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HomeMy WebLinkAboutNC0090212_Albermarle Kings Mountain Project_20240325AALBEMARLE& RECEIVED Kings Mountain Facility 348 Holiday Inn Drive MAR 2 5 2024 Kings Mountain NC 28086 North Carolina Division of Water Quality NCDEQ/DWR/NPDES Water Quality Permitting Section/ Industrial NPDES Permitting Unit 1617 Mail Service Center Raleigh, NC 27699-1617 RE: Pumping Operation and Monitoring Plan Albemarle Kings Mountain Mine Project NPDES Permit NCO090212 (Draft) 1.0 Introduction Albemarle U.S., Inc. (Albemarle), intends to reopen the Kings Mountain Mine, which produced lithium from the 1940s through the 1980s and contains one of the few known hard rock lithium deposits in the United States. The Kings Mountain Mine is in Cleveland County, North Carolina, adjacent to the city of Kings Mountain on the Interstate 85 transit corridor, approximately thirty miles west of the city of Charlotte. In 1993, exploration and mining operations ceased, and an open pit lake started to form due to rebounding groundwater. During the groundwater recovery period (approximately 1994 to present), some water was sporadically pumped from the Kings Mountain pit lake to an adjacent aggregate quarry to support quarry operations. In 2015, Albemarle acquired the site and resumed exploration and mine feasibility studies. In support of the Kings Mountain Mine Project (project), Albemarle has applied for, and has received draft NPDES permit NCO090212 for the temporary discharge of water contained in the pit lake at Kings Mountain. Issuance of the permit with an effective date of April 1, 2024 is currently expected. As required by condition A(2) in Part 1 of the permit, Albemarle has prepared and is submitting this Pumping Operations and Monitoring Plan for approval. 2.0 Elements of Pumping O&M Plan As detailed in the permit, the Pumping Operations and Monitoring (O&M) Plan should include the following elements. Each is briefly discussed in the following section, with additional detail provided later in this document. The pumping O& M plan shall include, but is not limited to, the following: A detailed site plan showing wetlands, ditches, well placements, pits, borrow areas, overburden storage, stormwater controls/ BMPs, vehicle maintenance areas, total drainage area, and access/haul roads Attached Figures 2 and 3 indicate the location of the dewatering activity, including the treatment plant, much of the pipeline route, and the discharge point at South Creek AALBEMARLE 10 Kings Mountain Facility 348 Holiday Inn Drive Kings Mountain NC 28086 Reservoir, and show the general topography. The dewatering pumping and treatment activities occur in the mine pit lake, which is an internally draining, isolated water body with no potential for discharge to waters of the state possible (other than the pumped discharge addressed in the permit). Therefore there are no stormwater BMPs proposed or required for the activities occurring in the pit lake. Similarly, since there is no active mining operation, there are no overburden storage areas, vehicle maintenance activities, etc. The pipeline connecting the mine pit to the South Creek reservoir was laid on the ground, thus avoiding ground disturbances that could cause loss of sediment to creeks. Detailed plans to maintain the surrounding hydrology that protects the affected streams and wetlands. Addressed in Section 3.0 and the respective monitoring to demonstrate compliance, and (Addressed in Section 4.0) The pumping regime deemed necessary to protect affected streams and wetlands. Protection of affected streams and wetlands will be accomplished through the proper operation of the treatment plant, and influent and effluent monitoring to ensure compliance with the discharge limitations. The water treatment plant will be staffed with operators that are licensed to operate a Class I treatment plant. An adaptive management approach will be taken as described in Section 6.0. 3.0 Plans to Maintain Surrounding Hydrology The pit lake is an isolated body of water (not connected to other water bodies The water will be pumped through a treatment system, then piped to South Creek Reservoir, which discharges to Kings Creek through two 36-inch pipes in the dam. Water leaving the discharge point (dam spillway pipes) flows over a series of energy dissipating features (rip rap, etc.) designed to minimize the velocity of water exiting the dam and entering Kings Creek. Dewatering is anticipated to take place over approximately 18 to 24 months. Baseline water quality has been assessed in the pit lake, South Creek, South Creek Reservoir, and Kings Creek since late 2018, including quarterly monitoring that has been conducted since May 2022. NCDEQ received a comprehensive report of the water quality in the affected water bodies, and has established volume and concentration discharge limits