NC0090212_Correspondence_20230220

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
March 15, 2023
Subject: Permit Application
Additional Information Request
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 an
initial review of the Permit Application (PA) for Albemarle / Kings Mountain's proposed lithium mine
project in Cleveland County North Carolina and has the following Additional Information Request (ADI).
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 REQUESTED
Delegation of Authority for Reports to be Filed: Based upon the information supplied it does not
appear that Albemarle has delegated state application(s) authority to Mr. Fisher. A solution would be to
add to the existing list in the letter accompanying the PA a line item for the "State of North Carolina."
2. PFAS Questionnaire: Please complete the PFAS questionnaire as Attachment 1 herein and submit
with the additional information.
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. Form 2D Data Required: Information (eg studies) and data provided to date regarding characteristics
of the discharge is not sufficient enough to enable NCDEQ to determine limits and monitoring
frequency for an NPDES permit. To address this please provide one-time sampling results for all missing
pollutants in EPA's Form 2D, tables B, C and D from submitted application. Analysis for compounds
in table E is necessary to determine if such contaminants might be present.
Sampling from various depths of Pit Lake due to its depth is also essential to provide representative
samples of possible pollutants in the proposed discharge during the anticipated project duration. Please
closely adhere to instructions contained in EPA's form 2D for presentation of results. Sampling shall be
conducted according to sufficiently sensitive test procedures (i.e., methods) approved under 40 CFR 136
for the analysis of pollutants or pollutant parameters.
4. SIC / NAISC Codes and Pre -Mining Dewatering Activities: SIC / NAISC codes provided in EPA's
form 1 section 3 must be reflective of the characteristics of the discharge. Based upon the information
and data provided the discharge resulting from dewatering of Pit Lake is anticipated to occur prior to
Lithium mining activity. Please revise the SIC / NAISC codes accordingly.
5. Dewatering Time Period Clarification: Please provide clarification as to why the EAA report
provided reflects dewatering is anticipated to occur for eight (8) months and yet the cost analysis
provided reflects a two (2) year period. If this apparent discrepancy is an error, please correct and
resubmit the corrected information.
6. Dewatering of Pit Lake and Groundwater: Since many of the elevations of Pit Lake are lower than
the existing groundwater table it is safe to assume that groundwater will flow into the lake area during
dewatering. Has this additional water source been factored into the anticipated time period of eight (8)
months for dewatering? If not how much more time will be required to completely dewater Pit Lake? In
addition, if more time is required to dewater Pit Lake how will this affect the existing time schedule for
recommencement of Mine's operation and requirements of the related discharge permit (e.g, NPDES
permit)?. Please provide a plan for such transition.
7. Dewatering of Pit Lake and Water Quality Standards: What measures (eg treatment alternatives such as
pH control and aeration) will be employed to ensure that discharge of Pit Lake will not cause: (1) Water
quality standards violations related to pH, DO; (2) and / or negatively impact (eg compromise) aquatic life
do to identified parameters; such as, ammonia, dissolved lithium?
8. End point?Please provide details on proposed treatment alternative(s) evaluation demonstrating that
the facility will be capable of meeting water quality standards or limits at all times during dewatering.
9. Potential Downstream Impacts do to Dewatering: We might send another comments on
this .Because the anticipated flow regime (eg. volume ana (1111ation) is far above the critical low flow of the
stream (eg. 7Q10) an expert will need to prepare and submit a report related to "Kings Creek Stability
and Water Quality Assessment" to the NCDEQ. Based upon information provided to date, the
projected flow regime will likely negatively impact creek stability and water quality.??? Elaborate. 7Q10
is X, how we could consider it minor discharge? Flow question
10. Potential Downstream Impacts do to Dewatering: Because the anticipated flow regime (eg. volume
and duration) is far above the critical low flow of the stream e.g. 7Q10) an expert will need to prepare and
submit a report related to "Aquatic Habitat Assessment". Based upon information provided to date, the
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

projected flow regime will likely negatively impact creek ecology.??? Elaborate. Bioassay of the stream
b/f and after?
11. Data Submittal Concern: For this submittal and any future submittals be cognizant of the fact that
using a scroll bar for additional text information in any given text entry box may get lost for review
purposes, if the reviewer is reading a printed and/or scanned in version of the document. In addition,
scanned in documents of any nature for public access loose the scroll bar functionality and thus may not
meet public accessibility requirements. Specifically for the application submitted in EPA's form 2E
section 7, to view the entirety of the text entered the viewer must be on a computer viewing an original
version of the application to use the scroll bar to view all entered text. Please revise the attachment to
eliminate the scroll bars .
12. Key Contact(s) for Communications: Also to ensure continuity, Division of Water Resources,
Industrial permitting unit requests that Albemarle / Kings Mountain designate a key contact with one
backup for all communications. With that said Derek Denard at: [e-mail] is the key
contact for with Doug Dowden at: [e-mail] serving as the backup. For all primary
communications should include these contacts.
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: [e-mail]
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]
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

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
Depa"mem of Envlmnmenfal Dual

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