20220114_ADI_36-35

ROY COOPER
Governor
DIONNE DELLFGATTI
Secretary
BRIAN WRENN
Director
Certified Mail
Return Receipt Requested
Certified Mail #7016 2140 0000 4368 3841
Mr. Patrick Brindle
NORTH CAROLINA
Environmental Quality
January 14, 2021
Executive Vice President - Chief Development Officer
Piedmont Lithium Carolinas, Inc.
32 N. Main Street,
Suite 100
Belmont, NC 28012
RE: Carolina Lithium Project Mine, Additional Information Letter
Gaston County
Catawba River Basin
Dear Mr. Brindle:
We have received additional information and comments concerning the application your company submitted for
the referenced mine site. In order for this office to complete its review of the referenced project in accordance with
G.S. §74-50 and §74-51 of the Mining Act of 1971, please provide additional or revised information in accordance
with the following comments:
For the following items, the Division still has questions concerning the Company's December 16, 2021, reply to
the Division's October 29, 2021, Additional Information Letter. All other items from the October 29, 2021 have
been resolved.
Item I (a): Requested MSD sheets for the chemicals being added to the Chemical and Separation processes.
Piedmont Lithium Carolinas, Inc. (PLCI) Reply: Supplied MSD sheets for the reagents being used.
Review: Division of Waste Management (DWM), still under review.
Division of Water Resources — Industrial Waste Program (DWR-IW), still under review.
DWR-Aquatic Toxicology Branch (DWR-ATB), the flocculent listed is not on the approved list.
Status: Please provide proof that the reagent list has been reviewed and found to be acceptable to DWR-
ATB. There could be additional requests concerning this item.
Item 2: Requested a copy of the Well Supply Mitigation Plan.
PLCI Reply: A response plan was provided.
D _E Q1� North Carolina DepartmentofEnvironmentalQualhy I Division of Energy. Mineral and Land Resources
5I2North Salisbury Street 11612 Mail Service Center I Raleigh, North Carolina 27699-1612
919.707.9200

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7016 2140 0000 4368 3841
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Review: Based on initial review, the plan does not make it clear that the complaintant can go through either
Division of Energy, Mineral, and Land Resources (DEMLR) or Piedmont Lithium (PLCI). If the
complainant contacts DEMLR, then DEMLR can engage PLCI.
DEMLR would make an independent assessment using the resources of DEQ.
PLCI needs to notify DEMLR-Mining Program of all complaints in a timely manner and when the matter
is resolved.
PLCI must state what water needs it will be suppling if item 4 of their plan is activated.
Status: The plan is still under review, will require further modifications.
Item 3. Supply proof that the company has applied for NCG02 Stormwater permit.
PLCI Reply: A statement that they applied for the permit.
Review: DEMLR-Stormwater Program reviewed the application and found the site did not qualify for the
NCG002. The Stormwater Program did inform the Company by letter that the Company needs to get an
Individual NPDES permit.
Status: The Company will need to supply proof that an Individual NPDES Permit has been received for
the mine site.
Item 7: Explain any adjustments PLCI might make to the blasting program on a cloudy day?
PLCI Reply: Will check with local airport to make sure there is no inversion.
Review: Reply does not state what PLCI will do if an inversion is present. Nor does the Company define
what constitutes a cloudy day.
Status: PLCI needs to supply further information on how they are going to handle days when blasting
conditions are less than ideal. The Company needs to explain how they will document this.
Note: The Company might be advised to move away from what constitutes a "cloudy day" and define what
weather conditions will trigger a modified blasting plan, then use the airport as a reference to determine if
those condition are present.
For the following items, the Division requires clarification on PLCI's December 16, 2021 response to information
requested by agencies, Departments or Division:
Item 1: MRO comments concerning the submitted erosion and sedimentation control plans.
PLCI Reply: PLCI submitted revised drawings.
Status: MRO still has concerns regarding the plans. PLCI need to contact Zahid Khan, Mooresville
Regional Engineer at 704-235-2145 to resolve their concerns with the plan.

