NC0090212_Correspondence_20230208

.A\ALBEMARLE 0
Albemarle Corporation
4250 Congress Street, Suite 900 Telephone: [phone]
Charlotte, North Carolina 28209 www.albemarle.com
Adam Parr, PE
Assistant State Mining Engineer
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
512 N Salisbury Street
Raleigh, NC 27604
Mr. Parr,
In October 2022, Albemarle submitted Water Quality and Geochemistry Sampling and Analysis
plans to DEMLR, DWR, and NCGS detailing baseline data collection efforts on the site. The site
received comments back on these SAPs on January 18, 2023; most of these comments were
related to future dewatering plans of the pit lake and are addressed in the NPDES Permit
application, submitted to NCDEQ in December 2022.
The NPDES application included baseline data and several engineering analyses in support of
the proposed temporary dewatering of the pit lake. Albemarle will draft a discharge plan as
required by the NPDES permit which will include monitoring of the pit lake water quality, pit lake
sediments, and discharge water quality.
Please see the following responses to the January 18, 2023, comments:
1. Comment from NCDEQ: "Please elaborate on known permitted discharge(s) to Kings
creek upstream of your site, as mentioned in SAP report. Analysis should account for the
other discharges within the area."
Albemarle response: "There is one known permitted discharge to Kings Creek upstream
of the site: dewatering pumping from the Martin Marietta Mine. Flow from Martin Marietta
was accounted for in the engineering analysis attached to the NPDES permit application.
In addition, Albemarle has been sampling a surface water monitoring location upstream
of the facility and downstream of the Martin Marietta Mine (location SW-10; see Table 1
and Figure 2 in the Water Quality SAP). These data have been included on the NPDES
permit application."
2. Comment from NCDEQ: "Due to presence of sediments in the deep pit, during the
dewatering chemistry of the discharge could change over time. What type of sampling
will occur during the dewatering process? How will Albemarle account for changing
chemistry, turbidity, and analytes, etc. as water is pulled from different areas of the pit?
Sampling and analysis of the sediment in pit pond should also be part of plan."
Albemarle response: "Sampling frequency of the discharge during the dewatering
process will be dictated by the NPDES permit. Albemarle will continue to sample the pit
lake on a quarterly basis throughout the dewatering processes. Sediment sampling in
the pit lake is anticipated to be conducted in Q1 2023."

.A\ALBEMARLE 0
Albemarle Corporation
4250 Congress Street, Suite 900 Telephone: [phone]
Charlotte, North Carolina 28209 www.albemarle.com
3. Comment from NCDEQ: "How will pit pond sampling as detailed account for changes in
chemistry, etc. at different elevations in the pond? Additional samples of the pit ponds
should be provided. Samples should measure from the top of the water surface at
regular intervals down to the sediment at the bottom to provide a better overall picture of
the water in the pit pond."
Albemarle response: "On a quarterly basis, Albemarle has, and will continue to, monitor
the pit lake at regular intervals of depth to continue to characterize the overall water
quality in the pit lake. The Water Quality SAP details this in Table 2 and the data were
presented in the NPDES permit application."
4. Comment from NCDEQ: "What type of measures will be put in place to control the flow
of the discharge from the pit to the streams? How will Albemarle ensure the stream
channel can handle the increase volume over the existing regular flow?"
Albemarle response: "The Engineering Analysis attached to the NPDES permit
application details the study done to ensure the stream channel can handle the
proposed discharge. The Engineering Analysis is supported by, and based on, a site -
specific sediment, background water quality monitoring including discharge from the
Martin Marietta Mine, and geomorphology assessment conducted on Kings Creek in
2022."
5. Comment from NCDEQ: "What impacts will the planned discharge from the short-term
but significant dewatering flow have on ecology of the downstream of Kings creek?"
Albemarle response: "The Engineering Analysis and the Aquatic Resource Evaluation
attached to the NPDES permit application details the low impact of the proposed
discharge on the ecology of Kings Creek. The Aquatic Resource Evaluation is
supported by and based on a site -specific aquatic survey conducted on Kings Creek in
2022."
6. Comment from NCDEQ: "A discharge plan is required as part of the NPDES permit. Will
the details of dewatering be included in the sampling plan? Does the SAP cover
requirement of sampling and analysis in EPA Application Form 2D for new dischargers?"
Albemarle response: "A discharge monitoring plan will be written for the NPDES permit.
Details of dewatering and the associated sampling and analysis will be included in this
plan."
7. Comment from NCDEQ: "We would recommend to use EPA draft method 1633 that
would be eligible for CWA permitting, instead of method 537 for analysis of PFAS. We
appreciate the proactiveness of Albemarle on this matter"

.s\\ALBEMARLE 0
Albemarle Corporation
4250 Congress Street, Suite 900 Telephone: [phone]
Charlotte, North Carolina 28209 www.albemarle.com
Albemarle response: "The site has reached out to North Carolina certified labs to make
sure they can analyze PFAS using EPA Draft method 1633. The SAPs and the future
dewatering plan are anticipated to include the 1633 method."
8. Comment from NCDEQ: "There are a few spots in the Characterization of Work that
reference LEAP instead of LEAF."
Albemarle response: "The Geochemistry SAP will be updated to correct the LEAF
acronym."
9. Comment from NCDEQ: "Please clarify the profile view of the geologic model. There are
no cross section lines and it is difficult to determine the location of the plan view."
Albemarle response: "The Geochemistry SAP will be updated to clarify the profile view of
the geologic model."