RSF-X C-C'. Limit equilibrium stability analyses were performed for static factors
of safety using either circular and/or non-circular failure surfaces and are summarized in
Tables 4, 5, and 6 in Appendix B: Abridged RSF-A and RSF-X Calculation Package of
Appendix G: Geotechnical Stability Reports, Calculations, and Cross-Sections. The stability of
the RSF embankments was evaluated for static conditions and pseudo-static conditions. The
detailed stability results are presented in Section 7: Geological and Analytical Sections in
Appendix B: Abridged RSF-A and RSF-X Calculation Package of Appendix G: Geotechnical
Stability Report, Calculations, and Cross-Sections. RSF construction will require the majority of
the saprolite in the upper 10 to 20 feet below existing grade (or pre-existing) native grades to be
removed since they may not be suitable for foundation support (see Sections 6.1.2: Saprolite
and 6.1.4: Anisotropy in Saprolite and Partially Weathered Rock in Appendix B: Abridged RSF-A
and RSF-X Calculation Package of Appendix G: Geotechnical Stability Report, Calculations,
and Cross-Sections for additional details). With the proposed removal of unsuitable material, the
RSF stability analyses result in acceptable factors of safety and overall RSF fill slopes of 2.5
horizontal to 1 vertical, as is currently planned and shown in Appendix A: RSF-A and RSF-X of
Appendix C: Design Sheets.
Since the extent of the RSFs locally encroaches upon the permit boundary, environmental
features (e.g., wetlands and creeks), and other infrastructure, they have been designed with a
minimum 100-foot setback distance for local scale failure events, as shown on Figure 4-1 of
Appendix A: Prefeasibility Engineering Design Report for Rock Storage Facilities A and X of
Appendix I: Abridged Engineering Design Reports. The probability of a waste rock material
runout event at the Project is considered very low; however, in the unlikely event of a runout, the
material has been modeled in two dimensions to remain within the 100-foot setback distance
(for additional details see Sections 4.4: Setback Distances and 4.5: Runout Assessment in
Appendix A: Abridged Prefeasibility Design Engineering Report for the Rock Storage Facilities A
and X of Appendix I: Abridged Engineering Design Reports).
The OSFs are permanent facilities that will be constructed in flat and level lifts during Project
development at their final configuration. They will have a slope of no greater than 3 horizontal
to 1 vertical and be revegetated once complete. If some of the OSF materials are later removed
for reclamation use as general fill or sold, the remaining OSF pile will be revegetated.
The open pit slopes have been designed using acceptance criteria based on internationally
accepted practices, data reliability, consequences of failure, and Project-level design. The
resulting Kings Mountain pit slope design acceptance criteria has been classified for four slope
scales (benches, inter-ramp, inter-ramp [above and below ramps] and overall slopes [interim
and final walls]) that are associated with minimum factor-of-safety values (for both static and
pseudo-static conditions), and maximum probabilities of failure (percentage) values (see Table
9-2 in Abridged Appendix A: Abridged Select Phase Geotechnical Report— Pit Stability and
Modeling of Appendix G: Geotechnical Stability Reports, Calculations, and Cross-Sections).
In addition, the pit slopes will mostly be excavated in more competent (stronger) partially
weathered rock and intact bedrock (see Section 6 in Appendix A: Abridged Select Phase
Geotechnical Report— Pit Stability and Modeling of Appendix G: Geotechnical Stability Reports,
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Calculations, and Cross-Sections) that have been structurally mapped and modeled for
discontinuities (rock mass strength) and limit equilibrium analysis slope stability. As a result of
the pit stability investigation, geomechanical laboratory results, and stability modeling work, the
open pit has been separated into four separate geotechnical sectors based on rock type that
include four separate pit wall designations: east, west, north, and south as shown on Figure 23:
Map and Cross-Section Showing the Pit Geotechnical Domains and Sectors.
The designed pit slope crest, located in the northeast part of the pit related to the east wall
(Sector 1) that lies adjacent to the permit boundary, will employ a single bench design
configuration that will allow a steeper overall slope angle (approximately 36 degrees—see
Figure 22: Proposed Pit Map and Cross-Sections) than the general slope requirements listed
above for clayey and sandy near-surface soil materials. In addition, minimum design setback
distances of 100 to 150 feet have been included from the pit crest to the permit boundary for
shallow (less than 150 feet pit depths) and deep (greater than 150 feet pit depths) pit design
scenarios, respectively.
When working in and around the perimeter of the pit, the operator will establish and follow a
written ground control plan for safe control of all highwalls, pits, and spoils banks left over from
legacy mining operations. The ground control plan will be designed to be consistent with
prudent engineering design and to provide safe working conditions. Details of the open-pit
excavations including bench widths and heights are described below in Section C.6.(D.).
In addition, a pit slope monitoring system will be implemented that will include the following
procedures:
• Daily inspections
• Tension crack inspections
• Prism monitoring
• Tactical radar unit monitoring
• Vibrating wire piezometers
Pit wall design strategies will include:
• Blasting design alignment (shallow footwalls and refining);
• Scaling and cleanup to reduce the rock fall hazard and maximize bench performance;
• Geotechnical pit mapping, including structural geology to assist in ground control
management;
• Pit slope and groundwater monitoring with defined trigger levels/thresholds; and
• Updated stability and pore pressure analyses to verify new pit designs.
Landslides will be prevented by employing the previously identified design implementation
strategies and monitoring methods and instrumentation noted above that will include monitoring
for and documenting (e.g., mapping and photographing) any fill material instabilities (e.g., rock
falls, sluffs, water ponding, ground movement, etc.) and tension cracks on the surface adjacent
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to the edges of the existing legacy open pits and/or excavations, and immediately notifying the
appropriate Project supervisor.
6. B) Provide a cross-section on the mine map(s) for all fill slopes (berms, waste
piles, overburden disposal areas, etc.), clearly indicating the intended side
slope gradient, installation of any benches and/or slope drains (with
supporting design information) if needed, and the method of final stabilization.
Relevant fill slope cross-sections and design descriptions are provided below.
RSF-A and RSF-X waste rock cross-sections are shown in Appendix A: RSF-A and RSF-X of
Appendix C: Design Sheets on Design Drawings 300 and 400, respectively. Both cross-sections
illustrate the initial constructed RSF temporary slope gradients of 2.5 horizontal to 1 vertical.
Diversion ditches/channels will be installed at the base of the fill piles near the edge of the
perimeter road fills (see Details 1, 2, and 3 on Design Drawing 500 in Appendix A: RSF-A and
RSF-X of Appendix C: Design Sheets) to collect and route contact water away from the facility
and into the facility collection ponds (RSF-A Collection Pond 61 and RSF-X Collection Pond 51).
Slope drains will not be required for the RSF slopes, as fill material will mostly consist of course,
granular, free-draining rock materials. Waste rock located at the RSF slope faces and across
the initial platforms (placed waste rock fill benches) will also be coarse, free-draining, and
durable. All planned RSF cross-sections are included on Figures 1, 2, and 3 in Appendix C:
RSF Cross-Sections of Appendix P: Cross-Sections and include: RSF-A, RSF-X, and RSF-W,
respectively. Temporary side slopes at RSF-W (inside the pit during development) will be
constructed at approximately 1 horizontal to 1.19 vertical (50 degrees) as shown on Figure 3 in
Appendix C: RSF Cross-Sections of Appendix P: Cross-Sections. The PAG rock at RSF-W will
be removed and temporarily stored at RSF-X after RSF-X becomes operational.