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7016 2140 0000 4368 3841
Page 13
Item 2(a & b): Submit copies of agreements between PLCI and publicly owned sewer operations concerning the
liquid waste being discharged into the sewer system. Supply a chemical analysis of the waste.
PLCI Reply: PLCI submitted a letter and a Technical Memorandum between PLCI and Two Rivers
Utilities, concerning this matter.
PLCI has requested that the materials supplied be treated "as good faith evidence that ongoing coordination
with the local sewer provider is occurring to discharge their processed wastewater effluent to a POTW with
pretreatment." PLCI did not supply chemical analysis of the waste.
Review: The Division of Water Resources -Water Quality Permitting Section-NPDES Industrial Permitting
Unit (DWR-WQPS) reviewed the documentation and raise many concerns. Please see the attached
document.
Status: PLCI needs to address DWR-WQPS concerns as presented in the attached document.
Item 4(a): Supply proof the site has received an Air Permit.
PLCI Reply: PLCI is still in the process of applying to Division of Air Quality for a permit.
Status: PLCI needs to supply proof they have received an air quality permit for the facility.
Item 6: Supply an archaeological study.
PLCI Reply: PLCI supplied a copy of the study.
Review: North Carolina Department of Natural and Cultural Resources -State Historical Preservation Office
reviewed the document. The Office supplied a Memorandum listing their concerns, attached.
Status: PLCI needs to address the concerns raised in the Memorandum.
After further discussion and review of your application, the following issues have been identified and need to be
addressed. It should be noted that the following represents new requests, and for this reason the amount of time you
have to address all of the issues raised by this letter has been reset to 180-days.
Item 1. To ensure compliance with NCAC §74-53 (4), please provide the PLCI's plan on how it is going to back
fill the East Pit and the South Pit. This plan must contain as a minimum:
a. Thickness of each lift.
b. The lift will have to be compacted.
1. What percent compaction will be achieved?
2. How will the compaction be measured (type of instrument or test to be used)?
3. Supply proof that the instrument or test will be adequate to measure the thickness of the lift to
ensure compaction levels have been achieved.

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Page 14
4. What will be the frequency of the test (amount of surface area per test)?
5. How will the measurements be recorded?
c. How long will it take the material to achieve 90% of its subsidence?
d. Certify that the plan will ensure that no pools of water on the finished grading will develop due to
subsidence.
e. How the company will address any pools that might develop after final grading?
Item 2. Please supply a comprehensive flowsheet showing both solid and liquid waste discharges from the
Separation Plant and the Chemical Plant. The flowsheet must show at a minimum:
a. A description of the materials including:
I. Any reagents that might be present.
lI. The concentration of the reagents.
III. Any product that will degrade and what are the by-products.
b. Worst case, how much of the material would be sent to the waste pile or the pit hourly and annually?
c. How frequently will the material be sampled and for what parameters?
Item 3. Please supply proof that PLCI has received all necessary permits required by DWR-WQPS, or
documentation from DWR-WQPS stating that a given permit is not required.
Item 4. Your application is inadequate to determine whether the reclamation plan will prevent leaching of pollutants
to groundwater. To avoid triggering NCAC§74-51(3), Please provide:
a. A protocol for analyzing all waste products, including the pit waste, to determine the pH range in
which the material will not leach.
b. The number of samples that will be analyzed to achieve statistical confidence that the pH range is
appropriate to prevent leaching.
C. Explain how the waste disposal areas will be zoned/encapsulated to ensure that if any leachate
forms, it will not migrate?
d. How will the waste pile be treated to ensure proper pH control?
DEMLR would like to recommend that PLCI meet with us and other partners in DWM and DWR to assist in
suppling a common understanding as to what is required. DEMLR will be more than happy to assist in facilitating
this meeting if PLCI desires this and request it.

