20211005_NCWRC_Comments

Q North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
MEMORANDUM
TO: Adam Parr
Assistant State Mining Engineer
Land Quality Section -
FROM: Olivia Munzer, Western Piedmont Coordinator
Habitat Conservation
DATE: 05 October 2021
SUBJECT: New Mining Permit Application for Carolina Lithium Mine, Gaston County, North
Carolina
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
permit application. Our comments are provided in accordance with provisions of the Mining Act of 1971
(as amended, 1982) (G.S. 74-46 through 74-68 15 NCAC 5).
Piedmont Lithium Carolinas, Inc. has applied for a new mining permit for the proposed Carolina Lithium
Project centered around 1501 Hephzibah Church Road in Bessemer City, Gaston County, North Carolina.
The project consists of the Concentrate Operations (mine operations) and the Lithium Hydroxide
Concentrate Plant (processing operations). The total acreage of the site is 1,548, of which 719 acres (ac)
will be disturbed by tailings/sediment ponds (20 ac), stockpiles (21 ac), wastepiles (119 ac), processing
area/haul roads (137 ac), mine excavation (403 ac), and other (19 ac).
Little Beaverdam Creek, Beaverdam Creek, and their unnamed tributaries in the Catawba River basin
flow through the proposed site. Beaverdam Creek and Little Beaverdam Creek are classified as a Water
Supply IV stream by the NC Department of Water Resources (NCDWR).
We have records for the dwarf -flowered heartleaf (Hexastylis naniflora; Federal Threatened, State
Threatened), bigleaf magnolia (Magnolia macrophylla; State Threatened), bog turtle (Glyptemys
muhlenbergii; Federal Threatened Due to Similarity of Appearance; State Threatened), Virginia
spiderwort (Tradescantia virginiana; State Threatened), dwarf threetooth (Triodopsis fulciden; State
Special Concern), and bald eagle (Haliaeetus leucocephalus; State Threatened), which is protected by the
federal Bald and Eagle Protection Act, in the vicinity of the site. State significantly rare species found in
the area include seagreen darter (Etheostoma thalassinum), Carolina foothills crayfish (Cambarus johni),
striate button (Mesomphix pilsbryi), glade milkvine (Matelea decipiends), and Georgia holly (Ilex
longipes). Additionally, an undescribed crayfish occurs in Beaverdam Creek downstream of the project,
and several state -listed aquatic mussels may occur in or downstream of the site. HDR conducted surveys
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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Piedmont Lithium Mine Permit Application
Gaston County
for federally protected species, and none were observed within the proposed mine site. Additionally, the
Eaker Farm Catawba Land Conservancy Easement occurs adjacent to the proposed site.
We have concerns for the direct and indirect impacts to aquatic and terrestrial resources in and adjacent to
the proposed project. Furthermore, we have provided some recommendations to minimize impacts to
aquatic and terrestrial wildlife resources.
The Groundwater Model Dewatering Simulations Technical Memorandum indicates that the
operations of the mine will change groundwater flow into wetlands on site and the baseflow of
streams; however, the impacts on streams and wetlands outside the site are not discussed.
Although water withdrawn during the operation will be returned to streams at NPDES permitted
discharge points, we have concerns for the impact of the mine operation from the dewatering of
streams and wetlands outside the site, including downstream, and the effect on aquatic and
terrestrial organisms.
2. We are concerned with the riparian and wetland buffer extending only 30 feet, per the Gaston
County Unified Development Ordinance. We are concerned that 30 feet will not provide enough
buffer to maintain stream bank stability and minimize erosion, especially during flooding; the
treatment of pollutants and sediments from the mining operation from entering streams and
wetlands; and providing travel corridors for wildlife. We recommend a minimum 100-foot
undisturbed buffer for perennial streams and a 50-foot undisturbed buffer for intermittent streams
and wetlands.
We are pleased to see NC Steep Slope Mix will be used for revegetation of the site. Rather than
the Flat Pea/Perennial Pea Mix (ERNMX-112), we would prefer one of the Native Steep Slope
Mix (ERNMX- 1810-2) or Ernst Native Habitat for Strip Mines Mix (ERNMX-111) because flat
pea is a non-native species with invasive tendencies. Alternative legumes to flat pea are ticktrefoil
(Desmodium spp.) or partridge pea (Chamaecrista spp.), both of which are included in the
recommended native mixes.
