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HomeMy WebLinkAboutAppendix K - Technical Memorandum – Evaluation of Mine Pit Operations on Water QualityPiedmont Lithium Carolinas, Inc. I North Carolina Mining Permit Application Appendices PIEDMONT LITHIUM Appendix K: Technical Memorandum — Evaluation of Mine Pit Operations on Water Quality DAAONT Technical NEMemorandum Evaluation of Mine Pit Operations on Water Quality Piedmont Lithium Carolinas, Inc. Gaston County, North Carolina August 30, 2021 This page intentionally left blank. Piedmont Lithium Carolinas, Inc. I Technical Memorandum — Evaluation of Mine Pit Operations on Water Quality Contents Contents 1 Introduction....................................................................................................................... 1 2 Data Comparison.............................................................................................................. 1 2.1 Groundwater..............................................................................................................1 2.1.1 Groundwater Levels.......................................................................................................... 2 2.1.2 Groundwater Quality......................................................................................................... 2 2.1.3 Leaching Potential of Tailings........................................................................................... 3 2.2 Surface Water............................................................................................................ 4 2.2.1 Surface Water Flow.......................................................................................................... 4 2.2.2 Surface Water Quality....................................................................................................... 5 2.3 Comparison of Groundwater and Surface Water Quality ............................................ 5 3 Conclusions...................................................................................................................... 7 4 References....................................................................................................................... 8 Tables Table 1. Well construction details............................................................................................... 2 Table 2. Model Predicted Dewatering Withdrawal Rates (HDR, 2021 a) ..................................... 5 Table 3. Comparison of groundwater and surface water samples .............................................. 6 Figures Figure 1 — Sample and Measurement Points Location Map Figure 2 — Plots of Groundwater Elevations Over Time Figure 3 — Box and Whisker of Groundwater Elevations Figures 4a through 4n — Box and Whisker of Groundwater and Surface Water Quality Data Figure 5 — Measured and Modeled Stream Flow Piedmont Lithium Carolinas, Inc. I Technical Memorandum — Evaluation of Mine Pit Operations on Water Quality ��� Contents List of Acronyms 2L NCDEQ 15A NCAC 02L .0202 groundwater standards DWM Division of Waste Management HDR HDR Engineering, Inc. of the Carolinas IMAC Interim Maximum Allowable Concentrations UGH Lithium hydroxide MCC Maximum Concentration of Contaminants MO Metso-Outotec NCDEQ North Carolina Department of Environmental Quality PACE Pace Analytical Services, LLC PCB polychlorinated biphenyls PSRG Preliminary Soil Remediation Goals PLCI Piedmont Lithium Carolinas, Inc. RCRA Resource Conservation and Recovery Act SVOC Semi -volatile Organic Compounds TCLP Toxicity Characteristic Leaching Procedures TSB Tin-Spodumene Belt USEPA Environmental Protection Agency VOC Volatile Organic Compounds Piedmont Lithium Carolinas, Inc. I Technical Memorandum — Evaluation of Mine Pit Operations on Water Quality ��� Introduction 1 Introduction Piedmont Lithium Carolinas, Inc. (PLCI) is proposing to construct an open pit mine in the Carolina Tin-Spodumene Belt (TSB) of North Carolina where lithium -bearing pegmatites have been identified. The approximately 1,548-acre Site is in an unincorporated area of Gaston County, on private land surrounding portions of Hephzibah Church Road, Whitesides Road, and St. Mark's Church Road, approximately one mile east of Cherryville, North Carolina. Planned mine operations will consist of the Piedmont Lithium Carolinas Mine #1, a Concentrate Plant, an Industrial Minerals Plant, and a Lithium Hydroxide Conversion Plant. This process will produce native overburden and dry -stacked concentrator tails at the Concentrator Plant as well as inert analcime residue from the Lithium Hydroxide Conversion Plant. PLCI is proposing to dry -stack the co -mingled mine refuse streams (native overburden, concentrator tails, and analcime residue) in the waste rock disposal area and/or use the refuse for reclamation to backfill the mine pits. In advance of mine development Piedmont Lithium Carolinas, Inc. (PLCI) commissioned HDR Engineering, Inc. (HDR) to develop and implement a baseline groundwater and surface water monitoring program to evaluate naturally -occurring conditions. In addition, HDR obtained one sample of analcime tailings produced in a microcosm study that mimicked potential lithium hydroxide conversion operations, for the purpose of testing to evaluate use of tailings as reclamation material. The analcime tailings were characterized as non -hazardous per Toxicity Characteristic Leaching Procedure (TCLP) testing. 