Final stabilization for the permanent RSF-A lifts (slopes) will be established by regrading
between lifts to 2 horizontal to 1 vertical, and construction of 16-foot slope breaks that will
remain at the top of each lift to reduce erosion from surface flows while vegetation is established
for long-term stability (see cross-section on Detail 1 on Drawing 100 in Appendix D: Closure
Drawing Package of Appendix O: Conceptual Closure Plan). Following grading of RSF-A, the
slopes and slope breaks will be covered with 1 foot of cover, 1 foot of growth media, and
seeded with a permanent mixture to achieve final stabilization.
The original WSB-1 embankment with slopes approximating 1 horizontal to 2.6 vertical (21.8
degrees) as shown on the cross-section on Detail B on Drawing 300 in Appendix B: WSB-1 of
Appendix C: Design Sheets, will be reinstated by placing and compacting suitable general fill in
the existing embankment breach, and the formation of a lower permeability internal core and
compacted fill or rockfill outer zone. For added stability, a compacted toe fill buttress (see same
WSB-1 cross-section noted above along with Detail 1 on Drawing 301 in Appendix B: WSB-1 of
Appendix C: Design Sheets)will be constructed to improve the predicted stability of the
embankment and anchor the new blanket drain section on the downstream embankment face.
During closure WSB-1 will require the removal of a section of the embankment raise over the
natural channel. The side slopes of the cut will be constructed at 3 horizontal to 1 vertical (see
WSB-1 Section B-B' on Drawing 200 in Appendix D: Closure Drawing Package of Appendix O:
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Conceptual Closure Report) and will be covered with 1 foot of growth media and reseeded.
Riprap will also be placed on portions of the restored drainage that have a channel grade slope
of greater than 5 percent.
The OSFs will be constructed during Project development at their final configuration with a slope
of no greater than 3 horizontal to 1 vertical (see cross-sections of OSF-1, OSF-2, and OSF-3 in
Appendix A: OSF Cross-Sections of Appendix P: Cross-Sections) and revegetated once
complete
The GMS pile will be a temporary facility that will be constructed with temporary slope gradients
of no greater than 3 horizontal to 1 vertical (see cross-sections for the GMS area in Appendix B:
GMS Cross-Section of Appendix P: Cross-Sections).
Berms will be constructed to the minimum mid-axle height of the largest self-propelled mobile
equipment that will travel on the roadway and at a side slope of angle of repose (35 degrees for
coarse rock; and 25 to 30 degrees for silty soils). Berms will be installed on both sides of the
haul roads for safety and are depicted on cross-sections in Details A, B, C, D, and F on Figure
35: Kings Mountain Mine Site Layout and Detail A on Figure 26: Kings Mountain Mine Site
Layout with Acreage Table.
6. C) In excavation(s) of unconsolidated (non-rock) materials, specify the angle of
all cut slopes including specifications for benching and sloping. Cross-
sections for all cut slopes must be provided on the mine map(s).
The RSF-A and RSF-X subgrade foundations will be carefully excavated and constructed prior
to construction of the overlying fill and dump platforms. RSF-A and RSF-X cross-sections are
depicted on Drawings 300 and 400, respectively, in Appendix A: RSF-A and RSF-X of
Appendix C: Design Sheets. Additional cross-sections showing the ultimate buildouts of RSF-A,
RSF-X, and RSF-W, along with original grades are shown on Figures 1, 2, and 3, respectively in
Appendix C: RSF Cross-Sections of Appendix P: Cross-Sections.
The proposed fill subgrade will be prepared in accordance with the lines and grades as shown
on the Design Sheets, including regrading and compaction with selected engineering materials.
Weaker zones of unsuitable saprolite within the RSF excavation footprints will be excavated to
stronger foundation soils/bedrock to improve stability especially around the toes of the proposed
facilities. It is anticipated that weak saprolite soils below the RSF-A toe will require excavation to
depths of between 10 and 20 feet (on average)with a maximum depth of 30 feet. It is also
anticipated that weak saprolite soils below the RSF-X toe will require excavation depths
between 20 to 25 feet (on average) and greater than 80 to 100 feet below existing grade at
RSF-X (see RSF-X Stability Cross-Section I and RSF-A Stability Cross-Section BX on the
plates in Appendix A: Prefeasibility Engineering Design Report for Rock Storage Facilities A
and X of Appendix I: Abridged Engineering Design Reports showing approximate limits of
saprolite removal). The depth of the RSF-X subgrade elevation is shown on Cross-Sections
C-C' and D-D' on Drawing 400 in Appendix A: RSF-A and RSF-X of Appendix C: Design
Sheets.
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The RSF foundation bases will be excavated at the safe slope angles identified above
(minimum 2 horizontal to 1 vertical slopes or flatter for clayey material and minimum 3 horizontal
to 1 vertical slopes or flatter for sandy material). Stability measures to improve excavation
stability may include buttressing with rockfill and/or other ground improvement techniques.
The RSF-X subgrade excavation will include excavation of unsuitable tailings and embankment
fill. Due to proximity and apparent interconnection of phreatic levels with South Creek Reservoir,
dewatering/draining of the reservoir and or sheet pile installation may be required to maintain
the stability of the RSF-X excavation slopes. The RSF-X materials will be removed during
closure and placed into the pit for permanent storage.
RSF-X will be constructed on saprolite and partially weathered rock to a total height of
approximately 200 feet with temporary maximum slopes of 2.5 horizontal to 1 vertical
(20 degrees). Following clearing/grubbing/stripping, the RSF-X footprint will undergo cut-and-fill
regrading to achieve an overall slope of 15 degrees to a maximum of 20 degrees to the
southwest (see Cross-Sections C-C' and D-D' on Drawing 400 in Appendix A: RSF-A and
RSF-X of Appendix C: Design Sheets), with a portion of the pad back sloped towards drainage
trench locations to improve slope stability.
The stability of the proposed RSFs using assumed geomechanical properties from the
geotechnical site investigations under various conditions (e.g., with subgrade excavation and
replacement of non-PAG waste rock, without subgrade excavation, and/or at various slope
angles ranging from 2 horizontal to 1 vertical to 4 horizontal to 1 vertical), is described on three
representative geological/analytical cross-sections (labeled RSF-A BX-BX', RSF-X I-I', and
RSF-X C-C'), which are included and summarized in Section 7 in Appendix B: Abridged RSF-A
and RSF-X Calculation Package of Appendix G: Geotechnical Stability Reports, Calculations,
and Cross-Sections.
6. D) In hardrock excavations, specify proposed bench widths and heights in
feet. Provide cross-sections of the mine excavation clearly noting the angles of
the cut slopes, widths of all safety benches and mine benches, and the
expected maximum depth of the excavation.
The proposed pit will be excavated over 9.4 years in five phases, Phase 0 to Phase 4, as shown
on Figure 22: Proposed Pit Map and Cross-Sections. Figure 22 also includes Cross-Sections A-
A' and B-B'. Cross-Section A-A' cuts the northern part of the pit and is oriented northwest-
southeast, whereas Cross-Section B-B' cuts the center of the pit and is oriented southwest-
northeast. The two cross-sections clearly show the angles of the cut slopes, widths of the safety
benches and mine benches, and the expected maximum depth of excavation.
