20211126_L-Stroup

From: lisa stroup
To: NCMininaProaram
Cc: david.I.shaeffer(nbusace.army.mil; Homewood. Sue; Ingle. Bruce
Subject: [External] Piedmont Lithium
Date: Friday, November 26, 2021 2:31:00 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
1- In the mine permit application, Section C, question 4 (b) How will dust from stockpiles,
haul roads, etc. be controlled? Their answer was by using a 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). Having worked with
Lithium processing at FMC, I am aware of the caustic and corrosive nature of Lithium. As a
former member of the PERT team at FMC, I received specialized training on treating
employees with lithium metal and chemical burns associated with lithium hydroxide and other
chemical processes and by-products. I am especially aware of how lithium violently reacts
with contact to water.
It should be noted that a certain amount of lithium would be expected to be present in the
waste rock tailings samples from the mine pits as well as the waste from the Lithium
Hydroxide Concentration Operations. Marshall Miller did not make any mention of the
concentration of Lithium in the analytical reports nor addressed the adverse effects that will
occur with the presence of Lithium ore waste when co -mingled with sulfides and other
minerals.
2- 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 falls within 5 miles of multiple Superfund and NPL
facilities with toxic chemicals, 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.
Making it extremely difficult for members of this community to access and respond to
information regarding former events and the proposed project).
At minimum a true health assessment needs to be conducted to evidentiate the actual number
of adverse health conditions this community is already burdened with. According to agency
comments, the area included in the EJ Screen was a 1 mile radius surrounding Latitude
35.2322,-81.1718. This is not in accord with the project area noted in SAW-2018-001129
Section 404 Permit (lat. 35.387869,-81.286758) nor coordinates indicated in the mining
permit application (lat. 35.38960,-81.28860). Additionally, it is noted that the majority of
published EJ reviews examined for community impacts on NC DEQ website are within a 5
mile radius of the facility. Why was only a 1 mile radius considered? According to the US
EPA, an overburdened community is defined as follows. Overburdened Community -
Minority, low-income, tribal, or indigenous populations or geographic locations in the United
States that potentially experience disproportionate environmental harms and risks. This
disproportionality can be as a result of greater vulnerability to environmental hazards, lack of

opportunity for public participation, or other factors. Increased vulnerability may be
attributable to an accumulation of negative or lack of positive environmental, health,
economic, or social conditions within these populations or places. The term describes
situations where multiple factors, including both environmental and socio-economic stressors,
may act cumulatively to affect health and the environment and contribute to persistent
environmental health disparities.
In EJSCREEN, buffers can be drawn up to 10 miles around a point, line or polygon. If
you have selected a geographic point, the tool will apply a buffer around that point. The buffer
ring will aggregate appropriate portions of the intersecting block groups, weighted by
population, to create a representative set of data for the entire ring area, honoring variation and
dispersion of the population in the block groups within it. For each indicator, the result is a
population -weighted average, which equals the block group indicator values averaged over all
residents who are estimated to be inside the buffer.
3- There is strong scientific evidence that indicates that exposure to the hazardous and toxic
substances produced from mining activity has negative long term effects on young
children. For 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 Health 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?
NCDEQ Community Mapping System EJScreening Tool Information
htWs://ncdenr.maps.arcgis.com/api2s/webappviewer/index.html?
id=IebOfbe2bcfb4cccb3cc212af8a0b8c8
EPA Environmental Justice
https://www.el2a.gov/environmentaljustice/ej-2020-glossary
hUs://www.el2a.gov/e-jscreen/how-interpret-standard-report-e-j screen
Children's Health
htips://www. epa. gov/children/rules-and-regulations-impact-childrens-health
httl2s://www.ncbi.nlm.nih.gov/12mc/articles/PMC1253729/
htips://www.epa.gov/sites/default/files/2015-04/documents/ensurinV,riskreducationnejac.pdf

Regards,
Lisa Stroup