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Page 15
It has been recommended that PLCI look at the EPA program "Leaching Environmental Assessment Framework
(LEAF)" for the type of program that will be needed for all of us to reach the final goal of no long term impacts to
the groundwater system.
Please be advised that the Mining Program is working with the Division of Waste Management on this issue, to
ensure that the results meet their standards and the needs of this mine.
Please note, this office may request additional information, not included in this letter, as the mining application
review progresses. Be advised that our review cannot be completed until all of the items listed above have been
fully addressed.
In order to complete the processing of your application, please forward two (2) copies of the requested information
to my attention at the following address:
Division of Energy, Mineral, and Land Resources
Department of Environmental Quality
1612 Mail Service Center
Raleigh, NC 27699-1612
As required by 15A NCAC 513.0113, you are hereby advised that you have 180 days from the date of your receipt
of this letter to submit all of the requested information. If you are unable to meet this deadline and wish to request
additional time, you must submit information, in writing, to the Director clearly indicating why the deadline cannot
be met and request that an extension of time be granted. If an extension of time is not granted, a decision will be
made to grant or deny the mining permit based upon the information currently in the Department's files at the end
of the 180-day period.
Though the preceding statement cites the maximum time limit for your response, we encourage you to provide the
additional information requested by this letter as soon as possible. Your prompt response will help us to complete
processing your application sooner.
Please contact me at [phone] if you have any questions.
Sincerel
David Miller, PE
North Carolina State Mining Engineer
Enclosures:
Item I, Memorandum from Douglas Dowden, DWR-WQPS
Item 11, Memorandum from Ramona Bartos, State Historic Preservation Office request.
c: Zahid Khan, Mooresville Regional Engineer

a
llorth Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
January 11, 2022
MEMORANDUM
TO: David Miller
State Mining Engineer
NC Department of Environmental Quality
FROM: Ramona Bartos ow. �•
Office of Archives and History
Deputy Secretary, Dadn J. Waters, Ph.D.
David.Mi I lerna,ncderin gov
SUBJECT: Mining Permit Application for Piedmont Lithium Carolinas, Inc., Carolina Lithium Project,
Gaston County, ER 18-0800
Thank you for your email of December 17, 2021, transmitting the archaeological survey for the above -
referenced project. We have conducted a review of the report and offer the following comments.
TRC, Environmental, Inc., documented 17 archaeological sites (3 1 GS398-3 I GS414) in the current project
area, which is an expansion of the Piedmont Lithium Carolinas Mine Project and comprises an area just
under 1,000 acres in size. Four of these sites are historic cemeteries, while two consisted of lithic isolates.
The remaining 1 I sites are documented as historic sites. The cemeteries were not assessed for National
Register of Historic Places (NRHP) eligibility but were recommended for avoidance with a 25-foot buffer
around each cemetery. The remaining 13 sites were recommended not eligible for NRHP listing.
Before we can fully review the survey results and concur with the report findings, we request the following
revisions to the draft report:
Front Matter
o In the Management Summary, please change "[n]ineteen field sites were recorded" to
seventeen and please include 31 GS400 in the fourth paragraph.
o List of Figures — Missing various figures in the list (11, 12, 15, 24, 28, 30, 36, 42, etc.).
Cultural Context
o We recommend that more recent publications be referenced for the Cultural Context
Chapter.
■ Prehistoric Overview section — there is only one reference from the last 20 years.
■ Historical Context— references for this section should be updated as well. We find
the following sentence on Page 19 especially problematic in its over generalization
Location: 109 East Jones Strecq Raleigh NC 27601 Mailing Address: 4617 Mail Scrvice Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