2 Data Comparison 2.1 Groundwater HDR compared groundwater elevation and quality data, surface water quality data, and toxicity testing data, in conjunction with anticipated dewatering rates and periods to evaluate potential effects of mine pit dewatering on water quality within the mine pit boundaries. Between June 2018 and February 2020, PLCI implemented a baseline groundwater and surface water flow and quality monitoring program to assess existing conditions prior to potential development of the mine site. These activities consisted of the installation of five monitoring wells (MW-1 through MW-5), one aquifer test pumping well (PW-1), and four aquifer test observation wells (OW-1 S, OW-1 D, OW-2S, and OW-21D). Subsequent to installation of monitoring and observation wells in 2018, HDR conducted 17 groundwater gauging events, 12 groundwater sampling events, 2 surface water flow monitoring events, and 12 surface water sampling events, and 1 aquifer pumping test. Construction and geologic details for monitoring wells installed during this program are presented in Table 1. Piedmont Lithium Carolinas, Inc. i Technical Memorandum — Evaluation of Mine Pit Operations on Water Quality ��� Data Comparisons Table 1. Well construction details Well ID Top of Casing (Feet msl) Depth (Feet) Geologic Material PW-1 756.75 500 Amphibolite MW-1 762.49 110 Amphibolite/Pegmatite MW-2 864.49 110 Amphibolite/Pegmatite MW-3 840.39 170 Amphibolite MW-4 884.97 153 Biotite Gneiss MW-5 756.75 152 Amphibolite OW-1S 760.63 60 Unconsolidated Regolith OW-1 D 761.14 302 Amphibolite OW-2S 755.87 30 Unconsolidated Regolith OW-2D 755.05 300 Amphibolite 2.1.1 Groundwater Levels Groundwater levels were measured, and groundwater elevations were calculated, in each well during 17 well gauging events conducted between August 2018 and February 2020. Water levels collected during this time indicate that seasonal fluctuations in groundwater elevations were evident throughout the monitoring period. In general, groundwater elevations increased in fall and winter months, and decreased in spring and summer months, as would be expected in the Piedmont Region of North Carolina. Based on these data, well MW-3 exhibited the widest range of groundwater elevation fluctuation (about 10 feet), while well MW-1 exhibited the smallest range of fluctuation (less than 4 feet). Groundwater elevations across the Site ranged from approximately 850 feet mean sea level (msl) at MW-4 to about 740 feet msl in MW-1. Groundwater elevations were plotted by month for each well and are shown on Figures 2a and 2b. Box and whisker plots for bedrock and overburden wells were generated to show the range of groundwater elevations in each well (Figures 3a and 3b). 2.1.2 Groundwater Quality Monitoring wells were purged and sampled during 12 sampling events between August 2018 and February 2020. Additionally, pH field measurements were observed above and below the North Carolina Department of Environmental Quality (NCDEQ) groundwater quality standard (21- Standard) range of 6.5-8.5 standard units (SU) in each of the wells during the monitoring period (Figure 4a). Baseline groundwater and surface water monitoring is documented in the Technical Memorandum - Water Quality Testing (HDR, 2020). Concentrations of arsenic, chromium, lead, manganese, and fluoride that exceeded the 2L Standards were reported in wells MW-2, MW-5, OW-1 D, OW-2S, and PW-1 during the monitoring period. Box and whisker plots for each constituent that exceeded 2L Standards were generated and are presented in Figures 4b, 4c, 4d, 4e, and 4f, respectively. Barium, cadmium, lithium, mercury, selenium, chloride, and sulfate were detected in at least one sample above the laboratory reporting limit, but below the respective regulatory standards during the monitoring period, as shown in Figures 4g, 4h, 4i, 4j, 4k, 41, and 4m, respectively. Piedmont Lithium Carolinas, Inc. I Technical Memorandum — Evaluation of Mine Pit Operations on Water Quality ��� Data Comparisons 2.1.3 Leaching Potential of Tailings As documented in the Technical Memorandum — Toxicity Testing of Lithium Hydroxide Conversion Plant Tailings (HDR, 2021), PLCI commissioned