NC0090212_Correspondence_20230808

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
John Kuhn
Mine Environmental Permitting Lead
Albemarle
348 Holiday Inn Drive
Kings Mountain, NC 28086
Dear Sir:
NORTH CAROLINA
Environmental Quality
August 10, 2023
Subject: NPDES Permit Application
Additional Information Request # 2
NCO090212 — Albemarle / 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 application review 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.
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�

3. USGS Data Requested: Please include a copy of USGS response regarding Kings Creek flow with your
revised / updated complete application.
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 water quality data of various depths.
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 (Attacbment 2A).
7. Flow Unit Consistency: For the application please be sure to keep discharge flow units consistent
(eitbergpd or mga) throughout as applicable.
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, SWI'CA 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 (and any known
upstream flour sources), plus Albemarle's estimated contribution. Thus, please re-evaluate the potential
impact to downstream aquatic systems based upon the total flow (e.g natural, Martin Marietta's, Albemarle's
contributions and otber known contributions) and resubmit the assessment to the NCDEQ as soon as possible.
9. Form 2D at page 16, Section 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 3.6 mgd flow? Please
correct as applicable.
10. Biological Waste Management Clarification: 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 per form's instruction.
11. 140 ft Pit Water Quality Data — Follow -Up: At page 67 (Pdf number) of the consultant's Memo (i.e.,.
Linkan Engineering dated Marcb 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 results noted be available?
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. 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. The complete application
should be resubmitted.
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: derek.denard(cr�,ded.nc.gov
Amir Adaryani PhD, Engineer I at: amir.adaryani o,ded.nc.gov
Michael Montebello, NPDES Program Branch Chief at: [e-mail]
David Miller, State Mining Engineer at: dayid.millernded.nc.goy
Adam Parr, Assistant State Mining Engineer, NCDEQ — [e-mail]
Andrew Pitner, Regional Supervisor (MRO) at: andrew.pitner(a�deq.nc.gov
Wes Bell, Senior Environmental Specialist (MRO) at: [e-mail]
Jeffrey Chandler, Environmental Specialist (MRO) at: [e-mail]
John Kuhn, Mine Environmental Permitting Lead Albemarle at: [e-mail]
Morgan Warren, Albemarle at: [e-mail]
Melissa Arnold, Assistant Project Environmental Scientist 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