Overall cut slope angles shown on Cross-Section A-A' are 52 degrees, 50 degrees, 45 degrees,
and 53 degrees on the west slope for Pit Phases 1, 2, 3, and 4, respectively. Pit Phases 3 and 4
form the eastern slope shown on Cross-Section A-A' that has an overall cut slope angle of
37 degrees. Overall cut slope angles shown on Cross-Section B-B' are 40 degrees, 37 degrees,
and 33 degrees on the south slope for Pit Phases 2, 3, and 4, respectively. The northern Phase
1 pit slope shown on Cross-Section B-B' has an overall cut slope angle of 23 degrees. The
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Phase 0 pit excavation (represented by a green line on Cross-Section A-A') occurs during
development and is associated with a short excavation depth.
The floor of the legacy open pit is at 660 feet amsl. The proposed open-pit mine plan will
expand the open pit by 900 feet to the southwest and deepen the pit floor another 465 feet (the
maximum depth of the planned excavation) to an approximate elevation of 195 feet amsl (the
elevation of the maximum depth of excavation). The overall slope heights and angles range
from 650 feet and 37 degrees at the east wall to 705 feet and 53 degrees at the west wall,
respectively. At the end of operations (see Figure 29: End of Operations [End of Mining Year
9.4] LOM Phase 3) the pit excavation will be 3,300 feet long, 1,800 feet wide, and 800 feet deep
relative to the pit crest elevation.
The pit slopes were designed based on design acceptance criteria that used industry best
practices, factors of safety, and probability of failure criteria for different slope scales including:
benches, inter-ramp, inter-ramp (above and below), and overall slope (interim and final walls)
(see Table 9-2 in Appendix A: Abridged Select Phase Geotechnical Report— Pit Stability and
Modeling of Appendix G: Geotechnical Stability Reports, Calculations, and Cross-Sections). A
geotechnical stability study for the proposed open pit (see Appendix A: Abridged Select Phase
Geotechnical Report— Pit Stability and Modeling of Appendix G: Geotechnical Stability Reports,
Calculations, and Cross-Sections) identified and modeled four geotechnical domains (see
Figure 23: Map and Cross-Section Showing the Pit Geotechnical Domains and Sectors). The
four open-pit geotechnical domains are associated with four separate walls (east, west, north,
and south) and bench face angles, widths, heights, and inter-ramp angles for each are
summarized in Table 10-5 in Appendix A: Abridged Select Phase Geotechnical Report— Pit
Stability and Modeling of Appendix G: Geotechnical Stability Reports, Calculations, and Cross-
Sections. Each of the geotechnical domains (and walls) are associated with single or single and
double-bench design configurations as described below.
The north, west, and south walls were designed with double benches (60-foot height) and single
bench (30-foot height) strategies. For the north, west, and south walls, the single bench slope
designs include:
• 78-degree bench face angles
• 20-foot bench widths
• 48.7-degree inter-ramp angles
The double-bench slope designs for the north, west, and south walls include:
• 78-degree bench face angles
• 26-foot bench widths
• 57.1-degree inter-ramp angles
The east wall geotechnical domain has more abundant structural controls and has been
designed more conservatively than the other three pit walls to include only the following single
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30-foot bench height configuration design parameters: 60-degree bench face angles, 20-foot
bench widths, and 38.8-degree inter-ramp angles.
7. Describe other methods to be taken during mining to prevent physical hazard
to any neighboring dwelling, house, public road, or public, commercial or
industrial building from any mine excavation. Locate all such structures on the
mine map if they are within 300 feet of any proposed excavation.
There are no neighboring dwellings, houses, public roads, or commercial buildings within 300 feet
of the mine pit. A preliminary blasting impacts study was prepared by Austin Powder to assess
flyrock, ground vibration, and overpressure from blasting operations, and concluded that blasting
will not cause exceedances of regulatory standards.
A detailed blasting plan will be implemented, which will involve pre-assessment and modeling of
each blast to meet regulatory limits. The response in Section C.11. below provides additional
details.
8. Describe what kind of barricade will be used to prevent inadvertent public
access along any high wall area and when it will be implemented. Vegetated
earthen berms, appropriate fencing and adequate boulder barriers may be
acceptable high wall barricades. A construction detail/cross-section and
location of each type of barricade to be used must be indicated on the mine
map(s).
The existing open pit at the mining site is currently fenced with a highwall barrier to prevent
public access. A portion of the pit is adjacent to a legacy stockpile known as Cardio Hill, as well
as the operating Martin Marietta mine. The open pit is located adjacent to the popular
recreational Gateway Trail, which will be relocated away from the site before commencement of
mining operations. No access incidents have occurred.
To further enhance safety measures and prevent unauthorized entry into the open pit area, a
high wall barrier/ new chain link fence will be constructed. This fence will be made of industrial-
grade, galvanized steel, and stand at a height of 6 feet. Installation will include excavation and
the addition of concrete footing to maintain stability and durability. The fence will be positioned
along the outer perimeter of the site, inside the berms, and inside Cardio Hill, effectively
delineating the boundary and restricting access to the open-pit area. The location of the fence
on the inside of the berm improves the aesthetic of the mine's perimeter. The combination of
Cardio Hill, Martin Marietta's site, fencing, berms, and existing and proposed vegetation function
together as the highwall barrier for the pit. The fencing will not cross any watercourse or
wetland.
In addition to physical barriers such as fencing, surveillance systems and lighting will provide
further deterrence against unauthorized access to the open pit. Surveillance cameras
strategically placed along the perimeter will monitor activity and provide real-time alerts in the
event of breaches or trespassing attempts. Combined with adequate lighting, particularly during
nighttime hours, these measures will deter potential intruders and enhance overall site security.
Moreover, signage indicating restricted access and warning of potential hazards will serve as
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additional reminders for the public to adhere to safety regulations and respect the boundaries of
the mining site. Regular monitoring and maintenance of these security measures will maintain
their effectiveness over time. This includes routine inspections of fence integrity, surveillance
equipment functionality, and lighting systems. Any identified issues or vulnerabilities will be
promptly addressed to maintain the integrity of the perimeter security and prevent potential
safety hazards_
9. Are acid producing minerals or soils present? If yes, how will acid water
pollution from the excavation, stockpiles, and waste areas be controlled?
It is anticipated that PAG waste rock will be encountered during operations. PAG rock will
initially be stored in RSF-W located within the existing mine pit (for approximately 2 years), while
construction of RSF-X is underway. During this period, runoff from RSF-W will be routed to the
open pit sump where it will be comingled with pit wall runoff and dewatering flow (see Figures
31-35: Kings Mountain Mine Site Layout Series)where settling will occur. The pit sump water
will then be pumped to the WSB-1 forebay, where additional settling will occur and where the
pumped water will be comingled with water in WSB-1 before either being recycled for facility use
and/or discharge of excess wastewater. Water quality modeling indicates that this temporary
situation will not cause exceedances of NCG02 discharge limits or any predicted exceedances
of North Carolina Surface Water Quality Standards (Appendix Q: Groundwater and Surface
Water Sampling and Analysis Program for the Kings Mountain Mining Project), and if necessary,
water will be held in WSB-1 to correct before discharge.
