20211129_L-Bell

North Carolina Department of Environmental Quality
Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, NC 27699
Dear Mr. Parr,
Please find attached additional public comments on the proposed Carolina Lithium
Project. Should you have any questions please feel free to contact me.
Sincerely,
� 62r;-?�
Locke Bell
RECEIVED
LAND QUALITY SECTION

THE OPERATION WILL HAVE UNDULY ADVERSE EFFECTS ON POTABLE
GROUNDWATER SUPPLIES, WILDLIFE, OR FRESH WATER, ESTUARINE OR MARINE
FISHERIES AND THE APPLICATION MUST BE DENIED.
The applicant admits that the operation of the mine will lower the water
table in the surrounding area. The applicant has failed to do proper
investigation as to the amount and degree of reduction it will cause. Even
with that said it is acknowledged that the spring fed small creeks and
streams which flow either on the site or on and across neighboring lands
will be adversely affected. The operation of the mine will cause these
creeks and streams to dry up. The destruction of these creeks and streams
will cause irreparable harm to the natural environment.
Looking first at the creeks and streams on the land of the applicant (setting
aside for the moment Big and Little Beaver Dam Creeks) there are several
which have diverse aquatic wildlife which includes "undetermined species"
of crawfish. Being spring fed they are currently subject to periodic drought
conditions. Any reduction in the water table will cause permanent death to
the aquatic flow and the wildlife living therein. Additionally, these creeks
and streams provide hydration to wildlife for a vast area. Creeks and
streams which have their springhead on the lands of the applicant also flow
onto the lands of neighbors. In one case there is a seven thousand foot long
spring fed creek which is a common boundary with the applicant and a
neighbor. N.C. Wildlife has inspected this creek and found unknown species
of crawfish which it needs time to study. Any open pit mining will destroy
the water table which feeds the springs which create the creeks. There
must be no mining permitted until such time as the State Fisheries experts
can determine the nature and extent of the wildlife in this creek. There are
other creeks and streams on the lands of the applicant which have not
been inspected by State Fisheries. Prior to any mining these creeks and
streams need to be inspected and all aquatic life determined. The failure to
address these issues would have an unduly adverse effect on the wildlife
and fresh water in and around the proposed mine.

There is also a spring fed creek which begins on the land of the applicant
and travels onto the land of an adjoining landowner. This creek will be
permanently dried up by any open pit mining. This denial of a landowner of
a creek which has flowed across the lands since the memory of man
runneth not to the contrary will be a violation of riparian rights and an
undue burden on the wildlife and fresh water. On the lands of the private
owner the creek provides nourishment to a great variety of fish and
wildlife. The adverse impact of the destruction of this creek must be fully
investigated prior to the consideration of granting any mining permit.

THE EPA HAS RECINDED THE TRUMP ADMINISTRATION MODIFICATION OF THE
REDUCTION IN FEDERAL REGULATIONS SURROUNDING THE PROTECTION OF
WATERWAYS AND ANNOUNCED THAT IT WAS GOING TO REVIEW THE RETURN TO
THE OBAMA STANDARDS.
The Mining Commission should refrain from any action on the application until
such time as the EPA has announced and implemented the new regulations. It is
likely that the new regulations will require much stricter protections for the
waterways on the lands of the applicant and will bar the activities proposed in the
application. The State Mining Commission should not be acting in contravention
of federal regulations.

THE OPERATION WILL HAVE UNDULY ADVERSE EFFECTS ON POTABLE
GROUNDWATER SUPPLIES
1. The applicant acknowledges that the water table in the area of the mining
operation will drop and, it will have an adverse effect on potable
groundwater on neighboring homes and businesses. What it cannot say
based on research done to this point is the extent of the adverse effect.
Therefore, at this time the mining commission cannot adequately
determine the overall extent of the adverse effects on potable
groundwater supplies.
What is known at this time is that there are hundreds of water wells in the
vicinity of the proposed mine. These wells are the only source of water for
hundreds of not thousands of citizens. The applicant has acknowledged
that any mining operation in the area will lower the water table leading to
the drying up of wells. There proposed solution to this crisis will be
addressed later. What the applicant has failed to do is determine and
display on the application the number of wells in the area. That map which
was presented as part of the application is wrong and must be replaced
with correct information. In one instance the map fails to show two wells
located on land adjoining the proposed mining operation. In another it fails
to show any well although at least one exists.
What is not known at this time is the depth of the wells. Many of the wells
are less than one hundred feet deep. Old ones were often lined with rock
to support the walls. Until a complete survey of the wells which might be
impacted by the mining operation the full extent of the unduly adverse
effects on potable water as it relates to these wells cannot be determined.