ER 18-0800, January 11, Page 2 of 3
and interpretation: "[tjhe Cherokee frequently raided white settlements during the
historic period and were attacked by the settlers in retaliation (Powell 1989).
o The first three words of the last paragraph on Page 18 (European -American Context) should
be separated from the paragraph similar to the 'Historic Native American Context' heading.
Background Literature and Records Search
o Please revise any reference to 31 LN223 to 31 GS417 (the OSA accidentally gave this site a
Lincoln County number when it was first recorded).
Methods
o Please include a map or maps, either in Methods or Survey Results, that shows the project
area with shovel test locations or notes areas covered using different survey strategies (e.g.,
areas shovel tested at 30-m intervals, areas investigated with pedestrian survey and
judgmental shovel tests or 50-m interval shovel tests, etc.) as well as portions of the overall
project area that were not intensively investigated beyond visual inspection, including labels
with the reason(s) why these areas were not intensively examined (sloped, wet, disturbed,
etc.). The second sentence of the first paragraph says indicates that Figure 2 differentiates
between the high and low probability portions of the project area when it shows the entire
project area with no differentiation between high and low probability.
o Please update the curation section to comply with OSA Standards and Guidelines. More of
an attempt should be made to curate artifacts in a federally recognized curation facility.
Please note that the North Carolina Office of State Archaeology (OSA) Standards and
Guidelines (https://files.nc.gov/dncr-arch/OSA Guidelines Dec2017.ndfl state that:
"All materials... recovered and created for purposes of compliance with state and
federal regulations shall be permanently curated in an approved archaeological
repository, preferably in the state of North Carolina." (OSA Guidelines p. 19)
These guidelines are intended to allow for transparency of process, access to materials by
future researchers, and compliance with federal regulations.
o Please revise the sentence that reads: "Artifacts would have been bagged..." to "Artifacts
were bagged..."
Survey Results
o Please include a table summarizing the archaeological sites that were documented during the
survey, including site numbers, site types, temporal range and/or cultural affiliation of the
sites, and site NRHP eligibility recommendations (see Page 25 of OSA Standards and
Guidelines).
o All font color should be black.
o No information provided on site 31 GS400.
o Please indicate that 31 GS407 may extend outside of the project area as it immediately abuts
the edge of the APE. If the site was not fully delineated and only the portion in the project
was assessed, the overall site should remain unassessed, with the portion within the project
area not significant or not contributing to any potential NRHP eligibility.
Location: 109 EastJones Stint, Raleigh NC 27601 Mailing Address: 4617 Mail Seevice Canter, Raleigh NC 27699-4617 Telephone/Faa: [phone]/814-6898

ER I8-0800. January 11, Page 3 of 3
o Figure 60 (Page 79) should be numbered Figure 65 and it needs to be added to the Figures
List.
o Figure 61 (page 80) should be numbered Figure 66 and the revisions need to be made on the
Figures List as well.
Conclusions and Recommendations
o Include 31 GS400 in sentence referencing all of the sites recorded during the survey.
References
o Add McShane 2014 citation.
Site Forms
o Please include any artifact catalogs and site maps with the individual site forms.
Given the displaced grave markers at several of the cemeteries and the somewhat questionable location of
burials at these cemeteries, we would recommend that each cemetery be further investigated with remote
sensing technology such as Ground Penetrating Radar to fully delineate the cemeteries and ensure
unmarked burials are not disturbed by project construction activities. If additional investigations are not
undertaken at the cemeteries, then we recommend that the proposed 25-foot buffer be increased to 100 feet
around each cemetery. We also recommend that the project plans be updated to include the four historic
cemeteries and the buffered areas around each cemetery to ensure they are avoided. We request any
additional information that is available that documents the cemetery avoidance plans. We also recommend
that the cemeteries be documented with the County Register of Deeds if not already documented so that
their locations are noted on the parcel data.
We look forward to reviewing and providing comments on the revised report.
These comments are made in accord with G.S. 121-12(a) and Executive Order XVI. If you have questions
regarding them, please contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579
or environmental.review(a)ncdcr.gov. In all future communication concerning this project, please cite the
above -referenced tracking number.
Cc: Brenda Harris, NCDEQ
Sean Norris, TRC
Krysta Stagar, USACE
brenda.harris(a.ncdenr. ov
snorris(a,trccompanies.com
[e-mail]
Location: 109 E at Jnnes Srreeq Raleigh NC 27601 Mailing Address: 4617 Mail Smice ('rnmr, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6998