All PAG in RSF-W will be relocated from the pit to RSF-X when construction is completed.
RSF-X and its associated collection pond (51) will be equipped with an impermeable lining, to
prevent migration of waters into groundwater, and to allow collection and treatment at the WTP.
At closure, PAG rock will be removed from RSF-X and used to backfill the pit. The PAG will be
placed in level lifts in the bottom of the pit, which will decrease the time needed to inundate the
PAG material with water. During closure, the pit will not discharge, and subaqueous disposal of
PAG material will prohibit further oxidation.
Although not directly requested in the application form, demonstration that the Project will not
have adverse impacts to surface and groundwater is provided in this section.
Groundwater
The potential for groundwater to be impacted from the proposed Project was evaluated in
several ways: i) establishing current baseline groundwater quality through routine monitoring, ii)
an extensive laboratory testing program on the leachability of select constituents from potential
future waste rock, and iii) predictive water quality modeling informed by the monitoring and lab
testing programs, which include particle tracking to inform the timing and direction of runoff and
seepage from mine waste facilities.
Routine water quality monitoring has occurred on the KMM site since May 2022 to establish
baseline water quality relative to NCDEQ groundwater and surface water standards. The
groundwater quality data generated to date has indicated there are several parameters that
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consistently exceed Class GA groundwater standards. These parameters are grouped into three
categories based on their geographic location and frequency of detection:
• pH: Slight exceedances of the pH standard both below 6 and above 9 have been observed
in sporadic wells, considered the result of natural processes.
• Antimony, cobalt, iron, manganese, and vanadium: Concentrations of these five parameters
above Class GA standards frequently appear in multiple wells throughout the property.
These elevated concentrations of the elements are considered to be naturally occurring
within the geologic formation.
• Gross alpha: Occurs frequently in select wells: RTKM22-399 and RTKM22-401, and less
frequently in SNKM22-432 and SNKM22-384 and is also considered to be naturally
occurring within the geologic formation.
Several methods of forward-looking modeling were completed to assess the potential future
impacts to water quality which could arise from the proposed Project. These are i) groundwater
modeling to assess changes in flow direction and potentiometric surfaces, ii) geochemical
modeling to assess changes in the chemical composition of groundwater and surface water,
and iii) particle tracking (or flow path modeling)which was coupled with geochemical modeling
to assess the timing and fate of any potential impacts predicted by the geochemical modeling.
High level conclusions from the numerical modeling program are as follows:
• Groundwater is shallow and will flow towards the pit and/or report to the flowing creeks on
the property (i.e., South Creek and Kings Creek) (SRK 2023). The competency of the
bedrock results in a shallow potentiometric surface with depths to groundwater averaging
20 to 100 feet bgs.
Potential impacts to groundwater that will report to surface waters were also evaluated. In
addition to the flows to Kings Creek and South Creek, groundwater entering the mine pit will be
discharged to WSB-1, along with collected seepage from RSF-A. Since RSF-A will not be lined,
some of the seepage water will enter the groundwater system and report to South Creek.
Geochemical modeling of seepage and runoff from RSF-A indicates there is a slight potential for
some regulated parameters to leach from the non-PAG rock (e.g., arsenic, antimony,
manganese). Several of these parameters are already elevated in the baseline and the
predicted concentrations are considered to be a factor of the geologic material and not the effect
of mining on the rocks. However, additional particle tracking modeling was implemented to
predict the flow path particles leaving RSF-A. Predicted flow paths indicate all groundwater will
report to either the mine pit (which will discharge to WSB-1), or to the South Creek/ Kings
Creek system. Ultimately, the study concluded that groundwater contributions to Kings Creek
and WSB-1 will not cause exceedances of NCDEQ Class C Water Quality Standards.
Surface Water
Routine quarterly surface water sampling from multiple locations at site has been occurring for
approximately 2.5 years. The number of locations has fluctuated over the Project duration to
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meet data needs, although at least eight locations representing important water features onsite
have been sampled during each event. To date, 75 sample events are available in total.
Sampling results indicate that baseline water quality meets NCDEQ Class C Water Quality
Standards, with exceptions noted below. These exceedances are considered to be geogenic in
origin and are not, therefore, an impact of the prior operation. Extensive geochemical testing of
the naturally occurring materials within the Project boundary has indicated that multiple metals
are present in the rocks at concentrations exceeding average crustal abundance and therefore
future exceedances may be observed within some water bodies. However, forward-looking
water quality predictions do not indicate any exceedances at permitted discharge points:
• Copper: Nine measurements in exceedance from 75 sampling events, observed in five
locations.
• Nickel: Four measurements in exceedance from 75 sampling events, observed in three
locations.
• Radium-228: Three measurements in exceedance from 75 sampling events, observed in
three locations.
• Gross alpha: One measurement in exceedance from 75 sampling events, observed in one
location.
• pH: Three measurements in exceedance (below 6) from 75 sampling events, observed in
three locations.
• Cyanide: Two measurements in exceedance from 75 sampling events, observed in two
locations.
WSB-1 will collect and discharge all waters that contact waste rock and ore along with process
wastewater, and therefore has the greatest potential to impact water quality in the downstream
Kings Creek. Albemarle performed water quality predictions for WSB-1 to compare the
anticipated discharge to NCG02 and North Carolina Class C Surface Water Quality Standards.
Results are summarized in the Table 12 below. It should be noted that concentrations of all
parameters, with the exception of pH, are predicted to be below NCDEQ Class C Surface Water
Quality Standards (and NCG02 wastewater discharge limits).
The predicted marginally low pH is attributed to the naturally acidic pH of rainwater that will
contribute direct precipitation to WSB-1, representing approximately 30 percent of total flow.
However, baseline water quality sampling of Executive Club Lake, which currently receives
essentially the same direct precipitation as will WSB-1, has not shown lower pH, which provides
strong confidence that the pH of the discharge waters will meet the NCG02 standard. However,
Albemarle has developed contingency plans if low pH is measured, which will include holding
material in WSB-1 to prevent discharge before mitigation is implemented.
The discharge of water from WSB-1 is, therefore, expected to meet all NCDEQ Class C Surface
Water Standards and NCG02 discharge limits.
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Table 12: Water Storage Basin 1 Water Quality Predictions
Parameter Surface Water WSBA Water Quality Predictions 3
- Chronic Acute
pH 6.0-9.0 6.0-9.0 5.64 4.94 5.75
Total dissolved solids 500 210 118 256
Chloride 230 8.71 6.8 11.8
Antimony 0.34/0.34 0.0009 <0.0004 0.0013
Aluminum 0.3/0.75 0.24 0.03 0.64
Arsenic 0.15 0.34 0.15/0.15 0.003 0.0004 0.004
Beryllium 0.0065 0.065 0.0004 <0.00008 0.0007
Cadmium 0.00064 0.00394 0.0001 <0.00005 0.0002
Chromium 0.104 0.794 0.117/ 0.004 0.001 0.011
0.905
Copper 0.0134 0.0204 0.002 <0.0008 0.005
Fluoride 1.8 6/6 0.16 <0.15 0.23
Lead 0.00394 0.104 0.0003 <0.0001 0.0006
Mercury 0.000012 0.000001 <0.0000003 0.000002
Nickel 0.0734 0.664 0.011 0.002 0.038
Selenium 0.005 0.0004 <0.0001 0.0006
Silver 0.00006 0.00654 0.0002 0.0001 0.0003
Zinc 0.1674 0.1654 0.126/ 0.04 <0.006 0.08
0.126
All concentrations in milligrams per liter(mg/L)
North Carolina Department of Environmental Quality 15A NCAC 02B.0211: Fresh Surface Water Quality Standards
for Class C Waters
2 The two numbers in the NCG02 column represent the daily maximum and monthly average
3 Source: SRK 2024d
4 Thresholds calculated assuming a hardness value of 150 mg/L as CaCO3(calcium carbonate)
NCDEQ= North Carolina Department of Environmental Quality;WSB-1 =Water Storage Basin 1
10. A) Describe specific plans (including a schedule of implementation) for
screening the operation from public view such as maintaining or planting
trees, bushes or other vegetation, building berms or other measures. Show the
location of all visual screening on the mine map(s) and provide cross-sections
through all proposed berms or proposed spacing, sizes and species for tree
plantings.
