NC0090212_Correspondence_20230811

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Joey Dean, Group Hydrogeologist
Albemarle
348 Holiday Inn Drive
Kings Mountain, NC 28086
Dear Sir:
NORTH CAROLINA
Environmental Quality
August 11, 2023
Subject: Permit Application
Additional Information Request # 2
NCO090212 — Albemarle / Kings Mountain
348 Holiday Inn Drive, Kings Mountain
Cleveland County / MRO
The NCDEQ Division of Water Quality Permitting's Industrial Permitting Unit (Division) has conducted a
review of the additional information provided on/or about July 12, 2023 for Albemarle / Kings Mountain's
proposed lithium mine project in Cleveland County North Carolina. Based upon the review NCDEQ has
the following Additional Information Request (ADI #2). Please provide all information requested herein to
this office during this renewal review period to the following:
NCDEQ/ DWR
NPDES Industrial Permitting Unit
Attn: Douglas Dowden
1617 Mail Service Center
Raleigh, NC 27699-1617
and by email to: [e-mail]
ADDITIONAL INFORMATION (ADI) REQUESTED
1. EPA Form 1 Required: Please include EPA Form 1 in accordance with the new delegation document.
The form is missing from the ADI response, despite being mentioned in the cover letter.
2. PFAS Lab Results Requested: Please include full lab results for PFAS report noted in attachment 2.
This information is necessary to validate the reported results.
3. USGS Data Requested: Please include a copy of USGS response regarding Kings Creek flow with your
revised / updated complete application.
North Carolina Department of Environmental Quality I Division of Water Resources
4NORT�HCv 512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTHCAROUNA ��// 919.707.9000
Department ofEnvlronmeroal Ouali�

4. Complete Forms 2D and 2E in Entirety: Please compile / complete ALL reportable data in EPA
forms 2D and 2E, and no necessary parts blank by closely following instructions. Please note responses,
such as "previously reported" is not sufficient. Use of replicated tables / EPA forms should be avoided.
However, you can use the same table multiple times to report different water quality data.
5. Technical Data Required: Although No Authorization to Construct (AtC) permit is required for the
proposed treatment and DWR will not technically review the plans, please note that:
a) As breakpoint chlorination will be used for Ammonia removal, a dichlorination unit should be
included to meet the expected Total Residual Chlorine limit (class C water quality standards).
b) A plan for handling the residual solids from treatment process should be provided.
c) Please clarify what type of polymer and coagulant will be used in the process. If the proposed
polymers/flocculant are not in the approved list of DWR, please provide its toxicity data for the
aquatic life.
6. Biocide 101 Form Required: Since, the proposal includes the use of polymer's / treatment additives
please complete Biocide 101 form, see attached (Attachment 2A).
7. GPD, GPM or MGD Clarification: For the application please be sure to clarify accurately whether the
discharge is gpd, gpm or mgd throughout.
8. King's Creek Flow Regime Clarification: Reviewing the data provided concerning King's Creek Flow
regime (e.g. USGS at 0.39 cfs, a non -documented 2.7 cfs, SWCA calculated 2.59 based on Martin
Marietta's contribution) and potential impact to downstream aquatic systems the data provided believed
not to have a potential impact is based upon just the proposed flow regime from Albemarle at roughly
2.5 — 2.7 cfs. However, for determining potential impacts to downstream aquatic systems the estimated
flow regime should be a cumulative factor: natural flow, Martin Marietta's existing contribution, plus
Albemarle's estimated contribution. Thus, please re-evaluate the potential impact to downstream aquatic
systems based upon the total volume (e.g. natural, Martin Marietta's and Albemarle's contributions) and
resubmit the assessment to the NCDEQ as soon as possible.
9. GPM or GPD at 2,500 Form 2D at page 16, Section 3. 3.1 Clarification: For form 2D at page 16,
Section 3, 3.1 it indicates Average Flow of 2,500 mgd or should it state 2,500 gpm which would be
roughly 3,600,000 gpd or 3.6 mgd at 24 hours a day of flow? Please correct and resubmit the entire
application.
10. Biological Waste Management Clarification: For Form 2D at page 24, Table A for Conventional
and Non -Conventional Parameters the table is not completed. How will biological waste from onsite
personnel during dewatering at the plant be managed or is the assertion that there will not be any
biological waste generated on site? Please complete Table A and resubmit the entire application.
11. Conventional and Nonconventional Pollutant Clarification: Form 2D Table B Certain
Conventional and Nonconventional Pollutants table is not complete for all parameters, why? However,
at page 62 (pdf number) of the consultant's report (e.g. Linkan Engineering's Memorandum) several
Conventional and Nonconventional Pollutants are revealed to exists in the Pit Lake. Please complete
Table B and resubmit the entire application.
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
Depanmem of Envlmnmenfal Dual