Metso-Outotec (MO) to replicate ore concentrate conversion methods to be undertaken by PLCI during operation of the proposed Lithium Hydroxide Conversion Plant through bench -scale testing to convert spodumene concentrate into battery -grade lithium hydroxide (LiOH). On behalf of PLCI, HDR obtained one sample of the Analcime tailings produced by the MO study to characterize the material via Toxicity Characteristic Leaching Procedures (TCLP). The pH of the fluid used for the TCLP analysis had an initial pH of 5.45 Standard Units (SU) and a final pH of 2 SU. Aluminum and calcium leached from the MO sample at concentrations above the laboratory reporting limit; however, neither constituent has a 2L Standard or United States (U.S.) Environmental Protection Agency (EPA) Maximum Concentration of Contaminants (MCC) for toxicity characteristic testing. Arsenic, barium, beryllium, copper, magnesium, manganese, strontium, titanium, and zinc leached at estimated concentrations (J-values) above the method detection limit established by USEPA, but below the laboratory reporting limit. For this Technical Memorandum, TCLP results for select constituents were plotted on the box and whisker plots for arsenic (Figure 4b) and barium (Figure 4g). 2.1.3.1 ARSENIC A total of 120 groundwater samples were analyzed for arsenic during the monitoring period; arsenic was detected 8 times, each time at a concentration that exceeded the 2L Standard. Arsenic exceedances occurred in samples obtained from MW-5 and PW-1 during the monitoring period. Arsenic was detected in the granular material (MO sample) used for the TCLP testing, but at an estimated concentration of 0.96J mg/kg. Arsenic leached from the granular sample at a concentration 0.22J Ng/L. Both concentrations were below the laboratory reporting limits. Arsenic is mobile under reducing conditions and rock type and high pH can contribute to elevated concentrations of arsenic in groundwater (USGS, 2021). Groundwater samples from MW-5 and PW-1 had pH levels above the 2L Standard (range of 6.5 to 8.5) in sampling events that corresponded to elevated concentrations of arsenic, indicating that while arsenic may be naturally occurring at the Site, it also may be biased high by high pH in the groundwater. Arsenic was not detected in any of the surface water samples collected from the Site. Well MW-5 was completed as a Type III well with a 2-inch diameter well set within a 6-inch diameter outer casing. The outer casing was set into the top of competent bedrock and grouted in place to reduce vertical migration of groundwater from the regolith aquifer into fractured bedrock. One possible explanation for the outlier concentrations reported in the August 2018 sample is that the sample was affected by high pH grout, causing concentrations of inorganic constituents to be biased high. Well PW-1 also exhibited high concentrations of arsenic. The four samples collected from PW-1 with high arsenic concentrations occurred in the first 5 sampling events after the well was constructed, possibly indicating that samples were affected by high pH grout in PW-1 as well. 3 Piedmont Lithium Carolinas, Inc. I Technical Memorandum — Evaluation of Mine Pit Operations on Water Quality ��� Data Comparisons Note that arsenic is a naturally occurring element in bedrock, unconsolidated overburden soils, groundwater, and surface water within the Piedmont Physiographic Province of North Carolina. The USEPA has established a standard, called the maximum contaminant level (MCL), for arsenic in water of less than 10 tag/L for public water systems; however, naturally -occurring arsenic is present in groundwater throughout North Carolina at concentrations from 1 pg/L to 800 tag/L (NCDEQ, 2021). Thus, the concentrations of arsenic detected during periodic groundwater monitoring conducted between August 2018 and February 2020 are consistent with naturally -occurring conditions in North Carolina. 2.1.3.2 FLUORIDE Fluoride exceedances occurred in groundwater samples from PW-1 and detections occurred it samples from other monitoring wells (MW-1, MW-4, MW-5, OW-1 S, OW-1 D, OW-2S, and OW- 2D) (Figure 4f). The presence of fluoride indicates that fluoride may be naturally occurring in bedrock at the Site and mobile in the aquifer. Fluoride occurs naturally in groundwater through dissolution of fluoride bearing minerals like amphibolite (Kumar, 2017). Alkalinity (high pH) is a factor for dissolution of fluoride (Kumar, 2017). Groundwater samples from MW-1, MW-3, MW- 4, MW-5, and PW-1 had pH levels above the 2L Standards (range of 6.5 to 8.5). Fluoride was not detected in the TCLP leachate testing or in surface water at the Site. 2.1.3.3 MANGANESE The granular material from the TCLP analyses contained iron and manganese at levels above the Protection of Groundwater PSRGs, but the concentrations are typical of naturally occurring soils in the Piedmont Physiographic Province (HDR, 2021 a). The concentration of manganese in the leachate was at an estimated concentration (J-value) but does fall inside the range of concentrations detected in groundwater samples (Figure 4e). 