Please see the response to Section C.5. above regarding the various buffer types proposed,
which will be used to provide screening of the operations from public view. One of the
unexcavated buffers consists of a berm that will be planted with native vegetation along certain
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sections of the property boundary. Plan view and cross-sections of the buffer and plant
installation are included on Figure 25: Kings Mountain Site Layout and Property Buffers. Buffer
types and locations were selected based on the VIA and consultation with the City of Kings
Mountain, which is described in more detail below and included in Appendix N: Visual Impact
Assessment Report.
10. B) Could the operation have a significantly adverse effect on the purposes of a
publicly owned park, forest, or recreation area? If so, how will such effects
(i.e., noise, visibility, etc.) be mitigated?
The Project will not have a significantly adverse effect on the purposes of a publicly owned park,
forest, or recreation area.
• The Gateway Trail is primarily used for passive recreation by community members and
school groups. As previously mentioned, most of the Gateway Trail exists within the Project
boundary and will be relocated, in partnership with the Kings Mountain Gateway Trail
Association, to an area that will not be impacted by the mine.
• The portion of the Gateway Trail that will remain after relocation is adjacent to the proposed
Project boundary and the ongoing Martin Marietta mine, where similar mining activities
occur.
• Patriot's Park is the closest public park to the Project location, approximately 0.8 miles from
the northeastern edge of the Project boundary and 0.5 miles from Martin Marietta.
• Crowder's Mountain State Park is the closest state park, with the park boundary
approximately 2 miles southeast of the Project.
Albemarle has conducted blast and vibration analyses that indicate that operations will not
produce adverse impacts at any of the public park or recreation areas, and these impacts will
not be detectable at Patriots Park or within Crowders Mountain State Park. The Project will not
cause increased traffic next to, or through, any of these public areas.
Due to the distance of the state park from the Project and post-closure compatibility with the
landscape, no significant impacts are anticipated with respect to noise, vibration, dust, or traffic
generation (Figure 47: Public Lands, Recreation, and Conservation Areas Map).
Albemarle developed a VIA to document existing conditions and assess potential impacts to
viewshed within the Project's surrounding area.
The results of the VIA specific to public recreational areas indicate that:
• The Project will not be visible from Patriots Park.
• Visual impacts from the Gateway Trail are already present, with overviews of Martin
Marietta's current operations, and Albemarle's legacy mine pit, available from the legacy
TSFs from prior mining operations. These visible mine features are highlighted and
discussed by signage along the Gateway Trail.
• The Project will not be visible from the majority of locations within Crowders Mountain State
Park. It will be seen only from elevated viewpoints (particularly from Kings Pinnacle) where
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the legacy mine features are only moderately apparent. The Project will become somewhat
more visible during construction and operations but will not significantly change the quality
of view obtained from Kings Pinnacle. Figure 5-6 in Appendix N: Visual Impact Assessment
Report indicates current and future state depictions of the view from Kings Pinnacle. As the
figure indicates, the most prominent feature visible will be RSF-A, which will remain after
closure.
11. Will explosives be used? If yes, specify the types of explosive(s) and describe
what precaution(s) will be used to prevent physical hazard to persons or
neighboring property from flying rocks or excessive airblasts or ground
vibrations. Depending on the mine's location to nearby structures, more
detailed technical information may be required on the blasting program (such
as a third-party blasting study). Locate the nearest offsite occupied
structure(s) to the proposed excavation(s) on the mine map and indicate its
approximate distance to the proposed excavation.
Explosives will be used during blasting to fragment the weathered and competent rocks to allow
excavation of the ore and waste from the open pit using excavators, loaders, dozers and haul
trucks. All blasting will be performed using ammonium nitrate/fuel oil, emulsion, bulk, or
packaged products. Shots will be initiated with non-el (shock-tube), electric, or electronic
blasting caps. Blasting will occur approximately five times per week, but not over weekends,
holidays, during daytime working hours, or when adverse meteorological conditions exist. All
blasts will be monitored with a seismograph. An experienced and licensed contractor will handle
all explosives. No explosives will be stored on the Project site. Variables (precautions) that will
be used to prevent physical hazards to persons or neighboring properties from flying rocks,
excessive airblasts, or ground vibrations are described below. A blasting study was performed
as part of the development of this permit application (Appendix R: Albemarle Kings Mountain
Mine — Blasting Impact Study).
The results of the blasting study were used to determine prefeasibility-level (plus or minus 25
percent accuracy level) seismic predictions (relative to nearby utilities and regularly occupied
onsite and offsite buildings). Preliminary KMM drilling and blasting designs, using a risk-based
classification scheme, have been developed by an experienced contractor in accordance with
established industry standard mathematical models developed by the U.S. Bureau of Mines
(Siskind et al. 1980a, 1980b). A detailed blast management plan will be developed with the
goals of sufficiently fragmenting the rock to feed the crusher as well as following North Carolina
regulations and incorporating information gained during controlled blasting trials to collect seed
ground vibration wave forms at different distances and orientations from the trial blasts. These
trial blasts will be used to determine the delay times to shift the frequencies away from the
natural frequencies of the structures or even cancel the waves to reduce effective ground
vibrations near critical structures.
For any regularly occupied building outside of the permit area, including a dwelling, house,
church, school, or public, commercial, or institutional building, ground vibrations will be
maintained below the thresholds identified in the Z-curve and contained in Albemarle's current
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mine permits. Ground vibrations will be maintained at historical and sensitive structures at less
than 0.5 inches per second (12.5 millimeters per second) for frequencies less than 40 hertz and
less than 0.25 inches per second (6.35 millimeters per second) for frequencies less than
40 hertz (a guideline taken from Konan and Schuring [1983] since there are currently no existing
North Carolina requirements for historical and sensitive structures).
• Airblast levels at the nearest offsite occupied structure will be maintained below the
requirements in North Carolina Mining Permits.
• Flyrock distances will not extend beyond the permitted zone and guarded zone (as currently
identified in the existing North Carolina Kings Mountain Facility—West Mining Permit No.
23-24 and in the North Carolina Surface Mining Manual [1996]).
Due to the proximity of mine facilities and other site-specific structures to the open pit, higher
risk zones (vs. lower risk zones) have been preliminarily identified using the mathematical
models described above. The blasting mathematical model identifies each site-specific structure
near the planned open pit, and all calculated peak particle vibrations and over pressure
vibrations in front of the free face results suggest that an acceptable blasting plan may be
developed to support the KMM open-pit mining plans.