12. Toxic Metals, Total Cyanide, and Total Phenols Clarification: For Form 2D at page 30, Table C
Toxic Metals, Total Cyanide, and Total Phenols the table is not complete for all parameters, why? Yet,
the consultant's report {e.g. Linkan Engineering's Memorandum at page 63 (pdf number)} reflects the
presence of Antimony, Arsenic and other parameters, yet no entries are made in Table C, why? Please
complete Table C and resubmit the entire application.
13. 140 ft Pit Water Data — Follow -Up: At page 67 (pdf number) of the consultant's report (e.g. Linkan
Engineering dated March 14, 2023) a reference is made to "A sample of 140 ft pit water is currently
being evaluated as per the treatment process described herein at Linkan' s Elko facility. All these works
are in support of this design basis. Analytical results will be presented when available." When will the
sample of 140 ft noted be available?
14. Analytical Results for the Pit Lake at Depth of 10 Feet Table A Clarification: The forms provided
at page 72 (pdf number) of the consultant's report (e.g. Linkan Engineering dated March 14, 2023), are
not complete, why? If testing for the parameter was not conducted, then indicate that fact. If testing was
conducted and the results reflected not present, then indicate as such. A response "Results previously
reported" is not adequate. Please complete Table A and resubmit the entire application.
15. Analytical Results for the Pit Lake at Depth of 10 Feet Table B Clarification: The forms provided
at page 73 (pdf number) of the consultant's report (e.g. Linkan Engineering dated March 14, 2023), are
not complete, why? If testing for the parameter was not conducted, then indicate that fact. If testing was
conducted and the results reflected not present, then indicate as such. A response "Results previously
reported" is not adequate. Please complete Table B and resubmit the entire application.
16. Analytical Results for the Pit Lake at Depth of 10 Feet Table C Clarification: The forms provided
at page 74 (pdf number) of the consultant's report (e.g. Linkan Engineering dated March 14, 2023), are
not complete, why? If testing for the parameter was not conducted, then indicate that fact. If testing was
conducted and the results reflected not present, then indicate as such. A response "Results previously
reported" is not adequate. Please complete Table C and resubmit the entire application.
17. Table A at Page 78 Clarification: The forms provided at page 78 (pdf number) of the consultant's
report (e.g. Linkan Engineering dated March 14, 2023) appears to be a copy of Table A at age 72, why?
18. Same for Table B at page 79?
19. Same for Table C at page 80?
20. Same for Table D at page 81?
21. Kings Creek Stability and Water Quality Assessment Report Copy Requested: The response
indicates at Page 5 of 97 (pdf numbers) "As mentioned in Section 2. 2. 1 of the Kings Creek Stability
and Water Quality Assessment (Report) submitted with the permit application ( December 13, 2022),
Martin Marietta is permitted to discharge 2, 250 gpm ( 5. 01 cfs) into Kings Creek according to their
active mining permit ( 23- 02)." Please provide a copy of that report as we were not able to locate it at
this time.
22. Application Must be Complete: For clarification, the application packet must be complete on its own,
thus references to previously reported and/or submitted is not acceptable.
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
Depanmem of Envlmnmenfal Dual

We appreciate your attention to these matters and look forward to continuing to work with you and your
team on this Permit Application. Pending review and evaluation of provided information, further action or
additional information may be required.
I thank you in advance to your attention to the above reference matters. If you have any questions about
the NPDES permit process, please contact me at the following e-mail address: [e-mail],
or telephone number: 919-707-3605.
Sincerely,
Douglas Dowden
Environmental Program Supervisor II
Industrial NPDES Permitting Unit
cc: Central Files; NPDES Files
ec: Derek Denard, Environmental Program Consultant at: [e-mail]
Amir Adaryani PhD, Engineer I at: amir.adaryani o ncdenr.gov
Michael Montebello, NPDES Program Branch Chief at: [e-mail]
David Miller, State Mining Engineer at: [e-mail]
Adam Parr, Assistant State Mining Engineer, NCDEQ — [e-mail]
Wes Bell, Senior Environmental Specialist (MRO) at: wes.befl ncdenr.gov
Jeffrey Chandler, Environmental Specialist (MRO) at: [e-mail]
Trevor Chesal, Mine Environmental & Approvals Manager at: [e-mail]
Joey Dean, Group Hydrogeologist- [e-mail] and hard copy via US Mail:
Albemarle; 4250 Congress Street, Suite 900; Charlotte, NC 28209
J. Kent Masters; Chief Executive Officer at: [e-mail]
Chris Garrett, SWCA at: [e-mail]
Sophie Swanson, Senior Water Resource Engineer, Mining, SWCA at [e-mail]
John Kuhn at: [e-mail]
Melissa Arnold, Assistant Project Environmental Scientist at: [e-mail]
Chase Conway, Consultant II; ERM at: [e-mail]
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
Depanmem of Envlmnmenfal Dual

