NC0090212_Correspondence_20230808 (2)

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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: doug.dowdengdeq.nc.gov
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
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORrH cARCLINA ^ �/
919.707.9000

DocuSign Envelope ID: OE7434B3-457C-47C4-AA99-6E7DD9DA086C
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 (Attachment 2A).
7. Flow Unit Consistency: For the application please be sure to keep discharge flow units consistent
(eitber d 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, SWICA calculated 2.39 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 flow 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 21) 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 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 results noted be available?
D � � 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
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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: doug.dowden(c�r�,deq.nc.gov,
or telephone number: 919-707-3605.
Sincerely,
Ev
DocuSigned by:
b+S NWAU,
CE9CD2D3C45B4D4...
Douglas Dowden
Environmental Program Supervisor II
Industrial NPDES Permitting Unit
cc: Central Files; NPDES Files
ec: Derek Denard, Environmental Program Consultant at: derek.denard(kdeq.nc.goy
Amir Adaryani PhD, Engineer I at: amir.adaryanikdeq.nc.gov
Michael Montebello, NPDES Program Branch Chief at: michael.montebellogdeq.nc.gov
David Miller, State Mining Engineer at: david.miller(c�r�,deq.nc. og_y
Adam Parr, Assistant State Mining Engineer, NCDEQ — adam.parrkdeq.nc.gov
Andrew Pitner, Regional Supervisor (MRO) at: andrew.pitner e,deq.nc.gov
Wes Bell, Senior Environmental Specialist (MRO) at: wes.belle,deq.nc.gov
Jeffrey Chandler, Environmental Specialist (MRO) at: Jeffrey.chandler(kdeq.nc.gov
John Kuhn, Mine Environmental Permitting Lead Albemarle at: John.Kuhn4albermarle.com
Morgan Warren, Albemarle at: morgan.warren&albemarle.com
Melissa Arnold, Assistant Project Environmental Scientist at: melissa.arnoldkswca.com
D � � 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
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Attachment 2A
EIOCIDUCHEMICAL TREATMENT
WORKSHEET-FORM 101
The following calculations are to be performed an any biocidal products ultimately discharged to the surface waters of
North Carolina. This work sheet must be completed separately for each biocidaI 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 #t NC Outfall #
County
Receiving Stream
7010 WS)
(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 Instrearn Waste Concentration (IWC in percent) of this discharge using the data entered
above-
(A-D-D.) X 100 { ) x 100
IWC = (7010)(0.646� + (A-D_D) _ { )(0-646) + ( ) =
This value (IWC) 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:
96
96
96
What feed or dosage rate (D.R-) is used in this application"? The units must be converted to maximum grams
of whole produ ct used in a 24hr pedod-
D.R-=
g1rams4hr 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 453.59cl.
128 A. oz. 1 gal_ water 1 lb.
D � � 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
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DocuSign Envelope ID: OE7434B3-457C-47C4-AA99-6E7DD9DA086C
Facility Name: NPDES9: NC
Estimate total volume of the water handling system between entry of biocidaI product and NPI]ES 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 hioeide addition? If unknown, enter NIA.
What is the decay rate (D_K.) of the product? If unknown, assume no decay (D.K=D) and proceed to asterisk_
The degradation must be stated at pH level within V2 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 G.69 = =Decay Rate (D.K.)
Calculate degradation factor (D_F_)_ This is the first order lass coefficient.
A{ D-D.)
* D_F. = (Volume) + (D.K.)
Ca Iculate Steady State Discharge Concentration:
Dischg Conc. _ (D.F.)(V lume)(3735) ( x )(3785) = mgA
Calculate concentration of biocide instrearn during law (flow conditions_
(Receiving Stream Concentration)
(Dischg. Conc.) x fl C%) ( } x ( } _ mgfl
100 - 100 -
Reoeiving Stream Concentration
III. Calculate regulated limitation.
List all LC50 and EC50 data available for the whole product according to the fallowing columns. (Note that units
should be in mg11). Please provide copies of the sources of this data.
Organism Test Du ration LC5ClEC50 (mgll)
D. PF Q. Form 101 (112019)
D � � 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
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2

DocuSign Envelope ID: 0E7434B3-457C-47C4-AA99-6E7DD9DAO86C
Facility Name: NPDES9: NC
Choose the lowest LC51)OEC50 listed above:
Enter the LCSOIECSD:
If the half life (H.L.) is less, than 4 days, perform the following calculation.
Regulated Limitation = 0.05 x LCSD = mgA
If the half ife (H_L.) is greater than or equal to 4 days or unknown, perform the following calculation.
Regulated Limitation = O.01 x LCSD = mgA
Choose the appropriate regulated limitation from the calculations immediately above and place in this blank:
mglliter
From Part I I enter the receiving stream concentration
glliter
I'V1. 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 (Print) Email Address 6. Phone Plumber
Signature Date
Person Completing This Works heet (If different from above)
Name (Print) Email Address 8. Phone Number
Signature Date
Please submit to, Division of Water Resources
Aquatic Toxicotopy Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Contact Info: Cindy Moore (cindy.a_nmoore�[exdenr_gov) or Susan Nfeadows. (susan_nteadcros cdenr.gov)
D.W Q. Form 101 (112001 d
D � � 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
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DocuSign Envelope ID: OE7434B3-457C-47C4-AA99-6E7DD9DA086C
Facility Name: NPDES 9: NC
Supplemental Metals Analysis
ff copper, zinc, or chromium are present in the proposed biocidal compound, complete this worksheet. A separate form
must be used for each metal andfor 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.
Metal Chemical Formula MalecularWeight cif Metal Formula Weipht CanoentraUaninBioaide
EXA MPL E
Copper CuSD4-5H2O 63.546 g/mofe 249.680 gATm�e 0.2 %
Dosage rate of Biocide (DR) jfrom page 1):
DR = gramslday
Average Daily Discharge (ADD) (from page 4):
ADD = million gallonslday
Discharge Concentration (DC} of Biocide:
❑R ( gramsIday)
DC = ADD = { million gallonsfday} = gramsfinillion gallons
Convert DC to microgramsiliter(ppb):
DC (pgll) _ ❑C (gram sfmillion gal) x 1 x 106IJA PW
3.785 x 106 litersfinillion gal -
Ca I Gulate the fraction of metal in the metal �ontaining compound (MF):
MW { gramsfmole)
MF = FW ramsfmole) _
Calculate the fraction of metal in the biocidal compound (BF):
BF = MF x MCC (%) 100 = x %
(1DO) _
Calculate the concentration of metal in the discharge (M):
M = DC x BF = ugn x = ugA
Calculate the instream metal concentration (IMC) at lo-w-flow conditions;
IMC = M x IW 01I ugfl x 100 = Wgll
Regulated limitation of metal (from below): ug11
NC General Statutes 15A NCAC 2113_0211 define:
Copper- 7 pgfl water quality action level' Zinc- 50 pgA water quality action level'
Chramium-50 pgfl water quality standard
(*Values which exceed action levels must be addressed directly by aquatic toxicity testing_)
JD. PFQ. Form 101
D � � 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
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