20211126_L-Stroup-2

From: lisa strouo
To: NCMininciProaram
Cc: david.l.shaefferCaiusace.army.mil; sue.homewoodCaibncciner.gov; Ingle. Bruce
Subject: [External] Piedmont Lithium
Date: Friday, November 26, 2021 12:33:01 PM
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Thank you for giving me the opportunity to publicly address some concerns. As background information, I am a
research biologist, formerly working in the QC Lab at FMC Lithium and as a research scientist for early stage
pharmaceutical drug discovery Research and Development for GSK.
I would like to request that my questions be documented and answered in complete detail, as per the NC DEQ
website.
1- My first concern with the Lithium Hydroxide toxicity testing to determine if any waste should be determined as
toxic. HDR noted that they obtained one 500 gram sample (total sample size) to be used in the tests, however outlined
in the EPA sample methods it indicates that a minimum sample size of 100 grams per testing procedure is
necessary. It is also noted in TCLP characterization that a minimum of four representative samples are necessary to
classify waste as non hazardous.
EPA preparation 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. According to EPA SW-847 The following should be
questioned: hold times were exceeded for EPA Method 808113, 8270E and 8260D, these methods are for Volatile
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 and analyzed at the labs. Per the EPA Method 1311
section 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.
EPA Method 8081B GCS Pesticides sample exceeded the method hold time and also has the qualifier L2, indicating
the analyte recovery in LCS is below QC limits resulting in a low bias. EPA notes that low bias is an area of
concern for samples under regulatory limits depending on the proximity to those limits. Additionally the qualifier D3
notes the sample was diluted due to the presence of high levels of non -target analytes or other matrix
interferences, noting Tetrachloro-m-xylene (S). Please note that matrix interferences can mask recovery of analytes
and they can not be accurately distinguished or separated from existing concentrations of target analytes or other
unknown components present in the sample.
2- HDR made note that the results of the arsenic leachate testing shows an estimated sample of 0.22J and is not
expected to leach from the tailings. Pace noted test method 6020B a matrix spike duplicate was not preformed due to
insufficient sample size. EPA Method 6020B for Arsenic contains several qualifiers. Matrix Spike/Matrix Spike
Duplicate was not performed due to insufficient sample size and DI -sample diluted due to presence of'high levels of
non target analytes or other matrix intereferences. It should be noted that matrix interferences can mask recovery of
analytes and they can not be accurately distinguished or separated from existing concentrations of target analytes or
other unknown components present in the sample. 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 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 constituents 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.
The community directly affected by the Hallman Beam Mine is also directly affected by the former Biggerstaff
Landfill and will fall within a 5 mile radius of the proposed project area, specifically the South Pit. According to
water monitoring reports from Biggerstaff Landfill, regulatory limits have consistently been exceeded for Cadmium,
Lead, Benzene, Vinyl Chloride, Tetrachloroethene, 1,4-dioxane (non-SIM), 1,4-dioxane (SIM) and 1,4-
dichlorobenzene. No well water testing has been conducted for water supply private wells adjacent to Biggerstaff
Landfill. It was noted in the NCDEQ documents, that waste material was deposited in Biggerstaff Landfill from FMC
Hallman Beam Mine and from FMC Lithium chemical processing plant. Given this information, the people in this
community have previous experience with similar operations that indicates a substantial possibility that the
operation will result in acid water pollution and groundwater contamination of toxic chemicals and heavy
metals. We have little confidence that our water, air, soil and health will be considered or protected based on
our past experiences.
3- The sample size and distribution of the Waste Rock Tailings shows a map that does not indicate the acreage of

each of the four mine pits but gives a representative image of the size in correlation to the other mine
pits. Considering the size of the proposed project in consideration of the number of samples taken at each pit, several
have minimum samples. Specifically the SouthEast pit that HDR identified as a possible source of acid mine
drainage.
According to multiple EPA technical guidance, sample bias imprecision can be a significant source of error. 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 (Appendix G), I have some concerns that sample bias is very probable
because not enough samples were taken from the South and East pits to make sure areas of high concentration were
not missed.
4- TCLP guidelines state that in order for waste to be classified as non hazardous, each target constituent (that will be
mixed together in waste piles), the concentrations tested should be added for a cumulative total. Meaning that the
levels detected in each separate analysis of core drill, water samples and Lithium hydroxide conversion, etc. waste
should have been added together and that concentration compared with the regulatory thresholds, before a non
hazardous determination was made.
Biggerstaff Landfill Water Monitoring
https✓/edocs.deq.nc.gov/WasteManagement/Browse.aspx?id=253326&dbid=0&repo=WasteManagement&cr=1
https:Hp2infohouse.org/ref/24/23526.pdf
https:Hdigital.ncdcr.gov/digital/api/collection/p249901 co1122/id/17023/download
https:Hgreensboro.com/on-the-trail-of-cancer/article_82e94e6d-06da-55bO-bO83-e3aedce889e2.html
Biggerstaff Landfill Cap Damage
https://www.google.com/amp/s/www.gastongazette.com/article/20160327/NEWS/160329132%3ftemplate=ampart
Biggerstaff Landfill Inspection
https:Hedocs.deq,.nc.gov/WasteManagement/O/edoc/1087298/3602_INSP_20180322.pdf
EPA Method 1311
hUs://www.epa.gov/sites/default/files/2015-12/documents/ 1311.pdf
RCRA Waste Sampling Draft Technical Guidance
h!Ws://www.epa.gov/sites/default/files/2015-10/documents/rwsdtg_O.pdf
https://www.eDa.gov/sites/default/files/2015-10/documents/chan7 O.ndf
Regards,
Lisa Stroup