The applicant has stated in its application that if neighboring wells go dry
due to the lowering of the water table due to mining then the applicant will
put in a new well. This is the acknowledgement of the undue adverse effect
without providing a solution. Once the well goes dry the family is without
water and faces a health crisis. There is no timetable for the installation of
the new well. The installation will cause unjustified disturbance to the lands
of the homeowner in way of mining rigs, trenching for lines and power.
There is no assurance that the new well will function as the water table
continues to drop. The position of the applicant is that after it destroys a
well it gets to decide if it is at fault and if so what and when it will cure the
damage. No where in civil or criminal law is the wrong doer granted the
authority to decide when and how and if the wrong should be corrected.
The drop in the water table exacerbates this threat to public safety in that
as the table drops it will not be one but numerous wells which will go dry.
There are not enough well drillers in the area to dig the new wells.
Therefore, as the situation expands the unduly adverse effects on the
potable water will increase exponentially. Even as these wells go dry and
the health and safety of the residents is placed in peril new wells will go dry
as the water table continues to drop. The existence of monitoring wells is
good in theory but will not prevent the crisis. The monitoring wells are
located to provide information to the mining operations. They will not
prevent residential wells from going dry. Any information drawn from these
wells will be the property of the mine operator which it would be required
to present to the mining commission. In the mean time the residential wells
are dry. Due to the nature of the movement of underground water the
monitoring wells cannot detect all activity. In short, it is acknowledged that
the water table will drop; residential wells will go dry; monitor wells cannot
stop this and can only provide information; neither the applicant nor the
commission knows the number or depth of the surrounding wells, so the
information gathered by the monitor wells is of little or no use in protecting
the local residents.

Before any consideration may be given to the mining application the full
nature and extent of the wells and the threat from the proposed mining
operation in the area must be investigated, reported, and reviewed.

THE MINING APPLICATION FAILS TO ADEQUATELY PROVIDE THE COMMISISON
WITH SUFFICIENT INFORMATION REGARDING THE FLOODING OF BEAVER DAM
CREEK.
The maps provided with the application are of insufficient definition as to
show the severity of the topography involved. There are areas within the
proposed mining site which are shown as within the one hundred years
flood plain. What these maps do not show is the depth of the flooding and
the force of the water. There are parts of Beaver Dam creek which flood
more than ten feet from the bottom of the creek and five feet from the
top. The flooding can spread more than two hundred feet laterally. Within
this area the proposed mine shows constructed aquatic sites. That is not
addressed and must be prior to any consideration of the application. Also
to b addressed is the impact of the flooding on the matter stored in the
ponds and the surrounding topography. At a point where the creek floods
in one direction, where the construction is located, there is an almost
vertical eighty foot high bank on the other side of the creek. Any blocking of
the flood path will undermine the security of this bank and could
reasonably lead to collapse. This would block the creek causing additional
flooding, silting and degradation of the creek. The current topography maps
are of insufficient proportion to reveal these issues. Before any
consideration may be given to the application new more detailed
topography maps must be provided and reviewed.
New topography maps need also to be accompanied by detailed marking
showing where the core samples were taken anywhere within in one
hundred feet of any creek or within one hundred feet of any ridgeline
decline in topography above a creek. There appear to be core samples
taken in 2020-2021 which are a places as close as 30 feet from Beaver Dam
creek in one place and less than 100 feet from the top edge of the above
referenced 80 foot ridge line. No determination can adequately be made
as to the unduly adverse effects on fresh water without a proper
consideration of the topography.

