NC0005177_Correspondence_20240617

arcadium
lithium
June 17, 2024
Chris Johnson
Environmental Program Manager
Division of Water Resources, NCDEQ
1621 Mail Services Center
Raleigh, NC 27699-1621
Subject: NOTICE OF VIOLATION: NC NOV-2024-TX-0017
Whcle Effluent Toxicity(WET)Testing
NPDES Permit No. NC0005177/001
Lithium Division Plant—Gaston County
Dear Mr. Johnson:
This letter serves as a response to NOV-2024-TX-2017 issued to the Bessemer City facility on
April 5, 2024, due to a January 2024 chronic whole effluent toxicity test value of 71%. The
company takes environmental compliance seriously, implementing rigorous measures to
minimize our impact across our operations. As a result of January's results, the facility has
performed the following activities.
• Conducted subsequent chronic toxicity analysis, as required by our permit, in February
and March 2024. All test results indicated a chronic toxicity test value of 100%,
indicating no inhibition of reproduction or significant mortality to Ceriodaphnia dubia.
The 1 st Quarter 2024 average value for chronic whole effluent toxicity is 90%, well
above the permit limit of 78%:
• Conducted chronic toxicity analysis in April 2024. (Test value 100%).
• Reviewed ten years of the facility's historical whole effluent toxicity testing results.
• Performed a detailed Root Cause Analysis to determine the cause of January's results.
• Reviewed sampling protocols and procedures with internal personnel.
• Reviewed analysis protocols and procedures with external lab personnel.
The Root Cause Analysis did not indicate a clear reason for the results of the January 2024
chronic toxicity test. Since the review of historical data did not show any failed tests in the past
10 years, the facility has determined January's results were likely due to the excessive amount
of rain received prior to the sampling event or a laboratory error.
Please contact me with any questions.
Sincerely,
+�7
J ie Watts
Bessemer City Plant Manager
[e-mail]
PO Box 795, Bessemer City,EEC 28016 704-868-5400 1 arcadiumlithium.com
PRIVATE&CONFIDENTIAL
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