2.1.3.4 BARIUM The granular material from the TCLP analyses contained barium at a concentration of 4.8 mg/kg. Barium was detected in the leachate sample at an estimated concentration of 43J tag/L. The concentration of barium in the TCLP leachate is similar to or an order of magnitude higher than the concentrations observed in groundwater samples (Figure 4g). 2.2 Surface Water 2.2.1 Surface Water Flow Surface water flow was measured at 15 locations within the mine permit boundary in May and June 2019 (Figure 1). Measured stream flow ranged from more than 10,000 gallons per minute (gpm) to less than 1,000 gpm on larger streams (FM-1 through FM-6) and smaller tributaries (Weir-1 through Weir-9), respectively (Figure 5). Rainfall occurred prior to and/or during both measurement periods, thus, neither of the measurement events appear to represent baseflow conditions. Dewatering for removal of resource from mine pits intercepts water that would naturally enter nearby streams and may cause or increase the flow of water from the streams to groundwater. Groundwater removed from mine pits during dewatering will be discharged to settling ponds prior to controlled release through permitted outfalls. After release, the water may flow out Piedmont Lithium Carolinas, Inc. I Technical Memorandum — Evaluation of Mine Pit Operations on Water Quality Data Comparisons through streams or wetlands or infiltrate into the groundwater system. The current operations plan has no more than two pits actively mined simultaneously. Dewatering discharge will be monitored through National Pollutant Discharge Elimination System (NPDES) permitting and compliance. Dewatering rates were estimated with groundwater modeling described in the Technical Memorandum — Groundwater Model (HDR, 2021 b) and are shown in Table 2. Dewatering rates range from 575 gpm in the first year South Pit is operating to 2,000 gpm in year 12 when both East and West Pits are being mined. Table 2. Model Predicted Dewatering Withdrawal Rates (HDR, 2021a) Pumping Rate (gpm) Model Year South Pit East Pit 50 West Pit North Pit Total 1 525 575 2 975 1,225 2,300 3 725 775 1,500 4 25' 1,025 1,050 5 751 950 1,025 6-10 N/A2 1,250 1,250 11 N/A2 1,575 1,575 12 N/A2 1,050 950 2,000 13 N/A2 0 500 850 1,350 14-16 N/A2 N/A2 1,0753 1,075 2.2.2 Surface Water Quality There were no exceedances of NCDEQ surface water standards 15A NCAC 02B (213 Standards) during surface water sampling events between August 2018 and February 2020. The range of concentrations of constituents in surface water samples are shown in box and whisker plots (Figures 2a through 4n). Phosphorus, lithium, and manganese concentrations shown in Figures 4n, 4i, and 4e, respectively, were generally higher during the warm season (May 2019 through October 2019). Chloride concentrations oscillated with the highest concentrations occurring in November 2019 (Figure 41). Sulfate concentrations were highest during the cold months with the highest concentrations occurring in December 2019 (Figure 4m). The highest pH values occurred in June 2019 and the lowest in February 2019 (Figure 4a). Arsenic and fluoride were not detected in any of the surface water samples. 2.3 Comparison of Groundwater and Surface Water Quality PLCI anticipates pumping groundwater from the mine pits to settling ponds prior to release to streams through permitted outfalls. Characteristics of the groundwater (dissolved oxygen, turbidity, pH, temperature, and constituent concentrations) may change depending on the length of time water is retained in the settling ponds. Thus, comparison of the average and range of concentrations for selected constituents with detections in both groundwater and surface water is appropriate to evaluate if groundwater discharge to surface water may affect surface water quality (Table 3). Piedmont Lithium Carolinas, Inc. I Technical Memorandum - Evaluation of Mine Pit Operations on Water Quality Data Comparisons Table 3. Comparison of groundwater and surface water samples Average Maximum Minimum Constituent Groundwater Water Surface Groundwater Water Surface Groundwater Surface Water Turbidity (NTU) 5.62 9.21 64.60 21.30 0.17 3.04 DO (mg/L) 4.58 10.47 9.09 26.75 0.14 6.23 pH 8.12 7.08 11.97 8.67 5.87 6.17 Temperature (°C) 16.38 14.18 20.50 22.00 12.00 6.10 Manganese (pg/L) 16.92 46.78 65.50 161.00 5.00 6.50 Lithium (pg/L) Chloride m /L 229.05 16.73 1370.00 3.30 45.90 5.70 30.50 6.40 1.58 3.70 1.00 2.20 Sulfate (mg/L) 4.65 2.22 19.40 3.90 1.00 1.00 Box and whisker plots