THE PLAN AS IT NOW DESIGNED FAILS TO ADDRESS THE FLOW OF WATER FROM
ITS PROPERTY ONTO THAT OF ADJOINING LANDOWNERS.
There is a creek on the land of the applicant which flows onto the land of an
adjacent landholder. There are two possible outcomes from the construction of
the mine as proposed each of which will have an unduly adverse effect on
groundwater. The first which is the destruction of the springs feeding the creek is
addressed elsewhere. The second is the damming up of the stream as shown on
the application. This will deny the downstream owner his rightful use of the
water and will unduly negatively impact wildlife. It will cause water to back up
into the mine site and is not shown on the map submitted. Before any
consideration can be given to the application the amount of water which will be
barricaded and the area which it will flood must be mapped and addressed
together with the adverse impact of the stagnant nature of the water.

THE APPLICANT HAS NOT BEEN IN SUBSTANTIAL COMPLIANCE WITH THIS ARTICLE
The applicant has falsely stated in its filing that it has inspected or offered to
inspect each house in the area in anticipation of blasting damage. While some
homeowners have been offered the opportunity to have their homes inspected
the applicant has refused the request of at least one homeowner and has not
contacted others.
The applicant has failed to comply with state and local rules regarding the
protection of the environment and has in fact stated in public filings that it
deemed such requirements immaterial. Such actions have lead to a degradation
of the environment.
The maps which accompany the application differ in serious ways from the ones
which it presented to the county commissioners and investors during the same
period. The commission cannot continue with the application process without an
investigation as to the relationship between what is being presented to the
commission and what is being presented to the public and elected officials who
will have to consider zoning. It is argued upon information and belief that at the
very time the applicant was preparing the maps which accompany the mining
application it was also preparing and presenting a different map to the public and
county commissioners. If in fact the petitioner has any intent to use the water
lines shown on the public maps to provide water to the mine site, that would be
part of the mining operation and must be addressed in the application. It is a clear
and material representation of the full scale of the mining operations and is in
contradiction to the application. Thus, the veracity of the application and the
applicant is called into question by the additional maps and the representations
to a local governing board as to the truth of the other map and its purpose.

THE MINE AS PLANNED WILL UNDULY HARM THE HEALTH AND SAFETY OF THE
CITIZENS IN THE SURROUNDING AREA BY BLASTING
The mining application acknowledges that the blasting which will take place
endangers the health and safety of surrounding homeowners. It simply does not
address the full extent of the dangers. First, falling rock is by its very nature a
danger to the surrounding area. It is not only the house which is threatened but
every square foot of the property. The blasting as proposed by the applicant will
be located beginning only one hundred feet from the property lines. This will
place the adjoining landowner in jeopardy of his/her health and safety if they are
out on their own land. Children playing on their own land will be placed in danger
of flying rock by the blasting. Agriculture will be unduly harmed. Rock blasted into
a pasture is a threat to livestock. Rocks blasted into a cultivated field is a danger
to machinery. Rock blasted into adjoining land will destroy out buildings. The
cavalier position of the applicant that when damage occurs just call us only goes
to show the lack of concern with the severity of the problem by the applicant.
Blasting will destroy those old wells which are laid with stone.
The application states that the applicant contacted every landowner within an
area it determined to be necessary to offer an inspection of the foundation of the
home. The purpose of this was to protect the applicant from false claims of
foundation damage from blasting. This acknowledges that there will be damage
to foundations and the applicant wants to ensure that it is only liable for the ones
it causes. Therefore, the applicant acknowledges that the health and safety of the
citizens will be unduly endanger the safety of the surrounding area. If blasting
damage was not possible the applicant would have no concern with claims. As it
did not review of cell tower interference because it is not a threat it did blasting
because it is a threat.
The history of blasting by mines in the area is one of houses shaking and people
dealing with the mental stress therefrom. Also, the distance which the blasting
traveled has been historically determined by previous mining. The application

now pending should not be considered until the empirical data as to these
matters of public health and safety has been collected and considered.
Government studies have been done regarding the health and welfare of children
from the effects of blasting. The application now pending should not be
considered until this information is gathered and considered. Once the above
information is considered it will be found that the proposed mining in the permit
application will cause an unduly adverse effect on the health and safety of the
surrounding community and the permit must be denied.