The nearest offsite occupied structure to the proposed pit/excavation is the residence at 920
South Battleground Avenue, which is located approximately 490 feet away from the ultimate pit
edge (Figure 48: Closest Occupied Residence to Pit).
The current model does not predict the frequency of ground vibrations; therefore, the blasting
study recommends conducting controlled shot trials to obtain seed ground vibration wave forms
as previously discussed in this response.
The Project will also conform with North Carolina blasting condition regulations required by
surface mining permits as identified in both the North Carolina Surface Mining Manual
(NCDEHNR 1996) and the existing East and West Mine permits, or where otherwise noted:
The results of the blasting impact study for ground vibration, air overpressure, and flyrock
provide a high level of confidence from the experienced blasting contractor that blasting can be
safely executed while maintaining compliance with North Carolina's requirements and
minimizing negative effects on adjacent offsite neighbors and their properties.
The following precautions will be used to prevent hazards to persons or neighboring property
from flyrock, excessive airblasts, or ground vibrations:
• Avoiding overcharging.
• Loading to design stemming length.
• Using smaller diameter blast holes and lower powder factors.
• Reducing the number of rows and size of the blast.
• Reducing the maximum instantaneous charge by delaying deck blasting.
• Orienting the blast face away from sensitive structures.
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• Avoiding blasting when wind is blowing towards sensitive structures.
• Establishing flyrock risk profiles using computer blast simulations to help develop specific
mitigation plans to keep flyrock contained to a designated area marked on the ground and
not extend beyond the permit area.
• Using controlled blasting techniques (e.g., pre-split, deck blasting, trench blasting, blasting
mats, etc.) as necessary.
12. Will fuel tanks, solvents, or other chemical reagents be stored onsite? If yes,
describe these materials, how they will be stored and method of containment
in case of spill. Indicate the location(s) of all storage facilities on the mine
map(s).
Small fuel tanks (natural gas, diesel, and oil) will be located onsite (Figure 49: Fuel Station
Location Map). Additionally, solvents and chemical reagents will also be stored onsite within
appropriately designed structures. Safety data sheets for all chemicals to be used and/or stored
onsite will be readily available and easily accessible to all onsite employees. A Spill Prevention
Control Plan will be developed for each storage area.
D. RECLAMATION PLAN
1. Describe your intended plan for the final reclamation and subsequent use of all
affected lands and indicate the sequence and general methods to be used in
reclaiming this land. This must include the method of reclamation of settling
ponds and/or sediment control basins and the method of restoration or
establishment of any permanent drainage channels to a condition minimizing
erosion, siltation and other pollution. This information must be illustrated on a
reclamation map and must correspond directly with the information provided
on the mine map(s). In addition, design information, including typical cross-
sections, of any permanent channels to be constructed as part of the
reclamation plan and the location(s) of all permanent channels must be
indicated on the reclamation map.
Albemarle has developed a preliminary conceptual closure plan (Appendix O: Conceptual
Closure Plan) to address DEMLR closure and reclamation requirements. Albemarle continues to
solicit feedback from the community and other stakeholders through public engagements and
correspondence to develop a post-closure vision that is acceptable to those who have a vested
interest in the Project. The closure and reclamation plan will be modified as needed as these
discussions progress.
The overall objectives of the of the closure strategy include the following:
• Ensuring legal and other obligations are met.
• Managing reputational impacts.
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• Relinquishing a safe and secure site where remaining infrastructure is chemically and
physically stable.
• Implementing closure actions that minimize impacts on remaining mineral resources.
• Protecting and preserving remaining environment, including limited impacts on community
water sources.
• Implementing socioeconomic transitioning measures to assist community sustainability and
future development.
The closure strategy includes implementation of BMPs so the Project is consistent with the
approved post-mining land use. The following briefly describes proposed closure activities for
primary Project components and facilities. More detailed information can be found with the
above referenced closure report.
• Revegetation: A revegetation plan for the site has been developed and includes the
appropriate seed mix consistent with DEMLR requirements.
• Stormwater: Surface water will be directed towards pre-Project flow paths to the greatest
extent possible. Sediment ponds will be breached or removed. Culverts will be removed and
filled/regraded. Remaining channels will be modified to meet probable maximum
precipitation storm events. The embankment of WSB-1 will be breached back to original
channel elevation.
• Open pit: PAG material from RSF-X will be backfilled into the open pit and will take
approximately two years to complete. The final backfill top elevation will be approximately
570 feet amsl (see Figure 30: End of Reclamation [After Mining Year 9.4] LOM Phase 4).
The open pit will be hydrologically recharged primarily from groundwater inflows. Water
quality within the pit will meet all applicable surface water quality standards. A berm will be
constructed along the edge of the pit for public safety purposes and the entrance will be
blocked with a locking gate to allow monitoring. The pit will fill with water until it reaches the
rim and enters a discharge channel, approximately 49 to 64 years after cessation of mining.
• Water treatment: Contact water from the RSF-X collection pond will continue to be treated
by the WTP in closure until all of the PAG rock from RSF-X has been removed and placed in
the pit. In addition, the WTP will continue to treat water from the RSF-X collection pond (51),
and all process waters (e.g., ponds, tanks) from the process plant until they have been
drained, emptied and reclaimed.
• Waste rock: RSF-A will remain after closure with a slope of 2 horizontal to 1 vertical after
final grading. The slopes will be covered with 1 foot of growth media and seeded with an
approved seed mix and tree seedlings. After the PAG material stored within RSF-X is
relocated to the open pit, the liner will be cut into strips and removed for disposal at an
approved location or within an onsite void. The underlying soils will be tested and
subsequently graded to promote water flow into South Creek. The regraded area will also
receive 1 foot of growth media and be seeded.
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• OSFs: No closure activities are anticipated in these areas other than revegetating any
surfaces disturbed by use of material during closure activities.
• WSB-1: Closure of WSB-1, will restore discharge from the reservoir to the current stream
condition by removing the embankment over the natural channel. The side slopes will be cut
to 3 horizontal to 1 vertical and covered with 1 foot of growth media and seeded.
• Infrastructure: All buildings will be decommissioned and demolished. Potentially impacted
soils will be tested and managed.
• Process facilities: The crusher and tailings loadout areas will be reclaimed and restored.
Growth media will be added to create 1 foot of overburden and seeded.
• NPI: The NPI areas will be reclaimed and restored in entirety. Growth media will be added to
create 1 foot of overburden and seeded.
• Power lines and power distribution: Any system that is determined to be needed post
closure will remain. Any temporary infrastructure that was installed to support operations will
be reclaimed and restored. The Duke Energy Corporation substation will not be removed.
• Water supply system: All pipes and pumps will be dismantled and removed.
• Roads: Roads that are needed post closure will remain and be narrowed to a width of
15 feet.
• Industrial and hazardous waste: Waste will be identified and properly disposed of per
Resource Conservation and Recovery Act (RCRA) requirements at an approved, offsite,
third-party facility.
• Well abandonment: There are no water supply wells as part of the Project. Any monitoring
wells not needed for post-closure monitoring will be closed in accordance with state
regulations.