in the permit that are protective of water quality in receiving waters. Albemarle has constructed a water treatment system to meet those discharge limits. Water entering the treatment system will be sampled at least once per shift to assess the levels of contaminants, and to calculate/adjust the appropriate dose of treatment chemicals required to achieve compliance with the protective discharge limits. AALBEMARLE,- Kings Mountain Facility 348 Holiday Inn Drive Kings Mountain NC 28086 In addition to the water quality monitoring, Albemarle conducted baseline assessments of aquatic biology in 2022 to understand the species present in the pit lake, Kings Creek, and other water bodies throughout the mine property. All species of fish, crustaceans, and bivalves encountered during the baseline assessment are listed as Least Concern by the International Union for Conservation of Nature. The results of the assessment and desktop research indicate that it is unlikely that federally listed or state -listed aquatic species of concern occur in the project area. Protection of downstream water quality, and the integrity of the receiving waters, will be protected primarily by complying with the discharge limits established in the permit, along with periodic observations of the physical condition of the creek in downstream locations. Channel stability of Kings Creek was also evaluated in 2022 to understand the potential impacts that may result from discharging water from the pit lake. The analysis determined that the dewatering process will not result in flooding or erosion impacts to Kings Creek, both within and beyond the boundary, unless flows exceed 3500 gallons per minute (gpm). Flow will be monitored continuously to demonstrate compliance with the limit, but the physical limitations of the pumps and treatment system make it incapable of pumping more than the discharge limit. 4.0 MONITORING REQUIRMENTS The NPDES permit monitoring program includes the documentation and monitoring of water quality and aquatic biology. Specific monitoring parameters are described in the following sections. 4.1 General Monitoring Water quality monitoring will include collection of field water quality parameters and water samples for chemical analysis. Monitoring will be conducted at the effluent point (after treatment) and in Kings Creek at about 100ft upstream and downstream of the discharge point (Table 1, Figure 1). Monitoring will take place in accordance with the permit and table 1. Table 1. Water Quality Monitoring Sites Location Latitude Longitude Location Description Effluent Discharge pipe or substantially similar location. Upstream Kings Creek, about 15011 upstream of South Creek Reservoir Outfall. Downstream Kings Creek, about 150ft downstream of South Creek Reservoir Outfall. AALBEMARLE Kings Mountain Facility 348 Holiday Inn Drive Kings Mountain NC 28086 4.1.1 Field Water Quality Parameters Field water quality parameters include temperature and pH. Monitoring will be conducted using a direct -read, hand-held water quality instrument such as YSI®, or similar, and measurements will be recorded using an electronic data collection platform, such as ESRI's Survey 123 or similar. Instruments will be inspected and properly calibrated according to the manufacturer's operating instructions prior to each use. In situ water quality monitoring will be co -located with water sampling locations. In addition, the Water Treatment Plant has process sensors that continuously collect water quality data at various stages of treatment which will allow for adjustments of treatment of the mine pit water to meet water quality standards. 4.1.2 Water Sampling The sampling team will document field -derived information, observations, and other field data using an electronic data collection platform, such as ESRI's Survey 123 or similar. Information collected should include sampling details such as field team members, sampler name, sample type, location name, GPS coordinates, time/date, general site conditions, and other observations (e.g., presence of wildlife, weather). Water samples will be analyzed for the parameters listed in the permit, using the procedures specified therein. The analytical lab will provide the appropriate bottle, required volume, and preservatives for each sample. 