comparing constituents that were detected in both groundwater and surface water samples are shown in Figures 4a through 4n. Comparison of these data indicate the following: • Manganese and barium concentrations are typically higher in surface water compared to concentrations in groundwater (Figure 4e and 4g, respectively). The concentration of manganese in most groundwater samples is below the 2L Standard. Barium concentrations are well below the 2L Standard. Discharge of groundwater to steams is not expected to raise concentrations of manganese or barium in the streams. • Lithium concentrations are lower in surface water compared to groundwater (Figure 4i). Discharge of groundwater directly into streams would not raise lithium levels above the standards. However, dewatering of mine pits will intercept groundwater that would naturally discharge to streams and may cause or increase water to flow out of the streambed into the ground. • Chloride concentrations are similar for both groundwater and surface water and are below the 2L Standard (Figure 41). • Sulfate is also present in both the groundwater and surface water at concentrations well below the 2L Standard. Groundwater has a higher range of concentrations of sulfate extending both above and below the range of sulfate concentrations in surface water samples. • Arsenic, chromium, lead, and fluoride were detected in a few groundwater samples but were not detected in any surface water samples (Figures 4b, 4c, 4d, and 4f, respectively). Some groundwater samples exhibited concentrations of arsenic, chromium, lead, and fluoride above the 2L Standards. Eight out of 120 samples had detections of arsenic. The number of detections for chromium, lead, and fluoride were also small relative to the number of samples collected. Groundwater is naturally discharging to streams on the Site and does not cause elevated levels of these constituents in the stream water. Discharging groundwater pumped during dewatering is not likely to raise concentrations of arsenic, chromium, lead, and fluoride in stream water. • Cadmium, mercury, and selenium were detected in groundwater samples but were not detected in any surface water samples (Figures 4h, 4j, and 4k, respectively). Cadmium Piedmont Lithium Carolinas, Inc. I Technical Memorandum — Evaluation of Mine Pit Operations on Water Quality Conclusions concentrations in all groundwater samples were below the 2L Standards. Selenium was only detected in the one sample collected from MW-5 after well construction (August 2018 event) and is likely not a constituent of concern at the Site. Mercury was only detected in three groundwater samples during one sampling event and is likely not a constituent of concern. • The average pH and the range of values of pH of groundwater samples is higher than that of the surface water samples. 3 Conclusions Comparison of groundwater and surface water quantity and quality data, as well as TCLP testing results, yield the following conclusions regarding potential effects of mine pit operation on water quantity and quality within the mine permit boundaries: • Groundwater levels appear to have a seasonal variation with fluctuations ranging up to 10 feet. Groundwater geochemistry also fluctuates and loosely follows a seasonal pattern. o Phosphorus, lithium, and manganese concentrations were generally higher during the warm season (May 2019 through October 2019). Chloride concentrations oscillated with the highest concentrations occurring in November 2019. Sulfate concentrations were highest during the cold months with the highest concentrations occurring in December 2019. The highest pH values occurred in June 2019 and the lowest in February 2019. • Based on modeled dewatering rates, the maximum decrease in baseflow is predicted to occur in Beaverdam Creek below the confluence with Little Beaverdam Creek during dewatering plan years 14 through 20 (end of year 20) when the combined West and North Pit is being dewatered and groundwater is flowing back into East Pit (HDR, 2021 b). Groundwater is naturally discharging to streams on the Site and does not cause elevated levels of naturally -occurring constituents in the stream water. Discharging groundwater pumped during dewatering is not likely to raise concentrations of arsenic, chromium, lead, and fluoride in stream water. Comparison of groundwater and surface water quality indicates the following. o Discharge of groundwater to steams is not expected to raise concentrations of manganese, barium, chloride, or sulfate in the streams. o Lithium concentrations are lower in surface water compared to groundwater. Discharge of groundwater directly into streams would not raise lithium levels above the standards. However, dewatering of mine pits intercepts groundwater that would naturally discharge to streams