DocuSign Envelope ID: 5CCBIFFD-3392-49FB-9Aa3-3FF4FBEB4965
ROY COOPER
Governor
JOHN NICHOLSON
fnterbn Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
I UVT t! AMNl u I
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IV0i Nwd t.�.
From: Doug DowdensnerE56Ea1MOD...
To: Mr. David Miller Environmental Programs Supervisor
State Mining Engineer NC DEQ / DWR /WQPS
DEMLR Archdale Building, 9th Floor
217 West Jones Street 512 North Salisbury Street
Raleigh, NC 27603 Raleigh, NC 27604
[phone]
doug. dowden(a.ncderin gov
Date: January 14, 2022 Delivery: [e-mail], and via
inter -office mail
Subject: Request for Inclusion of DWR Items in Additional Information Request from
Applicant Piedmont Lithium Carolinas, Inc; Carolina Lithium Project — North Carolina
Mining Permit Application / Near Bessemer City in Gaston County
Dear Mr. Miller:
On/or about 11/12/21 our office provided comments concerning the application for the proposed Piedmont
Lithium Mine dated August 30, 2021. Based upon our conversation today (1/14/22) with Mr. David Miller
we are of the understanding that the applicant provided responses to our concerns on/or about 12/15/21 and
NCDEQ Department of Water Resources (DWR) Water Quality Permitting Section (WQPS) input is
required by 1/14/22. As before NCDEQ DWR WQPS appreciates the opportunity to provide comments on
the Piedmont Lithium North Carolina Mining Permit Application dated August 30, 2021 and follow-up
responses dated 12/15/21. As you know, the WQPS, specifically the Industrial Permitting Unit (IPU)
reviews and provides guidance to applicant's seeking or needing coverage for various industrial operations
that generate industrial process wastewater.
1. Chemical Processing Wastewater: The Application in section C.3.d. reflects industrial process
wastewater from chemical operations will be discharged to a Publicly Owned Treatment Works
(POTW) with pretreatment. Thank you for providing the requested details concerning MGD to the
Long Creek WWTP. However, we still request submission of detailed chemical analysis or
characterization of the wastewater. This is necessary for DWR to determine if the selected POTW
has sufficient capacity to manage not only the flow volume, but the anticipated pollutant load under
our rules 15A NCAC 02H section .0900.
2. Prior to issuing this Permit we believe it is in the best interest of all that Long Creek WWTP submit
and secure approval from the NCDEQ DWR WQPS Municipal Permitting Unit for the anticipated
increased flow to the facility. In the advent that Long Creek WWTP is unable to accept the
additional flow what alternative plan does the facility operator have to manage and treat the
proposed flow? In addition, an application from Long Creek WWTP will include various studies
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
e.r.a+. u..wwa...� 919.707.9000

