NC0090212_Correspondence_20230302

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 Permitfing'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 (AD�.
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. This request is based upon information supplied to date, specifically
related to chlorinated organics.
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v 512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
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3. Form 2D Data Required: Information (eg studies) and data provided to date regarding characteristics
of the discharge is not sufficient enough to enable Division 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 elevations of Pit Lake due to its depth is 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 or two (2) years 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 specific 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. Potential Downstream Impacts do to Dewatering: Based upon information provided to date, the
projected flow regime (eg. volume and duration) will likely negatively impact creek stability and water
quality. Thus, please provide details on proposed treatment alternative(s) evaluation demonstrating the
facility will be capable of meeting water quality standards or limits at all times accounting for potential
variables that may exist during dewatering?
9. Dewatering and "Minor Increase": Please explain how proposed dewatering is a "minor increases
in flow due to the mine pit dewatering" and how this "is not expected to adversely impact the banks of
Kings Creek"? Based upon information provided to date the anticipated flow regime (eg volume and
duration) is far above the critical flow of the stream (e.g 7Q10), thus the potential exist for significant
ecological impacts to downstream waterbodies. Lastly, has Albemarle / Kings Mountain conducted a
bioassay of the creek; if so please provide that information? Please note that responses provided may
necessitate ADI request(s).
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

10. 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 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 use of scroll bars.
11. Key Contact(s) for Communications: To ensure continuity Division 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 primary contact for NCDEQ with Doug Dowden at:
[e-mail] serving as the backup. 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]
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

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