Attachment 2A
BIOCIDEICHEMICAL TREATMENT
WORKSHEET-FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each biocidal product in use. This worksheet is to be
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
Facility Name
NPDES # NC
County
Receiving Stream
Outfall #
71010 11
(All above information supplied by the Division of Water Quality)
What is the Average Daily Discharge (A.D_D.) volume of the water handling systems to the receiving water body?
A.D.D. = (in M-G_D.)
Please calculate the Instream Waste Concentration (IWC in percent) of this discharge using the data entered
above_
(A_D.D.) X 100 ( ) X 100 °,
'WC = (7Q10)(0.646) + (A_D_D) - ( )(0.646) + ( ) - 'O
This value (INC? represents the waste concentration to the receiving stream during low flow conditions.
II. What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part I?
Please list the active ingredients and percent composition:
o� y
o�
o�
What feed or dosage rate (D.R.) is used in this application? The units must be converted to maximum grams
of whole product used in a 24hr period_
D.R.= gramsl24hr period
Please note, fluid ounces (a volume) must be converted to grams (a mass). The formula for this conversion is:
Grams of product = fluid oz. of product X 1 gal. water X 8.34 lbs. X specific gravity of product X 453.59g.
128 fl. oz. 1 gal_ water 1 lb.
D E Q�JI North Carolina Department of Environmental Quality I Division of Water Resources
!/ 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NoarHCARouNA 919.707.9000
Department of Environmental Duality

Facility Name:
NPDES #: NC
Estimate total volume of the water handling system between entry of biocidal product and NPDES discharge point.
On an attached sheet please provide justification for this estimate (system volume. average cycles per blowdown,
holding lagoon size, etc.)
Volume= million gallons
What is the pH of the handling system prior to biocide addition? If unknown, enter NIA.
What is the decay rate (D-K.) of the product? If unknown. assume no decay (D.K.=Ot and proceed to asterisk.
The degradation must be stated at pH level within 112 pH standard unit within handling system. Enter the half life
(Half Life is the time required for the initial product to degrade to half of its original concentration)- Please provide
copies of the sources of this data.
H.L_ = Days
1
The decay rate is equal to H.L.X 0.69 = =Decay Rate (D.K.)
Calculate degradation factor (D.F.). This is the first order loss coefficient.
D.F. _ (Volume)
+ (D.K.) _ + ( 1 =
Calculate Steady State Discharge Concentration:
Dischg Conc. _ (D.F.)(Vollume)(3785) _ ( i? :0755} = mgA
Calculate concentration of biocide instream during low flow conditions
(Receiving Stream Concentration)
(Dischg. Conc.) x (IWC%) ( ; x ;
100 = 100 = mg/l
Receiving Stream Concentration
III. Calculate regulated limitation.
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in mg/1). Please provide copies of the sources of this data.
Organism Test Duration LC50/EC50 (mqA)
D. W Q. Form 101 rl 2019i
D E Q�JI North Carolina Department of Environmental Quality I Division of Water Resources
!/ 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NoarHCARouNA 919.707.9000
Department of Environmental Duality
A

Facility Name:
NPDES #: NC
Choose the lowest LC50/EC50 listed above:
Enter the LC501EC50:
If the half life (H.L.) is less than 4 days, perform the following calculation.
Regulated Limitation = 0.05 x LC50 = mgA
If the half life (H.L.) is greater than or equal to 4 days or unknown, perform the following calculation.
Regulated Limitation = 0.01 x LC50 = mgA
Choose the appropriate regulated limitation from the calculations immediately above and place in this blank:
From Part II enter the receiving stream concentration:
g/liter
I'1. Analysis.
If the receiving stream concentration is greater than the calculated regulated limitation, then this biocide is
unacceptable for use.
Person in Responsible Charge
Name (Printi
Email Address & Phone Number
Signature Date
Person Completing This Worksheet (If different from above)
Name !Printi
Email Address & Phone Number
Signature Date
Please submit to: Division of Water Resources
Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh. NC 27699-1621
Contact Info: Cindy- Moore (cindy.a.moore,&ncdenr.gI or Susan Meadows (sLisan_meadoirs (7ncdenr.gov)
D.IiQ. Form 101 i1 2019i
D E Q�JI North Carolina Department of Environmental Quality I Division of Water Resources
!/ 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NoarHCARouNA 919.707.9000
Department of Environmental Duality
3

