20211115_L-Stroup

Piedmont Lithium Public Hearing
Good Evening, thank you for giving us the opportunity to publicly address some of our concerns.
As background information, I am a research biologist, formerly working in the QC Lab at FMC
and in R&D for early stage pharmaceutical drug development for GSK.
In Sept., I submitted several comments with questions regarding the proposed mine, however I
have not received any responses thus far. I would like to request that my questions become part of
the official record and am providing you a written copy along with the referenced sources of my
information.
1- My first concern with with the toxicity testing to determine if any waste should be determined
as toxic. According to multiple EPA technical guidance, sample bias imprecision can be a
significant sourse of error. Considering the size of the proposed project in consideration to the
number of samples taken at each pit, several pits have minimum samples included in this analysis.
Specifically the SouthEast pit that HDR identified as a possible source of acid mine drainage. A
representative sample is required for careful analysis, this is intended to represent the full
area/environment where they are collected and should represent the bulk material. Inadequate
sample collection creates Sample Bias when parts of the project area are under sampled. This
causes the estimated values to shift away from the true values. Looking at the map provided, I have
some concerns that sample bias is very probable because not enough samples were taken to make
sure areas of high concentration were not missed.
I am wondering why an additional sample has not been submitted? According to the reports
generated by Pace Analytical, there are some obvious flaws in how the samples were received,
analyzed and reported. For example, the EPA preperation method 1311 for TCLP is a method
defined parameter. This means it can not be modified when used for Resource Conservation and
Recovery Act (RCRA) Testing. The following should be questioned: hold times were exceeded
for EPA Method 8081 B. 8270E and 8260D, these methods are for Violable Organic Compounds
and have a total hold time of 28 days. This total time was exceeded from the date of sample
collection to the date the samples were received at the labs. Per the EPA Method 1311 Becton 8.5
exceeding hold times is not acceptable in establishing if a waste does not exceed regulatory levels
for determining if a waste is hazardous.
HDR made note that the results of the arsenic leaehate testing shows an estimated sample of 0.22J
and is not expected to leach from the tailings. However, as noted by Pace, test method 6020B a
matrix spike duplicate was not preformed due to insufficient sample size. Lacking enough
analytical information leaves little confidence in the statements that are being presented regarding
toxic chemicals and metal that will impact our health and our environment. I am requesting that the
state agencies of NC provide guidance regarding making resampling and retesting each of these
parameters. Accepting the results as submitted is setting the stage for the additional accumulation
of toxic chemicals and metals in the groundwater and soil. This area has been overburdened with
these same constituants from the previous lithium mine located less than 4 miles from the proposed
site. We cannot afford to wait for another spill or release, we already completely understand this
isn't a matter of if. it is a matter of when it will occur.
2- In the application, Section C. question 4 (b) How will dust from stockpiles, liaul roads, etc. be
controlled? Their answer was by using water truck or other means. However they did not identify
specifically what other means they intend to control this particulate matter. Because serious
adverse health conditions and diseases have been linked to particulate matter, it is imperative that
this be addressed in a manner that seeks to be preventative (proactive) instead of enforcement
driven (reactive).
3- I would like to formally request that an Environmental Justice Cumulative Effects assessment be
conducted for at minimum a 5 mile radius from each of the intended mine pits, concentrator plant
and hydroxide conversion plant.
Even though this community currently fall within 5 miles of multiple Superfund and NPL facilities
with toxic chemical, release and spills, there is no information being provided to the community.
There is no health monitoring and no public information distribution made available in a format
accessible to the members of this community. (Please note that this community is grossly deficient
in the availability of broadband internet service access). At minimum a true health assessment
needs to be conducted the evidentuate the actual number of adverse health conditions this
community is already burdened with.

example, studies show that exposure to sulfur dioxide causes an array of respiratory issues. Even
though Piedmont Lithium states their intent to use this chemical compound, they fail to address
how they intend to protect the children attending Tryon Elementary School or the children who live
in this community from the cumulative effects that will cause an overburden in this community.
Executive Order 13045 addresses the risks of environmental pollution on children and mandates
that every federal agency does their due diligence to protect children. EPA's Children's lieallh
Policy requires the Agency "to consider the risks to infants and children consistently and explicitly
as a part of risk assessments generated during its decision -making process, including the setting of
standards to protect public health and the environment." Please explain which agencies will be
responsible for ensuring the children in this community will be protected. How will they be
protected? Who will monitor the potential risks and associated health issues? Who will pay for
that? How will they gain access to medical doctors?
Children's Health
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Adverse Health Effects related to Environmental Noise
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EPA Method 1311
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RCRA Waste Sampling Drab Technical Guidance
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