and may cause or increase water to flow out of the streambed into the ground. o Arsenic, chromium, lead, and fluoride were detected in a few groundwater samples, but were not detected in any surface water samples. Eight out of 120 samples had detections of arsenic. The number of detections for chromium, lead, and fluoride were also small relative to the number of samples collected. Discharging groundwater to streams is not likely to raise concentrations of arsenic, chromium, lead, and fluoride in stream water. Piedmont Lithium Carolinas, Inc. I Technical Memorandum — Evaluation of Mine Pit Operations on Water Quality References PLI plans to dry -stack non -hazardous mine refuse streams of native overburden, concentrator tails, and analcime tailings and/or use the refuse to backfill mine pits for reclamation (MMA, 2019). The results of the TCLP analysis indicate that the analcime tailings do not qualify as toxic hazardous waste (HDR, 2021 a). TCLP testing did not result in mobilization of arsenic. Precipitation and native groundwater will fill the porous space around refuse used to backfill mine pits. Native groundwater has a higher pH than the fluid used in the TCLP analysis. Geochemical reactions may differ from reactions that occurred in the TCLP analysis. 4 References HDR, 2019. Technical Memorandum Groundwater Model. Prepared for Piedmont Lithium. July 2, 2019. HDR, 2020. Technical Memorandum Water Quality Testing. Prepared for Piedmont Lithium. March 20, 2020. HDR, 2021 a. Technical Memorandum Toxicity Testing of Lithium Hydroxide Conversion Plant Tailings. Prepared for Piedmont Lithium Carolinas, Inc. August 26, 2021. HDR, 2021 b. Technical Memorandum Groundwater Model. Prepared for Piedmont Lithium Carolinas, Inc. August 27, 2021. MMA, 2019. Summary of Waste Rock and Process Tailings Geochemical Assessment and Addendum Report: Result of Humidity Cell Leaching Tests. Prepared for Piedmont Lithium, Inc. December 2019. North Carolina Department of Environmental Quality. Arsenic — Naturally occurring Arsenic in Groundwater. https:Hdeg.nc.gov/about/divisions/energy-mineral-land-resources/north- carolina-geological-survey/geologic-hazards/radon-arsenic PJ Sajil Kumar, 2017. Fluoride in Groundwater — Sources, Geochemical Mobilization and Treatment Options. February 20, 2017. United States Geologic Survey, 2021. https://www.usgs.gov/mission-areas/water- resources/science/arsenic-and-drinking-water?qt-science center objects=0#gt- science center objects Site-7 North Pit - t Site-2 MW 2 West it North - Site-1 r Site-6 West Pit South Site3 Site-4 i. 1 MW3 s Southpi5. J _ _ kr East 1W-4 r r r ti LEGEND Concentrate Operations Boundary (1260 ac.) Planned Pits ` * Dewatering Discharge Pond MW-5 ❑ Model Predicted Flow Locations o Pumping Well Monitoring Well $ Observation Well Ow-iD S 9 Surface Water Collection Sites Stream Flow Measurements Tributary Pw Beaverdam Creek A Little Beaverdam Creek OW -is 0 Feet 200 0 Feet 2,500 OVA — SAMPLE LOCATION MAP P I E PIEDMONT LITHIUM LITHIUM FIGURE 1 TECHNICAL MEMORANDUM: WATER QUALITY TESTING Piedmont Lithium I Technical Memorandum — Toxicity Testing ��� Figures. This page intentionally left blank. MW-1 MW-2 MW-3 752 N E 750 V c 748 0 M> 746 w ■ ■ ■ v 744 ■ m■ � � a ss � 3 742 -a ■ c 0 740 V 738 �,\ �19 b\T ��19 ��ti titi�� yeti M W-4 854 Ln E 852 ■ ■ 0 V� c $50 • ■ ■ ■ 0 } 848LU ■ ■ v 846 ■ 3 844 ■ ■ c 0 842 0 C7 840 (11 O,$ O�� (�, oti d, 0 O� O,, O3, OHO C50,�ti�y _x 826 N E 824 V ■■■ ■■ c 822 ■ • 0 T 820 • a3 W 818 v • • 3816•� 0 814 — (0 V 812 \,Y C�\' �\N ti\ti 14,11 4,11, \ti gK� ti\ti M W-5 011; Ln E 754 rf 752 0 } 750 LU - 748 746 ■ �r 0 744 • ■ 742 IV Is,- 6T 6'ti �\ti b\I b\" 6" b\'ti JT �\ti ��� ,\Nti �\N y��� -,\"Y h\ti \\ti q\'y ,�\N ti�ti PIEDMONT ►IT"JUM F)I 796 0 E 794 ■ c 792 • ■ • GVVElevation v_ ■ fit mslJ m> 790 # ■ Mean v ■ W 788 Plus One Standard deviation v � 786 • Minus One Standard devotion c # v ■■ 784 (0 Y 782 e e 0 &01 OHO " ti C5 titi�y yeti 11104\\ C)\ti ti11\y _1 P-1 ►6V Ln E 754 ■ c 752 ■ } 750 • v w ■ `a 748 ■ # 3 746 0 744 (7 742 Is, oti� oOtis Otis Otis oti 61c, 6'v ��� �� ��� b\" KV �KV \'' CS',b\" Groundwater Elevations August 2021 Figure 2a ow -is OW-11D 756 756 LA E 754 • FA E 754 0 • • GVVElevation C ! fit msl) = 752 o = o 752 Mean � 750 v 750 � � Plus One Standard deviation • w 74$ w 748 a`I a` Minus One Standard deviation av 3 746 to 3 746 c 0 744 c 2 744 L 0 0 742 742 IZ Q� O+y fl;I QNy Qti� ZN) QNy Qry� Q-y� Qy`� IS, Q11 oti� (SI, Qs� Qom, Qti� Q'4Ci S9 �����'i, ������ ����'L � �����ti��y��-�,��y��-r,������.