4.2 Specific Monitoring Locations and Requirements 4.2.1 Upstream Sampling Grab samples will be collected from the Upstream Kings Creek sampling location and analyzed for turbidity on a monthly basis. However, if the effluent turbidity exceeds 50 NTU, monitoring shall be conducted weekly during the months of June, July, August, and September and monthly during the remaining months of the year until effluent turbidity is less than 50 NTU. 4.2.2 Downstream Sampling Grab samples will be collected from the Downstream Kings Creek sampling location and analyzed for turbidity, pH, and temperature on a monthly basis. However, if the effluent turbidity exceeds 50 NTU, monitoring shall be conducted weekly during the months of June, July, August, and September and monthly during the remaining months of the year until effluent turbidity is less than 50 NTU. AALBEMARLE QD Kings Mountain Facility 348 Holiday Inn Drive Kings Mountain NC 28086 4.2.3 Effluent Sampling Grab samples will be collected from the effluent discharge. TSS, Turbidity, Temperature, Chlorides, Copper, Cyanide, Fluoride, Selenium, Silver, Sulfide, NH3-N, and pH will be sampled monthly. Nitrogen, Phosphorus, zinc, cadmium will be sampled quarterly. During all sampling events, the sampling team will check and record that there is no discharge of floating solids or foam visible in other than trace amounts. Flow will be monitored continuously by instream process sensors prior to discharge. Mercury sampling will be conducted on an annual basis and the sampling team will follow EPA Method 1669 (Appendix Q. Method 1669 is commonly referred to as the "Clean Hands — Dirty Hands" method and is briefly described below: Dirty Hands/Clean Hands — Upon arrival at the sampling site, one member of the sampling team is designated as "dirty hands " and another member is designated as "clean hands ". "Dirty Hands" is responsible for all activities that do not involve direct contact with the sample. Examples of activities performed by "dirty hands " include: • Removal of the double -bagged sample containers from the cooler • Holding and opening of the outer zip -type bag • Operation of any sampling apparatus involved in collection (e.g., peristaltic pump, grab sampling device, etc.) • If only two samplers are available, then "dirty hands " should also be responsible for performing all necessary documentation. "Clean Hands" only performs operations involving direct contact with the sample or sample collection container. These activities include: • Opening and closing the inner zip -type bag • All direct handling of the sample container, including attachment/detachment of sample container to/from collection device. • Transfer of the sample from the sample collection device to the sample container Sampling — Whenever possible, samples are collected facing upstream and upwind of the sampling team. "Clean hands" should remove the sample container from the inner bag and reseal the inner bag to minimize potential contamination. AALBEMARLE 0 Kings Mountain Facility 348 Holiday Inn Drive Kings Mountain NC 28086 Surface samples are collected using a grab sampling technique. This technique involves submersion of the sample container, filling and capping the container while still submersed to minimize exposure to airborne contamination. Prior to its final filling, the sample container should be partially filled and rinsed three times with the sample to be collected. All sample containers should be completely filled to minimize contact with the atmosphere and should immediately be tightly capped. While "dirty hands " holds open the outer ziplock bag, "clean hands " opens the inner bag, returns the filled sample container to the inner bag, and reseals the inner bag. "Dirty hands " then reseals the outer bag and places the sample in the cooler (Brooks). Whole Effluent Toxicity (WET) testing will be conducted on a quarterly basis, as a grab sample using the test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure. The tests will be performed during the months of February, May, August, and November and the sample must be obtained during representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in " North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 2010) or subsequent versions. AALBEMARLE 0 Kings Mountain Facility 348 Holiday Inn Drive Kings Mountain NC 28086 MINE DEVELOPMENT PRE- SELECT PHASE Prospective Pit Dewatering Monitoring Locations O Monitoring Location O NPDES Discharge Point Stream O Waterbody Project Area Cleveland County, NC USGS 7.5' Quadrangle: Kings Mountain, INC, 35081-83 NAD 1983 StatePlane North Carolina FITS 3200 Feet 35-2123°N 81.3544°W, pave Map FSRIA,,G1S0M,. x-a f Jio a v 202+ Updaled Inoue $ pm"No 703t� rv9 Mrn 7 202 01Jn n N A 1:3.600 SWCA fnvi�OMra(MT�L COnSUL1�nT5 AALBEMARLE'P�, Kings Mountain Facility 348 Holiday Inn Drive Kings Mountain NC 28086 Figure 1. Water quality sampling locations. At all other sampling locations, surface water samples will be collected by hand or peristaltic pump, depending on water depth. After donning new, powder -free nitrile gloves at each location, the sample bottle will be lowered into the water until full, then capped, taking care to not include any floating material in the sample container. If the water is too shallow to submerge the bottle, a peristaltic pump will be used. A peristaltic pump draws the sample through heavy -wall Teflon® tubing and pumps it directly into the sample