2. Is an excavated or impounded body of water to be left as part of the
reclamation? If yes, illustrate the location of the body(s) of water on the
reclamation map and provide a scaled cross-section(s) through the proposed
body(s) of water. The minimum water depth must be at least 4 feet, measured
from the normal low water table elevation, unless information is provided to
indicate that a shallower water body will be productive and beneficial at this
site.
The open pit will be partially backfilled by moving all PAG material from RSF-X as described in
the previous section (Section D.1.) and will refill through accumulation of groundwater and
surface water flows to a point where it will overflow through a discharge channel.
Will the body(s) of water be stocked with fish? If yes, specify species.
The open pit will not be stocked with fish upon closure and is currently not being considered for
recreational use.
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3. Describe provisions for safety to persons and to adjoining property in all
completed excavations in rock including what kind of permanent barricade will
be left. Acceptable permanent barricades are appropriate fencing, large
boulders placed end-to-end, etc. Construction details and locations of all
permanent barricades must be shown on the reclamation map.
The post reclamation pit and lake will require access restrictions for long-term safety.
Exclusionary fencing will remain in place to deter the public from accessing the open pit and
other areas deemed unsafe at the time of closure.
The overall objective of the closure plan will be to relinquish a safe and secure site where
remaining infrastructure is chemically and physically stable. Water treatment at the Project will
not be required after all the RSF-X materials have been removed during closure and placed in
the pit as backfill.
4. Indicate the method(s) of reclamation of overburden, refuse, spoil banks or
other such onsite mine waste areas, including specifications for benching and
sloping. Final cross-sections and locations for such areas must be provided
on the reclamation map.
A) Describe reclamation of processing facilities, stockpile areas, and onsite
roadways.
Office facilities, workshops, crushers, stockpiles, and warehouses will be temporary and
removed from the site during closure.
The processing plant and ancillary facilities will remain active until material processing has been
completed. Subsequently, the plant equipment will be cleaned, decontaminated, and removed
from the Project. The foundations will be demolished, removed, and reclaimed. Any remaining
chemicals will be disposed of in accordance with applicable regulations.
Roadways will be closed by ripping compacted surfaces, regrading as needed to promote
proper surface drainage, covering the area with growth media where needed, and revegetating.
4. B) Will any onsite roadways be left as part of the reclamation? If yes, identify
such roadways on the reclamation map and provide details on permanent road
and ditch line stabilization.
Roads that are not needed for closure and post-closure uses such as water
management/treatment, power generation, security, and monitoring will be closed. This will be
undertaken by ripping compacted surfaces, regrading as needed to promote proper surface
drainage, covering the area with growth media where needed, and revegetating. Where
possible, the larger roads that are retained will be resized for post-closure use by regrading and
ripping to a width that is appropriate for anticipated post-closure traffic.
5. Describe the method of control of contaminants and disposal of scrap metal,
junk machinery, cables, or other such waste products of mining. (Note
definition of refuse in The Mining Act of 1971.)
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There are no current plans or facilities in the Project plan to dispose of mining waste products
other than refuse in the form of waste rock (which will be managed onsite in RSF-A) and sand
tailings (which will be managed at the Archdale TSF site under a separate mining permit). PAG
rock will be managed in RSF-X during operations and moved to the mine pit for permanent
disposal after closure, where it will be covered with water.
The mining process does not use chemical extractive techniques, and therefore there is no
sludge or other waste product generated during processing that has the potential to release
contaminants from the process. Sludge/brines from the treatment plant, or any other waste
generated onsite, will be disposed of offsite and managed appropriately in accordance with
RCRA and North Carolina regulations.
6. No offsite generated waste shall be disposed of on the mine site without prior
written approval from the NC Department of Environmental Quality, Division of
Energy, Mineral, and Land Resources and either the Division of Waste
Management (DWM) or local governing body. If a disposal permit has been
issued by DWM for the site, a copy of said permit must be attached to this
application. All temporary and permanent refuse disposal areas will be clearly
delineated on the mine map(s) and reclamation map, along with a list of items
to be disposed in said areas.
Industrial and hazardous waste will be identified in accordance with RCRA and applicable waste
regulations and disposed of offsite at an approved third-party facility.
Other waste products will be removed and transferred to an appropriate waste disposal facility
once closure is complete (Appendix O: Conceptual Closure Plan).
7. Describe your plan for revegetation or other surface treatment of the affected
areas. This plan must include recommendations for year-round seeding,
including the time of seeding and the amount and type of seed, fertilizer, lime
and mulch per acre. The recommendations must include general seeding
instructions for both permanent and temporary revegetation. Revegetation
utilizing only tree plantings is not acceptable.
All areas receiving growth media as per the closure plan design specifications included in
Appendix O: Conceptual Closure Plan will be revegetated using an approved seed mix. Table
13 includes a preliminary seed mix and schedule for permanent revegetation (see Appendix A:
Recommended Revegetation Plan of Appendix O: Conceptual Closure Plan).
Table 13: Preliminary Permanent Seed Mix Composition and Schedule
Seed Mix Type Seeding Dates Seeding Rates
North Carolina Steep Slope Mix All dates 45 Ibs/acre
(ERNMX-310)
Native Habitat Strip Mine Mix All dates 20 Ibs/acre
(ERNMX-111)
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Seed Mix Type Seeding Dates Seeding Rates
Native Steep Slope w annual rye Feb 15—Aug 15 60 Ibs/acre
(ERNMX-181)
Native Steep Slope w grain rye Aug 15—Feb 16 75 Ibs/acre
(ERNMX-181-2)
Source:Appendix 0: Conceptual Closure Plan
Ibs= pounds
Temporary cover species for erosion protection and temporary revegetation on exposed cut
slopes, road embankment slopes, the GMS area, and earthen berms during construction and
operations, including application time frames and rate for erosion control, will likely include:
• Brown Top Millet—February 15 to August 15, 20 pounds per acre; and
• Annual Rye Grain—August 15 to February 15, 30 pounds per acre.
Temporary mine features will all be removed or modified during final reclamation. Progressive
closure of some portions of the site during operations, depending upon availability of equipment
and staff, will be done to test the effectiveness of the proposed methods and types of closure
activities. Activities could include addition of cover and growth media, surface water
management, and revegetation performance evaluation. Because RSF-A will be constructed
from the bottom up, the lower lifts/slopes constructed earlier in the mine life should be available
for permanent reclamation and closure when they are completed to their final configuration.
The side slopes of the WSB-1 embankment will be cut to a slope of 3 horizontal to 1 vertical and
covered with 1 foot of growth media and reseeded with an approved permanent seed mix.
Seed will be procured from an approved seeding contractor. No fertilizer or lime applications are
recommended at this time, due to the success of volunteer regrowth seen during site visits.
Mulch consisting of small grain straw is recommended at an application rate of 2,000 pounds
per acre and will be tacked or mechanically tied down within 2 days of mulch application (see
Appendix A: Recommended Revegetation Plan of Appendix O: Conceptual Closure Plan).
Selection of tree species for seeding is recommended to be similar to existing tree species
occurring in the Project area or adjacent to the Project area.
E. DETERMINATION OF AFFECTED ACREAGE AND BOND
A blanket bond of$1 million (the maximum amount under law) has already been provided to
DEMLR.