Facility Name:
NPDES #: NC
Supplemental Metals Analysis
If copper, zinc, or chromium are present in the proposed biocidal compound. complete this worksheet. A separate form
must be used for each metal and/or metal compound present in the biocide. List the metal, its chemical formula, molecular
weight (MW ), formula weight (FW). and the concentration of the metal compound in the biocide (MCC). Complete a
separate form for every metal present in the biocide -
Meta I Chemical=ormula Molecular Weight o`Me:al Formula Weight Concenration in Biocide
EXAMPLE
Copper CuSO4.5H2O 63.546 g�mole 249.680 gVrnole 0.2 %
Dosage rate of Biocide (DR) (from page 1):
DR = grams day
Average Daily Discharge (ADD) (from page 1):
ADD = million gallons/day
Discharge Concentration (DC) of Biocide:
DR f grams/day)
DC =ADD = ( million gallons day} = grams/million gallons
Convert DC to microgramsrliter (ppb):
DC (pg/l) = DC igramslmillion gall x 1 x 106 ug/g = pg;l
3781, x 106 liters/million gal.
Calculate the fraction of metal in the metal -containing compound (MF):
MF = M'4 _ grams mole)
F'W { gramslmole)
Calculate the fraction of metal in the biocidal compound (BF):
MCC I%) %
BF=MFx 100 = x 11001 =
Calculate the concentration of metal in the discharge (MI:
M = DC BF = ugrl x = pgA
Calculate the instream metal concentration (IMC) at low -flow conditions:
IMC = M x 1A, C(%I = Ngll x 100 % - NgA
Regulated limitation of metal (from below): ugill
NC General Statutes 'EA. NCAC 26 0211 define
Copper- 7 pgll water quality action level' Zinc- 50 pg/1 water quality action level'
Chromium- 50 pgll waver quality standard
('Values which exceed action levels must be addressed directly by aquatic toxicity testing.)
D. W Q. Form 101 r1 20191
D E Q�JI North Carolina Department of Environmental Quality I Division of Water Resources
!/ 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NoarHCARouNA 919.707.9000
Department of Environmental Duality
4

ATTACHMENT 1
PERMIT APPLICATION SUPPLEMENT- PFAS SCREENING QUESTIONS:
1. Do you use any material or products (directly or indirectly) in your operations that contain
fluorinated chemicals? If so, please identify what materials or products contain fluorinated chemicals.
• Please also address if you have any historical conditions and/or information for past practices at
the site related to fluorinated chemicals?
2. Will your facility formulate or create products (directly or indirectly) which contain fluorinated
chemicals? If so, please identify the specific fluorinated chemicals that may be formulated or created.
3. Will your facility produce solid waste, liquid waste, wastewater effluent, or other waste containing
fluorinated chemicals? Please be as specific as possible to describe what fluorinated chemicals may
result in the facility's wastewater, solid waste, or sludge.
4. Are there processes or operations that use equipment, material, or components that contain PFAS
chemicals (e.g., surface coating, clean room applications, solvents, lubricants, fittings, tubing,
processing tools, packaging, facility infrastructure)? Could these activities result in fluorinated
chemicals being discharged as products, or by-products (i.e., through leaching, chemical process,
heat treatment, pressurization, etc.)?
5. List CAS numbers of all known or believed present fluorinated compounds from the questions
above. Please provide descriptions, quantities, and whether there are any unknowns related to the
above questions.
6. Are there other facilities or operations in the U.S. or internationally that are identical to or may use
processes similar to the facility in North Carolina? If so, please provide facility identification
information and wastewater characterization including all PFAS compounds?
7. Additionally, have any PFAS analytical results been collected with any analytical test method similar
to the following EPA Test Methods. Are any of the fluorinated compounds listed in one of the
following methods and can you provide us with data resulting from these test methods?
• Methods 533 & 537.1 (drinking water)
• SW-846: Method 8327 (water)
• Draft Method 1633 (water, solids, tissue)
• "Total PFAS" Draft Method 1621 (wastewater)
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
Depanmem of Envlmnmenfal Dual