20211126_L-Stroup-3

From: lira strouo
To: NCMlninaProaram
Cc: david shaefferCdusace armv m'I• sue horn ood(oancdner am Ingle. Bruce
Subject: [External] Piedmont lithium
Date: Friday, November 26, 2021 12:17:35 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Reoort Spam.
In September I submitted two emails with questions and concerns regarding the mine permit application. To date I have received no reply nor response. I am
attaching copies of those two emails and would greatly appreciate receiving answers and/or explanations sufficient to address my questions and concerns.
Piedmont Lithium Carolinas
Lisa Stroup <Istroup93fcdgmaiI.com>
Thu, Sep 30, 2:49 AM
to ncminingprogram
Good Evening,
In response to the NC mining permit application submitted by Piedmont Lithium, I have several questions and concerns that I would like addressed.
1- Piedmont Lithium states that the proposed property has been previously mined. However the italicized question specifically asks if the site has been previously mined by
whom and when. The only response is "Unknown and that there is evidence of mining activity", please elaborate as to what evidence is observed and address why no
records of this mining are made available.
2- In regards to storm water point source discharge, please explain what chemical reagents and compounds are to be discharged into the sediment basins and what
processes, monitoring and/or regulations will be implemented to protect the soil and surface water and streams on the proposed property as well as those of neighboring
properties and areas where this storm water discharge will drain to further away from the proposed property.
In addition to this, please elaborate on what analysis and investigation has been conducted regarding the impacts of the Hallman Beam Mine (NPLfacility) and FMC Lithium,
now Livent (Superfund facility) and the accumulated concentration of hazardous and toxic contamination in the area of the proposed mine property.
For your convenience I have attached EJ SCREEN reports for a 5 mile radius of both the above mentioned sites which overlap each other and will also fall within the
neighboring community of the proposed property. For reference I have attached an EPA document for risk reduction of cumulative effects on communities with multiple
stressors. I am formally requesting an in-depth review and further analysis be addressed based on Executive Order 12898, Environmental Justice.
3- Piedmont Lithium states they intend for the waste water effluent from the chemical processing plant to be pre-treated and discharged to an existing municipal
system. Please provide the information for which municipal system this waste water is to be treated at, how will the waste water reach the facility, what modifications are
to be made in order for the facility to process the waste water and what are the regulatory requirements? Will Piedmont lithium absorb the costs associated or will this be a
burden on the tax payers?
Additional comment, there have been several EPA Superfund violations at two waste water treatment facilities in Bessemer City, both directly related to the waste water
processing from FMC. Both facilities can be accessed in EPA ECHO.
4- In response to the 50 foot undisturbed buffer between land disturbing activities and streams and wetlands, Piedmont Lithium states it will adhere to a 30 foot buffer per
Gaston County UDO for non-residential developments with less than 24% impervious surfaces.
I would like this to be reevaluated because an impervious surface is referring to any man made area that would change the flow of precipitation. With this in mind, I find it
difficult to accept that the proposed property and the multilevel processing plants, haul roads, conveyors, waste pits, sediment basins and mining sites would fall at or under
the 24% criteria in this county ordinance.
Due to the the high probability of acid water pollution and substantial deposits of sediment of stream beds previously encountered with the Hallman Beam Mine, I do not
feel that a 50 foot undisturbed buffer will provide sufficient protection to the streams and land. The probability that a mining activity at the level intended at this proposed
property is even more likely to have disastrous adverse effects on potable ground water, surface water and the wildlife that utilize this area. As well as the health and safety
of the community.
I would like to comment that during the public presentation at the June county commissioners meeting, Piedmont Lithium stated multiple times that they were committed
to the safety and protection of the community and the environment surrounding the proposed property. It is evident that this is not the case based on the response that
they believe they will not create more than 24% impervious surface as the sole reason for requesting a reduction in the undisturbed buffer area.
5- When addressing how they intend to prevent physical hazards to any neighboring house, public road, school, church, commercial or industrial building from mine
excavation, the only response was that the are located more than 300 feet from the property line of the proposed mine.
This fails to address how they will prevent physical hazards to the children attending Tryon Elementary School. While it is not expected that the children will be on the mine
property, there is no information on how they will prevent hearing loss associated with constant, repetitive blasting or the noise generated from the operation of the heavy
equipment necessary for mining. There is no information regarding how they will protect the children from the fine particulate matter that this same school is already
subjected to from the Hallman Beam Mine.