container. Some analytes may need to be field -filtered to remove suspended particulates. Samples can be filtered by placing adaptable filters on the peristaltic pump. Medical -grade silicon tubing can also be used in peristaltic pumps. The sampler should ensure that the tubing does not pick up sediments from the bottom of the waterbody or touch the inside of the sample bottle. The tubing will be purged by pumping surface water through the pump for 2 minutes before collecting any samples. Filtered samples will be collected first, followed by unfiltered samples. New tubing (and filter if applicable) will be used at each location. Additional volume will be collected for Quality Assurance/Quality Control (QA/QC) samples as needed. Sample containers and preservatives will be provided by the laboratory. Sample jars will be labeled immediately after collection and stored on wet ice until delivery to the laboratory. Samples will be shipped via overnight courier (FedEx), or hand delivered, under Chain of Custody (COC). Care will be taken to avoid shipping/delivery on weekends and/or near holidays. 5.0 DAM INSPECTION Because the dewatering operation will increase the flow of water through the dam, a daily inspection of the dam structure will be performed. The daily inspection will comprise a visual inspection of the dam's upstream face and downstream toe for the following: • Signs of erosion on the dam faces due to wave action, runoff and/or flow through the discharge pipe. • Changes in seepage condition at the dam toe, downstream face, or dam abutments. Changes in seepage conditions could include increased seepage rates, changes in seepage color, and/or increased turbidity. • Increased vegetation growth on the downstream face of the dam. potentially indicating increased saturation conditions. • Blockages at the appurtenance inlet and/or spillway, including signs of beaver activity and/or debris buildup. AALBEMARLE" Kings Mountain Facility 348 Holiday Inn Drive Kings Mountain NC 28086 • Changes in flow conditions out of the outlet pipe, including significant increases or decreases in flow rate which could indicate erosion or blockage, respectively. The results of the visual inspection will be recorded in a daily checklist and reviewed by the Mine Operations Manager. In the event an unusual condition is observed, the Mine Operations Manager will contact the Senior Manager of Geotechnical Governance for further direction. 6.0 MITIGATION MEASURES AND ADAPTIVE MANAGEMENT The NPDES permit monitoring program is designed to evaluate whether project goals and objectives are being met. During the course of monitoring, if impacts to water quality, streambanks, and aquatic life are identified, a modification in protocols or other actions may be needed to minimize or prevent impacts from compounding. The need for and specific measures taken will be determined based on the specific circumstances. Some examples of adaptive management measures to reduce/mitigate impacts may include, but are not limited to: • Water entering the treatment system will be sampled once per shift to assess the levels of contaminants, and to calculate/adjust the appropriate dose of treatment chemicals required to achieve compliance with discharge limits. • If NPDES effluent limitations (i.e., narrative conditions or analyte numerical values) are exceeded, Albemarle will investigate potential cause(s) and identify mitigation measures, as appropriate such as adjusting treatment chemicals, replacing parts in the treatment system, adding freshwater to Kings Creek) • If QA/QC samples show anomalies, sampling and analytical methods will be reviewed and modified or improved if possible. • If water quality meter probes or other instruments are malfunctioning or damaged, they will undergo recalibration, maintenance or replaced if deemed necessary. SHEET INDEX PLAN ML AREA OF PIT ISTURBANCE f: 42" �*+ t1's• �12647 KINGS MOUNTAIN PIT A 1 12852 r PRGV IDE SILT FENCE AT V/t tt STREAM BUFFER i r / r , r CAREA OF PIT DISTURBANCE f/f EAST MINE BOUNDARY (PERMIT 23.01) PREPARED BY: SWCA ENVIRONMENTAL CONSULTANTS SWCA 113 Ednburgh South DNw, Suits 12OCary NorthCarolina220 T7511 (p) 919.29222M www rcx.com PREPARED FOR: / I,ALBEMARLE' i IGNOS MOUNTAIN CLEVELAND COUNTY 348 NoNdRY Inn Drive N61M Mountain, NC 20 M PROFESSIONAL SEAL CA { SEAL 1 040761 FNGINEEa�?,` �pSHUA g NAY♦ PROVIDE SIFT FENCELLI i AROUND WETLAND I BUFFER �.;- - � I /.' '. � - ( TEST BLASTING AREA � _ - Z �! (n ', I SEE SHEET 3.1 FOR v ,2 ;f, •,I l/ DETAIL!...�""" �'I"" � N Z 0I ' /; / '6 0 DISTURBANCE.t` M O E4. e2o « 1` //F-'PROVIDE SILT FENCE AT ~ W U CA �`.. ! L g e 0 a'F WETLAND BUFFER �- tan Q Z ,. ka_ jf/ ,' MwE P T \ L 9� /.. ♦�� 2 Z J O I WA - - ___ L c. �- ,`- - " wro FACILITY DEWATERING DETERING ' ♦ _ C ~ Z_ - _ ___ __..- ...G. r*" as 'PPEUNE U I t/. �'r 0. 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