THE OPERATION WILL VIOLATE STANDARDS OF AIR QUALITY IF CONSTRUCTED AS
PROPOSED.
The applicant claims that it will use a conveyor belt of some one mile or more in
length which will be elevated high above the ground. This conveyor system will be
used to transport lithium which is a control substance under North Carolina law
and Federal Law. The conveyor system will be exposed to constant wind and
periodic rain, fog and mist. While the applicant claims that the system will be
sealed there is no evidence that this system has ever been used before or that it
will in fact be completely sealed. Logic and common sense conflict with this
assessment. The exposure of the lithium and accompanying chemicals to the
elements will violate standards of air quality that have been promulgated by the
department and restricted by control substances statutes. Constant air circulation
above the surface of the land and winds which are strong on a daily basis will
cause lithium to be blown from the conveyor system into the atmosphere. This
will expose the citizens living in proximity to the mine to inhalation of lithium, a
control substance. The application fails to show that the proposed system will
withstand nature as it exists and the direct and substantial physical harm to the
public health and safety.
Lithium reacts violently with water causing fire. The conveyor system will be of
such length as to produce a certain (unknown without further research) amount
of lithium powder as the lithium is conveyed over the long distance. With
changing moisture in the surrounding air from fog to mist to rain to a combination
of all will likely expose the lithium to violent reactions causing fire over open lands
leading to uncontrolled brush and forest fires. The application fails to show that
the proposed system will withstand nature as it exists and the direct and
substantial physical harm to the public health and safety.
The operation of a conveyor system of such magnitude as the one proposed in
the application will by its very nature create noise of such degree as to cause a
substantial physical harm to the public health and safety. The commission has

addressed the issue of noise as it relates to the open pit operation, however it has
failed to address the issue as it involves the operation of an open conveyor
system over such a large distance. Based upon this the application fails to show
that the proposed system will not be direct and substantial physical harm to the
public health and safety as contended herein that it will be.
The application must be denied or delayed until such time as the substantial
physical hazard to public health and safety can be insured as it applies to these
and other issues.

PUBLIC INFORMATION HAS BEEN SUBMITTED BY OTHERS WHICH MUST BE
REVIEWED, STUDIED, CONSIDERED AND APPLIED PRIOR TO ANY ACTION AND
SHOW THAT THE PERMIT MUST BE DENIED.
Lisa Stroup and others have submitted either in writing or orally vital documents,
reports, studies, and comments which show that the granting of the application
would have unduly adverse effects on potable ground water supplies, wildlife,
estuarine, and marine fisheries. They also show that the operation of the mine
will violate standards of air quality, surface water quality and ground water
quality that have been promulgated by the Department. Additionally, they show
that the operation of the mine will constitute a direct and substantial physical
hazard to public health and safety and to neighboring dwelling houses.
The reports show that previous experience with similar operations indicates a
substantial possibility that the operation will result in substantial possibility of
acid water pollution.

THE OPERATION WILL CONSTITUTE A DIRECT AND SUBSTANTIAL PHYSICAL
HAZARD TO PUBLIC HEALTH AND SAFETY AND PUBLIC PROPERTY BY ANY
ATTACHMENT TO A MUNICIPAL WASTE WATER OR DRAIN WATER SYSTEM.
The application makes reference to the mine attaching to a municipal waste or
drain water system for the disposal of the 380,000 to 1,300,000 gallons of water
used each day. First, there is no municipal or any governmental waste water
system within miles of the site. No system can be installed without a municipal
eminent domain action which no municipality will do. The nearest municipalities
lack sufficient capacity to take the water. Upon reaching the 85% capacity level a
municipality must expend great sums of money in compliance with federal and
state regulations. The overburdening of the system would constitute a direct and
substantial physical hazard to public health and safety and public property.

PROPER REVIEW OF THE APPLICATION REQUIRES COLLECTION AND
CONSIDERATION ON THE NUMEROUS AREAS CITED ABOVE. NO DETERMINATION
CAN BE MADE WITHOUT SUCH ADDITIONAL INFORMATION AND REVIEW. NOW,
AND ONCE EACH OF THE ABOVE REASONS IS REVIEWED, EACH IS IN AND OF
ITSELF SUFFICIENT TO DEMAND THAT THE APPLICATION BE DENIED. THEY MUST
ALSO BE CONSIDERED COLLECTIVELY. DOING SO REVEALS THE TOTALITY OF THE
REQUIREMENT THAT THE APPLICATION BE DENIED.