DocuSign Envelope ID: 5CCB1FFD-3392-49FB-9A83-3FF4FBEB4965
and analyses to determine if the proposed receiving water can accommodate the proposed pollutant
load; including but not limited to proposed sulfate, chloride, organic carbon content and TDS.
3. At this time, we believe based upon the information provided that proposed coverage under NCG02
may be inadequate to meet the operational needs of the facility. It is our position that the proposed
industrial process waters potentially generated at this mine site would not have coverage under this
stormwater general permit including: boiler blowdown, scrubber waste, cooling water. These
wastewaters may need to be discharged under the potential POTW Significant Industrial User
Permit or seek separate coverage to discharge through the NPDES program. Again, at this time we
request that the applicant provide information on other wastewaters generated, including full waste
characterization and proposed disposal methods.
Since discharges associated with "the waste rock disposal areas will be collected in ponds and
subject to NPDES monitoring prior to discharge to receiving waters" at this time the applicant
should apply for an NPDES discharge permit with the NCDEQ DWR WQPS IPU prior to issuance
of this Permit.
4. The information and data provided in regards to TCLP and humidity cell analyses suggests that the
facility operator should secure an individual stormwater or wastewater permit to commence
operations. Humidity cells are not necessarily the best way to simulate the process in mine setting
and the related variation. Also, it's not known whether other real oxidation state (e.g. low DO,
anoxic) would happen or not. We recommend that this option be evaluated and determined by the
applicant before proceeding further.
5. A review of the information provided did not include "Attachment 2 Concentrate Operation
Drawings (Sheets 1-34) as noted in Appendix G — Response to DEMLR MRO Comments, please
provide these sheets.
6. The information provided in Appendix I - the Technical memo on the W WTF considerations raises
a few questions that require additional clarification as follows.
• We request that the facility operator [Long Creek W WTF (NC0020184)] review the November
5, 2021 Technical Memorandum and acknowledge in detail that the facility not only can accept,
but can adequately handle and treat the proposed flow. This detail should be included in their
letter to Piedmont Lithium.
• Based upon the information provided baring any pretreatment issues the wastewater system
may have capacity. However, information provided did not include sufficient detail to
determine if the sewer system has adequate capacity to handle the projected flow. The WWTP
acceptance letter should include language that the existing sewer system has adequate capacity
and an identified route for the flow in MGD.
• Based upon a review of the data provided there will be potential impact to the POTW MBAS
due to oxygen transfer limits, the ability of the wastewater system to separate solids from
liquids, and the potential to create overall operational issues associated with foaming. Thus, we
request additional information from the applicant detailing how these concerns will be
addressed.
• Additional details and supporting data are requested as to how the W WTP operator will manage
the increased flow and pollutant load to ensure that biosolids utilization at the facility will not
be impacted.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh. North Carolina 27699-1617
��+w�•++� /'� 919.707.9000 Pnge 2of3

DocuSign Envelope ID: 5CCB1 FFD-339249FB-9A83-3FF4FBEB4965
• Has the applicant evaluated how the potential levels of sulfate, chloride and TDS
concentrations can impact toxicity testing at the POTW? If so, please provide additional details
and data on how this was determined, such as a pilot study or bench scale testing.
The information and analysis provided in the 12/15/21 response evaluates compliance with
applicable Water Quality Standards; however, additional detail is required to evaluate how the
facility operator will manage inhibition or sludge criteria at the plant. Please provide additional
detail specifying how the plant operator will address inhibition or sludge criteria or an analysis
of same.
7. Based upon the information provided to DWR it will be necessary to have a robust pretreatment
treatment unit at the Lithium plant and the POTW will need to develop local limits. Please provide
details so that DWR can evaluate.
8. As a final note of concern the high flow wet weather data used to make assimilative capacity
determinations is very optimistic. We request that assimilative capacity determinations be made
based upon low flow data. Please provide the updated analyses.
The information being sought is necessary to make a fully informed opinion of whether the proposed facility
operations are planned adequately enough to mitigate potential environmental, specifically water quality
degradation.
We look forward to working with DEMLR staff and the applicant's team on this important project. If you
should have any questions or require clarification, feel to reach out to any of the following Water Quality
Permitting Section team members.
Michael Montebello
Municipal Permitting Unit Supervisor
NC DEQ / Division of Water Resources / Water Quality Permitting Section
NPDES Industrial Permitting Unit
Office: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
Office: 919 707 3614
michael. montebel loamcdenn gov
Douglas Dowden
Industrial Permitting Unit Supervisor
NC DEQ / Division of Water Resources / Water Quality Permitting Section
NPDES Industrial Permitting Unit
Office: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
Office: 919 707 3605
doug.dowdenna ncdenr.eov
Amirhossein (Amir) Rezaei Adaryani, Ph.D
Division of Water Resources / Permitting
Department of Environmental Quality
Office: Archdale Building, 9"' Floor (925Q/T)
512 North Salisbury Street, Raleigh, NC 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Office: 919-707-3704
Ami nadarvaniAncdenr. eov
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
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