�����ti�����'L y��i. ti ���ti �����ti �����ti y��������ta��L�����ti������ � �����`L �����ti �����`L ti OW-2S Fir.. 754 = 752 750 13� i LU " 748 ■ 3 746 _ = 744 c C7 742 �°�`��°'�411 's ii~(° OW-2 D 756 N 754 = 752 0 } 750 LU L 748 3 746 _ 744 t� 742 e bti O, Q� Q0 PIEDMONT LITHIUM F)I Groundwater Elevations DA7E August 2021 FICAA;E Figure 2b PLI Groundwater Monitoring Wells (Bedrock) c;40 Median 1 1 %, ff CC L511/6,7.] % 9%-91 % }� V outliers so U 780 760 Elm l)'i•;-ID O -2D IYIYV-1 IYIYV-C M V-J IYIYV-4 M V-5 Groundwater Elevation � � Box and Whisker of Groundwater Elevations in August 2021 PIEDP►Ntlwiv F)I the Bedrock Wells Figure 3a PLI Groundwater Monitoring Wells (Overburden) 755 — Median 9%-91 % D outliers 750 Q ,4 r A V 40 ow -IS OW-2S Groundwater Elevation �� Box and Whisker of Groundwater Elevations in August 2021 PIEDP►INIU F)I the Overburden Wells Figure 3b 12 10 c 9 7 5 5 pH in Groundwater and Surface Water I 0 0 o o � T T G + T I 0 T I 1 1 I 1 1 I I T T I 1 1 I 1 1 I I 4 I 1 I 1 I T FI FI FI I 1 I 1 I I I I 1 I 1 i I I I 1 I 1 I I I I 1 I I I I + + + + + 0 I Groundwater Surface Water Aug Apr Jun Jul Aug Sept Oct Nov Dec Jan Feb Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan 201E 2019 2019 2019 2019 2019 2019 2019 2019 2020 2020 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 Date PIEDMONT ►Ntl IUM F)R Box and Whisker of pH Levels in All Wells or All Stream Sampling Locations for Each Sampling Event J Median T !� 5 °14-75 % 9%-91 % O outliers NDAD Standard August 2021 Figure 4a 103 102 10° Arsenic Concentration in Groundwater and Surface Water MW-5 Groundwater T I I I I I T I I O I + + I x x x x x x x x x x Surface Water Arsenic was not detected in any surface water samples. Aug Mar Apr Jun Jul Aug Sept act Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan 2018 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 2020 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 Date PIEANT ►NtHIUM F)I Box and Whisker of Arsenic Concentration in All Wells or All Stream Sampling Locations for Each Sampling Event Median + I]}, ff ff %-91 % outliers X TCLP NCAC Standard August 2021 Figure 4b U 1os 102 10' 100 MW-5 Groundwater Chromium Concentration in Groundwater and Surface Water Surface Water Chromium was not detected in any surface water samples. Aug Mar Apr Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan 2018 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 2020 2019 2019 2D19 2019 2019 2019 2D19 2019 2019 2019 2020 Date PIEDMONT ►Ntl IUM F)I Box and Whisker of Chromium Concentration in All Wells or All Stream Sampling Locations for Each Sampling Event Median 25 °14-75 % 9%-91 % outliers — NOAO Standard August 2021 Figure 4c 4(1 020i 0 ivi vv-.-) l 1 1 1 1 Groundwater Lead Concentration in Groundwater and Surface Water X Surface Water Lead was not detected in any surface water samples. Aug Mar Apr Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan 2018 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 2020 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 Date Median + it, 5 °10-75 % 9%-91 % outliers NCAC Standard DATE Box and Whisker of Lead Concentration in All Wells August 2021 PIEDMONT FDIor All Stream Sampling Locations for Each Sampling F' LITHIUM Figure 4d Event Manganese Concentration in Groundwater and Surface Water 180 i I 160 Groundwater � Surface Water — Median + it, 5'/o--75 % 10 L outliers X TDLP — NOAO Standard 120 L L D 4 � T J 100 L I I 0 L ! I 1 g0 L L ! ! I 1 I 1 — 0 L ! I 1 O 0 ! ! I 1 1 1 0 60 L � T 0 I I O I + I I + 1 1 40 T 0 I 0 I 4- 4— 0 I I T I 1 20 I I + F IF- I 0+ 1 I-V7 H0 F x F F i = -4�-j Mar Apr Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan 2D19 2D19 2019 2019 2019 2019 2019 2019 2019 2020 202D 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 Date PIEDMONT LITHIUM F)2 DA7E Box and Whisker of Manganese Concentration in All August 2021 Wells or All Stream Sampling Locations for Each FIU'` Figure 4e Sampling Event U 2._ 0.5 0 Fluoride Concentration in Groundwater and Surface Water O Groundwater ❑ ❑ G O O O r I T 1 I I I T 1 I T I I I 1 I I T I I I I 1 I I I I I I I 1 I I I I T I I I 1 I I I I 1 1 1 1 i i 1 I I I + f f f 1 I I I I Surface Water Fluoride was not detected in any surface water samples. Aug Mar Apr Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan 201E 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 2020 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 Date PIEDMONT ►Ntl IUM F)3 Median T �f 25 %- 75 % 9%-91 % outliers NOAO Standard Box and Whisker of Fluoride Concentration in All August 2021 Wells or All Stream Sampling Locations for Each Figure 4f Sampling Event Barium Concentration in Groundwater and Surface Water 10 MW-5 Groundwater Surface Water Median r �f i 5%-75% i 9%-91% i O Q outliers TLP NCAC Standard 10 i i _ J `ax ! i 3 i i c ! p o O 10 i i + + i I0 4— 4- + + + + 10� Aug Mar Apr Jun Jul Aug Sept Cct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Cc[ Nov Dec Jan 2018 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 2020 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 