4. Minimize removal of native trees and shrubs during construction. If buffers need to be replanted
(pg. 14, Section 10a.), we recommend planting native species, such as a mix of hardwood and
pine trees.
5. We recommend monitoring water quality, and perhaps surface flow downstream of the project
and/or discharge point.
6. Ensure all stormwater outlets are drain through a vegetated upland area prior to reaching any
stream or wetland area. Sufficient retention designs should be implemented to allow for the slow
discharge of storm water, attenuating the potential adverse effects of storm -water surges; thermal
spikes; and sediment, nutrient, and chemical discharges. Ensure erosion control and
sedimentation basins and associated structures (i.e., dissipater pads) are located outside the
recommended stream buffers, which are a minimum 100-foot for perennial streams and a 50-foot
for intermittent streams and wetlands.
7. We appreciate that bridges will be used for stream crossings, but the design could cause potential
erosion could result from the current design. The spans are set on footers, which could cause bank
disturbance during construction, and after construction, the minimal daylight under the structure
prevents vegetation from growing and causing unstable banks. To prevent the banks from
eroding, the span width could be increased to move the footers away from the top of bank, or use
a boulder toe stream restoration structure, or something similar, to maintain normal channel
width. Secondly, use onsite material excavated during bridge construction to backfill the spans to
match the floodplain elevation. Lastly, ensure the bridge is aligned appropriately with the
floodway to reduce erosion during high flow. Also, consider that flood debris can catch on the

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Piedmont Lithium Mine Permit Application
Gaston County
abutment of the spans and the rack buildup can destabilize the stream bank and effect sediment
transport.
8. Avoid clearing the proposed project from roughly March through August, which includes the
migratory bird nesting season and maternity roosting season for bats.
9. Heavy equipment should be operated from the stream bank rather than in the stream channel to
minimize sedimentation and reduce the introduction of other pollutants into the stream.
10. All mechanized equipment operated near surface waters should be inspected and maintained
regularly to prevent contamination from fuels, lubricants, hydraulic fluids or other toxic
materials.
11. Water discharges from the site should be proportional to the size of the receiving stream so the
hydrology of the stream is not altered, and all discharges should comply with NPDES permit
requirements. In particular, turbidity of the discharge should be maintained at or below the
permit requirement. High water discharge rates and turbidity can negatively impact aquatic
resources within and downstream of the site. Excessive silt and sediment loads can have
numerous detrimental effects on aquatic resources including destruction of spawning habitat,
suffocation of eggs, and clogging of gills of aquatic species.
12. This region is known for underground mine, shafts, and mine -like features that serve as
hibernaculum for several bat species. If any mines or mine -like features occur onsite, NCWRC
would like to survey the structure prior to construction and exclude any bats to ensure they are
not impacted by disturbance. Due to white -nose syndrome, populations of bat species that use
mines and caves have declined drastically. Please contact me if these features are present at the
mine.
13. Strict sediment and erosion control measures should be installed prior to any land -disturbing
activity. The use of biodegradable and wildlife -friendly sediment and erosion control devices is
strongly recommended. Silt fencing, fiber rolls and/or other products should have loose -weave
netting that is made of natural fiber materials with movable joints between the vertical and
horizontal twines. Silt fencing that has been reinforced with plastic or metal mesh should be
avoided as it impedes the movement of terrestrial wildlife species. Excessive silt and sediment
loads can have detrimental effects on aquatic resources including destruction of spawning habitat,
suffocation of eggs, and clogging of gills.
14. We recommend reclaiming the relatively shallow sediment basins as wetlands, where practicable.
Thank you for the opportunity to comment. Further information and free technical guidance from the
NCWRC is available upon request. For questions or comments, please contact me at [phone] or
olivia.munzergncwildlihLM.
ec: W. Thomas Russ, NCWRC
David Miller, NC DEMLR
Kelly Thames, HDR Engineering of the Carolinas, Inc.