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. 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?
Even though this school and community currently fall within 5 miles of multiple Superfund and NPL facilities with documentation of excess toxic discharge, 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. By making the information
available in this format only it further hinders the affected community.
6- How will the private wells of neighboring residences be affected? Piedmont Lithium stated they did not anticipate any wells going dry but they are not positive this will
not occur. Well water is the only available source of water for this community. Should the excessive amount of water intended to be consumed and the dewatering of the
excavation pits, it is highly probable that residents will have limited access to water. It is also very likely that our water will be contaminated with hazardous and toxic
chemicals and minerals. Because we rank in the 80th percentile for low income, even if a municipal water supply were available most residents could not afford it.
How will you address the loss of crops to the farmers in this community? The proposed mine directly threatens to remove 1,500 plus acres of high quality farmland, it will
drastically impact cattle farmers. By reducing the availability of fresh potable water for the livestock, disturbing the soil on current crop land and contaminating surrounding
land with toxic chemicals that will cause death and disease in our livestock. Yet no one from Piedmont Lithium has contacted the farmers in this community t address our
concerns and discuss how they intend to collaborate with the agricultural community in the proposed mine property.
7- 1 would like to address the information on blasting. The question asked what precautions for preventing physical hazards to people and property from flying debris,
excessive air blasts and ground vibrations. The answer does not address the frequency of the blasts nor what actions you will take to prevent hearing loss to your
employees and the community, how will this impact off shift workers? What actions will you take to address the diminished property values, our quality of life, impacts to
other businesses and the stress this noise will cause livestock?

Piedmont Lithium Carolinas
Lisa Stroup <lstrou 9p 3Pgmail.com>
Thu, Sep 30, 4:50 PM
to ncminingprogram
1- Please address why the QC analysis for TCLP samples was reported in Joules and not in the definitive sample size and how this was affected by the samples
exceeding QC limits but being accepted based on sample recovery.
2- Please explain the relative percent difference (RPDs) of chemical analysis being outside of the control limits and no re -analysis was conducted.
3- Leach tests indicated antimony, cadmium, chromium, cobalt, lead, selenium, thallium and vanadium exceeded 2L NC Standards and may cause leaching of
chromium, selenium and vanadium, which all have chronic toxic exposure health risks. Yet the application states that there are no exceeding limits of toxic waste
present in waste material or tailings.
4- Please explain statements regarding the proposal to not classify tailing material as toxic hazardous waste even though arsenic, chromium, selenium,
vanadium, iron, manganese and lead exceed NC DEQ PSRGs, Groundwater limits or EPA thresholds.
5- Why are there no analyses for PCB, VOC's or SVOC's?
References for Email 1
Hallman Beam NPL Site- EPA ECHO
https://echo.epa.gov/deta led-faciIity-report?fid=NCG020135&sys=lCP
EJScreen Report Hallman Beam Mine
https://eiscreen.epa.goy/mapper/mobile/EJSCREEN mobile.aspx?geometry=%76%22spatialReference%22%3A%76%22wkid%22%3A4326%7D%2C%22x%22%3A-
81.29364723955773%2C%22v%22%3A35.337538378088084%7 D&u n it=9035&a reatvoe=&a reaid=&basema o=streets&otitle=35.33754%2C+-81.29365&distance=5
EJ Screen FMC
httos://ejscreen.eoa.gov/mapper/mobile/EJSCREEN mobile.asox?geometry=%7B%22spatialReference%22%3A%7B%22wkid%22%3A4326%7D%2C%22x%22%3A-
811.28584999999998%2C%22y%22%3A35.285110000000024%7 D&u n it=9035&a reatvoe=&a reaid=&basema n=streets&ptitle=Bessemer+City%2C+North+Ca rol i na&d ista nce=5
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."
httr)s-//www.epa.goy/ch ld re n/rules-and-regulations-i m pact -chi ld rens-health
htt ps: //www.rcbi.nlm.n h.gov/pmc/art c I es/P M C 1253729 /
httos://www.epa.gov/clean-a r-act-overview/dean-air-act-title-iv-noise-pollution
https://www.nonoise.ore/I brarv/handbook/handbook.htm
httos: //www.epa.gov/sites/default/files/2015-04/docLiments/ensur ngriskreducation neiac. odf
Regards,
Lisa Stroup