Date Box and Whisker of Barium Concentration in All August 2021 PIEDPAONT 1NIMr���t F)3 Wells or All Stream Sampling Locations for Each Figure 4g Sampling Event Cadmium Concentration in Groundwater and Surface Water 2 Median Groundwater Surface Water + it, 51/o--75 % 9%-91 % outliers NCAC Standard J MW-5 � 0 p c 0 T I I I Cadmium was not detected in any surface water samples. I I I 0, Aug Mar Apr Jun Jul Aug Septr Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan 2018 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 2020 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 Date PIEDMONT LITHIUM F)I DA7E Box and Whisker of Cadmium Concentration in All August 2021 Wells or All Stream Sampling Locations for Each F' Figure 4h Sampling Event Lithium Concentration in Groundwater and Surface Water gn 1Qs D 0 0 0 T T I I ! TI I I T I i I I I I I I i ! ! I Surface Water I I I I I I ! I —Median I I ! I I I I I I ! I T {r I I ! I II I I I I I 5%-75% I + I [ I ! !0 outliers J �7 C D 102 c I I I I G O p O O Q D O O 0 D T I T I 0 I 0 D O G. ! i I I ] ! T Q a Groundwater 1 � I ! I I 1 � 101 Mar Apr Jun Jul Aug Sept Oct Nav Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nav Dec Jan 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 2020 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 Date Box and Whisker of Lithium Concentration in All August 2021 PIEDMONT Wells or All Stream Sampling Locations for Each FIG_= 111CM1i1�1 Figure 4i Sampling Event 0.35 0.3 L 0.25 @N 0.15 0.1 Mercury Concentration in Groundwater and Surface Water 0 Groundwater Surface Water Mercury was not detected in any surface water samples. Apr Jun Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Dec Jan 2019 2019 2019 2019 2019 2019 2019 2020 2020 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 Date PIEDMONT LITHIUM FDI Box and Whisker of Mercury Concentration in All Wells or All Stream Sampling Locations for Each Sampling Event Median + !L 25 °10-75 % 9%-91 % outliers DA7E August 2021 FICAA;E Figure 4j 30 25 J 20 U 15 10 Selenium Concentration in Groundwater and Surface Water MW-5 Groundwater Surface Water T I I I I I I I Selenium was not detected in any surface water samples. I I I I I Aug Mar Apr Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan 2018 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 2020 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 Date PIEDMONT ►NtHIUM F)I Box and Whisker of Selenium Concentration in All Wells or All Stream Sampling Locations for Each Sampling Event Median + IL 25 °1�-75 % 9%-91 % outliers NCAC Standard August 2021 Figure 4k Chloride Concentration in Groundwater and Surface water 10 Median Groundwater Surface Water + ff 5%-75% %-91 % outliers NOAO Standard 10` J E C D C 0 C f_7 101 Q• I 10 �L 1 I R f 1 11 1- 1 -1 Aug Mar Apr Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan 2018 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 2020 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 Date Box and Whisker of Chloride Concentration in All August 2021 PIEDMONT 111rIMri�1 Wells or All Stream Sampling Locations for Each Figure 41 Sampling Event Sulfate Concentration in Groundwater and Surface Water Median Groundwater Surface Water + !], 5 % A51/1w-.7 7%-9 1 1 % outliers NCAC Standard 102 J E - / MW-5 c 0 0 U 101 1 D 0 0 O T Q T 1 Q 0 + 1 + , + 1 I 1 1 + + + + + + I I + 1 1 I 1 17 + 1 0 0 G 1 100 1 I I 1 1 Aug Mar Apr Jun Jul Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Jan 2015 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 2020 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2020 Date PIED�� Box and Whisker of Sulfate Concentration in All August 2021 111rIMri�1 Wells or All Stream Sampling Locations for Each Figure 4m Sampling Event Phosphorus Concentration in Surface Water CIA G O T I I Median '-' ..I 4 I + pt 9%-91 % outliers c.I2 J E 0.1 c 0 C O c cD 4.48 I 0 I 4.46 I I I I - I T + I I I 1 0.44 I I I I + 1 Q Q O 0 0 0.02 February March April May June July August September October November December January 2019 2D19 2D19 2419 2019 2019 2019 2019 2019 2019 2019 2020 Date PIEDMONT ►Ntl IUM F)l Box and Whisker of Surface Water Quality Data August 2021 Figure 4n 12000 10000 8000 CL° 6000 : 4000 2000 0 (a) Measured Surface Water Flow 1111111- -- 11 - -- - - -- ■ 5f 15f2019 - 5/15/2019 0 6/11/2019 - 6f 15f2019 PIEDMONT ►IT"JUM F)I 12,000 10, 000 8,000 CL ° 6,000 0 ,i 4,000 (b) 2,000 0 Model Predicted Baseflovwr in Streams IIIIIIII Steady 1 2 3 4 5 State Model Year 6-10 11 12 13 14-20 ■ Beaverdarn Creek above Confluence ■ Little Beaverdam Creek ■ Beaverdam Creek Below Confluence ■ Unnamed Tributary Measured and Modeled Stream Flow August 2021 Figure 5 Piedmont Lithium I Technical Memorandum — Toxicity Testing ��� Figures. 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