F. NOTIFICATION OF ADJOINING LANDOWNERS
Notification to adjoining landowners will be performed in accordance with North Carolina Mining
Permit Application requirements. A map and list of all adjoining landowners has been provided
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in Appendix A: Mine and Reclamation Maps (Figures 50 through 56) and Appendix S:
Landowner Notifications, respectively.
G. LAND ENTRY AGREEMENT
Included in Mine Permit Application form.
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K REFERENCES
Albemarle Corporation (Albemarle). 2024a. Kings Mountain Mining Project Truck Trip Counts.
Email from Albemarle Corporation dated May 6, 2024.
Hatch Engineering Ltd. (Hatch). 2023a. Albemarle Kings Mountain Mine Select Phase— Permit
Information. Report submitted to Albemarle. Includes preliminary site and plant designs.
September 15, 2023. Hatch Project No. H371132.
Hatch. 2023b. Albemarle Kings Mountain Mine Select Phase EPCM: Permit Information.
October 13, 2023. Project No. H371132-4900-840-046-0002, Rev. A.
Hatch. 2023c. Kings Mountain Mine Select Phase Study- Process Plant Description. Report
prepared for Albemarle. Report date: December 12, 2023.
Hawley, M., Cunning, J., and The Commonwealth Scientific and Industrial Research
Organization (CS IRO). 2017. Guidelines for Mine Waste Dump and Stockpile Design.
Clayton South, VIC: CSIRO Publishing.
Horton, J.W., Jr. 1981. "Shear Zone Between the Inner Piedmont and the Kings Mountain Belts
in the Carolinas." Geology, V. 9, Number 1, 1981, p. 28-33.
Horton, J.W., Jr. 2008. "Geologic Map of the Kings Mountain and Grover Quadrangles,
Cleveland and Gaston Counties, North Carolina, and Cherokee and York Counties,
South Carolina." U.S. Geological Survey Scientific Investigations Map 2981, 1 sheet,
1:24,000 scale, 2008, with 15 p. pamphlet.
Konon, W. and Schuring, J. 1983. 'Vibration Criteria for Historic and Sensitive Older Buildings."
American Society of Civil Engineers. Preprint 83-501.
Merschat, A.J., Hatcher, R.D., Jr., Byars, H.E., and Gilliam, W.G. 2012. "The Neocadian
Orogenic Core of the Southern Appalachians: A Geo-traverse through the Migmatitic
Inner Piedmont from the Brushy Mountains to Lincolnton, North Carolina." In: Eppes,
M.C., and Bartholomew, M.J., eds., From the Blue Ridge to the Coastal Plain: Field
Excursions in the Southeastern United States: Geological Society of America Field
Guide 29, 2012, p. 171-217.North Carolina Sedimentation Control Commission
(NCSCC). 2013. Erosion and Sediment Control Planning and Design Manual. May 2013.
North Carolina Department of Environment, Health, and Natural Resources. (NCDEHNR). 1996.
North Carolina Surface Mining Manual.
Read, J. and P. Stacey. 2009. Guidelines for Open-pit Slope Design (LOP). CISRO. Victoria,
Australia.
Siskind, D.E., M.S. Stagg, J.W. Kopp, and C.H. Dowding. 1980a. Report of Investigations RI
8507 Structure Response and Damage Produced by Ground Vibration from Surface
Mine Blasting. United States Bureau of Mines.
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Siskind, D.E., V.J. Stachura, M.S. Stagg, M.S., and J.W. Kopp. 1980b. Report of Investigations
8485 Structure Response and Damage Produced by Airblast from Surface Mining.
United States Bureau of Mines.
SRK Consulting U.S., Inc. (SRK). 2023. Particle Tracking Simulations for Kings Mountain.
Memo Submitted to Albemarle Corporation. Memo dated October 31, 2023.
SRK. 2024a. Technical Report— Factual Report, Kings Mountain Mining Project. Report
submitted to Albemarle Corporation. Report date: April 9, 2024.
SRK. 2024b. Rock Storage Facilities RSF-A and RSF-X— Pre-Feasibility Site Characterization
Report, Kings Mountain Mining Project Rev03. Report submitted to Albemarle
Corporation. April 19, 2024.
SRK. 2024c. Water Storage Basin 1 (WSB-1) - Pre-feasibility Site Characterization Report,
Kings Mountain Mining Project. Report submitted to Albemarle Corporation. Report date:
April 19, 2024.
SRK. 2024d. Technical Report: 2023 Prefeasibility Study— Geochemistry Water Quality
Predictions, Kings Mountain Mining Project. Prepared for Albemarle U.S., Inc. April 15,
2024. Albemarle Document No.: KM60-EN-RP-9151.
SWCA Environmental Consultants (SWCA). 2023a. Wetland and Waterbody Delineation Report
for the Albemarle Kings Mountain Lithium Mining Project, Cleveland County, North
Carolina. Report prepared for Albemarle U.S., Inc. Report Date: January 2023.
SWCA, 2023b. Phase I Archaeological Survey and Geoarchaeological Investigation for the
Proposed Kings Mountain Mining Project, Cleveland County, North Carolina. Report
submitted to Albemarle, U.S., Inc. Report date: March 2023.
SWCA. 2024. Additional Phase I Archaeological Survey for the Proposed Kings Mountain
Mining Project (Addendum 2). Report submitted to Albemarle, U.S., Inc. Report date:
June 2024.
Terracon. 2024. Kings Mountain Mining and Concentration Facility— Geotechnical Engineering
Report: Phase 1 — Crusher and ROM Pad. Report submitted to Albemarle Corporation.
Report date: April 2, 2024.
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APPENDIX A MINE AND RECLAMATION MAPS
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APPENDIX B PERMIT RELEASE FORM
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APPENDIX C DESIGN SHEETS
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APPENDIX D 2022 PREFEASIBILITY STUDY - HYDROGEOLOGY STUDY
AND GROUNDWATER MODELING
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APPENDIX E WATER SUPPLY WELL MITIGATION PLAN
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APPENDIX F STORMWATER MANAGEMENT PLANS AND EROSION AND
SEDIMENT CONTROL PLANS
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APPENDIX G GEOTECHNICAL STABILITY REPORTS, CALCULATIONS, AND
CROSS-SECTIONS
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APPENDIX H 2O23 PREFEASIBILITY STUDY - BASELINE GEOCHEMICAL
CHARACTERIZATION (ABRIDGED)
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APPENDIX I ABRIDGED ENGINEERING DESIGN REPORTS
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APPENDIX J SAFETY DATA SHEETS
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APPENDIX K 2023 PREFEASIBILITY STUDY: SURFACE WATER - WATER
BALANCE DEVELOPMENT REPORT
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APPENDIX L FEDERALLY AND STATE-LISTED SPECIES REPORT
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APPENDIX M LETTER FROM CITY OF KINGS MOUNTAIN ON SEWER
AVAILABILITY
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APPENDIX N VISUAL IMPACT ASSESSMENT REPORT
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APPENDIX O CONCEPTUAL CLOSURE PLAN
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APPENDIX P CROSS-SECTIONS
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APPENDIX Q GROUNDWATER AND SURFACE WATER SAMPLING AND
ANALYSIS PROGRAM FOR THE KINGS MOUNTAIN MINING PROJECT
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APPENDIX R ALBEMARLE KINGS MOUNTAIN MINE - BLASTING IMPACT
STUDY
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APPENDIX S LANDOWNER NOTIFICATIONS
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